ML20136B163
Text
{{#Wiki_filter:_ _ UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ) TEXAS UTILITIES GENERATING ) COMPANY, et al. ) Docket Nos. 50-445-2 ) and 50-446-2 (Comanche Peak Steam Electric ) Station, Units 1 and 2) ) CASE'S REQUESTS FOR ADMISSION CASE hereby requests that Applicant and Staff admit thats i ~ -1. The Technical Review Team (TRT) found a lack of awareness on the part of quality control (QC) electrical inspectors to document in the inspection reports when the installation of the " nuclear. heat-shrinkable cable insulation sleeves" was required to oe witnes cd. [ September 18, 1984 ~ Letter from D. Eisenhut to M. Spence ("TRT Report #1", I.a.1)3 's 2. The TRT found inspection reports that did not indicate - that the required witnessing of splice installation was done. (TRT Report fl, I.a.2) 3. The TRT found a lack of splice qualification requirements and provisions in the ii.stallation procedures to verify the operability of those circuits for which splices were l being used. (TRT Report $1, I.a.3) 4. The TRT found selected cable terminations that did not agree with their locations on drawings. (TRT Report $1, 1.a.4) 5 l l l 8601020450 BD1113 PDR F OI A GARDE 0 5-59 PDR l l
5. The TRT i:2-d :; n V'.are acne:nf:rmanca raper:2 01T22) concer..ing vender-ins:L'. ;l
- minal 1 ;3 in "CI m:t:r c:ntr:1 sen.ars-had been i=pr:parl; :::::d. 'TRT Rapert 11, I.a.5) 6.
The TRT found, in numarcus cases, that safaty-related cables within flexible conduits inside main centrol room panels did not meet the minimum separatica requirements. (TRT Report 41, I.b.1) 7. The TRT found, in several cases, that 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. No evidence was found that justified the lack of separation. (TRT Report #1, I.b.2) 8. The TRT found that the existing TUEC analysis sEbstantiating the adequacy of the criteria for separation between conduits and cable trays had not been reviewed by the NRC staff. (TRT Report 41, I.b.3 ) 9 '. The TRT found two minor violations of the separation criteria inside panels CP1-EC-PRCB-09 and cpl-EC-PRC3-03 concerning a barrier that had been removed and redundant field wiring not meeting minimum separation. The devices involved with } the barrier were FI-2456A, PI-2453A, PI-2475A, and IT-2450, I associated with Train At and FI-2457A, PI-2454A, PI 2476A, ar c', IT-2451, associated with Train B. The field wiring was associated with devices HS-5423 of Train B and HS-5574, nonsafety-related. (TRT Report $1, I.b.4) i e ,m ,-,--e c, 7 4-
10. Tho TRT found that tha cupport installcticn fcr n:n-safe y-related cenduits less than or squal to 2 inches was inconsistent with seismic requirements and could find no evidence that substantiated the adequacy of the installation for nonsafety-related conduit of any size. (According to Regulatory Guide 1.29 and FSAR Section 3.7B.2.8, the seismic Category II and nonseismic ite=s 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.) (TRT Report $1, I.c) 11. The TRT found a lack of supportive documentation regarding personnel qualifications in the training and certification files, as required by procedures and regulatory requirements. (TRT Report $1, I.d.1) 12. The TRT found a lack of documentation for assuring that the requirements for electrical QC inspector recertification were being met. Specific examples are: One case of no documentation of a high school diploma or General Equivalency Diploma. 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 documentation in the training and certification files substantiating that the person met the experience requirements. (TRT Report fl, I.d.1) i l I l
13. Tho TRT fcund o lack of guidolin00 cnd prcccdural requirements for the testing and certifying of electrical QC inspectors. Specific examples are: No time limit or additional training requirements existed between a failed test and retest. 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. (TRT Report #1, I.d.2) 14. The TRi found that no engineering analysis was performed prior to corrective action being taken on a documented occurrence in which reinforcing steel was omitted from a Unit 1 reactor cavity concrete placement between the 812-foot and 819-foot 1/2-inch elevations. This reinforcement was installed and inspected according to drawing 2323-S1-0572, Revision 2. However, after the concrets was placed, Revision 3 to the drawing was isnued showing a substantial increase in reinforcing steel over that which was insta31ed. Gibbs & Hill Engineering was informed of the omission by Brown & Root Nonconformance 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 l l
als: placed in the next concrete lift above the 819-foot 1/2-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 cannot determine the safety significance of this issue until an analysis is performed verifying the adequacy of the reinforcing steel as installed. (TRT Report $1, II.a) i 15. The TRT found that, based on the review of available inspection reports and related documents, on field observations, and on discussions with TUEC engineers, it cannot determine ~ whether an adequate air gap has been provided between concrete l structures. (TRT Report $1, II.c) 16. The TRT found that TUEC has not adequately demonstrated qcmpliance with FSAR Sections 3.4.1.1.1, 3.8.4.5.1, and 3.7.3.2.8, which require separation of Seismic Category I 4 buildings to prevent seismic interaction during an earthquake. l (TRT Report #1, II.c) 17. The TRT could find no evidence that the possible effects of a failure of nonseismic items (other than the sloping suspended drywall ceiling) and for nonsafety-related conduits ( whose diameter is 2 inches or less, had been 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 i items, nor.were the fundamental frequencies of the supported masses determined to assess the influence of the seismic response i I l 1 ~..
