ML20136A966

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Status Repts for 840720 & 0810 in Electrical Area.Viewgraphs from Technical Review Team 840918 Briefing & Comments on Util Program Plan & issue-specific Action Plans Encl
ML20136A966
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/20/1984
From:
NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20136A539 List: ... further results
References
FOIA-85-59 NUDOCS 8601020364
Download: ML20136A966 (92)
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{{#Wiki_filter:_ /' V'. i r t- .M) l + July 20, 1984 NRC TRT - Comanche Peak 1 and 2 Status Report Electrical Area Scope 50 Allegations: 17 construction related 33 QA/QC related 10 Allegation Categories (10 SSERs) Issues Cable Termination Problems - Cables not terminated per drawings - In-line butt splices not witnessed by QC - In-line butt splices acceptance criteria - Violation of procedures 4 - Design changes incorrectly in drawings - NCRs on vendor-installed lugs not properly dispositioned Cable Tray & Conduit Installation Problems a - 60 to 70 tray supports improperly installed - Addition of higher sides to trays a - Clearance of trays from pipes - Loose fittings in diesel generator building Electrical Equipment Separation Problems - Separation of cables in wireways and terminations inside panels - Separation of cables at entrance to an exit from panels 4 - Selected separation concerns in the general plant area Control Room Ceiling Fixture Supports - Field run conduit, drywall and lighting supports may not be seismic Category I QA/QC Electrical Problems - Inappropriate handling of NCRs and reporting of NC situations - QC electrical inspector training / qualification - Inspection reports - Inspection item removal notices - In-process inspections - Construction in-progress and post inspection procedures - Performance of startup testing and release of operational control from startup to operations procedures - Designation of electrical and mechanical components .g, _ 9' 7-0601020364 851113 l PDR FOIA GARDE 85-59 PDR 0

E {.. 5 'j.e i Riectrical Cable Installation Problems 1 - Improperly installed cables 4 - Cable overfill in trays - Mismatch between actual number of cables in trays and computer record ~ Nature of A11eastions ~ Most allegations are general and vague. Two of the allegations concerning separation and cable splicing deficiencies are based on interpretation of existing regulatory 4 - requirements by the alleger. NRR assistance may be required to establish a position concerning these two cases. l Status - First two weeLa Allegations assigned to subject categories. Work packages prepared for each subject category. 1 i 4 Action plans for approach to issue resolution were defined and 2 discussed. I Action plans for evaluating all allegation, including resources allocation and schedule were prepared. 4 TURC, Regions II and IV and NRR personnel were contacted as j j1 needed to obtain background information on alleged issues. The review of information and inspection of the installation as i related to the allegations have been completed for all subject categories except fort cable installation, cable tray & conduft installation, electrical inspection reports, in-process electrical inspection reports and electrical inspection item removal notices. i It is anticipated that the remaining reviews of information and 1 inspections will be completed during July 30 and 31, 1984. A request to interview the allegers responsible for allegations AE-22 and AQE-21 has been made. 4 !i 4 i !} " =

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1 One draf t SER was done. Projected completion date for onsite related work August 3,1984. Projected completion date of first draft of last SSER is August 9, 1984. The majority of the first draft SSERs are projected to be completed by July 31, 1984. Potential Problems Separation between redundant flex conduits inside control board panels. QA/QC related deficiencies e 4 e e J '"* MU 7- -961 .g ,p.

DrOft 1 - 8/10/84 status report 8/10/84/CP2 NRC - TRT - COMANCHE PEAK UNITS 1 AND 2 r STATUS REPORT - AUGUST 10, 1984 i ELECTRICAL AREA i SCOPE 51 allegations: 19 construction related y 32 QA/QC related j 1 special review team concern 9 allegation categories (9 SSERs) a i. STATUS i l All 9 SSERr, completed and reviewed by technical writer 2 new allegations of minor significance remaining (estimated effort 4 hours) Two of completed SSER may require minor revision ACTIONS REQUIRED FROM TUEC BEFORE FUEL 1.0AD ) ELECTRICAL CABLE TERMINATIONS Re-evaluate and redisposition all NCRs concerning lugs in GE motor control centers Include in procedures provisions to verify operability of circuits j containing butt splices, and assure that the splices are qualified for service conditions and are not located adjacent to each other. Reinspect all safety-related terminations in control room and cable spreading room to verify that they are in accordance with drawings. Identify all butt splices in panels, clarify procedural requirements with regard to heat sprinkable sleeves or. splices, assure all QC inspections requiring witness have been performed, and assure that all butt splices are identified in drawings. ELECTRICAL EQUIPMENT SEPARATION Reinspect all electrical control panels that contain independent / safety and nonsafety-related conduits separated less l than 1 inch and either correct each violation of separation criteria or demonstrate by analysis the acceptability of the conduit as a ', j, barrier. ,'f Reinspect all the panels and correct each violation of the t separation criteria concerning independence cables and flexible i conduits separated less than 6 inches, or demonstrate by analysis the acceptability of the conduit as a barrier. 1 l ~

,c' !.l Correct two minor violations of separation criteria inside panels concerning a barrier found down and redundant field wiring not meeting separation. CONTROL ROOH CEILING FIXTURES SUPPORTS Provide analysis that substantiate (1) the adequacy of the overall seismic support system installation for all items above the ceiling in the control room, and (2) the adequacy of the seismic support system installation for nonsafety-related conduit in other seismic Category I areas of the plant besides the control room. ELECTRICAL QC INSPECTOR TRAINING / QUALIFICATIONS Evaluate testing program for QC inspector qualifications and optimize'it to assure that proficiency is achieved and maintained. Review current QC inspector training and certification files and include all required documentation. WEIT SESSION All onsite inspections and SSERs preparation have been accomplished. Thus, there is no need for the electrieni group to participate in the next session - unless there is a need to meet with selected allegers. e 4 4 e 9 h i I i l I

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/ AMC - 727^- 6mswwe~ S Wm r r / d uo 2-y 1 fee er^2 & e /.f.a.crseewe a.rnn o<,1 A/ae M ~ j r .At/w.c r 3 /, / 9 f +- ACTIONS REQUIRED FROM TUEC BEFORE FUEL LOAD ELECTRICAL CABLE TERMINATIONS Re-evaluate and redisposition all NCRs concerning lugs in GE motor control centers Devetate see auere o ut ererrou measunes T u A-s tu n t T 'h* ' ^ f: i_,_:::f n _ 7._.': i - M y operability of circuits containing butt splices, h that the splicas are qualified for service conditions and are not located adjacent to each other. Reinspect all safety-related terudnations in control room and cable spreading room to verify that they are in accordance with drawings. Identify all butt sp Jess in panels., clarify procedural requirements with regard to heat-hprinkable sleeves on splices, assure all QC inspections requiring witness have been performed *, and assure that all butt splices are identified in drawings. ELECTRICAL EQUIPMENT SEPARATION Rein' pect all electrical control panels that contain s independent / safety and nonsafety-related conduits separated less than 1 inch and sicher correct each violation of separation criteria or demonstrate by. analysis the acceptability of the conduit as a barrier. Reinspect all the panels and correct each violation of the separation, criteria concerning independence cables and flexible conduits separated less than 6 inches, or demonstrate by analysis the acceptability of the conduit as a barrier. Gw.c Avatyres ree v u rs s r-n v r, 4 r r s T H r e tt e rvn m m c r eA n ari ea o vyw vu e.vou.rs duo c+ntes en Ay r frwrtw I4 T t tv e'L P~r? fE f t sh te")t r CT 4 d.nJ C # w c e te s e si t t u d. r Correct two minor violations ' concerning a barrier found M,of sep"aration criteria inside panels

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-Af C7/DA/S AlrQt//ffD MDM '70GC Bff oM F t/ f 2 t o A'b Wo^W .i -,6$).;'Q&. e. 3 CONTROL ROOM CEILING FIITURES SUPP - W; ' ?y:,' M seismic support systProvide analysis that substa l .j in the control room,em installation for all items abo ..1 l?! and (2 Category I areas of the plant besidsystem e ceilin 1 upport e conduit in oth ELECTRICAL QC INSPECTOL TRAINING /Q ^ ,-I ICATIONS Evaluate testing program for QC ins, rr stort. e r r e. i optimize it to as Review current QC /g g g et proficiency is achieved 4 1 nspecfor training and certification fil include all req,uired documentation t ~,. . s' a ntained. A Pco t'rt r a n c e ..Y ), es and eart/ CV90s)!un.rtre ro ve o' err a ss,evw w.4r.,ereee,..c, TA e sti? A it t P r'Ti tr e,1 M O v a v nt e r Y b* i Q 't THQCf ne'errno'c'rf niCP(gygp g P C s,* s) > Q C C l et rot t C A L. srv7

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s Drcft 2 - 8/3/84 = AE-13/CP2 i COMANCHE PEAK OPEN ISSUE ACTION PLAN t Task: Electrical 1 - Electrical Cable Terminations Ref. No.: AE-13. AE-163 AE-18, AE-22, AE-26, (AQE-7 Part), (AQE-8 Part), AQE-12 AQE-36, (AQE-37 Part), (AQE-39 Part), (AQE-46 Part). Characterization: Various allegations pertaining to electrical cable terminations, splices in panels, and related activities. 9 Initial Assessment of Significance: Possible safety-significant Source: Various s Approach to Resolutions: i Become familiar with specific issues through review of work packages and related source documents. \\- s Review FSAR and related site procedures to determine installation / inspection requirements i I 'k il F01A-85-59 i,- j f ho I - - ~ - ,y -,.,,,w-.s ___-,m.

g,. t. 2-i 3, Perform inspections of installed hardware (where appropriate) l and reviews of applicable records (as necessary) to determine compliance with requirements and/or connaitments. 3 Review for safety-significance and/or generic implications and perform additional inspections and document reviews as necessary. ~ Related Open Issue Identification: None Status: Open Review Lead: Calvo Stipport: None Estimated Resources: 12 man-days Estimated Completion: July, 31, 1984 I CLOSURE: I l Reviewed by: 1' TRT Leader l w. e e.mm m-a s e - -e e wi- ,- + - - -

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y:.... ay and n_t,. ? . - li , f....,g,, _... 7, ~ Sc, r,g2./g,,#c,y,. ; *. ;' .m -Ref. No.: ...s .. ~. AQE.10 AE-14, AE-27, AE-29. AE ..fi.',a,w :. c. m;. e \\ ; n :., ,i s... .u,.. AQE-3. AQE-4, and AE-24 .,:,, ;~.. ,a 7. .ar* _...s.....,s,- -s. ,J a. s u~.. ,..:.,.$.f,.. 4<J. . y.

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1........~... 9;.,., =,...g 4.,., ?;e. .. o , T e..'i, m.# y. ...: n.. 1. C.f g.'j f?f. s.i, t.h?.i w. Inspect electrical component referen .. c.. g.i 2..~. .t .g. c.:;p. t. .m; 2. ced in the ... s. m....,..,. %. c 3 :, n'.. e,:,: :.r..,e. M.."... ii..n~ Review NRC regulations and the appli v ,.:ff ' - - cant's FSAR t 3. -' p :^ W... ... r. ...( Interview personnel with responsibility nl '.:) 3 .,.... c. 4. or the Refer any deficiencies to TRT manager .,l .,.. '.y %.s ,*v',, .. % ; ',

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5. Evalusta allegations for generic / safety implications. i 6. Report on results of review / evaluation of allegations. Related Open Issue Identification: None -Status Open Review lead: Jose A. Calvo Support: None Estimated Resources 7 man-days Eatinated Completions: July 31, 1984 CLOSURE: Reviewed by: TRT Leader i

.o i Related Open Issue Identification: None t k Status: Open t I Review Lead Jose A. Calvo Support: None 4 Estimatad Resources: 12 man-days Estimated Completion: August 4. 1984 CLOSURE: l Reviewed by: TRT Leader W G b I-i 1; ~' en s e-r . =.

.= I Droft 4 - 8/6/84 .i Electrical 5/CP3 i COMANCHE PEAK OPEN ISSUE ACTION -PLAN Electrical [- Control Roca Ceiling Fixture Supports Task: l Ref. No.: AE-17 Characterisation: Allegation concerning field run conduit, drywall and lighting installed in the area above the pancis in the control room. Initial' Assessment of Sinnificance Components any not have been installed properly. These components may have safety-related significance. l Source Refer to CP Allegation Chart and Statement of Allegations from source documents attached. l' Approach to Resolutions: 1. Inspect electrical component installation referenced in allegation. 2. Review NRC regulations and the applicant's FSAR couaiteents. I 3. tuterview personnel with responsibility for the electrical component. l , i I L l! ,I s... ..w -...--..m

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s i i 8 4. Refer any deficiencies to TRT manager. 5. Rvaluate allegations for generic / safety implications. 1 [ 6. Report on results of review / evaluation of allegations. 7. Review IR-83-24 to determine if documentation adequately supports findings for this allegation. Related Open Issue Identificationt N/A ? 6 Statust Open ./' . ~ Review Lead , Jose A. C"alvo s. Support s k'one - 7 Estimated Resou*ceAt 12 ann / days lt i s Estimated Complation: August 10. 1984 f CLOSURE: ,i 4 l l J Reviewed by: l l TRT Leader i t l I ? 1 -esae re:w mm, =, -#.,% ew..,,., ,,,v- ,,g%g.e L.

4 Draft 2 8/6/84 .i - CP1 Action Plan-Electrical 6 COMANCHE PEAK OPEN ISSUE ACTION PLAN i f Electrical,4'- Electrical NCR Activities 1 . Task: Ref. No.: AQE-1 through 5. AQE-25 AQE-33 through 38 (only part of 36), AE-24. AQI-40 AQE-41, Agt-42, AQE-45, AQE-47, AQE-48, AE-50, Parts of j AE-22 AE-27, and AQE-36. Characterisation: Various concerne involving NCR program, includings i (a) Generation (b) Disposition (c) Prevalent use of "use-as-is" I .(d) Inaccurate Evaluation (e) "Q" Item Traceability (f) Specific Technical Concerns Initial Assessment of Significance NCRs may have been dispositioned' improperly. NCRs not issued, which make the validity of construction quality questionable. Sourcet Various allegations Approach to Resolutions: i' (1) Review pertinent documentations relating to the NCR program (2) Examine NCRs (3) Interview QC personnel (4) Make inspections (S) Evaluate results (6) Report on Results Related Open Issue Identification: None 1 Statust Open !'l Review Leadt Jose A. Calvo supperet None a l Estimated Resourcest 8 man-days d'; ~ ,l Estimated Completionst July 30, 1984 i CLOSURE: 4 Reviewed by: TitT Leader jI .,I I a * ~ -ee----e*- - * * - * - ' " - -*t'

u +: 1 r ( COMANCHE PEAK OPEN ISSUE ACTION PLAN i b I Electrical [6 Task: QC Inspector Training / Qualification Ref. No.: AQE-8, parts of AQE-4 AQE-6, AQE-12 i Characterization: Some electrical QC inspectors are inadequately i qualified. f Initial Assessment of Significance: Question of. whettier the positions of i RG 1.58, R1, and ANS1 N42.4.5-1978 as augmented by the,FSAR Section 17.1.2 are being met, t Source: Various allegations Approach to Resolutbus: e 4 1. Review all pertinent documentation (procedures, codes *, standards, etc.) g 2. . Discussed adequacy of procedures, etc. 3. Review training / certification program 4. Review training / certification files 5. Interview QC personnel 6. Evaluate review findings 7. Report on results, Related Open Issue Identification: None Status: Ope Review Lead: Jose Calvo Support: =. Estinated Resources:: '10 man-days Estimated Completions: July 26, 1984 s 2 CLOSURE: i Reviewed by: TRT Leader } e i s 3 .i - E q c (< 5 1

Draft 2 - 8/6/84 AE-19/CP2 i 1 COMANCHE PEAK OPEN ISSUE ACTION PLAN i Electrical [1 - Electrical Cable Installation Task: 3 Ref No.: AE-19, (AE-29 Part), AE-30, AE-50,(AQE-5 Part), SRT-10, AE-28 Characterization: Various allegations pertaining to electrical cable installation, cable tray fill, cable splicing in raceway, and related 1 activities. Initial Assessment of Significance: Poesibly safety-significant Approach to Resolutions: Become familiar with specific issues through review of work packages and related source documents t Review PSAR and related site procedures to determine 1 installation / inspection requirements 9 Perform inspections of installed hardware (where appropriate) and reviews of applicable records (as necessary) to determine compliance with requirements and/or commitments. 't .)