.g-4 spectrum at the control reem ceiling tievation would have on the seismic response of the ceiling elamants. (TRT Report 11, II.d) r 18. The TRT found that certain tast objectives of Chapter 14 of the FSAR and Regulatory Guide 1.68 requirements for the conduct of preoperational testing were not met. (TRT Report $1, III.a.1) s 19. The TRT found a deficiency in Test' Procedure.lCP-PT 12, " Bus Voltage and Load-Survey" in that because acceptable voltages could not be achieved with the specified transformer taps, they were changed. A subsequent engineering evaluation required, returning to the original taps, but no retest was perforned. 20. The TRT found a deficiency in Test Procedure ICP-PT 05, " Steam Generator Narrow Range Level Verification" in that fevel detectors 1-LT-517, 518 and 529 were replaced with i temporary equipment of a design that was different from that which was to be eventually installed. (TRT Report #1, III.a.1) 21. The TRT found a deficiency in Test Procedure ICP-PT ; 1 05 " Pressurizer Level Control" in that level detector 1-LT-461 appeared to be out of calibration during the test and was replaced after the test. The retest approved by the Joint Test Group was a cold calibration rather than a test consistent with the original test objective, which was to obtain satisfactory data under hot conditions. (TRT Report $1, III.a.1) 22. The TRT noted during a review of completed hot functional test data, that the Joint Test Group did not approve .i l the data until after cooldown from the test. The tests are not l i i 1 l i
considered complete until this approval is obtained. In order to complete the proposed post-fueling, deferred preoperational hot functional test,- the Joint Test Group, 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. (TRT Report #1, 1 III.a.2) 23. The TRT found that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel load, certain limiting. conditions of the proposed technical specifications cannot be met, e.g., all snubbers will not be operable since some will not have been tested. (TRT Report $1, III.a.3) 24. The TRT found that data for the thermal expansion tests (which have not yet been approved by the Joint Test Group) did not provide for traceability between the calibration of the measuring instruments and the monitored locations, as required by Startup Administrative Procedure-7 (although the information was separately available in a personal log held by Engineering). l (TRT Report $1, III.a.4) 25. The TRT found a deficient leak rate test in that 1 apparently after repairing leaks found during the first two attengts, the third attempt at a CILRT was successful. It was a 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 tested with satisfactory results, NRC approval was not obtained l
to perform 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. -(TRT Report $1, III.b) 26. The TRT found, in its review of prerequisite test records, that craf t personnel were signing to verify initial conditions for tests in violation of startup Administrative Procedure-21, entitled: " Conduct of Testing" (CP-SAP-21). This procedure requires this function to be performed by System Test Engineers. Startup management had issued a memorandum imprc;erly authorising craft personnel to perform these verifications on selected tests. (TRT Report $1, III.c) 27. The TRT found that System Test Engineers were not being provided with. current design information on a routine, controlled b'a s is, and had to update their own material when they considered it appropriate. (TRT Report $1, III.d) 28. The TRT found that no fillet weld inspection criteria existed for certain types of skewed welds. The TRT found that Brown & Root weld inspection procedures CP-QAP-12.1 and QI-QAP-11.1-28 for NF supports did not address some types of skewed welds. Although TRT was told by Brown & Root personnel that procedure QI-QAP-11.1-26 for piping weld in'spection was used, no evidence documenting the use of this inspection procedure was provided to the TRT. The lack of inspection criteria and lack of verification of proper inspection procedures being conducted for some types of skewed welds are a violation of ASME Code for NF supports committed to by TUEC in FSAR Section 5.2.1 and a
-v 9-viciation of Criterien X'lII in Appendix B of 10 C.F.R. 50. D;ovember 29, 1984 Letter from D. Eisenhut to M. Spence ("TRT Report 92, V.a)3 29. The TRT found that, although the small sample of welds the TRT inspected are acceptable, due to deficiencies in inspection records and the apparent lack of inspect f.on criteria, the TRT is not certain whether some types of skewed welds were inspected properly. The lack of documented inspections and criteria for some types of skewed welds in NF supports represents a safety concern regarding the possible existence of under-sized i welds in supports which are required to resist various design load. (TRT Report $2, V.a) 30. The TRT attempted to review TUEC records for ultrasonic (UT) measurement results and general installation practices. The ? TRT was told that ultrasonic testing of these types of bolts was not a procedural requirement; however, TUEC was unable to provide any other installation, records for TRT review. The TRT concludes' that this lack of installation inspection records is a violation c( QA, procedures and Criterion XVII in Appendix 'B of 10 C.F.R. 50. (TRT Report $2, V.b) 31. The TRT, in reviewing the.GRT findings in the area of piping design consideratiens, has discovered that piping systems, such as Main Steam, Auxiliary Steam and Feedwater, are routed from the Electrical Control Building (seismic category I) to the Turbine Building (non-seismic category I) without any isolation. To be acceptable, each seismic category I piping system should be isolated from any non-seismic category I piping system by separation, barrier or constraint. (TRT Report 92, V.c) A e ew-e e.w e-== l 32. Region IV inspections have confirmed the existence of plug welds in cable tray supports located in the Unit 2 Cable l Spreading Room. (TRT Report $2, V.d) 