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Review for safety-significance and/or generic implications i and perform additional inspections and document reviews as necessary. Related Open Issue Idensification: None Status: Open Ii i Review Lead: Jose A. Calvo Support: Necessary to contact alleger to determine exact nature . of one allegation. Estimated Resources: 8 man-dayr Estimated Completions: July 31, 1984 Closure: = -i I I Reviewed by: 'i TRT Leader } ( i i i i i = v~ en-e-ww.-_ -..--s-wa.- --mm

Draft 4 - 8/6/84 Action Plan - Electrical 15/CP3 COMANCHE PEAK OPEN ISSUE ACTION PLAN Task: Allegation Group Electrical,Jf - Electrical Procedures f. Ref. No.: AQE-23, AQE-32, AQE-39, AQE-44, AQE-46, and parts of AQE-6, AE-18, AE-20 and AQE-37. Characterization: Various allegations pertaining to: (a) Omission of procedure requirements. (b) Reduction in the number of required inspections. (c) Adequate basis for procedure revisions. (d) "Use-as-is" dispositions contrary to procedures. 4 (e) - Paper flow problems exist involving rework. (f) Use of butt splices contrary to procedure. l (g) Redundant train separation. Initial Assessment of Significance: The adequacy of procedures to ensure the quality of construction tasks. i Source: Allegations: Approach to Resolutions: (a) Examine and review pertinent documentation (b) Conduct interviews (c) Evalu. ate results (d) Report on results Related Open Issue Identification: None Status: Open s Review Lead: Jose A. Calvo Support: None Estimated Resources: 6 man-days Estimated Completion: August 4, 1984 CLOSURE: I LL Reviewed by: TRT Leader a 3 f . i s - - - - ~ ~ o

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_[^:.. ; ^ - (.,,. -3 r + i COMANCHE PEAK OPEN ISSUE ACTION PLAN 'h Task: Electrical Category - Inspection Reports, Inspection Item Removal [ Notice, and In-process Inspection. l-I Ref. No.: AQE-7, AQE-43 l Characterization: Concern is that validity of irs and IRNs. Also, in-process inspections are not being performed. Initial Assessment of Significance: irs may have been signed off without inspections being made or were falsely signed to close out IIRNs. Source: Allegations Approach to Resolutions: (1) Review pertinent documentation (2) Interview paper flow group personnel responsible for irs and IR"s (3) Examine irs and IRNs (4) Interview QC Electrical Inspector (5) Evaluate Results (6) Report on Results Related Open Issue Identification: None Status: Open Review Lead: Jose Calvo Support: None Estimated Resources: 4 man-days 4 I f Estis:sted Completions: August 3, 1984 CLOSURE: Reviewed by: ,TRT Leader l'. ( [* i l T i l I, 4 t k ~ ~ ^ ~ ~ ~ ~ -*=

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j,.: - i l: > 7; demonstrate by analysis the acceptability of the conduit as a barrier for each case where the minimum separation is not met. 2. In several cases, separate safety and nonsafety-related cables and safety and nonsafety-related cables within flexible conduits inside main control room panels did not meet minimum separation requirements (Table 1 identifies examples of these cases). No evidence was found that justified the lack of separation. Accordingly, TUEC shall reinspect all panels at CPSES, in addition to those in the main control room of Unit 1, and either correct each violation of the separation criteria concerning separate cables and cables within flexible conduits, or demonstrate by analysis the adequacy of the ficxible conduit as a barrier. 3. -The TRT found that the existing TUEC analysis substantiating the adequacy of the criteria for separation between conduits and %._ _ sable trays had not been reviewed by the NRC staff. Accordingly, TUEC shall submit the analysis that substantiates the acceptability of the criteria stated in the electrical erection specifications governing the separation between independent conduits and cable trays. 4. The TRT found two minor violations of the separation criteria inside panels CPI-EC-PRC8-09 and CPI-EC-PRCB-03 concerning a berrier that had been removed and redundant field wiring not meeting mini)uum separation. The devices involved with the barrier were FI-2456A, PI-2453A, PI-2475A, and IT2450, associated with Train A; and FI-2457A, PI-2454A, PI-2476A, and IT-2451, associated with Train B. The field wiring was associated with devices HS-5423 of Train B and HS-5574, nonsafety-related. Accordingly, TUEC shall correct two minor violations of the separation criteria inside panels CPI-EC-PRCB-09 and CP1-EC-PRCP-03 concerning a barrier that had.been removed and redundant field wiring not meeting minimum separation. e. 1 i ..T !I 1 3 1

~. 5. :. - i-Ij Table 1 ) Examples of Cases of Safety or Nonsafety-Related Cables In Contact With Other Safety-Related Cables Within Conduits in Control Room Panels 1. Control Panel CPI-EC-PRCB Containment Spray System Cable No. Train Related Instrument EG139373 ' Wgreen) Undetermined E0139010 A (orange) Undetermined 2. Control Panel CP1-EC-PRC8 Reactor Control System Cable No. Train Related Instrument ET793BT Wgreen) Reactor manual trip switch E0139311 A (orange) Undeterv.ined 3. Control Panel CP1-EC-PRCP Chemical & Volume Control System l; Cable No. Train Related Instrument EG139335 Wgreen) LGV-ll2C ,,.E0139301 A(orange) Undetermined j 4. Control Panel CPI-EC-PRCB Auxiliary Feedwater Control System Cable No. Train Related Instrument 4 E0139753 A orange) FK-2453A E0139754 A orang ) FK-2453B E0139756 8 green FK-2454A EG139288 8 green FK-24548 l l i: I l

~ ~ "~~ .1. 1 ...1' 2 2 Z.". " -~ ' ' ~ ' ' ~ ;" ~ ' I :. - 'i-Vl l-.i t .j c. Electrical Conduit Supports 1 The TRT examined the nonsafety-related conduit support installation in selected seismic Category I areas of the plant. The support install s'gn f i non-safety related conduits less than or equal to 2 & ons stent with seismic requirements and no inches 4 evidence could be found that substantiated the adequacy of the installation for nonsafety-related conduit of any size. According to Regulatory Guide 1.29 and FSAR Section 3.78.2.8, the seismic Category II and nonseismic items should be designed in such a way that their failure would not adversely affect the function of safety-related components or cause injury to plant personnel. Accordingly TUEC shall propose a program that assures the adequacy of the seismic support system installation for nonsafety-related conduit in all seismic Category I areas of the plant as follows: 1. Provide the results of seismic analysis which demonstrate that all nonsafety-related conduits and their support systems, satisfy the provisions of Regulatory Guide 1.29 and FSAR Section 3.78.2.8. 2. Verify that consafety-related conduits less than or equal to 2 inches in diameter, not installed in accordance with the requirements of Regulatory Guide 1.29, satisfy applicable design requirements. d. Electrical QC Inspectc'r Trainino/ Qualifications i The TRT examined electrical QC inspector training and certification files, and requirements for personnel testing, on-the-job training, .i and recertification. The TRT also interviewed selected electrical QA/QC personnel. 1. The TRT found a lack of supportive docts:entation regarding personnel qualifications in the training and certification files, as required by procedures and regulatory requirements. Also, the TRT found a lack of documentation for assuring that the requirements for electrical QC inspector recertification were being met. Specific examples are: l One case of no documentation of a high school diploma or General Equivalency Diploma. ). ~I 1i i ) ......w. p.. e. -m,_,. -.. --

[*" a-6- - f One case of no documentation to waive the remaining 2 months of the required 1 year experience. One case where a QC technician had not passed the required color vision examination administered by a professional eye specialist. A makeup test using colored pencils was administered by a QC supervisor, was passed, and then a waiver was given. Two cases where the experience requirements to become a Level 1 technician were only marginally met. One case of no documentatio'n in the training and certification files substantiating that the person met the experience requirements. 9 Accordingly. TUEC shall review all the electrical QC inspector 4 training, qualification, certification and recertification files against the project requirements and provide the information in such a form that each requirement is clearly shown to have been 4 met by each inspector. If an inspector is found to not meet the training, qualification, certification, or recertification requirements, TUEC shall then review the records to determine the adequacy of inspections made by the unqualified individuals and provide a statement on the impact of the deficiencies noted on the safety of the project. 2. The TRT found a lack of guidelines and procedural requirements for the testing and certifying of electrical QC inspectors. Specifically, it was found that: No time limit er additional training requirements existed between a failed test and retest. 4 No controls existed to assure that the same test would not be given if an individual previously failed that test. No consistency existed in test scoring. No guidelines or procedures were available to control the disqualification of questions from the test. No program was available for establishing new tests (except when procedures changed). The same tests had been utilized for the last 2 years. Accordingly, TUEC shall develop a testing program for electrical r QC inspectors which provides adequate administrative guidelines, procedural requirements and test flexibility to assure that } suitable proficiency is achieved and maintained. i r i! l] -a

~ fl.:'1 The deficiencies identified with the electrical QC inspections have generic implications to other construction disciplines. The implications of these findings will be further assessed as part of the overall progranraatic review of QC inspector training and qualification and the results of this review will be reported under the QA/QC category on " Training and Qualification." II. Civil / Structural Area a. Unable to Justify Reinforcing Steel Omitted in the Reactor Cavity The TRT investigated a documented occurrence in which reinforcing steel was omitted from a Unit I reactor cavity concrete placement between the 812-foot and 819-foot 1-inch elevations. This reinforcement was installed and inspected according to drawing 2323-51-0572, Revision 2. However, after the concrete was placed, i Revision 3 to the drawing was issued showing a substantial increase in reinforcing steel over that which was installed. Gibbs & Hill Engineering was informed of the omission by Brown & Root Nonconfomance Report CP-77-6. Gibbs & Hill Engineering replied that the omission in no way impaired the structural integrity of the structure. Nevertheless, the additional reinforcing steel was added as a precaution against cracking which might occur in the vicinity of the neutron detector slots should a loss of coolant accident (LOCA) occur. A portion of the omitted reinforcing steel was also placed in the next concrete lift above the 819-foot 1-inch level. This was done to partially compensate for the reinforcing steel omitted in the previous concrete lift and to minimize the overall area potentially subject to cracking. The TRT requested documentation indicating that an analysis was perfomed supporting the Gibbs & Hill conclusion. The TRT was subsequently informed that an analysis had not been performed. Therefore, the TRT cannot detemine the safety significance of this issue until an analysts is performed verifying the adequacy of the reinforcing steel as installed. Accordingly TUEC shall provide an analysis of the as-built condition of the Unit I reactor cavity that verifies the adequacy of the reinforcing steel between the 812-foot and 819-foot 1-inch i elevations. The analysis shall consider all required load ]_ combinations. b. Falsification of Concrete Compression Strength Test Results The TRT investigated allegations that concrete strength tests were falsified. 50-445/79-09; 50-446/79-09)gion IV investigation (IE The TRT reviewed an NRC Re

j Report No.

of this matter that included 1 s e m

n ._r.. ' -~ - - - 1 -l q 3 interviews with fifteen individuals. Of these, only the 1 alleger and one other individual stated they thought that falsification occurred, but they did not know when or by whom. The TRT also reviewed slump and air entrainment test results of concrete placed during)the period the alleger was employed (January 1976 te February 197, and did not find any apparen': Variation in the g unifomity of the parameters for concrete placed during this period. Although the uniformity of the concrete placed appears to minimize i the likelihood that low concrete strengths were obtained, other allegations were raised concerning the falsification of records associated with slump and air content tests. The Region IV staff addressed these allegations by assuming that concrete strength test results were adequate. Furthermore, a number of other allegations dealing with concrete placement problems (such as deficient aggregate grading and concrete in the mixer too long) were also resolved by assuming that concrete strength test results were adequate. The TRT agrees with Region IV that, while the preponderance of evidence suggests that falsification of results did not take place, the matter cannot be resolved completely on the basis of concrete strength test results, especially if there is any doubt about whether they may have been falsified. Due to the importance of the concrete strength test results, the TRT believes that additional action by i TUEC is necessary to provide confirmatory evidence that the reported concrete strength test results are indeed representative of the strength of the concrete installed in the Category I conc mte structures. l Accordingly TUEC shall determine areas where safety-related concrete was placed between January 1976 and February 1977, and provide a l program to assum acceptable concrete strength. The program shall include tests sucn as the use of random Schmidt hammer tests on the concrete in areas where safety is critical. The program shall 1 include a comparison of the results with the results of tests per-formed on concrete of the same design strength in areas where the i i strength of the concrete is not questioned, to determine if any significant variance in strength occurs. TUEC shall submit the 3 program for performing these tests to the NRC for review and approval prior to perfoming the tests. c. Maintenance of Air Gap Between Concrete Structures l[ The TRT investigated the requirements to maintain an air gap between concrete structures. Based on the review of available inspection reports and related documents, on field observations, and on discussions with TUEC engineers, the TRT cannot determine whether an adequate air gap has been provided between concrete structures. Field investigations by B&R QC inspectors indicated ,,.'] unsatisfactory conditions due to the presence of debris in the air 1 s >i' b' ~

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i ^ ' k d g. O gap, such as wood wedges, rocks, clumps of concrete and rotofoam. The disposition of the NCR relating to this matter states that the " field investigation reveals that most of the material has been removed." However, the TRT cannot determine from this report (NCR C-83-01067) the extent and location of the debris remaining between the structures. ~ Based on discussions with TUEC engineers, it is the TRT's u'nderstanding that field investigations were made but that no pemanent records were maintained. In addition, it is not apparent that the permanent instdlation of elastic joint filler material ("rotofoam") between the Safeguards Building and the Reactor Building, and below grade for the other concrete structures, is consistent with the seismic analysis assumptions and dynamic models used to analyze the buildings, as these analyses are delineated in the Final Safety Analysis Report (FSAR). The TRT, therefore, concludes that TUEC has not adequately demonstrated compliance with FSAR Sections 3.4.1.1.1, 3.8.4.5.1, and 3.7.8.2.8, which require separation of Seismic Category I buildings to prevent seis::;ic interaction during an earthquake. Accordingly, TUEC shall: 1. Perform an inspection of the as-built condition to confir:n that adequate separation for all seismic category I structures has been provided. 2. Provide the results of analyses which demonstrate that the presence of rotofoam and other debris between all concrete structures (as detemined by inspections of the as-built conditions) does not result in any significant increase in seismic response or alter the dynamic response characteristics of the Category I structures, components and piping when compared with the results of the original analyses. d. Seismic Design of Control Room Ceiling Elements The TRT investigated the seismic design of the ceiling elements i installed in the control room. The following matrix designates those ceiling elements present in the control room and their seismic category designation: 4 k , 4 j e w> g-n. -r v- +- w- - - - - -,-r

-~ l... I 4 10 - 1 1. Heating, Ventilating and Air Conditioning Seismic Category I 2. Safety-Related Conduits Seismic Category I 3. Nonsafety-Related Conduits Seismic Category II 4. Lighting Fixtures Seismic Category II 5. Sloping Suspended Drywall Ceiling Non-Seismic a. 6. Acoustical Suspended Ceiling Non-Seismic n, 7. Lowered Suspended Ceiling Non-Seismic According to Regulatory Guide 1.29 and FSAR Section 3.78.2.8, the seismic Category II and nonseismic items should be designed in such a way that their failure would not adversely affect the functions of safety-related components or cause injury to operators. For the nonseismic items (other than the sloping suspended drywall ceiling), and for nonsafety-related conduits whose diameter is 2 inches or less, the TRT could find no evidence that the possible effects of a failure of these items had bee:: considered. In addition, the TRT determined that calculations for seismic Category II components (e.g., lighting fixtures) and the calculations for the sloping suspended drywall ceiling did not adequately reflect the rotational interaction with the nonseismic items, nor were the fundamental frequencies of the supported masses determined to assess the influence of the seismic response spectrum at the control room ceiling elevation would have on the seismic response of the ceiling elements. Accordingly, TUEC shall provide: 1. The results of seismic analysis which demonstrate that the nonseismic items in the control room (other than the ,j sloping suspended drywall ceiling) satisfy the provisions of a Regulatory Guide 1.29 and FSAR Section 3.78.2.8. E' 2. An evaluation of seismic design adequacy of support systems for the lighting fixturu (seismic Category II) and the suspended drywall ceiling (nonseismic item with modification) which accounts for pertinent floor response characteristics of the systems. 7 3. berification that those items in the control room ceiling not installed in accordance with the requirements of ,i Regulatory Guide 1.29 satisfy applicable design requirements. 4. The results of an analyris 'that justify the adequacy of j the nonsafety-related conduit support system in the control room J for conduit whose diameter is 2 inches or less. e i i ?! ] i e

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t-l 11 - ]l; S. The results of an analysis which demonstrate that the foregoing problems are not applicable to other Category .i-II and nonseismic structures, systems and components 3j; elsewhere in the plant. e. Unauthorized Cutting of Rebar in the Fuel Handling Building The TRT investigated an alleged instance of unauthorized cutting of rebar associated with the installation of the trolley process aisle rails in the Fuel Handling Building. The claim is that during installation of 22 metal plates in January 1983, a core drill was used to drill about 10 holes approximately 9 inches deep. The TRT reviewed the reinforcement drawings for the Fuel Handling Building and determined that there were three layers of reinforcing steel in the top reinforcement layer of tne slab. This reinforcement layer consisted of a No.18 bar running in the east-west direction in the first and third layers, and a No. 11 bar running in the north-south direction on the second layer. The review also revealed that the layout of the reinforcement and the trolley rails was such that the east-west reinforcement would interfere with the drilling of holes along only one rail location. However, if 9-inch holes were drilled, both the first and third layers.of No. 18 reinforcement would be cut. Design Change Authorization No. 7041 was written for authorization to cut the uppemost No.18 bar at only one rail location, but did not reference authorization to cut the lower No.18 bar. DCA-7041 also stated that the expansion bolts and base plates may be moved in the east-west direction to avoid interference with reinforcement running in the north-south direction. The information, described in DCA-7041, was substantiated by Gibbs & Hill calculations. If the ten holes were actually drilled 9 inches deep, then the allegation that the reinforcement was cut without proper authorization would be valid. 7 Accordingly, TUEC shall provide: 1 1. Infomation to demonstrate that only the No.18 reinforcing steel in the first layer was cut, or 2. Design calculations to demonstrate that structural integrity is maintained if the No. 18 reinforcing steel on both the first and third layers was cut. a III. Test Programs Area a. Hot Functional Testing (HFT) . ~ The TRT reviewed a sample of the completed data packages for HFT l i; preoperational test procedures, pertinent st,artup administrative procedures, NRC inspection reports, and the preoperational test index ,j and its schedule. The TRT also inspected test deficiency reports ,-y,- -y-e

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a d' j,;. 'f.- (TDRs) that were generated as a result of test deficiencies found prior to and during HFT. 1. Chapter 14 of the FSAR and Regulatory Guide 1.68 provide .~l requirements for the conduct of preoperational testing. i In reviewing test data packages, t..,s TRT found that certain test objectives were not met. It appears that the Joint Test Group approved incomplete data packages for at least three preoperational hot functinal tests. These were: Test Procedure Deficiency ICP-PT-02-12. " Bus Beca'use acceptable voltages Voltage and Load Survey" could not be achieved with the specified transformer taps, they were i changed. A subsequent engineering evaluation required returning to the original taps, but no retest was performed. i ICP-PT-34-05, " Steam Level detectors 1-LT-517, 518 Generator Narrow Range and 529 were replaced with Level Verification" temporary equipment of a design that was different from that which was to be eventually installed 1CP-PT-55-05 Level detector 1-LT-461 appeared i " Pressurizer Level to be out of calibration during the Control" test and was replaced after the test. The retest approved by the JTG was a 4 cold calibration rather than a test consistent with the original test objective, which was to obtain satisfactory data under hot conditions. Accordingly, TUEC shall review all complete preoperational test 3 4 data packages to ensure there are no other instances where test j-objectives were not met, or prerequisite conditions were not i satisfied. The three items identified by the TRT shall be !~ included, along with appropriate justification, in the test deferral packages presented to the NRC. 'O ^ 1 i !}- e -. - ~ - - - -.

^ ~ ~ _L..:- " ^ ^' ~ L ~; , -;3._ [ ^- ~ ~ 3, ~ ~ l ? i y 13 - 4 '), j 2. The TRT noted during a review of HFT completed test data that 4 the JTG did not approve the data until after cooldown from the test. The tests are not considered complete until this approval is obtained. In order to complete the proposed post-fueling, i: deferred preoperational HFT, the JTG, or a similarly qualified group, must approve the data prior to proceeding to initial criticality. The TRT did not find any document providing assurance that TUEC is committed to do this. Accordingly, TUEC shall commit to having a JTG, or similarly qualified group, review and approve all post-fueling preoperational test results prior to declaring the system operable in accordance with the technical specifications. ~ l 3. The TRT pointed out that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel load, certain limiting conditions of the proposed technical 3 specifications cannot be met, e.g., all snubbers will not be Jl operable since some will not have been tested. t Accordingly. TUEC shall evaluate the required plant conditions for the deferred preoperational tests against limiting conditions in the proposed technical specifications and obtain NRC approval where deviations from the technical specifications are necessary. 4. Data for the thermal expansion tests (which have not yet been approved by the JTG) did not provide for traceability between - the calibration of the measuring instruments and the monitored locations, as required by Startup Administrative Procedure-7. The infomation was separately available in a personal log held by Engineering. 1 Accordingly, TUEC shall incorporate the information necessary to provide traceability between thermal expansion test monitoring locations and measuring instruments. TUEC shall also establish administrative controls to assure appropriate test and measuring equipment traceability during future testing. b. Containment Intergrated Leak Rate Testing (CILRT) <j The TRT reviewed the data package for the CILRT performed on Unit 1, and discussed the conduct of the test with TUEC and NRC personnel who participated in or witnessed it. a 1 3q 1 - -, -, - _ _ - - ~. - - - - - - - - -, - - , - - * ~ s s ---e-- ,--,,.-,--,,---,,,-,,,,,,,_-,,,.,,,,-,,n,,.-. w c- ,-,,-------,-,-wwn.,_,g-,-----,. ,,-,-,.-----..-_,.rww

~ + a; .l, 4 3 Apparently after repairing laaks found during the first two attempts, the third attempt at a CILRT was successful. It was successfully completed after three electrical penetrations were isolated because the leakage through them could not be stopped. Though the leaks were subsequently repaired and individually I i tested with satisfactory results, NRC approval was not obtained to perfom the CILRT with these penetrations isolated. In addition, leak rate calculations were performed using ANSI /ANS 56.8, which is neither endorsed by the NRC nor in accordance with FSAR commitments. Accordingly, TUEC shall identify to NRC any other differences in the 4' conduct of the CILRT as a result of using ANSI /ANS 56.8 rather than ANSI M45.4-1972. Additionally, TUEC shall identify to NRC all other deviations from FSAR commitments. i c. Prerequisite Testing The TRT reviewed FSAR commitments, startup administrative procedures, prerequisite test records, craft personnel qua.lification records, and discussed them with startup and craft management personnel. The TRT also observed test support craft personnel at work and interviewed some of them to gain familiarity with their attitudes and i capabilities. The review of test records revealed that craft personnel were signing to verify initial conditions for tests in violation of startup Administrative Procedure-21, entitled: " Conduct of Testing" 4 (CP-SAP-21). This procedure requires this function to be perforined by System Test Engineers (STE). Startup management had issued a ~ memorandum improperly authorizing craft personnel to perform these 3 verifications on selected tests. i f Accordingly, TUEC shall rescind the startup memorandum (STM-83084), which was issued in conflict with CP-SAP-21, and ensure that no other 3 memoranda were issued which are in conflict with approved procedures. 4 d. Preoperational Testing The TRT assessed the preoperational test program by reviewing t' administrative procedures, interviewing startup personnel, and examining test records, schedules, system assignments, subsystem definition packages, and the master data base. Problems found with test data are addressed in section III.a of this ,3 enclosure. The TRT also found that STEs were not being provided with 'i-current design information on a routine, controlled basis, and had to l (- update their own material when they considered it appropriate. '1 l1 Accordingly. TUEC shall establish measures to provide greater assurance that STEs and other responsible personnel are provided with

y current controlled design documents and change noticesi Ll

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n. p-su. c. /.' ~ I i } TEO NICAL REVIEW TEAM BRIEFING aritrBER 18,1% INTIGUCTION R)LE OF TE TRT TRT EVIEW AREAS ELECTRICAL /INSTRLFENTATION CIVIL /ECHANICAL QA/QC COATINGS TEST PROGRAMS STATUS OF ONSITE EVIEW EFFORT POTENTIAL ISSLES IN AREAS OF ELECTRICAL /INSTRlPENTATION CIVIL TESTPROGRAMS l - (QA/QC, E0MICAL AM) C0ATINGS AREAS LATER) cactuSim F01A-85-59 .w-am,---

~ .e.' Y ,[ p 4 TECHNICAL REVIEW TEAM (TRT) 5 s Project Director T. A. Ippolito AE00;^ - v Assistant ? ' " J. Gagliardo IE Staff f M atti R.C. Tang R. Wessman e l I I l4 l l [ ~ Electrical / Civil /Machanical' QA/QC Leader Coatings Leader Test Programs i Instrumentation Leader i Leader Leader J. Calvo, NRR L. Shao, RES H. Livermore, R;III P. Matthews, NRR R. Kemig R-I s I 3 /N I i i t- - L _ _ _. _ _-. / s__ .1_ __ a, Technical. Issues Technical Issues Prcgrannatic and -Technical Issues Technical Issues,. 1 Generic technical 1 Allegations - Allegations - issues and 1 Allegations A11egatior.s allegations QA/QC Related QA/QC Related i DA/QC Related DA/QC Related to E. I&C to Civil / Mech. Integrate nA/nc to Coatings to Test Programs i from other groups l Interface with l i other groups on .i QA/QC O l ) ,i 1

a- + - _-a, -en m m m w&b4Mo ,M w -,-moe*=w 'em O G TYPICAL TRT INVESTIGATIVE ACTIONS ~~ 0 APPLICANT RECORDS REVIEW 0 INTERVIEWS WITH ALLEGERS 0 REVIEW 0F AFFIDAVITS APO DOC &ENTS PROVIDED BY ALLEGERS 0 INTERVIEWS WITH APPLICANT Af0 BaR STAFF 0 REVIEW 0F DEPOSITIONS 0 REVIEW 0F 0FFICE OF INVESTIGATIONS REPORTS 0 REVIEW 0F REGIONAL INSPECTION RECORDS 0 INSPECTION OF PLANT SYSTEMS APO CTF0ENTS O AS-BUILT VERIFICATION PROGRAM 0 ASSESSENT OF SAFETY SIGNIFICANCE i 9 'j h 1 -w w----w-w w-- r www,ru y y-e +w-

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W ALLEGATIONS BREAKDOWN -v / NO, OF N0, OF Afd GROUP LEADER CATEGORIES ALLEGATIONS ELECTRICAL J. CALW 9 53 CIVIL / STRUCTURAL ' L. SHA0 17 56 TEST PROGRAMS R KEIMIG 7 19 i A 1 4 1 ~_ 4 h e I / t I f 4 4 1 k h 9 R 1 \\ l. 1 ) s . - - - - ~. _..., _,, _ -.,. _ _. 4-- - y- - - - - - - - - - - - \\- [ I. 1 _i,

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.- n i I t ELECTRICAL /INSTRMNTATION ALLEGATIONS SIMMRY i 4 i APPLICANT ACTION CATEGORY NO. OMRACTERIZATON KftER OF ALLEGATIONS -REQUIED I2m &" S 1 ELECTRICAL CABLE 12 YES\\ u. fnt et' ameav = - 1 n,.n.,4"'/.Tj 6,i TER11 NATIONS \\ 2 E U RICAL N TRAY 9 ND a COM)UIT INSTALLATION 1,O'

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l 3 ELECTRICAL EQUlftENT 9 YES "[, ' ')," 'l, 7,;, T,.' ' " SEPARATION m,.. 1 -.,,. a c n o n,. sc,, .a rm-4 ELECTRICAL COM)UIT SLFPORTS 1 YES ~ u ~.,s c ro oe t. 5 ELECTRICAL NCR ACTIVITIES 23 NO 6 ELEGRICAL QC INSPECTOR 4 YES TRAINING /00ALIFICATIONS i 7 ELECTRICAL CABLE INSTALLATION 6 NO 8 ELECTRICAL PROCEDURES 10 ND 9 ELECTRICAL INSPECTION REPORTS, 2 NO INSPECTION REMNAL NDTICES a IN-PROCESS INSFECTIONS TOTAL 77*

  • ACTUAL MPBER OF ALLEGATIONS IS 53; SOE ALLEGATIONS INW)LVED MORE IliAN OE CATEGORY.

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E y A FCTRICAL/INSTRlPENTATION [ CATEGORY NO.1 - A FCTRICAL CABLE TEMINATIONS 1 POTENTIAL OPEN ISSlES: Te,, a m m, ~ ~,,,'c .~' or LACK OF AWAREESS OF QC ELECTRICAL INSPECTORS TO IEICATE IN TE ]gy~,0';,'l~f,., INSPECTION REPORTS MEN TE INSTALLATION OF TE "ECLEAR EAT-SHRIEAGE 1',"' %,f CABLE INSULATION SLEEVES" WAS REQUIRED TO BE WITESSED. f NC'eY o SELECTED INSPECTION REPORTS DID NOT IEICATE THAT TE REDUIRED

me WITESSING OF SPLIE INSTALLATION WAS DOE.

e o ABSENCE OF SPLICE QUALIFICATION REDUIREPENTS AE PROVISIONS IN THE INSTALLATION PROCEDURES TO VERIFY OPERABILITY OF THOSE CIRCUITS FOR MlICH SPLICES ERE BEING USED. 1 o SELECTED CABLE TERMINATIONS ERE IN DISAGREEPENT WITH DRAWINGS. o NONCO E ORMANCE REPORTS CONCERNING VE E OR-INSTALLED TERMINAL LUGS IN GE ETOR CONTROL CENTERS HAD BEEN IPPROPERLY CLOSED, ACTIONS REQUIRED BY TEC: o CLARIFY PROCEDURAL REDJIREPENTS Am INSPECTOR TRAINING WITH RESPECT TO TE AREAS IN MIICH WCLEAR EAT-SHRI*ABLE SLEEVES $E REQUIED ON BlITT SPLI Ss ASSUE THAT SUCH SLEE'ES ARE INSTALLED MIERE EQUIRED, o ASSUE THAT THE QC INSPECTION REDUIRING WITESSING FOR BUTT SPLICES HAVE BEEN PERFORE D A E PROPERLY DOCIEENTED: AND VERIFY THAT ALL BUTT SPLICES AE PROPERLY IDENTIFIED ON TE APPROPRIATE DRAWINGS AE IN PAELS, o DEVELOP ADEQJATE INSTALLATION / INSPECTION PROCEDURES TO ASSURE TE OPERABILITY OF THOSE CIRCUITS CONTAINING BUTT SPLICES, THAT TE WIRING SPLICING MATERIALS AE QUALIFIED FOR TE SERVICE CONDITIONS, AND THAT SPLICES AE NOT LOCATED ADJACENT TO EACH OTHER. i I l ..-__w.- .w+ =

CONTIPAJED 2-( o EINSPECT ALL SAFETY-ELATED AND ASSOCIATED TERMINATIONS IN TE CONTROL N" ^ R M' *. f f *

  • s ROOM PAELS At0 IN TE TERMINATION CABIETS IN TE CABLE SPEADING ROOM IfC t TO VERIFY liiAT TEY AE IN ACCORDANCE WITH DRAWINGS. SHOULD TE RESILTS

"",._',,.',s y 0F llilS EINSPECTION REVEAL AN UNACCEPTABLE LEVEL OF NONCOPFORMANCE 10 DRAWINGS, TE SCOPE OF THIS REINSPECTION EFFORT SHALL BE EXPAl0ED TO. INCLUDE ALL SAFETY-RELATED Al0 ASSOCIATED TEFMINATIONS AT CPSES. o REEVALUATE APO REDISPOSITION ALL NCRs RELATED TO VENDOR-INSTALLED e. TERMINAL LUGS IN GE t0 TOR CONTROL CENTERS. i l h 0 i -w-.. ,m

l . ELECTRICAL /INSTRIPENTATION CATEGORY NO. 3 - ELECTRICAL EQUIPENT SEPARATION POTENTIAL OPEN ISSUES If;,', '[ o NtrtNuus LA&.d a-SEPARATE SAFETY-RELATED CABLES WITHIN FLEXIBLE ' 5 , g ~j,,,,, COEUITS INSIDE MAIN CONTROL PAELS DID NOT EET MINIM SEPARATION ,,, a REQUIREENTS. o,.....,. s % ~....c TS%<7-0 SEVERAL CASES OF SEPARATE SAFETY A E NONSAFETY-RELATED CABLES AND SAFETY AE NONSAFETY-RELATED CABLES WITHIN FLEXIBLE CONDUITS INSIDE MAIN CONTROL R00M PAELS DID NOT NET MINIM SEPARATION REQUIREENTS. o EXISTING TIEC'S ANALYSIS SUBSTANTIATING THE ADEDUACY OF TE CRITERIA FOR SEPARATION BETEEN CDEUITS AND CABLE TRAYS HAD NOT BEEN REVIEWED BY TE NRC STAFF. o TWO MIER VIOLATIONS E TE SEPARATION INSIDE PAELS CPI-EC-PRCB-09 AND CPI-EC-PRG-03 CONCERNING A BARRIER FOUE REPOVED AE REDUEANT FIELD WIRING NOT EETING MINIM SEPARATION. ACTIONS REQUIRED BY TEC o EINSFECT ALL PAELS AT CPSES THAT CONTAIN REDUNDANT SAFEIY-RELATED CABLES WITHIN C00VITS, OR SAFETY AE NON-SAFETY ELATED CABLES WITHIN CONDUITS, AND EITHER CORRECT EACH VIOLATION OF TE SEPARATION CRITERIA, OR DEF0NSTRATE BY ANALYSIS TE ACCEPTABILITY OF TE CONDUITS AS BARRIERS FOR EACH CASE WHERE TE MINIM SEPARATION IS NOT ET. o EINSPECT ALL PAELS AT CPSES, AND EITHER CORRECT EACH VIOLATION OF THE SEPARATION CRITERIA CONCERNING SEPARATE CABLES A E CABLES WITHIN FLEXIBLE ^ CONDUIT, OR DEP0NSTRATE BY ANALYSIS THE ADEDUACY OF THE CONDUITS AS BARRIERS. o SUBMIT TE ANALYSES THAT SUBSTANTIATE TE ACCEPTABILITY OF THE CRITERIA STATED IN.TE ELECTRICAL EECTION SPECIFICATIONS GOVERNING THE SEPARATION BETWEEN INDEPENDENT CONDUITS AND CABLE TRAYS, o CORRECT TWO MINOR VIOLATIONS OF TE SEPARATION CRITERIA INSIDE PAELS i; CPI-EC-PRCB-09 Am CPI-EC-PRCP-03. l -w,, ,,,m ayw,-m r

l ..f.. a.. 2 ? !Iv v y_. FI FCTRICAL/INSTRPENTATION Da L.w,,-1 C,y CATEGORY NO. 4 - ELECTRICAL COM)UIT StifUKIS w,o n, s m u ,.., e c u. c <.- gg n..j ( l', ( FOTENTIAL OPEN LSSUE e om ' n '- '- o TE SUPPORT INSTALLATION IN SEISMIC CATEGORY I AREAS, OTER ,,,..,,, e.., e - ~ z. THAN TE CONTROL 100M, FOR NONSAFETY-ELATED C(N)UIT LESS THAN '""/ OR EDUAL TO TWO INCES IN DIMETER WAS INCONSISTENT WITH SEISMIC F" M ~ REQUIRE E NTS. NO EVIDENCE COULD BE FOUND THAT SUBSTANTIATED

,.y s c t THE ADEQUACY OF THE INSTALLATION FOR NONSAFETY-RELATED C0f0VIT

' S.C '.' ~. 0F ANY SIZE. ,. : '..,.,w g-ACTIONS REQUIRED BY TEC 0 SLESTANTIATE TE ADE12]ACY OF THE SEISMIC SUFFORT SYSTEM INSTALLATION FOR NONSAFEIY-REl.ATED COM)UIT IN SEISMIC CATEGORY I AREAS OF THE PLANT OTER THAN TE CONTROL 100M. e S 4 f G i 1 ) a i + k + p- ,e,- ,--s- .,_,_..,..-nn_, -, ,n, ,-,.,,_e.,.,,_,-7., a-,,,,

n ^ I FIFCTRICAL/INSTRlPENTATION CATFr@Y 2, 6 - FIFCTRICAL QC IldtuuR TRAINING / QUALIFICATIONS 7,,, POTENTIAL OPEN ISSLES ' i,,e,s . %~ s o L4CK OF SUPPORTING DOClFENTATION ON PERSOffEL WALIFICATIONS IN TE .c ~ ~ < ~- TMINING AE CERTIFICATION FILES, . (%,c n o '" ' o LACK OF GUIDELIES AE PROCEDURAL REI1JIREENTS FOR TE ELECTRICAL QC 7^,',',[',[,, INSPECTOR TESTING PROGRAM, ,g d 7"m,." '" ,O LACK OF DOClf'ENTATION FOR ASSURING THAT TE REQUIREENTS FOR ELECT QC INSPECIDR EGRTIFICATION ERE BEING ET. ACTIONS EWIRED BY TUEC REVIEW ALL TE i1ECTRICAL QC INSPECTOR TRAINI LIFICATION, CERTIFI-o CATION AE ECEUIFICATION FILES AGAINST TE REQUI N AE PRNI TE Ilf0lNATION IN SUCH A FORM THAT EACH U IS CLEARLY SHOWN HAVE EEN ET BY EACH INSPECTOR IF AN INSPECTOR IS FOU E TO ET TMINING, QUALIFICATION, CEkTIFICATION, OR RECERTIFICATION , TIEC SHALL TEN EVIEW TE EU)RDS TO DETERMIE TE ACCEPTABILITY OF INSPECTIONS MADE BY TE ifl0UALIFIED IEIVIDUAL gDEj gTg TE IPPACT OF TE DEFICIENCIES ETED ON gAE i o DEVELOP A TESTING PROGRAM FOR ELECTRICAL QC INSPECTORS WHICH OPTIMIZES ADMINISTRATIVE GUIDELIES PROCEDUE REDUIREENTS AE TEST FLEXIBILITY TO ASSUE THAT SUITABLE P$0FICIENCY IS ACHIEVED AE MAINTAINED. j o THESE ACTIONS SHOULD BE COORDINATED AS APPROPRIATE WITH OTER ACTIONS ON TE SAE SUBJECT THAT WILL BE ADDRESSED UNDEF TE QA/QC CATEGORY CN I " TRAINING AND QUALIFICATION," 1 1 1 'h l ji a e I ~_ _.y. --o-...,... -. - - - ~ ~. -, -._,, __,, m ,y, ,,.__r,. -