33. The TRT determined that the alleged incident pertained to restoration of the Unit 1, loop 1 main steam line to its initial, correct installation position. (The line had shifted during flushing operations due to the weight of the added water and because the temporary supports sagged.) The TRT also determined that the modifications to permanent pipe supports were necessary to provide proper support to the main steam line in its restored position (initial designs for and construction of the supports had been based on the shifted position of-the line) and, although the alleged vibrations could not be confirmed, their associated stresses might not have dameged the main steam line. The TRT review of a TUE0 analysis, performed 1 year after the incident, concluded that the analysis was incomplete. An evaluation for the full sequence of events leading up to the incident had not been performed. The TRT review of Gibbs & Hill '. _ ~ - Specification No. 2323-MS-100 indicated that there were inadequate requirements and construction practices for the support of the main steam line during flushing, and for temporary supports for piping and equipment in general. In particular, evaluations to assure the adequacy of temporary supports during flushing and installation were not required. (TRT Report 92, V.e)
34. The TRT found, based on a review of about 200 fuel pool travelers, that the fuel pool travelers included irregularities such as: 1) There was apparently a routine practice during construction of the fuel pool that allowed craft personnel to complete a portion of the inspection report forms prior to the actual inspection. Craft i personnel entered the word " SAT", dated the entry, and left b2ank only the space for the QC inspector's signature. It appeared that the craft personnel were judging the inspection results prior to inspection. l 2) The date accompanying the signature for visual examination of an inside weld was changed to a date that appeared to precede the examination. 3) Entries by the same inspector for two different inspections did not appear to match in that one entry appeared to be written by another person. 1 1 4) The procedure number for a dye penetrant inspection was changed by an inspector different from the one who I i conducted the inspection. F 5) The date for a dye penetrant inspection was changed by an inspector other than the one who performed the inspection. 6) Fuel pool travelers were found with missing QC signoffs-for fitup and cleanliness. No proof could be found that some of the required weld fitup and cleanlinesss inspections were ever performed. _7 ) The TRT review disclosed the.*ollowing irregularities with traveler entries in addition to those listed above (a) Date changes after the fact (b) Signoffs for functions out of ~ sequence (c) Corrections after the fact (d) Changes to first party inspector date signoffs 1 (e) Missing signatures [ January 8, 1985 Letter from D. Eisenhut to M. Spence ("TRT Report #3", 2.A)3 i 35. The TRT found no basis or criteria for paint removal or identification methodology of " worst case" pipe whip restraints which'had received inadequate source inspections. This resulted - - +, - - ~.+,e .-e r--- me---,--- -n,-,---,,
_ from a TRT review of 12 NCRs issued involving veld d:J::t. ' - - ~. ' Report #3, 2.B) 36. The TRT found that although pipe support compenents ' :' r been previously inspected and accepted by TUEC QC as meeting tha respective construction and installation requirements, of 42 pi;) supports inspected, 46 deficiencies were identified. (TRT Repor-
- 3, 4.A)
(See Attachment 1, " Table 1 Pipe Supports in Unit l') 37. The TRT found that TUEC did not report to the NRC, pursuant to 10 C.F.R. 50.55(e)(1), the omission of thread-locking devices in the Unit 1 nuclear safety systems and did not attempt corrective action until May 1984, when TUEC tested previously applied paint for thread-lock capability. That test was inconclusive, since it did not establish that the paint, an epory grocess, would reliably perform as an effective locking device under al.'. service cenditions and throughout the expected lifetime of the plant. (TRT Report #3, 4.A.2) 38. The TRT found that TUEC could not identify to the TRT which paint was the subject of testing. (TRT Report $ 3, 4. A.2 ) 39. The TRT found that paint was applied to ASME code-controlled, NF hardware per specification 2323-AS-30 (non-Q) which required no inspection. (This issue appears to be generic for Unit 1.) (TRT Report #3, 4.A.2) 40. The TRT found that TUEC did not initiate an NCR, a required by procedure, identifying the widespread problem of missing locknuts; only a Request for Information was apparently generated which TUEC could not locate for the TRT. (TRT Report 93, 4.A.2) e s,, . -, _ ~.
, i i i I 41. The T.'.T feu.-l that pipe support RC-1-901-702-C32S had a load bolt at a ':aam attachment which did not exhibit an approved locking device. (The bolt material type was SA-307 grade A.) The TRT found that pipe support CS-1-085-003-A42K had no approved locking device on the "special clamp" bolts, even though the design drawing for this clamp showed each bolt.with a nut and a locknut. (TRT Report #3, 4.A.2) 42. The TRT found that the baseplate for pipe support CC-X-039-006-F43R, located in the component cooling system, Room.249A, Fuel Handling Building, violated minimum edge distance criteria for bolt holes. (TRT Report #3, 4.A.3) 43. The TRT found the horizontal member of Support CC - 126-010-F33R was 3 inches lower at its centerline relative to the upper bolt-hole centerline than shown on the vendor-certified drawing. (TRT Report #3, 4.A.4) 43. The TRT found that the as-built drawing of the above-listed support had not been revised to reflect the actual installed condition in the plant. This support was located in the c,omponent cooling system, Room 247A, in the Fuel Handling Building. (TRT Report #3, 4.A.4) 44. The TRT found that an excessive free gap existed between spherical bearing and washers on the sway strut assembly i of support CC-1-126-015-F43R. (TRT Report #3, 4.A.5) a 45. The TRT found that other supports with similar bearing gap anomalies. found in TRT's inspections were : RC-1-052-016-C41K, RC-1-052-020-C41K, and MS-1-416-001-533R. (TRT Report $3, 4.A.5) 6 . - ~., - - - m---,, ,---r
. 46. The TRT found that the frequer.cy of this type of procedure violation in the TRT's limited inspection suggests that this problem is generic for Unit 1. (TRT Report $3, 4.A.5) 47. The TRT found paint contamination in the bearings of both snubber assemblies on component support SI-1-909-006-C41K that severely obstructed the bearing cavities and limited their movement. (TRT Report #3, 4.A.6) 48. The TRT found that a similar condition exists on support MS-1-416-002-S33R. (TRT Report (3, 4.A.6) 49. The TRT found that procedure QI-QAP-11.1-28, Revision. d,., c, 25, Attachment 29 permits less than full thread engagement in ,[l{:},p' threaded plates. This allowance for less than full thread engagement is a potential violation of the ASME Code Section III, NF-4711: no code case was invoked to set aside this procedure. (TRT Report #3, 4.A.7) 50. The TRT found that snubber (shock arrester) adapter-plate bolt threads were insufficiently engaged in all four ~ threaded holes of component support MS-1-416-002-S33R. (TRT Report #3, 4.A.7) 51. The TRT found a similar lack of full thread engagement! deficiencies on NF supports SI-1-090-006-C41K and CT-1-013-012-S32K. (TRT Report $3, 4.A.7) 52. The TRT found that sight holes were present in the strut body to verify threaded rod engagement. The. rod was not visible through the sight hole for support RC-1-901-702-C82S. (TRT Report #3, 4.A.8) l
4 . 5:. The TRT found locking latica daliciancies. An example .a; .';a - ; e." isr:: 'To. AF-1-001-014-S33R had a broken cotter pin. (TRT Raper: 73, 4.A.9) 54. The TRT found load sides of pipe clamp halves that were not parallel. An a ample is that clamp halves for pipe supports AF-1-001-00;-33 R and AF-1-001-014-S33R were not parallel. (TRT Repor 73, 4.A.10) 55. The TRT found pipe clearance outside of allowable tolerance violations. An exa=ple of is that pipe support CO 126-013-F33R exhibited no clearance on top or bottom, while the hanger drawing called out 0" on the bottom and 1/16" on top. ~ (TRT Report #3, 4.A.11) 56. The TRT found that a similar problem existed for pipe sgpport AF-1-001-702-S33R. (TRT Report #3, 4.A.11) 57. The TRT found that pipe clamp locknuts were loose. An ~( example was that a pipe clamp locknut for pipe support AF-1-035-Oll-533R was found loose (less than finger-tight). (TRT Report f3, 4.A.12) 58. The TRT found that pipe support CC-1-126-014-F43R exhibited angularity that exceeded requirements. (TRT Report #3, 4.A.13) 59. The TRT found that a similar problem existed with pipe support RC-1-052-020-C41R. (TRT Report #3, 4.A.13) 60. The TRT found that snubber cold set (AC) dimansion did not match the design drawing. An example was that pipe support CS-1-085-OO3-A42K deviated by approximately 1" from the cold set dimension shown on the design drawing. (TRT-Report $3, 4. A.14) I
. 61. The TRT found that support configuration did not match the design drawing. An example was that pipe support snubber CT-1-005-004-S22K was installed end-to-end opposite from the orientation shown on the drawing. (TRT Report #3, 4.A.15) 62. The TRT found that a similar problem existed with pipe support CT-1-013-010-S22K, where dimensional discrepancies existed on the support drawing that detailed the orientation of the snubber. (TRT Report #3, 4.A.15) 63. The TRT found that a component type /model number did not match the design drawing. An example was that model numbers of installed snubbers for pipe support SI-1-090-006-C41K did not match the model number on the design drawing. (TRT Report # 3, 4.A.16) 64. The TAT found that a similar problem existed with pipe support RC-1-052-020-C41R. (TRT Report #3, 4.A.16) 65. The TRT found that weld data cards were missing QC initials for welds. An example was that support number CC-1-126-013-F33R had some welds performed with no QC inspector initials or" signature on the corresponding blocks of the weld data card ~~ for that support inspection package. (TRT Report #3, 4.A.17) 66. The TRT found deficiencies in identification of materials and parts. An example was that'a replacement part (sway strut eyerod) for pipe support CT-1-013-014-S32R had no apparent material identification either on the hardware or in the documentation package for the support. The Material j Identification Log (MIL)'did not list any identification 1 traceable to the origin of the replace part. (TRT Report #3, 4.A.lB) i r l 4 -c
__ _ _ 67. The TRT found that a similar problem existed with pipe supports CC-1-126-012-F33R, CC-X-039-005-F43R, and AF-1-035-Oll-S33R. (TRT Report #3, 4.A.18) 68. The TRT found a frequently occurring number of strut and snubber load pin spherical bearing clearance with washers that were excessive (Ref. QI-QAP-ll.1-28, Sec. 3.7.3.1 Rev. 25). (See Attachment 2, Table 3 Summary of Additional TRT Inspections) (TRT Report #3, 4.B ) 69. The TRT found a* frequently occurring number of strut and snubber load pin locking devices (cotter pins or snap lock rings) which were damaged or missing (Ref. QI-QAP-ll.1-28 Rev. 25, which did not specifically address load pin locking devices). (See Attachment 2, Table 3 Summary of Additional TRT Inspections) .,TRT Report #3, 4.3) ( 70. The TRT found a frequently occurring number of pipe clamp halves on load side which were not parallel (Ref. QI-QAP-11.1-28, Sec. 3.7.3.1 Rev. 25). (See Attachment 2, Table 3 "72 Summary of Additional TRT Inspections) (TRT Repore 43, 4.B) 71. The TRT found a frequently occurring nunber of bolts threaded into tapped holes of snubber adapter plates that had less than full thread engagnment. (See Attachment 2, Table 3 Summary of Additional TRT Inspections) (TRT Report #3, 4.B)
- 72. 'The TRT found that a frequently occurring number of "Hilti Kwik" bolts (concrete expansion anchors) as installed did not meet minimum effective embedment criteria (Ref. QI-QP-11.2-1, Sec. 3.5.1 Rev. 16).