^ I I CIVIL / STRUCTURAL ALLEGATIONS SIM1ARY CATEGORY NO. OF APPLICANT ND. CHARACTERIZATION ALIFGATIONS ACTIONS REQUIRED 1 INADEDUATE MATERIALS 6 NO USED IN CONCETE 2 CONCETE PLACDENTS 3 NO 3 POOR WEATER CONDITIONS 2 NO 4 CONCETE VOIDS / CRACKED 7 NO 5 MISCELLAEDUS CONCETE 4 ND 6 REBAR IIPROPERLY INSTALLED / 9 YES OMITTED 7 CONCEE - UND0ClMMTED 1 NO 8 FALSE / WRONG DOCLPENTS 6 YES 9 QC INSPECIDR TRAINING 1 NO 10 IlPROPER TESTING 6 NO 11 SEISMIC DESIGN /00NSTRUCTION 1 YES 12 CONCETE CONSIRLCION 1 NO A2 DEFICIENCIES /DLERANCES 13 CRACKS IN CONCRETI BEEATH 1 NO THE EACTOR VESSE. 14 SEISMIC DESIGN OF (DNTROL ROCN 1 YES CEILING EL9ENTS 15 REBAR IW ROPERLY DRILLED 5 YES 16 EXCAVATION / BACKFILL 1 NO 17 CONCREIE SAIPLING 1 NO TOTAL ALLEGATIONS 56 1

I .i I i CIVIL /STRUGURAL CATEGORY K). 6 - lMABLE TO JUSTIFY EIFORCING STEEL MITTED IN REACTOR CAVITY WALL POTDfTIAL OPEN ISSE A PORTION OF EIEORCING STEEL WAS OMITIED IN A EACTOR CAVITY CONCETE WALL PLACEKNT BEIEEN ELEVATION 812' - 0" Af0 819' - 06". ACTION EQJIED BY TlEC TIEC SIDAD PR[NIDE AN ANALYSIS THAT VERIFIES TE ADEQUACY OF TE EIEORCING STEEL IN TE AS-BUILT QPOITION 0F TE EACTOR CAVITY WALL, j l i 1 i e f I l. I i

q 1 I i CIVIL /STIUCTURAL CATEGORY NO. 8 - FALSIFICATION OF CDNCRETE COMESSION STENGTH TEST ESlLTS POTbHIAL OPEN ISSE ALLEGATION ON FALSIFICATION OF 00NCETE 00PPRESSIVE STENGTH TEST ESULTS C0lLD NOT BE PRDWD VALID OR INVALID. CONCETE STENGTH L0ER THAN THAT SPECIFIED IN TE DESIGN MAY EDUCE TE LDAD ESISTING CAPACITY OF STRUCilEES. I ACTION EQUIED BY TlEC TlEC SHOULD DETERMIE AEAS WERE ELATED 00NCETE WAS PLACED DURING TE ERIOD FRM JAMJARY 1976 TO FEBRJARY 1977 APO PROVIE A PROGRAM TO ASSURE ACCEPTABLE t i i CONCETE STENGTH, SUCH AS C0f00CT APPROPRIATE RAND (N SONIDT HAPTER TESTS ON i i TE CONCETE IN AEAS WEE SAFETY IS CRITICAL. I i I O I g + l

i'

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.I - I It k CIVIL /STRUCTIRAL ' CATEGORY NO.11 - MAINTENANCE OF AIR GAP BElWEN CONCREE STRUCTIEES FOTENTIAL OPEN ISSES i BASED ON TE REVIEW 0F AVAILABLE INSPECTION EPORTS E ELATED DOClPENTS, FIELD OBSERVATIONS E DISCUSSIONS WITH TEC ENGIEERS, TE TRT CE0T DETEIMIE WETER AN L ADEWATE AIR GAP HAS BEEN PROVIDED ETEEN CONCEIE STRUCTURES. ACTION EQUIRED BY TEC l PROVIE DOClMNTS OR INSPECTION ESULTS TO DEENSTRATE THAT ADE00 ATE SE"ARATION BE1EEN i j ALL CONCETE STRUCTURES HAS BEEN PROVIDED. PERFORM ANALYSIS TO DEENSTRATE THAT TE AS BUILT C0EITIONS DO NOT SIGNIFICANTLY INCEASE TE SEISMIC ESPONSES OF CATEGORY I STRUCTURES E 00E0ENTS. l i l t I l

CIVIL / STRUCTURAL CATEGORY NO 14 - SEISMIC ESIGN OF 00NTROL ROOM ElijNG ELEENTS FOTENTIAL OPEN ISSE

  • 'l FIELD M COMIT, TE SUSPEEED EILING ELEENIS, Am TE LIGHTING FIXTURES INSTALLED IN TE CONTROL ROOM &ILING AE CLASSIFIED AS NON-SEISMIC OR SEISMIC CATEGORY II AE MAY FALL AS A RESULT OF A SEISMIC EVENT.

i i ACTION EQUIED BY TEC PROVIDE OR MOIFY SEISMIC CALQLATIONS ON SEISMIC CATEGORY II AE NON-SEISMIC ELEENTS IN TE CONTROL ROOM &ILING TO DEP0NSTRATE lliAT TEIR FAILURES WILL NOT AFFECT SAFETY RELATED 00lf0ENTS OR CAUSE IPUURY TO OPERATORS. 1 PROVIDE lE RESULTS OF AN ANALYSIS WIIOi DEENSTRATE THAT TE FOREGOING PR[BLEMS AE NOT APPLICABLE T0 QTER CATEGORY II Am NONSEISMIC STRUCTURES, SYSTEMS, AE C0E0ENTS ELSEMEE IN TE PLANT. 1 ,5

1-i 2 4

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CIVIL STRLTURAL CATEGORY E.15 - UN4llTHORIZED CllTTING OF REBAR IN TE RR HAELING BUILDING FOTENTIAL OFEN ISSE (MAUTHORIZED alTTING OF REBAR ASSOCIATED WITH TE INSTALLATION OF TE THOLLEY PRD&SS AISLE RAILS IN TE FlE HAELING BUILDING MY HAVE OCQJRRED. LOSS OF'TE REBAR MY REDUCE TE LOAD i RESISTING CAPACITY OF TE CONCRETE FLOOR SLAB. ACTION EQUIRED BY TEC PROVIE TE FOLLOWING IWORTION REGARDING DRILLING 0F REBAR: a~ (1) IWORMATION THAT DEP0NSTRATES THAT OM_Y THE LFPERST #18 BAR WAS GlT, OR ); (2) DESIGN CALQLATIONS THAT DEP0NSTRATE THAT STRUCRIRAL INTEGRITY IS MAINTAIED IF #18 BARS i IN T'iE UPPEST AE TE LOWERPDST LAYERS AE QIT. r t j l l L, i l l' I I

t TESTING PR) GRAM ALLEGATIONS SlfNARY l CATEGORY 70 0F APPLICANT ND. OMRACTERIZATION ALLE$ATIONS ACTION EQUIED ~ 1 DEFICIENT HDT RETIONAL TESTS 12 E 2 NO TESTING PROGRAM FOR (filT 2 1 NO I 3 DEFICIENT CONTAINNT LEAKAGE TESTING 1 E i 14 FUKD PEREQUISITE TESTING 1 E ,j 5 FUKD PREDfERATIONAL TESTING 2 E 6 NONCONSERVATISM 0F TlEC MANAGEMNT APPA0ACH I ND 7 MINIMAL QA/0C SURVEILLANCE OF TESTING 1 NO ACTIVITIES TOTAL ALLEGATIONS 19

l

.i:l; 4 l I' i i .j 6 l l i I 1 l i,

.~ : .~ , j! ' i f TESTING FH0 GRAM CATEGORY W.1 - WT FUNCTIONAL TESTING \\ FOTENTIAL ORN ISSES: o DEFICIENCIES IN EVIEW 0F f9EDFERATIONAL TEST ESil.TS BY TE JTG. i o EVIEW ESil.TS & PEDFERATI(MAL TESTS PUNED FOR COMUCT SIRM1FNT TO INITIAL RR } LOAD E PRIOR TO ECLARING SYSTEM ORRABLE PER TEONICAL-SPECIFICATIONS o .00EIGURATION & SYSTEMS MAY NOT EET TE0MICAL SPECIFICATION EDUIREENTS FOR l' : OPERABILITY, FOR CERTAIN P00ES, WEN PEDFERATIONAL TESTS AE COMUCTED SlESEGENT TO 'l jl INITIAL RR LOAD i i !i o TRACEABILITY 0F TE TEML EXPANSION TEST EQUIFENT, CALIBRATION DATA, E LOCATIONS i WERE TEST EDUIFENT USED 4 t ACTION EGJIED BY TIEC: l* o INCLL0E WT WICTIVES NOT ET DlRING FEBRUARY - JtE 1983 WT IN SLESEQlENT ET PEGRAM [ E EVIEW ALL OF WT TEST PACKAGES TO IDENTIFY ANY OTER DERSIGITS BY JTG i i o 00mITENT TO F0ML REVIEW E AFPfMAL 0F DEFERRED ffE0FERATIONAL TEST RESULTS BY QUALIFIED GROUP PRIOR TO ECLARING SYSTEM OPERABLE ER TE0MICAL S CIFICATIONS I = I o COEUCT EVALUATION TO IDENTIFY SYSTEE WlIOl W0llD NOT EET TE0MICAL SPECIFICATION OPERABILITY EDL,'IREENIS DURING FOST-FlEL LOAD f9EDPERATIONAL TESTING ACTIVITY E SlEMIT TO MC FOR REVIEW o INCLLEE CALIBRATION DATA FOR SPECIFIC EASURING DEVI&S E LOCATIONS WEE DEVICES EE USED IN TEST E00RDS l

. -. -~ TESTING PROGRAM CATEGORY 2, 3 - CONTAllMNT INTEGRATED LEAK RATE TESTING FUTENTIAL OFEN IR9FR: o CALQLATION OF CILRT RESULTS NOT IN ACCORDANCE WITH FSAR COMITENTS E 10 GR 50, APREIX J 4 j o CERTAIN ELECTRICAL PEETRATIONS ERE ISOLATED DURING CILRT t E ACTIONS EQJIRED BY TEC: o IDENTIFY E JUSTIFY DEVIATIONS FROM FSAR CGMITENTS AE EC EDUIENNTS THAT OCCURRED DURING C0EUCT OF CILRT l l l> i e = l i

  • l i

i

~~-~~~.-o .-e E a f TESTING PROGRAM CATEGORY M). 4 - FHEEWISITE TESTING FUTENTIAL OPEN ISSLES:

L o

STARTlP MANAGEENT BYPASSED APPROVED ADMINISTRATIVE PROCEDLES WITH MM)RAELM h ACTIONS REDUIED BY TIEC: o RESCIM) STARTlP EP0RAElM (STM - 83084) WICH WAS ISSED IN COELICT WITH CP-SAP-21 o ASSURE THAT NO OTER 700 RAM)A ERE ISSLED WICH Q)ELICT WITH APPROVED ADMINISTRATIVE OR OTER PROCEDURES i, i l i 6

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l i e i i e h 4 1

<g - - - - - - I...., j l - 'l i ~! 0 e+ _a E B B is W s ~ f 5 s li el ~ a s g 5 i Q g Wg s = la i a e ,p W G= = m g g l ~ E o o j O

. ; : ;.,._.. ;;..,.,,:;;. _.l, ;;;;.. .u..,~',,~ fpfcw gow ase{ - Arv r xs n a r.p W a$$ey $ 4 Y" i x <ct - 4 A u be./JZ ypuc.' f ~ n '5 e4 witstr 77ttr 7~/Er

pro, 7 7,s ef surco

/w fftM f)'#AP NUCLEAR REGULATORY COMISSION (NRC) ELECTRICAL AND INSTRUMENTATION (E&I) i TECHNICAL REVIEW TEAM (TRT) COMENTS' 0F TEXAS UTILITY ELECTRIC COMPANY (TVEC) PROGRAM PLAN AND ISSUE - SPECIFIC ACTION PLANS DATED OCT08ER 8, 1984 FOR COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) t UNITS 1 AND 2 OCTOBER 16, 1984 F0lA-85-59 s 4

1 . ~....,.. ........,..a. .a. l et i HEAT SHRINKABLE CABLE INSULATION SLEEVES, ITEM NO. I.a.1, SECTION 4, "TUEC ACTION PLAN" Calculated sample size in accordance with STD-105D should be stated. r eth os p-. s,s

,n

,3 : f,,, r,. < .i Equipment selected for sampling should be stated in TUEC action plan. j. /. Subparagraph 8: Post-Construction Inspection Procedure QI-QP-11.3-40 was not addressed. ruou t e s e" MIL-STD-105D(RevisionUsed)gsubmitted to the NRC. Rejecting criteria should consider expanding the sample size based v. on the seriousness of unacceptable cases found. e e S "~ - .-....w.. .m,_..... _,.,.

- = - .. N1 . - -....,.l.: : INSPECTION REPORTS ON BUTT SPLICES. j ITEM NO. I.a.2. SECTION 4 TUEC ACTION PLAN" f JR$ R(v s tr.>= D T5 V "i W~ d Indicate how the additional IR's, associated with thegTRT, were obtained by TUEC (potential programmatic QA/QC concern). What is TUEC's cases for selecting the additional sample of twelve v cables? (MIL-STD-105D?).

h. Phase 2 shou'1d be implemented irrespective of the findings in Pnase 1.

Phase 2 is also accomplished as part of TUEC action plan Item I.a.3, Section 4.A (3rd paragraph) and Section 4.B. /Furthermore, Amendment Fof the FSAR states there are only limited amounts of butt splices used and the NRC staff accepted this practice on this basis. ~ l 1 l 1 l .w. y.-c -ewee ---e-------- -1 ---weW~ w wmv'e uwwvv-m ~ www-e-wpm &-*--~m---yw-w-m M t w-?-~-2-'M-m-W-e ~ "r"-----

r^ BUTT SPLICE QUALIFICATION, ITEM NO. I.a.3. SECTION 4 "TUEC ACTION PLAN" Identify those circuits in which butt splices existed. Indicate how the test was accomplished. What were the acceptance / rejection criteria. / ection 4.A (paragraph 3) should be coordinated with Phase 2 in S Item I.a.2.' /. Bundles containing splices in Section 4.B should be coordinated with Phase 2 in Item I.a.2. D e W i s

r - n _. _ s. AGREEMENT BETWEEN DRAWINGS AND FIELD TERMINATIONS. ITEM NO. I.a.4, SECTION 4, TUEC ACTION PLAN 'I Para. 4.A; Equipment selected for sampling should be stated in TUEC action plan. T o.r o Para. 4.A; The drawings associated with the terminations sampled should g reflect all the latest design documents and shall be so identified in the TUEC action plan. Provide the design change numbers and documents used by TUEC to establish C o rUtf C f L Y that the TRT deficiencies cited for the three cables, were =2+4ehe+^ "y connected.r.arxectly. Based on the TUEC preliminary assessment of the deficiencies cited by the TRT, and TUEC indication that additional documents,were av,ailable to account for the disagreements to drawings, poses a potential pro- .t'., .~ t- 't e,( i ', . ' "c, grammatic QA/QC concern that will require further evaluation. ,ep)s.0gr[9- , c 'j 4, , J 1,, i, o ,,'/,'q[')/.! efine what TUEC means by reliability req D $'[(gk,b, acceptance and rejection criteria. i 3(.y, b t RC staff does not agree with the acceptable conditions as stated d i s ' \\ d M in Section 4.A.A and B (page 3 of 4). Operability is not of concern, s \\ '".M \\A k Otd v"!L / but e)nhorwance of hardware to drawings is the issue. kt gp e t t" 4 , \\ gj%f r L7t u o ur.r e s sa m.- p eu is i ou ' N $*W /// L c/ft t-' }J y-tfu - y yy g.,~g p p y /Jt,r y, Nua e 1,.o,,,, ,,,,,,g n.,: y cx t* ' ( k k< n, a G p,M W h "A u&$. & cA ene.e m' I" y W **f SY*! 1C.,{ Lac'fu t g (q/c le g al LeQ T~, fy y& {,e4 d q & a cl s..< fr!/idf ( ) ._~ -__. - - _ _ - _ _ _ _ _ -. -.

r ._r,_.__. 2_ Acceptable conditions using cable / conductor terminations at a size larger should be supplemented to include that this condition is acceptableaslongasagoodconnectionisestablished[Section 4.C (page 3 of 4)]. s i e .e 0 e 0 e e m,w~,.....-. .-e..., ~~ 4

".. ;; ~ ~ - 4 6, NCRs ON VENDOR INSTALLED AMP TERMINAL LUGS. IILM NO. I.4.5. SECTION 4 "TUEC ACTION PLAN" e==<ss Other NCR's identifying lugs bent or twisted in aseems of 60*, disposi-tioned(statedintheNCRform)thatthelugsare"determinedto"not pose an equipment serviceability problem", should also be included in the TUEC action plan. 4 t 9 6 O I s e 4 n....~, 4

.~ s: FLEXISLE COND'JIT 70 FLEXIBLE CONDUIT SEPARATION, IILM NU. I.b.I, 5ECTION 4 "TUEC ACT 'ON PLAN The analysis shall cons'ider the acceptability of redundant flexible conduits in contact with each other. 3 e 5 0 e 9 4-i e 6 i I - _. _.. ~, _. -

7..