(See Attachment 2, Table 3 Summary of Additional TRT Inspections) (TRT Report #3,'4.B) ._m._
. 73. The TRT frequently found that locking devices for threaded fasteners.were missing or of a non-approved type. (See, Table 3 Summary of Additional TRT Inspections) (TRT Report #3, 4.B) 74. The TRT found undersize welds on electrical conduit supports and cable tray hangers. An example of undersize welds was that three or four welds on conduit support C120-21-194-3 (cable spread room) were undersized. The required weld size was 1/4" at all weld joints, while the measured weld size was 7/32" to 5/32" for the full lengths of three out of the four welds. (See Attachment 3, Table 4 Sum =ary of Electrical Raceway Support Inspection by the TRT - Unit'1) (TRT Report #3, 4.C.1) 75. The'TRT found that cable hanger CTH 5824 (Containment Building) had 13 undersize welds. The all-around welds on the six horizontal beans should be 1/4" in size, according uo details L1 and L2 on Drawing FSE-00159, sheet 5824, 1 of 2. The measured size of these welds was 3/16' to 5/32" at each connection. (See Table 4 Summary of Electrical Raceway Support ..'In,spection by the TRT - Unit 1) (TRT Report #3, 4.C.1) 76. The TRT found that support IN-SP-7b exhibited undersize welds measuring 7/32" to 5/32" instead of the required 1/4". (See Attachment 3, Table 4 Summary of Electrical Raceway Support Inspection by the TRT - Unit 1) (TRT Report #3, 4.C..) 77. The TRT found risplaced welds on hangers. An example was on hanger CTH-6742, where the TRT found that two structural welds were made in the wrong direction. The 3/16" shca welds which join MK-10 and MK-ll were made horizontally instead of I
shevn on drawing FSE-00159, sheet 6742. CC vertically, as Inspecticn Repo-* v?-I-0024909, dated February 16, 1984, acceptec' all inspectable attributes as satisfactory prior to the TRT inspection. (TRT Raport #3, 4.C.2) 78. The TRT found unauthorized configuration changes on cable tray hanger CTH 5824 (Containment Building) which had been f abricated to include 40 more stif feners and 80 more welds than required er shev.: on drawing FSE-00159. sheet 5824, 2 of 2, Detail L2. Inspection Report ME-1-0006155 verified final QC inspecticn and acceptance en January 3, 1984. (TRT Report $3, 4 C.3) 79. The TRT found that cable tray hanger CTH-6742 (Auxilia:7 Suilding), Clip, MK-12, should be 6" x 6" x 3/4" angle stock in accordance with FSE-00159, shest 6742. The actual Elange thickness of MK-12 was 3/8". (TRT Report #3, 4.C.3) 80. The TRT found Hilti anchor bolt installation deficiencies. An example was CTH-6742 (Auxiliary Building) anchor bolt torque which was not verified (paragraph 3.5 of 'the procedure). (TRT Report #3, 4.C.4) The TRT found that Hilti bolts were not marked in 81. accordance with Attachment 1 of the procedure on L'TH-6742. (TRT Report $3, 4.C.4) 82. The TRT found that the. length of the Hilti bolts was not verifiable (paragraph 3.2) on CTH-6742. (TRT Report #3, O 4.C.4) 83. The TRT found that five base plate bolt holes oa CTU- ) 1 (Containment Building) had violated minimum edge distanr;e -- 5824 edge distance cannot be less than 17/8" (Attachment 2 of the
. i ) procedure). Actual distance was 1 5/8" to 1 3/8" from the nearest plate edge. (TRT Report #3, 4.C.4) 84. The TRT found that one Hilti bolt on CTH-5824 was skewed to more than 15 degrees. (Maximum allowable skew was 6 degrees without corrective bevel washers (paragraph 3.1.2) (TRT Report #3, 4.C.4) 85. The TRT found that Hilti bolt torque on hanger CTH-6741 (Auxiliary Building) was not documented aa being verified by QC (paragraph 3.5). (TRT Report #3, 4.C.4) 86. The TRT found inconsistency in the application of nuts for SA-325 bolts in that both staedard and heavy hex nuts were used. No stipulation was found which would permit the use of standard (non-heavy) hex nuts. This condition is a potential v,iolation of the Material Specification ASTM A325 (ASTM, Part 4- ~ 1974) paragraph 1.5, which provides that " heavy hex structural bolt's and heavy hex nuts shall be furnished unless other dimensional requirements are stipulated...." B&R Drawing No. FSE-000159, sheet 5824, 2 of 2, required the use of ASTM A325 b61tr for cable tray hanger numbe.r CTH-5824. (TRT Report #3, 4.C.5) l 87. The TRT found that many problems indicative of inadequate drawing control existed at CPSES from September 1981 to April 1984. These problems had been identified prior to the o TRT's evaluation by bcth TUEC and NRC Region IV audits and reviews. (TRT Report #3, 5.B) 88. The TRT found that at least between August 1983 and April 1984:
. l 1) Drawings released to the field were not current. 2) Drawing and specification changes were not Current. 3) Design documentation packages were incomplete. / 4) The document control center did not provide the satellites with up-to-date drawings, component i modification cards, design change authorizations and document revisions. 5) Drawings hanging from an open rack, which had no i checkout control, were available to craft and QC personnel. l 6) Design change logs were inaccurate. 7) Design documents were not always accounted for in the document control center. 8) Current and superseded copies of design documents [ were filed together. l 9) Satellite distribution lists were inaccurate. l 10) There were discrepancies between drawings contained in the satellites and those in the i '~,, document control center. 11) Some drawings were missing from the satellit? files. t 12) Telephone requests for design documents resulted [ in the issuance of documents that bypassed the i controlled distribution system. -i (TRT Report 93, 5.B) 89. The TRT found that the effects of document control l inade,quacies prior to July 1984 have yet to be fully analyzed by TUIC. (TRT Report $3, 5.B) l 1 90. The TRT found -that deficiency reporting procedure CP-EP-16.3 appeared to relate only to craft and engineering personnel and was not directed to noneraft and nonengineering personnel who may have had knowledge of reportable items. l Procedure CP-EP-16.3 indicated that the applicable manager was r A t i e b I r-
. I responsible for documenting and reporting Deficiency and Disposition Reports (DDRs); but there were no checks or balances I to ensure that a manager or a designated substitute would process a DDR. (TRT Report #3, 5.C) 91. The TRT found that TUEC did not consider the CYCNA audit findings regarding the document control center as appropriate for formal reporting to the NRC pursuant to 10 C.F.R. 50.55(e), as required by procedurs CP-EP-16.3, " Control of Reportable Deficiencies." (TRT Report v3, 5.D) 92. The TRT found that the document control center issued a controlled copy stamp to the GC department to expedite the flow Methods of hanger packages to the Authorized Nuclear Inspector. for this kind of issuance and control of such stamps were not described in TUEC's procedures. (TRT Report #3, 5.E) 93. The TRT found that 20 percent of the training records reviewed contained no verification of educatior_ or work experience. (TRT Report #3, 6.A) 94. The TRT found that the results of Level I certification tsts were used for some Level II certifications rather than the results of a Level II test. (TRT Report #3, 6.B) I 95. The TRT found that after failing a certification test, a candidate could take the identical test again. (TRT Report #3, 6.C) 96. The TRT found that certifications were not always l signed or dated. (TRT Report 13, 6.D) 97. The TRT found that white-out was used on certification tests. (TRT Report #3, 6.E) s 3 a w ...m. em, -+.-. -- -,-- v-w-l 95. The TRT found that seven inspectors had quasticni '.s i qualifications. ('?XT Report #3, 6.F) 99. The TLJ found that there was no limit or centrol On the number of times, vxamination could be retaken. (TRT Report 43, 6.G) 100. The TRT found tbst no guidelines were provided for the use cf waivers for on-the-job training. (TRT Report $3, 6.H) i 101. The TRT found that in some cases racertificatien was accomplished by a simple "yes" from a supervisor. (TRT Report
- 3, 6.I)
I 102. The TRT found that there was no formal orientation training for document control center personnel prior to August 1983. (TET Report #3, 6.J) 103. The TRT found that the responsibility for e administration of the non-ASME training program was not clearly . assigned to a single individual or group. (TRT Report #3, 6.K) 104. The TRT found that non-JSME personnel capabilities f were loosely defined by levels (I, .I, III). (TRT Report $3, i 6.J,), s._ i 105. Tha TRT found that there Jere numerous additional problems in non-ASME certification testing, such as: no requirement for additional training between a failed test and the retest; no time limitation between a failed test and a retest; two differer. t scoring methods to grade a test and a retest; no guidelines on how a test question should be disqualified; no program 'for periodically establishing new tests except when i pror.edures changed; and no details on how th.e administration of tests should be monitored. (TRT Report $3, 6.M) i 4
106. The TRT found that the exemption provision in ANSI N45.2.6, which allowed substitution of-previous experience or demonstrated capability, was the normal method for qualifying inspection personnel rather than the exceptional method. (TRT Report #3, 6.N) 107. The TRT found that installation of certain butt-welded valves in three systems required removal of the valve bonnets and internals pric: to welding to protect temperature-sensitive parts. The Aree systeca involved were the spent fuel cooling and cleaning systems, the boron recycle system, and the chemical and volume control system. This installation process was poorly controlled in that disassembled parts were piled in uncontrolled areas, resulting in lost, damaged, or interchanged parts. This [racticecreatedthepotentialforinterchangingvalvebonnets and internal parts having different pressure and temperature ratings. (TRT Report $3, 7) 108. The TRT found that the scrap and salvage pile in the fabrication (fab) shop laydown yard was not identified and did not have restricted access. ~(TRT Report $3, 8.A) 109. The TRT found that material requisitions prepared in the f ab shop did not comply with the applicable procedure. (TRT Report #3, 8.B) ~ 110. The TRT found that the fab shop foremen were not familiar with procedures that controlled the work under their i responsibility. (TRT Report $3, 8.C) 111. The TRT found that f abrication and installation ) procedures did not include information to ensure that B&R-f i O
f abri:2ted threads conformed to dasign 2 2:ifi:::1:ns er to :n 1 applicable standard. (TRT Report 13, 3. C.1 112. The TAT found that indetarminat: b:13 1212:i:11 that 1 acccmulated as a result of site cleanup operati na s2:2 mingled with controlled safety and nonsafety material in the fab shop laydown yard. (TRT Report #3. 8.E) 113. The TRT found that site surveillance of =atarial storage was not documented. -(TRT Report #3, 8.. ) 114. The TRT found that work in the fab hop was performed in response to memos and sketches instead of hanger packages, travelers, and controlled drawings. (TRT Report #3, 8.G) 115. The TRT observed that not all snubbers were wrapped with protective covering when welding was being done in close proximity to them. This practice was a violation of D&R phocedure CP-CPM-14.1, which required protection of installed equipment during welding. (TRT Report #3, 9.B) 116. The TRT found that the TUEC procedure for preparation.., and processing of NCRs did not contain explicit instructions for handling voided NCRs. (TRT Report 13, 10.A) - s. ;. 117. The TRT found that NCRs were used as a tracking document to record removal of a part from equipment on a permanent equipment transfer rather than for reporting a non-conforming condition; such usage of the NCR was not defined in procedures. (TRT Report #3, 10.B) 118. The TRT found that there was an inconsistency between paragraphs 2.1 and 3.2.1 in procedure CP-QP-16.0. Paragraph 2.1 required all site employees to report nonconformances to their l
26 -
- 2 ria
- :: to the sita OA supervisor, while paragraph 3.2.1 r2;uired persons other than CA or QC personnel to submit a draft NCR to the Paper Flow Group.
(TRT Report #3, 10.C) 119. The TRT found that the NCR form had no form number or revision date to indicate that the form was being adequately controlled. (TRT Report $3, 10.D) 120. The TRT found that there were two versions of the TUEC NCR for=, one with and one without a space for the Authorized Nuclear Inspection (ANI) review. (TRT Report #3, 10.E) 121. The TRT found that the NCR form had no space to identify the cause of the nonconformance and the steps taken to prevent its recurrence. (TRT Repcrt #3, 10.F) 122. The TRT found that the NCR form had no provision for quality assurance review. (TRT Report #3, 10.G) 123. The TRT found approximately 40 different forms (other than NCRs) for recording deficiencies. Many of these forms and reports were not considered in trending nonconforming conditions.? (TRT Report #3, 10.H) ,1,24. The TRT found the material traceability was adequate for those 33 pipe supports, with the exception of four material identification discrepancies out of 3; pipe supports checked (as noted in section 4 on as-built inspections). (TRT Report #3, 11) 125. The TRT found that TUEC failed to maintain material a traceability for safety-related material and numerous hardware components. (TRT Report #3, 11) 126. The TRT found that a QA breakdown in material l traceability maintenance for safety-related material and hardware components was reported to TUEC in an ASME Code survey in October I l l I s.