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TLEXIBLE'CONDUITT02ABLESEPARATION, I ITG NO. I,b A. SECTION 4, 2 /EC ACTION PLAN" The analysis shall consider the acceptability of flexible conduit .. r to redundant cable in contact with each othdr. If the analysis bnstrates the flexible conduf t as an acceptable barrier, specifications, drawings, procedures and associated documents , a s. s, ,,,, e s.. t : shall be corrected accordir. gly r ; edened+y the TUEC action plan. I 4 e I 4 J

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I* /J. k{,i (/d [ uenTEo STATE's }. NUCLEAR REGULATORY COMMISSION % f2. t i C. } i e. \\...*/ t 4 NOV 1g MEMDRANDUM FOR: Joseph Scinto Deputy Director Office of the Executive Legal Director i FROM: Vincent S. Noonan, Project Director Comanche Peak Technical Review Team 1

SUBJECT:

COMANCHE PEAK TECHNICAL REVIEW TEAM (TRT) AND REGION IV INPUT TO THE STAFF'S RESPONSE TO TEXAS UTILITIES 50.57(C) MOTION TO LOAD FUEL AND CONDUCT CERTAIN PREC,RITICAL TESTING i Enclosed are allegations and issues still under evaluation by the TRT in the Civil / Structural, Mechanical / Piping, Electrical / Instrumentation. Test l Programs, and QA/QC areas affecting systems that may be needed for fuel load j and the precritical testing requested by the applicant. There are no outstanding issues in the TRT Coatings area that would affect the systems i needed for fuel load and precritical testing requested by the applicant. Also enclosed is the status of Region IV room inspections as they relate to the applicants motion. / I r ect Director nche Pe achitical Review Team j l cc: E. Case D. Eisenhut i R. Martin, Region IV { J. Gagliardo R. Wessman 1 A. Vietti - R.C. Tang P. Matthews L. Shao 2 i J. Calvo } R. Keinig N. Liverworv j R., la rt f. FO!A-85-59 ~ h l ) 3W f 1 . /o l g ml6

} e. I s) ' ) Allegation.s and l'echnical Issues Still Under Evaluation By the TRT j in the Civil / Structural Area Affecting systems That May Be Needed for 'l 1 Fuel Load and the Precritical Testing Requested By the Applicant i q 1. Interac. tion of Seismic Category I Buildings and Systems Housed Within Them The TRT investigated the requirements to maintain an air gap between concrete structures. The TRT reviewed available inspection reports and .related documents, made on field observations, and had discussions with TUEC engineers. The TRT found a lack of supportive documentation that an air gap has been provided between concrete structures. TUEC has not adequately demon.- strated compliance with FSAR Sections 3.8.1.11.1, 3.8.4.5.1 and 3.7.8.2.8, which require separation of Seismic Category I buildings to prevent seismic interaction during an earthquake. Accordingly, by letter dated September 18, 1984 TUEC has been required to perform inspections \\ and provide the results of analyses to demonstrate that Seismic Category I structures, systems, and components are safe in the as-built ! condition. s i In response to.the MAC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984, to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently preparing a latter to TUEC documenting these specific connents. Since a thorough ~ dsesdnent o0 this issue has not been completed as yet, it is inappropriate to consider fuel load and the precritical testing i requested by the app 1ft' ant at this time. 2. Seismic Design of Control Room Ceiling The TRT investigated the seismic desi,gn of the ceiling elements installed in the control room. I ~ 'This" review revealed that TUEC had not adequately demonstrated that the suspended ceiling (, lighting fixtures and non-safety related conduit over l the control room which are classified seismic Category II or Non-Seismic-by TUEC) are appropriately designed such that their failure would not adversely affect the functions of safety-related components in the control room or cause injury to operators. Accordingly, by letter dated s e. Sept r 18,1984, TUEC has been required to provide further analyses and av luations to justify their design. In addition, TUEC has-been- [ ~ requi to provide the results of an analysis which demonstrates that the foregoing problems are not applicable to other Category II and j non-seismic structures, systems and components elsewhere in the plant.; I' ~ ~

  • n,.

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e ,y 3 s,~. i 1{ 2-In response to the NRC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is ' ) currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984 to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific connents. Since a thorough assessment of this issue has not been completed as yet, it is inappropriate to consider fuel load and the precritical testing , requested by the applicant at this time. 7, Allegations and Technical Issues Still Under Evaluation By The TRT in Mechanical /P1 zing Area Affecting the Systems That May Be Needed For Fuel Load and The 'recritical Testing Requested By The Applicant. TheTRTevaluaNionofallegationsandissuesintheMechanical/ Piping area is still in progress. The staff is planning to have a public meeting with the applicant to identify requests for additional information in the Mechanical / Piping area in late November 1984. The TRT review of the following allegations and issues would require action by the applicant-before proceeding with the fuel load licensing process. 1. Plug Welds The TRT is evaluating alleged unauthorized and undocumented plug welds that were fabricated in pipe and cable tray supports and base plates located throughout the plant including the South Yard Tunnel and Unit 2 Cable Spreading Room. 2. Piping Systems Between Seismic Category I and Non-Seismic Category I Building l The TRT is evaluating an issue identified in the April 1984, CPSES Special Review Team Report that the affects of seismic interactions have 1 not been considered, contrary to the FSAR Section 3.7.8.2.8 connitment. 3. Skewed Welds On Pipe Supports 4 ~ 'The TRT is evaluating alleged lack of written QC inspection procedures for the examination of certain types of skewed welds on pipe supports initially identified in ASLB Hearings on July 30, 1982, by Mr. C. Atchison. e 4. Cutting Of Boits On Steam Generator Lateral Supports I The'TR1isevaluatinganallegationthatsomeanchorboltsinthesteam zationj[or upper lateral supports were shortened without proper authorf-genera l L uring installation of the beams because there was concrete in the 1 j hole. 5. Temporary Supports During Piping Installation 4 Ii i l . ame,.

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i I ? 3_ The TRT, while evaluating an allegation that a main steam line was forced. into place using the main polar crane in Unit 1, identified additional concerns regarding: 1) the effects of settlements at temporary supports during flushing of the main steam line; and 2) the adequacy of temporary supports in general. t Allegations and Technical Issues Still Under Evaluation By The TRT I in the Electrical / Instrumentation Area Affecting Systems That May Be Needed for Fuel Load and the Precritical Testing Requested By The. Applicant 1. Electrical QC Inspector Training / Qualification Deficiencies The TRT examined GC electrical inspector training and certification files, and requirements for testing program, on-the, fob training and recertification program. The TRT found a lack of supportive documentation regarding personnel qualifications in the training and certification files, as required by procedures and regulatory requirements, and also found a lack of documentation for assuring that the requirements for electrical QC inspector recertification were being met. Accordingly, by letter dated September 18, 1984, the staff requested additional information from TUEC. In response to the NRC lettier of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984, to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific comments. These deficiencies identified with the electrical QC inspections have generic implications to other construction disciplines. The implications of these findings are being further assessed as part of the TRT overall programmatic review of QC inspector training and qualification. It is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time, due to the uncertainty regarding the .. qualification and training of inspectors involved in inspecting systems ] needed for this activity. 2. Conduit Support Installation Deficiencies in Selected Seismic Category I Areas 1 The TRZ examined the nonsafety-related conduit support installation in select pseismicCategoryIareasoftheplant. The support installation l-for nolisafety-related conduits, less than or equal to 2 inches, was i inconsistent with seismic requirements, and no evidence could be found J ! that substantiated the adequacy of the installation for nonsafety-re h ted conduit of any size. Evidence could not be found that substantiated.the i e f. 1 i ! v*4eie ww ,-m 3 --e--.- .--em.--.y--,a-,---.m-g --,y-n--- g

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l.,~.~ " J ~ _.. _. T ~~ ~ ~ ~ '... I. 3 failurd would not adversely affect the function of safety-related components or.cause injury to plant personnel. The safety significance of the loss or uncertainty about the operability of these systems is that the lack of analysis makes the quality of the supports indeteminent and consequently their behavior during a seismic event could not be precicted. The TRT concludes that the conformance of the seismic support system installations with Regulatory Guide 1.29 had not been demonstrated. Accordingly, by letter dated September 18, 1984, i ,the staff requested additional information from TUEC. t In response to the NRC letter of September 18,1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on October 19 and123, 1984, to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific coments. These problem areas identify a potential generic implication to all seismic Category I areas of the plant. It is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time, due to the uncertainty of operability of the systems needed for this activity. 3. Electrical Equipment Separation Deficiencies } l, The TRT review concerned with the separation criteria between separate cables, trays and conduits in the control room and cable spreading room; and the compatibility of the electrical erection specifications with regulatory requirements. After reviewing documentatic' and inspecting random' samples of separation between safety-related cables, trays and conduits and between them and nonsafety-related cables, trays and conduits, the TRT found: (1) numerous cases of safety-related cables within flexible conduits inside main control room panels, which did not meet minimum separation .. requirements; (2) several cases of separate safety /nonsafety cables and separate safety cables within flexible conduits, inside main control room panels, which did not meet minimum separation requirements; and (3) existing TUEC's analysis substantiating the adequacy of the criteria for separation between rigid conduits and open/ ladder cable trays had not been reviewed by the NRC staff. Accordingly, by letter dated September 18,1944, the staff requested additional information from TUEC. In res nse to the NRC letter of September 18, 1984, the applicant has' f. developed a program to resolve the NRC staff concerns which the staff is I currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984 to discuss the staff's coments on the 1 applicant's proposed program plan to resolve this issue, and is carrently preparing a letter to TUEC documenting these specific comments. i .I ._ [ E+=... = .- I

f_ f - -5 The safety significance of the loss or uncertainty about the operability of these systems is the apparent lack of separation that could result in 'i the loss of redundancy when the installation is challenged by design basis i events. This could possibly cause loss of capability to achieve safe shutdown depending on the circumstances surrounding the event and the circuits involved. These problem areas have potential generic implications in all safety-related control panels and cabinets. It is inappropriate to consider . fuel load and the precritical testing requested by the applicant at this time, due to the uncertainty of operability of the systems needed for this activity. 4. Electrical Cable Temination Deficiencies-l i l The TRT inspected random samples of safety-related terminations, butt splices inside panels, and vendor-installed terminal lugs in ITE Grinnel switchgear and motor control centers, and reviewed documentation relative 1 to the installations. The TRT found: (1) lack of awareness of QC electrical inspectors to 4 acknowled e requirements for nuclear heat-shrinkable cable insulation sleeves; 2) selected inspection re rts did not indicate the required witnessing of splice installation; 3) absence of splice qualification requirementsinprocedures;and(4)selectedcabletermination installations were in disagreement with as-built drawings. Accordingly, I by letter dated September 18, 1984, the staff requested additional [ information from TUEC. In response to the NRC letter of September 18,19P4, the applicant developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The. staff met with TUEC in public meetings on October 19 and 23, 1984 to discuss the staff's casuents on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these spec,1fic connents. The implied safety significance of the loss or uncertainty about the ...opergbility of these systems is that the lack of witnessing of the installation, disagreement of the installation with as-built drawings, or improperly dispositioned NCRs, could place the quality of installation in question. Furthermore, the absence of qualification requirements, or provisions to demonstrate operability cast doubt on the adequacy of the butt splice installation. I r ~. These blem areas have potential generic implications to all safety-relat panels, switchgear cabi~ nets, motor control centers, and [ temin ion cabinets. It is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time, due to the j uncertainty of operability of the systems needed for this activity., j { 4 I -.-v.= = = _ -

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l-

A11ega' ions and Technical Issues Still Under Evaluation By The TRT In The t

Test Program Area Affecting Systems That May Be Needed For Fuel Load and The i i Precritical Testing Requested By The Applicant The TRT review of completed Hot Functional Test data packages which had e been reviewed and approved by the Joint Test Group (JTG), revealed that TUEC had not met the objectives of three of the 17 test data packages i reviewed. Accordingly, TUEC was instructed, by letter dated September 1 18, 1984, to review all complete preoperational test data packages to I ensure there are no other instances where test objectives were not me,t, j 'or prerequisite conditions not satisified. In response to the NRC letter of September 18, 1984, the applicant has i i developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on' October 19 and 23,1984 to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific connents. Since a thorough assessment of this issue has not been completed as yet, it is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time. In addition, the TRT is currently investigating the board's concerns about startup quality assurance (Board Memorandum dated October 1,1984) and is scheduled to respond in late November. I l Allegations and Technical Issues Still Under Evaluation By the TRT In the f-Quality Assurance / Quality Control (QA/QC) Area Affecting Systems That May Be Needed For Fuel Load and The Precritical Testing Requested By The Applicant The TRT evaluation of allegations and issues in the QA/QC area is still in progress. The staff is planning to have a public meeting with the applicant to identify requests for additional information in the QA/QC l l area in late November. The TRT review of the following allegations and l issues would require action by the applicant before proceeding with the ,,, fuel,, load licensing process. (. 1.- Management Connitment to QA/QC (' The TRT is evaluating alleged management directives to not report problems, intimidation of inspectors, and unqualified QA/QC supervisory persontpel. Idhfie no specific technical issue was identified from the indivi ual allegations, a collective concern from these allegations was ~. identi ied relative to QC inspector training and qualification, and the applic t's commitment to an effective QA program. a 2. Parts Interchanged In Diaphram Valves The TRT is evaluating an allegation that numerous diaphram valves were j disassembled and subsequently reassembled interchanging.certain parts. l I g, .,. 7 . ;.y _..

7-3. A -Built Verification The TRT is evaluating the results of an as-built verification effort conducted as an input into the total QA/QC assessment in that it is used to measure the effectiveness of the applicant's QA/QC program for work performed prior to the TRT's review. The TRT perfomed inspections on completed hardware using the final as-built drawings of the hardware. Open Items In The Region IV Walkdown Inspections Affecting Systems That l May Be Needed For Fuel Load and the Precritical Testing Requested By The Applicant The staff has completed inspection of the Caole Spread Room, Fuel Building, Containment Building, and Safeguards and Auxiliary Buildings. The staff concludes that inspection of the Cable Spread Room and Fuel Building did not reveal matters that would affect system operability for i the systems and components required for fuel load and.the precritical testing requested by the applicant. As part of the inspection of the Containment Building, the staff ident:fied a violation related to the as Built Design Documentation Program that may affect system operability for the systems and components required for fuel load and the precritical testing requested by the applicant. A review of the licensee's program for verification and control of design i documents was conducted. Specific drawings and diagrams were selected by the manager, nuclear operation and TUGC0 Nuclear Engineering for updating prior.to fuel loading. The inspection was conducted to determine (1) adequacy of procedures governing the generation and completion of as-built design documents (drawings and specifications) and (2) the schedule for completion of the as-built drawing documentation. The inspection of document control resulted in findings that the actual status of certain design drawings could not be detennined and that some design drawings available for use by the control room were out of date. i These findings were cited as a violation of Criterion V to Appendix B of 10.CFR Part 50. Th' staff concludes that while the Unit I containment building inspection e did not identify violations which specifically indicate progrannatic weaknesses in the applicant's program relative to the operability of systems necessary for fuel loading and precritical testing, a violation .conce ing ttie as-Built Design Documentation Program was identified for r-which e NRC staff position is indeteminate until the applicant's .to the violation is evaluated. i-respo Finally, the results of room inspection of the Safeguards and Auxiliary -j Building are still under evaluation. Consequently, the NRC staff "l-1 3 - - - mn... ~m m - - e-sr w--* = - - - r e

.. ii j. I .l-i 8-position is indeteminate until the inspection report is issued and the applicant's response is evaluated. I .i t I l t h O m es e ee O w a ~ F. ] t I e I t t. ... essa - e,-. .~..u.._...,._.n;._.

v 1 f. g(p' nc%'o , UNITED STATES [g i e 5 g% e,"]j ;,E NUCLEAR REGULATORY COMMISSION l 2 n WASHINGTON, D. C. 20655 i N.+..../. ] .JAh 2 415ES \\

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Docket'Nos: 50-445, 50-446 l Texas Utilities Electric Company ATTN: M.D. Spence, President TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201

Subject:

Comanche Peak Response Team Action Plan

Dear Mr. Spence:

On October 19 and 23, 1984, we met with you and members of your staff, at your request, to discuss the Program Plan and Issue-Specific Action Plans (the " Plan") submitted to the NRC on October 8, 1984. This Plan was developed in response 'to the NRC letter of September 18, 1984, requesting r.dditional information as a result of the Technical Review Team assessment of certain onsite detivities at Comanche Peak. These activities were in the electrical / instrumentation, civil / structural, and test programs areas. By letter dated November 21, 1984, the staff received Revision 1 to the Program Plan. We noted that you have incorporated into the revised Program Plan many of the general connents raised in the referenced meetings, such as, the need for obtaining an external perspective and independent assessment, identifying a basis for selection of samp1.e. sizes, identifying root causes, and consideration of all relevant informationia particular area. We L also note that you are still reconsidering the Program Plan and ere going !2 to revise the Issue-Specific Action Plans to address our comments. Since we l 1: ave not received your revised Issue-Specific Action Plans, we are providing our detailed comments in an Enclosure to this letter so that you may consider them in.your revision. 1 You will soon be receiving.the Supplemental Safety Evaluation Reports (SSERs) i in the electrical / instrumentation, civil / structural, and test programs areas. The SSERs will provide further clarification and additional actions required as part of our continuing assessments. 1 F01A-85-59 3X l ^ $9poio J l

~ e i M. D. Spence - Prior to' approval of your plan, the NRC requires you -to resol've all the matters discussed herein. As discussed at these sneetings, the.TRT will continue to assess the actions you are taking pursuant to the Plan, and revisions thereto.. As part of this assessment, I will be meeting with you j periodically to discuss the progress of the Plan.- i Sincerely. [g o an Director omanche P ak Project

Enclosure:

As stated g

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~ 4- ~ f Enclosure s COM ENTS ON COMANCH'E PEAK l ' RESPONSE TEAM ISSUE-SPECIFIC ACTION PLANS r 1 I. Electrical /Instrumentatio'n Area a.1. Heat Shrinkable Cable Insulation Sleeves 1. When clarifying the construction installation procedures to identify the conditions which require actual installa tion of nuclear heat shrinkable insulating sleeves, revision of procedure QI-QP-11.3-40 l " Post Construction Inspection of Electrical Equipment and Raceways" should be considered to assure that the inspection of nuclear heat shrinkable insulating sleeves is documented. a.2. Inspection Reports on Butt Splices -:) 1. The. action plan does not identify the record retention system used to indicate how the additional inspection reports (which Is I ! document the required butt splice witnessing) were obtained. l] !l' t 'i 2. The action plan does not state the basis for selecting the l ' l additional sample of twelve cables. i '. i, 4 l l t w--

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2.- g t 3. Phase 2 of the action plan, irrespective of findings in ,i ' Phase 1, which requires the identification of all drawings on which butt splices occur, shall be implemented. Amendment 44 of the FSAR permits only limited amounts of butt splices to be used, and the NRC I' staff accepted the practice on this basis. 4. It should be noted, Phase 2 is also accomplished as part of action plan Item I.a.3, Section 4.A (third paragraph) and Section 4.B. a.3. Butt Splice Qualification 1. Identify those cables and circuits in which butt splices exist in control panels. 2. Section 4'.A (paragraph 3) should be coordinated with action plan Item I.a.2, Phase 2 in verifying butt splices in appropriate i' panels. 3. Section 4.B should be coordinated with ac' ion plan Item I.a.2, t Phase.2 in verifying butt splices in bundles. '4. The action plan does not take into. account completed butt ll. splice installations which may not be found staggered due.to ;he e l ~

7 - _ _- _ ,}_.___-.._..._..__~.. .l__._.._. ~ f_1.... ~ la'ck of provisions and requirements in the appropriate installation f , \\ procedures. a.4. Agreement' Between Drawings and Field Teminations i. j 4 1. The action pla'n does not define what is meant by circuit reliability requi'rements used as the criteria by TUEC engineering for specific acceptance / rejection criteria. l' '4 2. The NRC staff does not agree with TUEC's position of acceptable + conditions based on operability alone. In this issue operability, as well as, conformance of hardware to the "as built" configuration drawings and documents is o'f concern. 3. Acceptable conditions, in the action plan, using cable / conductor terminations of a size larger, should be supplemented to - include the requirement for a good connection to be established.

d 4.

The action plan shall identify all the latest design documents t'o the "as built" configuration drawings, to be used in the TUEC sampling program. a.5. NCR's on Vendor Installed AMP Terminal Lugs 1 1 } _~

[.. T. - -.... 7.__ 'j-4- 1. The action plan does not require the lug manufacturer to i ij \\prov]dedocumentedanalysestosubstantiatehischangeinposition d between the'APC memo of $eptember 2,1981(60' bendacceptable)and documented telephone record of April 17,1984(90'be'hd acceptable). 2. The action plan does not require the lug manufacturer or TUEC engineers to address the sechanical strength and electrical charac-teristics of.the identified " twisted" conditions identified on the J l' NCRs. 3. Other NCR's which identify terminal lugs bent'or twisted. in iscess of 60*, which have been dispositioned as "It is our determination that these tenninals do not pose an equipment serviceability problem and may be used-as-is" should also be included in the action plan. C b.1. Flex'ible Conduit to Flexible Conduit Separation 1. The results of the analyses to be submitted to the NRC staff t in qualifying the flexible conduits as an acceptable barrier, shall k include the acceptability of redundant flexible conduit,s in cortact I' with each other. l I l $ l! l i l-, l w-r w---.--------m-- -w y e.- --ryi.w--y..n ir

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}.[ -.. ^ ~ " [ ~ ~ ~. - ~ ~ ^ ~ ~ ^ ~ ^ ^ ^ ~ ~ l -l 5- ^ 2. The analyses, as required by the IEEE Std 384-1974 (Section ' 5.6.2)/ Regulatory. Guide 1.75, Revision 2, shall be based on tests performed to determine the, flame retardant characteri.stics of the ~ wiring, wiring materials, equipment, and other mater'fals internal to the control panels.' 1 3. If the above' analyses can demonstrate the flexible conduit as an acceptable barrier, the G&H/TUEC design criteria, erection specifications, drawings, QA/QC procedures, and other related documents shall be corrected accordingly and identified in the action plan. b.2. Flexible Cofiduit to Cable Separation 1. The results of the analyses to be submitted to the NRC staff in qualifying the flexible conduit as an acceptable barrier, shall include redundant cable in contact with the flexible conduit barrier. 'i 2'. The analyses, as required by the IEEE Std 384-1974(Section 5.6.2)/ Regulatory Guide 1.75, Revision 2 shall be~ based on tests'. performed to determine the flame retardant characteristics of 'the wiring, wiring materials, equipment, and other materials internal to' the control panels. ee k " ^ ' ' w e -,.,----..-m..-e w_ 4 ,-e,.- m-, .-3--,,____. -y--

.. L : ~ ^ ~ i 3. If the above analyses can demonstrate the flexible conduit as an acceptable barrier, the G8H/TUEC desiga criteria, erection i specifications, drawings, QA/QC procedures, and other related documents shall be corrected accordingly and identiffed in the action i'

plan, i

b.4. Barrier Removal I 1. If the root cause is determined to have generic implication for the redundant field cables not meeting the six inch min; mum separation requirement, the action plan shall prescribe the additional action. d.1. QC Inspector Qualifications d.~2. Guidelines for Administration of OC Inspector Test 1. TUEC must consider the results of the overall programatic review of QC inspection qualifications when responding to items d.1 ~ and d.2. t-II. Civil / Structural Area ~ li. b. Concrete Compression Strength i i'f -_ _ __ p.. _

^ ~ 7-t 1. The action plan does not take into account the fact that more ' ' than one strength of c'oncrete may have been placed between January f 1976 and February 1977. Bo,th'4,000 psi and 2,500 psi concrete grades were used on.~the project, If both are presen 'in the' tested concrete they must Be' analyzed separately. 2. The action plan contemplates conversion of rebound numbers to compression strength by use of the calibration curve supplied by the s manufacturer. Since there is a high degree of uncertainty associated with the' application of a general calibration curve to a particular set of materials, the statistical analysis should be carried out directly using the recorded rebound numbers. 3. Paragraps 4.(5) mentions comparison testing of concrete placed outside the time frame in question.. To eliminate age effects this concrete should match the age of the concrete in question as closely as possible. Preferably concrete placed before the end of 1977

j should be used.

~ 4'. The sampling plan stipulates that 50 placements from both the concrete in question and the concrete not in question will be tested. This number is adequate, but there is no mention of the number of tests to be run on each placement. The plan should state l the number of test areas. on each placement where concrete is in question and the number of test areas on each placement where it is not. As explained in Item 5, a sufficient number of tests on each 1 [ placement where concrete is in question should be performed to 1 ) substantiate the quality of each individual placement. -~- - w w +-.. = -e..- c r.. r--

i i 5. Because the allegation being investigated is that some .j ' indi'vidual tests were falsified, the strength results.for the period in question should not be regarded as a single population. The mean values for individual placements should be c'ompared with the mean of the concrete not in question at the 5% level o'f significance. The specific criteria to be used for judging the final acceptability of the overall test results should be delineated in the plan. Also identify remedial actions which would be followed if the test results fail to pass the acceptance criteria. 6. Submit QI-QP-2.5-7, " Determination of Strength of Concrete by Use of the Concrete Test Hammer" and QI-QP-13.0-5, "Verificat.f on of: Cdncrete Test Hammer." 7. As noted in Section 5, the program for performing these tests should be submitted to the NRC for staff review and acceptance. 0 8. Paragraph 4.(7) refers to a term "significant variation." Please ~ define the term more specifically in the context of action plan ~ II.b. c. Maintenance of Air Gap Between Contrete Structures 1. Paragraph 4.(1) should indicate that QC inspections of the seismic gaps will be performed for all Category I structures. O l i

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m-. .wo - m-i e e n .,.wg_ I g. 2. Paragraph 4.(3) indicates that the original analyses were based on clear gaps, but that subsequently the design engineer evaluated l the portions of the separation ~ areas for the effectsfof the presence of rotofoam. Clarify what areas were evaluated and when these .i evaluations were performed. Submit these evaluations with the 'i overall response to this issue. 3. Paragraph 4.(3) and the Decision Criteria should also indicate ..:j that changes in seismic response (e.g., effects of loads transferred j between buildings and changes in seismic loads of structures) will be evaluated. ~ 4. Describe more fully what is meant by the statement that "QC will document the debris characteristics on a 'best-effort' basis, using conservative estimations as needed." 5. Submit the revised procedure QI-QP-11.0-3, " Concrete or Mortar 3 [ Placement Inspection." 1 ,I d. Seismic Design of Control Room Ceiling Elements .'[

1..

Provide details of the new horizontal-seismic restrain'ts ' discussed in Pa.agraph 4.(a)(1) and explairi what is going to replace' I the gypsum panels as discussed in Paragraph 4.(a)(2).

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~ ' -~ ~ .-- r_- .-. :: 2 . L.-. l - 10.- 1 l 2. Describe the seismic analyses, including the details of the ti dynamic models that will be used to evaluate the ceiling structures. ~ .] 3. It should be clearly demonstrated that the non-safety related Di . conduit support system in the control room for conduit 2 inches or less is covered by the generic analyses discussed in Paragraph 4.(b) i . of Item I.c. i f 4. The Standards / Acceptance Criteria should be more explicit as to the analysis and design criteria that will be utilized in evaluating i the ceiling. structures -(Item II.d) and the nonsafety-related. londuit(ItemI.c). ~ 5. With respect to item 4.(c), a more detailed discussion of the general approach to be used for evaluating the seismic design adequacy of other Category II structures, systems and components i elsewhere in the plant should be provided. The discussion should include the modeling methods, analysis approaches, key assumptions and basis thereof, as well as the computer codes to be utilized in L.! the evaluation. Also explain why only the architectura'l features i throughout the plant and not all,non-seismic related items will be evaluated to determine the adequacy of the Damage Study program. ~! g ? e e t

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,;;7. II - t 6' The results of the reviews described in Paragraphs d(c)(1) and 4(c)(2) to address the adequacy of the treatment of Category II and ~ non-seismic structures, sys,tems and components elsewh'ere in the plant should be aud'ited by an independent review te' m consisting of ~ a engineers not involve'd with the original evaluatfons. The details of these audits and findings should be submitted to the NRC for review. The TRT may then conduct an independent audit to confirm these findings. Ilf. Test Programs Area ~ a.1-Hot Functional Testing (HFT) Data Packages 1. The background section states that the technical review team (TRT) performed its review of the hot functional test data packages to ascertain the acceptability of the test results. This is not true. The TRT did not validate any test data; the team only s reviewed the test procedures .d resultant data to determine conformance with the CPSES FSAR, Chapter 14 commitments and NRC Regulatory Guide (RG) 1.68 " Initial Test Programs for Water-Cooled ~ Nuclear Power Plants." Validation of test results'is being perfomed, on a sampling basis, by NRC Region IV. The revision to the action plan should clarify the scope of the TRT review. f e I s. e l m -a me-

_f ^- ^^ ^ ^ ~ ^ -[,_ ~ ^ ~ - 2. Regulatory Position 3, Section C of-RG 1.68 states that, to the s extent practical, the plant conditions during the (preoperational) d_ tests should simulate the actual operating and emergency conditions ~ to'wh'i'ch'the structure, system, or component may be subjected. It also states that, to the extent practical, the' duration of the tests should be sufficient to permit equipment to reach its normal equili-brium conditions (e.g., temperatures and pressures), and thus decrease the probability of failures, including "run-in" type failures, from occurring during plant operation. Explain the rationale for not meeting this regulatory position in the cases of ICP-PT-02-12, " Bus Voltage and Load Survey," 1CP-PT-34-05, " Steam Generator Narrow Range Level Verification," and ICP-PT-55-05, " Pressurizer Level COTitrol." 3. The action specified by NRC in our letter dated September 18,1984, is that all preoperational test packages should be reviewed to determine if there are other instances where test objectives were not met. (The TRT intended that the TUEC pay particular attention to RG l.68, Regul,atory Position 3 during this review.) TUEC's action plan (4'.A.5.) states that the seven HFTs not included in the TRT ~ ,I review will be reviewed for compliance with test objectives. Th'e ,i next action (4.A.6) implies that only if an unspecified number of il test objectives are identified as not having been satisfied during that review would a statistical sampling in accordance.with l MIL-STD-105, Table X-G-2 be conducted for the other 136 preoperational c; tests. This is not acceptable to the NRC. The seven HFTs shall be added to the 136 re,stning preoperational tests and a statistical - ~

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l1

7_.._ ..1. m.,- Z ~ 'i- ~ ' ~ ~ ~ ~ ~ ~ ~ f j 13 - i sample done on that total. Also, TUEC shall provide the basis for \\ \\ the statistical sample selected. In addition, RG 1.68 should be l reviewed by the. group who will conduct the review of,lthe preoperational tesOpackages to ensure that each meiEb'er understands the concept which it ' advocates..TUEC shall provide the rationale ' ~ for selection of the review group members. a.3 Technical Specification for Deferred Tests 1. Since it 'is no longer intended to defer certain preoperational tests ,J until after fuel loading and since a special test except' ion will be sought by TUEC from the NRC for snubber operability for testing after fuel load, the original issue as identified by TRT is no ~ longer of concern. Revise the action plan to reflect this change. 4 a.4 Traceability of Test Equipment 1. The background section attributes the lack of traceability between the calibration of temperature measuring instruments and the monitored l} locations to personnel error. The TRT believes that the error was caused when the thermal expansion test procedure was revised to r' move the instrument number from the data sheet. Startup e Adminis'trative Procedure (SAP)-7 recognizes that traceability is fi rcquired and provides optional methods to ensure this traceability. ll However, when the thermal expansion test procedure was revised, an [ 1. ?. 1 l e-c -+,, - - -, y- ,y -i-y., y p_,..mg %y w w w.,..___m--m-

. _ _. ~ L~ .. ] ,, }; -.... 7. ~ - 14.-- ~ option was chosen which would not en'sure the required traceability. } \\ Therefore, the TRT questions whether the person who revised the I. procedure and those who. approved the revision adequately understood the need for traceability. The TUEC Action Plan shou'ld address this i

question, In addition, the action plan should include a commitment

~ to review Unit 2 preoperational test procedures and Unit 1 and 2 initial start-up and plant operating procedures to ensure that similar errors do not exist and will not recur. .j ~ b. Conduct of Containment Integrated Leak Rate Testing (CILRT) 1. This is another example of where a preoperational test was conducted with the system in a configt 'ation wtiich did not simulate the actual ~ plant operating and emergency conditions to the extent practical, as required by RG 1.68. Regulatory Position 3. Con' sider the CILRT in t'he response to the coment III.a.1(2), i 'I 2. The ' background section states that due to an oversight, the CPSES FSAR ~ was not amended to reflect deviations from 10 CFR 50, Appendix J and I t ANSI N 45.4-1972 during the conduct of the' containment integrated leak rate test, ICP-PT-75-02. The action plan should be revised to l explain how this oversight occurred and what the potential is for i other similar oversights resulting in the FSAR' not being amended when deviations occurred. Also, address the TUEC procedure for l* ~ jj i. \\ k ,w-w

s. ~ l 15 - i ~ documenting and processing deviations from FSAR.comitments to ,l ensure that they are included in future amendments to the document. ~ c. Prequisite Testing 1. While not specifically addressed by the TRT in its description of this issue, TUEC should be aware that other completed Prerequisite Test Instructions were found, i.e., other than XCP-EE-1 and XCP-EE-14', 'where craft personnel had' signed for verification of prerequisites in li6u of System Test Engineers. Other prerequisite tests were not addressed by TUEC in response to this issue. The Action Plan should address all Prerequisite Test Instructions and .. include an assessment of th'e impact of,any improper verification on - subsequent testing. d. Preoperational Testing g 1. At the' October 19, 1984 NRC meeting TUEC stated that the records retrieval system at CPSES is complex. Since the background section i, for this item states that a large number of design' documents are p. utilized by start-up TUEC shall reassess the adequacy of t'he Iction j I-Plan for this item and document that reassessment in'the revised Action Plan. O. O 4 l s

g.7 _ ~. Af#dM

  • hf h*fT NRC TRT - COMANCHE PEAK. UNITS 1 AND 2

(; ELEL,1NICAL AND IN5INUMENTATION FINDINGS b.. Electrical Cable Terminations Lack of awareness of QC electrical inspectors to indicate in the inspection reports when the installation of the " nuclear heat-shrinkage pable insulation sleeves" was required to be witnessed. Selected inspection reports did not indicate that the required witnessing of splice installation was done. Absence of splice qualification requirements and provisions in the installation procedures to verify operability of those circuits for which splices were being used. Selected cable temination installations were in disagreement with i drawings. l Nonconfomance reports concerning vendor-installed terminal lugs in SE motor control centers had been improperly closed. A c 1... < U FC A-85-59 ~ }- g i 0- n l V-^ -9, -,,w-- .+yg-r--+-4.w-,ym&wy---,-.__-,-+--.74.-.yw--,w g -, ,.e- - - wm-.. -,efw.w_e-,,,yy---. e+-----%.-- ---w

.::- 3..., a:__ -.__._ n - .t s i 'p [ 1 4RC TRT-CONANCHE PEAK, UNITS I AND 2 9 ELECTRICAL AND INSTRUMENTATIOTFT11DTRGs Electrical Equipment Separation 4 - Several cases of separate safety and nonsafety-related cables and flexible conduits inside control r6cm panels did not meet minimum separationrequiremenis. No evidence was found that justified the lack of separation. Existing TUEC's analysis substantiating the adequacy of the criteria for separation between conduits and cable trays had not been reviewed by the NRC staff. l Two minor violations of the separation inside panels concerning a 1 barrier hund removed and redundant field wiring not meeting mini-num separation. l l 9

==--.-.~,.-o s ---w+e-

~ h. t,, ',, ~ ~ ~~ . ~.:. ; - s k-r NRC TRT-COMANCHE PEAK, UNITS 1 AND 2 ELEGIMICAL AND IN5TRUMENTATION FINDINGS Control Room Ceiling Fixture Supports The support installation in the control room for the nonsafety-related conduit was inconsistent with seismic requirements and Arnnseu for the suspended drywall ceiling and lighting supports 4 o t satisfy seismic requirements but no analysis could be found that v et - substantiated the adequacy of 1nstallation. 4 The support installation in other seismic Category I areas besides the control room for nonsafety-related conduit less than or equal to two inches in diameter was inconsistent with seismic requirements. No evidence could be found that substantiated the adequacy of the installation l. l l l l' f i. ' _i ~

7

4. -..._

F i l t i r- .J i i .r j. t NRC TRT COMANCHE PEA.K, UNITS 1 AND 2 ELECTRICAL AND INSTRUMENTATION FINDINGS ( Electrical QC Inspector Training /Oualifications The lack of supportive documentation of qualification in the training and certification files. The lack of guidelines and procedural requirements for the testing program. t The lack hf, documentation for assuring tha't the requirements for QC electrical inspector re.ctification were'being met. .I .F 4 e t e I

,,, g__.._.