1981 yet was not reported to the NRC in accordance with the requirements of 10 C.F.R. 50.55(e). (TRT Report 43,'ll) Respectfully submitted, b. WA I bISJ Rh 'h?HONY M. ROISi4AN A BILLIE PIRNER GARDE Trial Lawyers for Public Justice, P.C. 2000 P Street, N.W., Suite 611 Washington, D.C. 20036 (202) 463-8600 Counsel for CASE D
- m*9
- e e
gg I 1 i i a ,e ,p ---m ,,,,y-,y-se4,-, _ -, -y,-w+, wy,,yv,w,
p M,- e N o UNITED STATES ? f *'. $.y%b h) I NUCLEAR REGULATORY CC?.".'!SSICN WASHING TON. O. C. 20355 Yr4/y/ s,, s.- FEB _15 Isas MEMORANDUM FOR: Vincent S. Noonan, Director Comanche Peak Project THRU: J. Calvo, TRT gg' E&I Group Leader FROM: E. Marinos, TRT E&I Group
SUBJECT:
BOARD CONCERNS REGARDING START-UP QUALITY ASSURANCE As a result of my review of the various affidavits and transcripts relating to the Board's concerns, I am in substantial agreement with the prcposed affidavit prepared by Rick Xeimig. The affidavit provides adequate responses within the narrow context of the Board's stated concerns. In reviewing, however, the proposed affidavit prepared in behalf of Rick Keimig and Ward Smith, by Geary Mizuno I believe that a broader interpretation is placed on the Board's concerns. Therefore, a significant amount of technical review and inspections would be required in order to fully address the Board's anticipated questions raised in that affidavit. Specifically, in order to detennine the appropriate use of procedures for testing RPS iaverters, the following staff effort would be required: A step-by-step review of the Applicant's startup Administrative procedere, CP-SAP-10. " Start-up Program Quality Assurance Plan Impleeentation," and Test Procedure ICP-PT-02-02, "Preoperational Test Procedure." Witnessing of implementation of procedures in actual testing of RPS inverters. QA/QC review of calculations to determine acceptability with regard to requirements of 10 CFR 50 Appendix B. Staff examination of preoperational-test data to determine whether a comprehensive review was done by the Applicants of calculations o relating to voltage regulation. Interviews with plant System Test Engineers to evaluate their use of c the procedures, yg} ky Review the design and operational characteristi.cs of the inverters. \\ l l a 6 IO rp$! D Ol~ d d eq ~ C~ U ~ ed t e k 43d 1
....,9,. N B 1 5 1955 Assuming that we require to submit to the Board an affidavit similar'.to that proposed by Geary Mizuno, a realistic schedule for completing the required staff effort will extend to the end of March 1985. Therefore, we are proceeding with our effort to meet this schedule, unless we are directed to do otherwise. l-E. Marinos Comanche Peak Technical Review Team E&I Group t cc: G. Mizuno -R. Keimig J. Calvo i A. Vietti i ? t I t t { f i i ... _. ~.,.., _
i ? 9/30/$ ~ V,. ~% ---- - 1.
- .,. - e
% ';. ~. ~ _ a. k, 2 ~. ' 3 i ^~ i 5 ~ A le atien Catecery: Electrical anc Instrument'a' tion 7, Elactrical Ca:le Installation Allecation Number: AE-19, AE-28 AE-30, AE-50, Parts of ACE-5 and AE-29 h,MR ~ 5 anc Special Review Team SR -v/ 2 / _.n Characterization: It is alleged that: g.A -); '~ i
- - Cables were not " trained" in 'a workmanlike -nisiieTTnsthe cable spread '
' ing room and in function boxes 105c knd 1059 (AE-28)f' i 'sssrs.s-
- S a's-. S'enf ficae:e: Tne i : lied safety s'gnificar:! ie
':nat i=p:'cperly. rainec cables, improper cable splices and overlea:ec I cable trays coulc place the quality of the installation in question. Prer W:- Wanship. Allecations AE-28 and Part of ACE-5 invcivec in: tar.ceD tf irr;rocer cable "traiEing" (orJr.essing),. poor workmanship in ca:,le installation, and cables installed in raceways containing trash anc ha:ard - ous'cebris. The issues of improper " training" of cables and poor workman. ship in Junction boxes 1058 and 1059 were inspected by the TRT. The TRT %,6.. I findings agree with the previous NRC RIV determination that these cables. which are nonsafety-related, were properly trained and that they exhibited Q UC an acceptable degree of workmanship .These findings were discussed with the alleger who indicated that the junction box numbers may not have been correct and provided additional information concerning the lccation of the j bexes in the plant. The TRT is currently evaluating this new ir. formation L. and wili report the results in a supplement to this 55:R. Cenclusiens and Staff Positions: Basedontheinspectionofthecableb irstaliations for catie splices'in cable trays, workmanship, cable tray il, ad:sc loao on cable trays by thercolag raterial, and revie cf
- -.' s ; :*its 's.
- ::sd; s!, C I ' * !: e :-':- *s : r
!!!It'- . : s:-. -e;:r s, a : 7,;;. 3, :s
- :' :a5
.a.::.:-..: w. ::. r. i e' bs ca:Te instal'a 'on en ra:e.sy fi'i -evisas: anc i t:s:.s: ss. f M d'l e s a:lis Ed irstalla.' n require..e.:s. Therefore, :ne TRT c: cic:ss :nat, _fd
- J,l trese aliscations cc id not be substantiated. Lhemnits cf the IRT review of 'new-information concerning allegati6n AE-28 'will be repor ed in'!