?. MM ' j ~ '$ ~ l. Document Name: TELECOPY COMANCHE PEAK Q[ N-f f -] ' i~ Requestor's.ID: SIICSB01 ~ Author's Name:- 14 J. Calvo cj c's; Document Comments: TELECOPY TO BE TELECOPIED TO COMANCHE PEAK l 1 5 v ~ i j F0lA-85-59 o i ~ 3/ 3g

..7...__. I a il:. NRC TRT - COMANCHE PEAK, UNITS 1 AND 2 => ELELIMICAL AND INSTRUMENTATION (E&I) INPUT TO OPEN ISSUES LETTER .] a i 1. Electrical Cable Terminations The Technical Review Team (TRT) inspected random samples of safety-related terminations, butt splices inside panels, and vendor-installed terminal lugs in General Electric (GE) motor control centers, and re- . J. viewed documentation relative to the installations. The following items were found: Lack cf awareness of f'uality controlf (QC) electrical inspectors q l to acknowledge in the inspection reports when the installation of the " nuclear heat-shrinkable cable insulation sleeves" was required to be witnessed. gj'electedinspectionreportsdidnotindicatethattherequired 4 witnessing of splice installation was done. Absence of splice [ qualification requirements and provisions in the installation procedures to verify operability of those circuits for which splices were being used. i Selected cable termination installations were in disagreement with drawings. a a k ...~s.

^~ 1.11..._. t.. j .3- ~'. qj: Nonconformance reports (NCRs) concerning vendor-installed ters-1 4 inal lugs in GE motor control centers ha y been improperly i Closed. ~ The implied safety significance is that the lack of witnessing of the installation, disagreement of the installation with as-built drawings, or improperly dispositioned NCRs could place the quality of installation in question. Furthemore, the absence of qualifi-cation requirements, or provisions to demonstrate operability cast doubt in the adequacy of the butt splice installation. The TRT con-cludes that the various cable temination installt.tions examined 4 meet established requirements except for those items identified in, the actions below. The Texas Utility Electric Company (TUEC) shall propose a program that assures that all the following actions are accomplished.in both units of Comanche Peak Steam Electric Station t (CPSES) prior to fuel load of each unit: .s 't 'i (

4 1

.)

i;

'i- .1 ~

3-Reevaluate and redisposition all NCRs related to vendor-installed e .:i ~ terminal lugs in GE motor control centers. Develop adequate installation / inspection procedures to assure the 3-! operability of those circuits containing butt splices, that the wiring splicing materials are qualified for the service conditions. andthatsplicesarenotlocatedadpenttoeachother. .+ Reinspect all safety-related and associated terminations in the 9'

  • control room panels and inthe termination cabinets in the cable

'2 4 spreading room to verify that they are in accordance with drawings. ( i-Should the results of this reinspection reveal an unacceptable 1 of nonconformance to drawings, the scope of this reinspection } d effort shall be expanded to include all safety-related and associate terminations at CPSESAits4-and-2.- i', ' Physically identify all butt splices in panels; clarify procedural requirements with respect to the areas in which n(uclear heat-shrinkable sleeves are required on splices; assure that such .{ sleeves are installed where required;. assure that the QC inspections requiring witnessing for splices have been performed and properly 'i. ?!.. documented; and verify that all butt splices are properly identified on the appropriate drawings i, '9ths.r ram -, j

j i

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.]. .g, Electrical Equipment Separation The TRT review concerned with the separation criteria between separ-ate cables, trays and conduits in the control room and cable spread-ing room; and the compatibility of the electrical erection specifica-tions with regulatory requirements. After reviewing documentation and inspecting random samples of separation between safety-related cables, trays and conduits and between them and nonsafety-related l' cables, trays and conduits, the TRT found the following items: n ~ r-. w.- r. ;,,m t co f rv;* sst o. e r) e Cs = No C-J ' t M

  • r

Several cases,of sepa,rafe safety and nonsafety-related cables e w. n ',.:, te: - ~ < *. . ;e .r: and flexible conduits inside control room panels did not meet minimum separation requirements (Table 1 identifies these cases). No evidence was found that justified the lack of separation. Existing TUEC's analysis substantiating the adequacy of the cri-d. teria for separation between conduits and cable trays haue not 4 een reviewed by the NRC staff. Two minor violations of the separation criteria inside panels 2 CP1-EC-PRCB-09 and CP1-EC-PRCP-03 concerning a barrier found removed and redundant field wiring not meeting minimum separa-tion. The devices involved with the barrier were (FI-2456A, k .4 ? t m--~~ e s

  • ~.

e-e. aae s.s av.. ~. y.* .g eq. ye- --A--m. p-.weq y-e wy e-yme. >w w -gy-we-p-+w.--- -ewd, m

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~ {. - .i.l ~ PI-2453A, PI-2475A and IT-2450, associated with Train A; and FI-2457A, PI-2454A, PI-2476A and IT-2451, associated with .o ~ TrainB). The field wiring was associated with devices (HS-5423)(TrainB)andHS-5574fnonsafety-related). i i The safety significance of these. findings'is the apparent lack of separation, that could result in the loss of redundancy when the in-stallation is challenged by design basis events. This could possibly cause loss of capability to mitigate the consequences of accidents are to achieve safe shutdown depending on the circumstances surrounding i the event. The TRT concludes that the installations examined meet established separation requirements except for those items identi-fied in the actions below. The TUEC shall propose a program that assures.that all the following actions are accomplished,in both units of CPSES prior to fuel load of each unit: A l I; 1 8 enumem em.a. A. -g, - *- e e a es,.egeee.-~ = +. -

' ~ ~ - ~ ) i.i -

  • Reinspect all panels at CPSES, Units 1 and 2, in addition to those in the main control that contain redundant safety-related p-conduits, or safety and nonsafety-related conduits and either correct i

i. each violation of the separation criteria, or demonstrate by the ) &3 analysis the acceptability af the conduit ad a barrier for each case Nre the minimum separation is not met.

  • Reinspect all panels at CPSES.-Units-1-snd-2; in addition to these 8

~g. in the main control room and either correct each violation of the I separation' criteria concerning separate cables and flexible conduits, or demonstrate by analysis the adequacy of the flexible conduit as a

s barrier.
  • Submit the analysis that substantiates the acceptability of the criteria stated in the electrical erection specifications governing the separation between independent conduits and cable tres.

, Correct two minor violations of the. separation criteria inside A., o panelsCPI-EC-P'CB-09) CPI-EC-PRCP-03concerningabarrier R 'i found remo.yed and redundant field wiring not meeting minimum separation. l- ,k i t e ~^ ~ 3 f a ~ =--etaa - ~** - ---+-*a-*~~

e 1 ' f ij ..) Table 1 a Cases of Safety or Nossafety-Related Cablee In Contact With Other,$ataty-Related Conduits in Control Boom Fanels 1. Control Panel CP1-EC-PRCB-02 Containment Spray System Cable No. Train Related Instrument

  • f EG139373 3 (green)

Undetermined E0139010 A (orange) Undetermined a 1 2. Control Panel CP1-EC-PRCB-07 Reactor Control Cable No. Train Related Instrument EG139383 B (green) Reactor manual trip switch 30139311 A (orange) Undeteruined 30139310 A,(orange) Undetermined EG139348 3 (green) Undetezzined' 3. Control Panel CP1-EC-PRCP-06 Chemical & Yolume Control System Cable No. Train Related Instrument [' EG139335 3 (green) LCV-112C' 1 } B0139301 A (orange) Undetermined __30139305 A (orange) - - __-LCV-1123 -1 EK139605 Nonsafety CSALB-LAB _.. -(in bundle) 7 I e w-x _ r. ._..-._,_,r._ ..~. ...m...

....i..;.. _ d-_, u,v. . ;,, a.,_. - --r t..,b. - ~ v_ - i. -g .i i 4. Control Panel CF1-EC-FRCB-09 Auxiliary Feedvater Control System ?. Cable No. Train . Related Instrument [ 30139753 A (orange) FK-2453A l E0139754 A (orange) FK-2453B EG139756 9p'(green) FK-2454A EG139288 3 (green) FK-24543 EG145780 3 (green) FK-2454A i } EG1'45781 '. t. 3 (green) Ff-2460A A0138622 A (orange Assoc.) BS-2452a/B EK139647 Nonsafety BS-2383 5. Control Panel CF1-EC-PRC5-08 Feedvater Control Cable No. Train Related Instrument EG140309 3 (green) FK-2324 EG139757 3 (green) FK-2328 NK13957 Monsafsty BS-211A l l 4 t a I i I i i 1 1 m i .. - - -,. -, -. -.. - -.,, ~.. -,. - _.,,,,.w.-.,--- _,,----,.n.

~ ~ ~;. ........___._.......;uc - ;_ u r - i-L 9-l C, Control Room Ceiling Fixture Supports l The TR,T inspected the installation and reviewed the documentation 'i i concertjing the field run conduit, drywall and lighting located above the suspended ceiling in the main control room. The TRT also i examined'nonsafety-related conduits in selected seismic Category I areas of the plant. The following concerns were identified:

.. m'-

.I~ c. . { o e, r The support installation in the control room for the nonsafety-q related conduit was inconsistent with seismic requirements and for the suspended drywall ceiling and lighting supports appeared to satisfy seismic requirements but no analysis could be found that substantiated the adequacy of the installation. The support installation in other seismic Category I areas besides the control room for nonsafety-related conduits less than or equal to two inches in diameter was inconsistent with seismic require-ments and no evidence could be found that substantiated the ade-quacy of the installation. S ecc a. O ' 1 }i ' ' 9 i 7v ci Cn 1,C g..,

  • (Wt '3.Kl)

'L. E' n w (l ra 3-( ~ % n!'- 7.- f t .. a q.,-. :.. t / 6 L' e o ' b cwch es , s e.- i r. e 3 The safety significance of these findings is that the lack of analy-i i sis makes the quality of the supports indetennined and consequently f their behavior during a seismic event could not be predicted. The l TRT concludes that the conformance of the seis:'iic support system f e bm o f l' '-m h ' ' ' I k U\\-t * & ':, c /: 1. oa c c,.,e 4, A L

f. '

,l l.e,a. 7 y I e

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C... ~ ^.~ ...-..:..a..z:.- u==; ..:;.. = -.:_. g, r i.- 1 _a, iftsta11ations with Regulatory Guide 1.29 had not been demonstrated. The TUEC shall propose a program that assures that all the following (; I actions.'.are accomplished *,ierboth inits of-CPSES-#or to fu~el load of sach' unit: s i Substantiate (1) the adequacy of the overall seismic support system installation for all the items located above;the ceiling i.n the main i. r)

c.,,

, iv r v c c. 3 .t control room,,and (2) the adequacy of the seismic support system in-sta11ation for nonsafety-related conduit in other seismic Category I areas of the plant besides the control room, A-f ' - n i

  1. 1.'

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ooo os, D / r*;:= t.* r:et (*. s e. ,e . e., '. / Electrical OC Inspector Trainino/ Qualifications /., /.* / The TRT examined QC electrical inspector training and certification, files, and requirements for testing program, on-the-job training F //". ' I' and recertification program. The TRT also conducted interviews f., ), /, , j with QA/QC personnel. The following concerns were identified: The lack of supportive documentation of qualification in the 1 [ j training and certification files as required by procedures and regulatory requirements. Specifically, it was found: 9 f' W f fc '13--t j= A/ f - (? C sr n A -st 'l l%

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One case of no documentation of a high school diploma i

1 or General Equivalent Dip! ma. \\; t l

One case of no documentation to waive the remaining two 1

? months of the required one year experience.

One., case where a QC technician had not passed the required color vision examination administered by a professional eye specialist. A makeup test using colored pencils was administered by a QC supervisor, was passed, and then a waiver was given.
Two cases where the experience requirements to become level 1 technician were only met marginally,

.i 3

One case of no documentation in the training and certification files substantiating that the person met the experience require-ments.

~ The lack of guidelines and procedural requirements for the test-ing program. Specifically, it was found that: 4 t 4 i

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==. :. .:_: r 7 ~ 3_33_;; 3-1 o.. ..i _; -1. i j

No time limit or additional training requirements existed i

between a failed test and retest. .c j. P

No controls existed to assure that the same test would not be given if the taker previously failed it.

No c,onsistency existed in test scoring.

No guidelines or procedures were available to control the dis-qualification of questions from the test.
No program was available for establishing new tests (except when procedureschanged). The same tests had been utilized for the 1ast two years.

The lack of documentation for assuring that the requirements for QC electrical inspector recertification were being met. I ,j / The implied safety significance is that the lack of training or quali- - f, [ fication of QC electrical inspectors could result in inadequate inspections of safety-related components. The TRT concludes that there is evidence to indicate that the QC electrical inspector quali-fication program lacks programmatic controls which may be indicative i ] L\\ j r l t-

...........-.._-.........a....-- l }., 3 13 - } 4 )! .that the required level of qualification was not obtained for some electrical QC inspectors. Since the naining -and certification pro- ~ I gram 1's.the same for all disciplines (except ASME),hhe-TRIT on-clades-that the deficiencies identified with the electrical QC in-i ^ t spections have generic implications to other construction disciplines. The implications of these findings will be further assessed as part of the overall progrannatic review of QC inspector training and quali-fication and the results of this review will be reported under the QA/QC category on " Training and Qualification." In order to resolve this issue, the TUEC shall propose a program that assures that all the following actions;are accomplished:in both units of CPSES prior to fuel load of each unit: o Develop a testing program for QC electrical inspectors which opt-inizes administrative guidelines, procedural requirements and test flexibility to assure that suitable proficiency is achieved and j maintained. ~ t o Review all the QC electrical inspector training, qualification, a certification and recertification files against the project re-t .; j ^ 1 i ~ quirements and provide the infomation in such a fem that each i i 4 I f i ~ ~ '~----- --ai-wwy- - - _- go g,wy 7r y p. ymm ypy,-wy.-- www -,w- ,-e _e,.,, e-- ,s-

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requirement is clearly shown to have been met by each inspector. If an inspector is found to not meet the training, qualification certification, or recertification requirements, TUEC shall then t review the records to detemine the inspections made by the un-qualified individuals and provide a statement on the impact of the deficiencies noted on the safety of the project. J i, '3 These actions should be coordinated as appropriate with other actions on the safae subject that will be addressed under the QA/QC category on " Training and Qualification." t t .s a e 1 4 I I l l \\ e ee 6m = -. +.. --...,-

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POTENTIAL OPEN ISSUES ( CATEGORY NO. 1 - ELECTRICAL CABLE TERMINATIONS j I t l . ISSUE FINDINGS LOCATION REFERENCE DOCLMENTATION NOTES 1 Tcminal Lugs No reference to or Safeguards Bldg i 1 NCR's E-84-01066 evidence of an Elevation 852, thru engineering evaluation Room 103, Panel E-84-01076 required by vendor. CPI-EPSWEA-02, i No mechanical strength Cubicles 1 thru 10 or electrical characteristics addressec on twisted lugs. ' Butt Splices Lack of awareness for bx Room 135, IR's ET-1-0005393 Cables are located nuclear heat shrinkable Elevation 83J. thru inside control, cable insulation sleeves Cable No. AG-009300 ET-1-005396 annunciator, relay, in high radiation areas AG-106080 ET-1-0006776 and termination EG-016462 ET-1-0014790 cabinets. EG-ll8347A E0-009307 A0-104313 EG-130471 Ccble Teminations Not in agreemer.t Panel Cable with drawing CPI-ECPRCB-14 E0-139880 CPI-ECPRTC-16 EO-110040 cpl-ECPRTC-16 E0-Il8262 CPI-ECPRTC-27 EG-10aSo a CPX-ECPRCV-01 EG-G21956 l-CPI-ECPRCB-02* hK139853

  • n afety 1

1 j POTENTIAL DPEN ISSUES l CATEGORY NO. 3 - ELECTRICAL EqulPNENT SEPARATION i i-I55UE5 & FINDInto LOCATIW1 nuin j Violations of cable separation Main Control Room Panels: conccrning separate safety-CPI-EC-PRC8-02 Containment Spray System No analysis related cables within 'ficxible conduits. - CPI-EC-PRC8-07. Reactor Control to demonstrate cpl-EC-PRG-06. Chemical Volume is control conduit as CPI-EC-PRCB-09. Aux.F.W. Control an acceptable i CPI-EC-PRCB-08. F.W. Control barrier. J Violations of cable separation MCt Panel cable No. 7 rain Related !concerning separate safety CPI-EC-4CB-E EG-139373 8 Lorn Instrument !and non safety-related cables EO-139010 A (org i and separate safety cables . CPI-EC-PRC8-07 EG-139383 8 grn React. Manual Trip No analysis (org within flexible conduits. E0139311 Switch to demonstrate A8 I( CPI-EC-PRG-06 EG139335 grn LCV-112C conduit as an E0139301 A[ora acceptable CPI-EC-PRCB-09 E0139753 AI,org) FK-24534 barrier. E0139754 A(org) FK-24538 EG139756 8I,grn) FK-2454A 8 ((grn) EG139288 8 grn FK-24548 cpl-EC-PRC8-08 EG140309 ) FK-2324 Violations of redundant Main Control Room Panels: safety-related field MCR Panel Instrument Train Instrument Train uiring not separated CPI-EC-PRCB-09 FI-2456A A FI-2457A B by either six inch minimum PI-2453A A PI-2454A B distance or an acceptable PI-2475 A PI-2476A 8 barrier..- IT-2450 A IT-2451 8 CPI-EC-PRC8-03 HS-5423 B HS-5574 C l

h. 9 = O c$ --f# b ,V %) I b a p d i ef 2 -Aa ~ t ~ r e y g*$. j ^ ~ i* s ,.e / %;, - m - J 1 ,J W i .c g e O h t i .y e c) Af. j ig7 y I_. T 'j + P d _A.- ^ y P f H I ~2 > 0 e0, 1 .) V 4 =c ? tb' d N T '3 G $ ;i ] dV 4 3 2 n t a a $ L"! ]

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. ~.. POTENTIAL OPEN ISSUES CATEGORY NO. 4 - ELECTRICAL CONDUll SUPPORTS \\ jISSUEANDFINDINGS LOCATION l NOTES j i j h Elev. Equip. Area l Analysis to substantiate Aux. ,131'-6" Boric Acid Tant i . Art:as other than the main control i the adequacy of the Aux. 842" Reactor Coolant i scismic support system & Blowdown Filter room ' installations for non safety-Aux. 873'-6" Mechanical Equip Rs. related conduit (less than or 886'-6" tiechanical Equip Rm. i equal to two inches in diameter) in other plant 4 scismic Category I areas. 9 f l, f i 9 l t

" 7- -, p.. fue rg/cn//wrArowewmr/od - ftrcreim a c 7xtercrox rrodwcl&wir. l'

l... ! C M rdoMY #p,6 j

Occ w ruy6e rive-Dowma arma i a i. se rs 1 l i One case of no documentation of a high school diploma q .l or General Equivalent Diploma. t. g. P One case of no documentation to waive the remaining two l men'ths of the required one year experience. s i One, case where a QC technician had not passed the req color vision examination shinistered by a professional A makeup test using colored pencils was eye specialist. administered by a QC supervisor, was passed, and then a ~ waiver was given. Two cases where the experience requirements to become leve technician were only met marginally. One case of no documentation in the training and certificatio files substantiating that the person met the experience requ l ments. ~ .I 1 1 i i

n_ --- - - - - - ~ - - - - -- - - - - - = - - - - - -- r_. Y* fifCTR/ritt /.7WJ'7;euswfyrM7 sos / ? ^2srrw.y us.4 rirermesL ee zu.s:ere. u mai-/Aunnr.

w.....

/dck s.r>~ d urce t tus.c Aub Pito cerD userte s e e asisrarmor:vr.f r Frps is-Z 7/NC PWe>GR N 1 1j

llo time limit or additional training requirements existed between a failed test and retest.

j p. D.

110 controls existed to assure that the same test would not be ti given if the taker previously failed it.
11o consistaticy existed in test scoring.

llo guidelines or procedures were available to control the dis-qualification of questions from the test. 11o program was available for establishing new tests (except when procedureschanged). The same tests had been utilized for the last two years. O a i t i i f i 4 6 1 l $ I I 1

p2 _.._..._;m._._...._:.__m..___.- ...____.___._.l..... tw $ k ,k. _ k i $ h) 1 i ( t e j% k ef a-f A&f, -t -i - g l7. cl A-d i a .y ps, s

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SUMMARY

OF EVALUATIONS [ 3.1 Electrical and Instrumentation (E&I) Group Sumary 4 3.1.1 Overall Assessment and Conclusions Most of the concerns and allegations in the E&I area were raised by the elec-trical QC inspectors and were found to be very general, reflecting a lack of understanding of the significance of the issues raised. This was clearly indi-cated in several of the concerns and allegations which were addressing problems j associated with nonsafety-related equipment. Further contact with the indivi-duals raising the concerns did not provide the required specificity to focus on i- ; the concerns. The general nature of the concerns and lack of understanding of the significance of the issues may be an indication of lack of proper training in electrical QC inspection even though some of QC inspectors had experience on a this type of work from other nuclear power plant facilities in addition to CPSES. The TRT evaluations as well as the actions required of TUEC to resclve these concerns are addressed in the QA/QC Group SSERs. In general, the quality of the E&I installations highlighted by the concerns was found to be acceptable, except for few cases which the E&I Group deter-mined to have safety significance. To detemine the extent of the generic implications of these concerns *further review and inspections are required j by TUEC. The E&I Group concludes that the problems found with electrical cable termina- / tions, electrical equipment separation and control room ceiling fixture sup,w rts together with the findings concerning inadequate training and qualiff-r.M(N of electrical QC inspections, are an indication of programatic weaknesi in $. The subject of programatic weakness in QC as well as the actions re-quired or TUEC are addressed in the QA/QC Group SSERs. I' The deficiencies identified during the review of the concerns related to both hardware installation and QA/QC related matters are an indication of weakness in the QA/QC program and are used as inputs to the overall programatic review by the QA/QC Group. The results of this QA/QC programatic review will govern the breadth and depth of the actions required of TUEC to resolve not only the l, specific E&I concerns identified in this report but also all other programmatic 'l concerns related to construction activities of E&I installations. Therefore, i ! t the E&I Group concludes that any actions taken by TUEC to resolve the specific ESI concerns identified in this SSER, or establish root causes and appropriate l corrective actions concerning them shall not be considered final until they are i properly integrated with the results of the overall programmatic review per-fonned by the QA/QC Group. i 1 F0$85-59 } 1 1

L_a: ~^ ' ~ T-----------~~ e i 3 i 3.1.2 Scope of Concerns and Allegations The concerns in the E&I area relate to construction activity including equipment installation, specifications, drawings, procedures, personnel training and qualification records, and inspection. There are 53 concerns in this area 20 of which are hardware related and 33 are QA/QC related. The E&I Group reviewed an additional item of concern identified by the SRT re-garding overloading of cable t-ays due to the installation of "thermolag" material. The above concerns are consolidated by subject into nine separate i categories. A concern may be assigned to several applicable areas if it raises issues that are connon to the subject areas. When assigning QA/QC related allegations to subject categories, those with available information on specific equipment location are also assigned to the hardware related categories such that a direct inspection of the equipment installation in- "l volved would be performed. The nine categories and characterizations are as follows: i. Category No. Sub.iect Characterization of Concerns and Allegations 1 Electrical Cable Improper-sized lugs, improper use of cable Terminations butt splices in panels and cable temina-tions not conforming with drawings. - 2 Electrical Cable Problems with cable tray seismic supports, Tray & Conduit clearance of process pipes from cables in i Installation cable trays and loose conduit fittings. 3 Electrical Equipment Violation of the cable separation criteria i Separation between separate cables, trays and conduits and inconsistency between specifications and regulatory requirements. 4 Control Room Ceiling Field run conduit, drywall and lighting 4 Fixture Supports supports in the. control room were classified as non-seismic.- 5 Electrical Improper generation and disposition of Noncomformance electrical NCRs. Report (NCR) l Activities l 6' Electrical QC Inspectors were inadequately qualified, Inspector received help to pass certification 1 Training and tests. Qualifications t l

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7 Electrical Cable Cable tray overfill, cable spliced Installation in trays and improper cable dressing. I 8 Electrical Procedures Omissioc and changing of requirements from electrical inspection procedures without proper justification. 9 Electrical Inspection Inspection reports written without Reports Inspection reinspections and in-process inspections Item Removal not conducted. Notices and In-Process Inspections 3.1.3 Electrical and Instrumentation Group The E&I Group consisted of seven reviewers who, collectively, represented 140 years of engineering experience, of which 90 years were in the nuclear industry . in electrical and instrumentation engineering design, quality assurance and control, inspection, construction, project management and regulatory activi-ties. The E&I Group members included two representatives from the Office of Nuclear Reactor Regulation, one from NRC Region IV Office, three from a national laboratory, and two from consulting firms. 3.1.4 Findings for Electrical and Instrumentation Concerns The E&I findings are contained in nine supplemental safety evaluation reports (SSERs) one for each subject allegation category. Each SSER lists and char-acterizes all the concerns raised by the allegations and the special review team. In some instances the EAI Group, during its evaluation of an allegation discovered a new concern unrelated to the original allegations. These new con-cerns were also evaluated and reported in the appropriate SSER. Cassen areas between E&I SSERs and SSERs of other TRT Groups are presented in Table 3-1 of this report. An assessment of the safety significance of the concerns as well as the generic implications of the findings; and the root cause of each concern as appropr-iate, are also presented in the SSER. In addition, each SSER includes con-clusions and staff positions; actions required of TUEC; potential violations; and reference documents. s On September 18, 1984, the TRT presented at a public meeting the E&I findings as well as the actions required by TUEC to reach final resolution of the i issues. The TRT noted at that meeting that the EAI findings as well as the actions required of TUEC could not be considered final until they are integrated with the results of the overall programmatic review being conducted by the QA/QC TRT. Since then, minor modifications were made to these findings and actions-to include the results of the review of additional infonnation and to integrate them with the results of the review by cn QA/QC Group. Group. O b 3 w e 4 - e., - s-o

1 = .i The E&I TRT found no problems with the concerns raised by the allegations or 4 j : the s'pecial review team regarding the installation of electrical cables; nor could the E&I Group find any evidence of discrepancies in the electrical NCR lI activities, el.ectrical procedures, electrical inspectinn reports, inspection removal notices and in-process inspections. The E&I Group concludes that the concerns in these areas either have no safety significance and generic implications, or could not be substantiated. However, the QA/QC related _ areas are being further assessed by the QA/QC Group as part of its overall { programmatic review. The QA/QC areas involved are referenced in the E&I i l; SSERs. J In the areas where,the E&I Group found problems with potential safety i significance and generic implications, the actions required by TUEC are specified for resolving these issues. In the cable teminations area, the E&I Group found problems with the installation and inspection procedures and documentstion of butt splices in panels; the documentation of safety-related and associated tenninations in panels; and the disposition of NCRs related to vendor-installed terminal lugs. The E&I Group concludes that the adequacy of the QC inspection program as related to the deficiencies identified above could not be substantiated. 1 The ESI TRT found only one problem in the area regarding electrical cable tray and conduit iastallation. This relates to the lac < of craft training in i l the use of an installation manual for conduit and junction box supports'. In the area of electrical equipment separation the E&I Group found severai cases of separate safety and nonsafety-related cables and flexible conduits (containing safety and nonsafety-related cables) inside main control room i panels that did not meet minimum separation requirements. And no evidence was i found to justify this lack of separation. The ESI Group found two instances of - violation of the separation criteria concerning separation of redundant instrumentation and field wiring by barrier. The EAI Group also found that existing TUEC's analysis substantiating the acceptability of the criteria for separation between independent conduits and cable trays had not been reviewed by the NRC staff. The E&I Group therefore concludes that the adequacy of the 1 QC inspection program as related to the deficiencies identified above could not l be substantiated. The area of potential safety significance and generic implications concerning i the control room ceiling fixture supports was jointly reviewed by the E&I and the Civil and Mechanical TRTs, Regarding the electrical aspects of this concern, the EAI Group concludes that the installation of the nonsafety-related conduit in the control room was inconsistent with seismic requirements and that the suspended drywall ceiling and lighting supports appeared to satisfy seismic requirements but no analysis could be found that confirmed the adequacy of the l supports. The EAI Group also inspected selected seismic Category I areas of [ the plant and concludes that the installation of nonsafety-related conduits of 1 less than or equal to two inches in diameter is inconsistent with seismic i l installation requirements. lt t l i 4 t ve W+ e mpwp-=->weWsu--4.i-gpr mw egyr-T'W'T**--TWNW WM*W ewe +*'-WNC--w+'TNw W8*-*"nMMW9N9W'9'- W

e - The last area of potential safety significance concerned the lack of programatic control of the electrical QC inspector qualification program which may be indicative of inadequate qualification for some electrical QC inspectors. Since the training and certification program is the same for all disciplines (except ASME), the E&I Group concludes that the deficiencies l identified with the electrical QC inspector training and qualifications have generic implications to other construction disciplines. The implications of the E&I. Group findings were further assessed by the TRT QA/QC Group as part of the overall programatic review of QC inspector training and qualification. (See SSER for QA/QC Category No. 4, " Training and Qualification." l The E&I findings and actions required by TUEC (presented in Section 4.0 of this SSER) as related to the specific concerns and allegations were discussed with those individuals responsible for raising them and willing to participate in these discussions. Any disagreements with the EAI findings noted by these individuals as well as the E&I Group resolutions concerning them are reported in the appropriate category SSER. 9 .en 4 i ! i I i 9 4 e 1 i 5 ,a.. --.-,..-,,,,-,.,.-,.,,....,-,.------,-.,,.._,,..,-n,-

_ _ _ _ _ ~ r g. o Ej l Table 3-1 [ Comon areas between E&I SSERs and Other Disciplines SSERs i1-E&I SSER Connon Areas No. Within EAI SSERs other TRT Disciplines SSERs. t 1 E&I-6 QA/QC-8 2 QA/QC-8 3 -8,6 QA/QC-8 > 4 CAS --- 5 -6,1,2,7,8 QA/QC-6,5 s 6 QA/QC-4e., + 7 8 -5,1,3 _ QA/QC-8 QA/QC-5 9 s 6 E a I t. i i 3 i 4 a e ) 1 t s t a 4 6 4

= i 4 ACTIONS REQUIRED OF TUEC 4.1 Electrical and Instrumentation Area 4.1.1 Electrical Cable Terminations (See SSER for E&I Category No. 1) o Reevaluate and redisposition all NCRs related to vendor-installed terminal lugs in ITT Gould-Brown Boveri switchgear; and perforu and document the results of engineering analyses to justify any resulting "use-as-is" dispositions. o Develop adequate installation and inspection procedures to ensure (1) the operability of those circuits which contain butt splices in panels, (2) that the wire splicing materials and methods used are qualified for anticipated services conditions, and (3) that splices are not located adjacent to each other. o Reinspect all safety-related and associated terminations in the control room panels and in the termination cabinets in the cable spreading room to verify that their locations are accurately depicted on all current design documents. Should the results of this reinspection reveal an unacceptable level of nonconformance to design documents, the scope of this reinspection effort shall be expanded to include all safety-related and associated terminations at CPSES, e o Clarify p,rocedural requirements and provide additional QC inspector training with respect to the areas in which nuclear heat-shrinkable sleeves are required on splices, and ensure that (1) such sleeves are installed where required, (2) all QC inspections requiring witnessing for splices have been performed and properly documented, and (3) all butt splices are properly identified on the appropriate design drawings and are physically identified within the appropriate panels. o Evaluate the adequacy of the QC inspection program as related to the deficiencies identified above to establish root causes and appropriate corrective actions. These actions shall be integrated with other actions. addressed under QA/QC Category No. 8. "As Built." 4.1.2 ' Electrical Cable Tray and Conduit Installation (See SSER for E&I Category No. 2) o Evaluate the adequacy of craft training in the use of installation manuals to establish root causes and appropriate corrective actions. This action shall be integrated with other actions concerning craft training addressed under QA/QC Category No. 8,."As Built." 4.1.3 Electrical Equipment Separation (See SSER for E&I Category No. 3) i o . Reinspect all panels at CPSES, in addition to those in the main control room for Units 1 and 2 that contain redundant safety-related cables within l 1 www-- w ---r-- -e--,.-------

, _ _J. .m. o t conduits, or safety and nonsafety-related cables within conduits, and either correct each violation of the separation criteria, or demonstrate by analysis the acceptability of the conduits as c barrier for each case j where the minimum separation is not met. l .o . Reinspect all panels at CPSES, in addition to those in the main control room identified in Table 1 of SSER for E&I Category No. 3, and either correct each violation of the separation criteria concerning separate cables and cables within flexible conduits, or demonstrate by analysis the adequacy of the flexible conduit as a barrier. j o Correct two instances of violation of the separation criteria inside panels CPI-EC-PRCB-09 and CPI-EC-PRCB-03 concerning a barrier that had been removed and redundant field wiring not meeting minimum separation. o Submit the analysis that substantiates the acceptability of the criteria stated in the electrical erection specifications governing the separation between independent conduits and cable trays. o Evaluate the adequacy of the QC inspection program as related to the deficiencies identified above to establish root causes and appropriate corrective actions. These actions shall be integrated with other actions addressed under E&I Category No. 6. " Electrical QC Inspector Training and Qualifications," and QA/QC Category No. 8. "As Built." 4.1.4. Control Room Ceiling Fixture Supports (See SSER for E&I Category No. 4) o Substantiate (1) the adequacy of the overall seismic support system installation for all the items located above the ceiling in the control / room, including nonsafety-related conduit, suspended ceiling and lighting and (2) the adequacy of the seismic supportisystem installation for nonsafety-related conduit in Seismic Category I areas of the plant other than the control room. This action shall be, integrated as appropriate with other actions addressed under Civil / Structural Category No. 14, " Seismic Design of Control Room Ceiling Elements." .'~ 4.1.5 Electrical QC Inspector Training / Qualifications (See SSER for E&I Category No. 6) o Evaluate the testing program for QC electrical inspector qualifications and develop a testing program which optimizes administrative guidelines. procedural requirements and test flexibility to assure that suitable proficiency is achieved and maintained. o Review all the electrical QC inspector training, qualification, certifica-tion and recertification files against the project requirements as docu-mented in the FSAR and provide the information in such a fonn that each requirement is clearly shown to have been met by each inspector. If an inspector is found to not meet the training, qualification, certification, or recertification requirements, TUEC shall then review the records to determine the adequacy of inspections made by the unqualified individuals and provide a statement on the impact of the deficiencies noted on the safety of the project. O 2 --.a.--.

a. .s i o Justify the allowance to administer separate (waiver) tests, as permitted by procedures in lieu of examinations administered by independent professional eye specialists. i o These actions shall be integrated,' as appropriate, with other actions addressed under QA/QC Category No. 4 " Training and Qualifications." t R I e 1 9 3* .-.w- .m__ w.--. 4}}

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