a s.::ple ent to this SSER. --- --s _ 3 I. i A:-icns :ecuired: N:ne. t F0!Ac85-59 ' 36
g- / E-Z9a b .noek i / 5 ECER.EdtE oc.u M I C Y h .L .- % m 3\\aQ o%.%L 2. C9 5i% h L.1n,% L Y 7 de :e.p.3 W.us n o n $ 1s\\v e ~ Sw - I-b A 9E.e S) Or bbv S,192d TJ EC. Eh,m do, i., 2. 4, M D n E W E R. h C o 9. M M T h ' ( I' '
- m\\
r c r \\N ' $$U l. 0 ** \\ WiOW C2 rh 'M $ $ s <* #, './ ' L.e b'). p x.,j DN o. c wv'S e ' e. tv. A n 5 ^ en ,, s \\ 'tO O W\\ \\tA'o L h M C-4N4 b \\,C Ob CL V \\fc.a \\ C W) ; C.,.r41 A A 07 F A a S u o s ~.ar.a- < h.)u n \\ nds hc. n k e-5y \\ y s i_Q _i t,a s ! L ~ wv y v% 0 en e.f6.,us s avt s 'd. t ,'t % e ( cdd ,s.;A s m n s a Ce,Lv n(L: ;- x a E p u_d, k & J. b., al.lu N < m,. 9,Sh ( G thcou(4 ock!2y 'kh4 her 2, t.,
- Avv;de ittu
'g4' ck m kry n u m\\uvg L d s vya r, s e JL.:. s.m. a r.~_ % L L s 4% A l.[.L M V ) h b e 'b$, t4 n 1 e n - ma.rtn,) o.e.s.r v,.s e\\a:q n u.r-.* s p.t e, ~c. e. s. 'k [krk ne:c wL k s a.mLkL &La &Jhaan sss a avmv h1 Lcm.J OJ %'muc-.% ' L 4 CLce.Da (4 w %, Jh me 'md. l a c. A rr v ryas \\g cM v\\ ' n beJ L% _v-u. s s w %s \\. '..x \\ bbh 110 C,sw hen k ( r-c.v) m.: 'M g.,u.i c..v.c. 'u ./ (.(Qt-I2)dce M_%q e n .k n Niet.@- .c-rJJ %: 's oh 3Yc \\ n b v w a k. e n ' c e n c 2, n b c,3 s l T I
~ ~ .x 4 c. } J._J_.C'O.* m M Yd /k ,V. J. c h Cs b$O lb 00 t vi W Jsue I.'.'.Ct J, S (4 m a g }) ( ./ ? r, r T_d VStta vt4t W M h. ) A M.0,, tj-v i c.14 /,x.,) e .1 ( T YLS ^ 2.4 i kJ.vw \\M' cu k (. W t.h 'W Sl^ W 1 vt cl W vn.aw ssee.-, b x-2.0 F y-4Pih vc1 0tM * '> c c. 5 ' ~J. Ch b c LA.,. 4 $bC I /s-La f.P f f\\ o y vw. [4 L L F1 mbrum c t_ wA cued b u.o i vt c.-a,. St. hums n~ed hu N u p (*. w% I ce c e ct Mb)M I (c) Reinspect all safety-related and associated terminations in the con-f. trol room and in the te-mination cabinets in the cable spreading room to verify that their ic:ations are in accordance with all current design documents. Shei.'.d the results of this reinspection reveal an u acceptab'e level of r:n=enformance to design documents, tne secpe
- ' --> s rei s;ectie e##: : sha'l be er.:a-dsd to it:b.:s t n'=:y-rs'a ed and associate: arninatiens at Comanche Peak Steam Electric
/ g g-q _ -[ ) y % T. g g j Station (CPSES). (
1 j r '\\ -LL _ / L ' ~ ;' D ( (s).y.; . n 9 \\ e 'g \\ s m). ~b r. a z
- _ :~ ~. -
j,.J.. ~ ex \\ j m. 'oe h *- 4 Y.,'
- 1 8M e
e L.c ). S $ tA 4 N'e g3 c W - L A SC.a - W cL t 1 r oe et s v a L, w b o.%. ', o.* # 3 ctw1 h r e h.. ' - 5 \\ i r. 7. vy.. can LM.vam aJ. O u..kh. w ~ oci,u ls. i n.s t L \\. mm e-4.-snsh.cLLs wr-4 5. V_2. w l.a: a \\ O 'rj \\ k ,., d.0 )A4dY 'i $d h j.1 C,\\ b d '. = M \\ r> C c.e,c - C' > c. e u_^ t :v~. \\ 'l.v '*v O = bj g k to CA. Y cu i. b v-A. b i t o. u. %.h.t O.% '. C. C N aq>l,ves~:.z.s_%( I \\j \\ s e.'Tto d 5 E Q t.u E E.) c a e-{. x ja t i s c.za w n = tar ar ' M ;[.rk b 6 3 %% ' 7 #., - ' \\b \\d b kN Q re A ' kY Y m s n (,o n,5 kw,a > n ;er,.2:e u n km s vh vir,wk ( % C.2 'i '9 ~5-ti [ tV 50 1 3 ik 4c.op.1 o 4 $s v-5d wm w r ac.bm, Ad,w ( se bn 6. I. o. A b y, b.II C '-ad. I M \\ nSC.2.c_W ch o :-- 7his h &, vo R c.Os cLe,_ 6 ' ~ xc. e b m,,. ') \\ v,. ca \\w. _o. es 12 p-q. m a g m. o u m tw an n-d a cuc.c.x bh.u u a.N l s t r (*)J Y n v A. 6)v-cv4 n rzep O ',1 c4
- c,r-et.e c M M %..
s \\ Q s. - Af ~ :,% s a e.a. t-A 4 g, < --. rn m v.a ') CI" \\^L c.A. v% (. ~C f'W Q l d f.2 Mie um, \\
e 2 A L A. .a O I 4 \\k /4 C a 2 .q>\\ / \\ ,b'1 ~ ( )' b, i A A +N 4 Y Y (i s ,g C g,3;c h D' i ' I \\ 1 '( t D' og \\ 0,< P t \\ l n N .I J \\- ngs. 2 (N,' f % L_ w ~ ..\\. k 4 3 hf I n 4 Pb 9 3 N . 5,. A {- 1 o-I 6
_ =. R:visica: 0 Pagt 1 of 4 i ITDi NUMBER I.a.4 Agreement Between Drawings and Field Terminations 1. Description of Issue Identified by NRC Selected cable terminations were found that did not agree with their locations on drawings. Examples are as follows: Panel CP1-ECPRC3 , Cable E0139880* Panel CP1-ECPRTC-16, Cable E0110040 Panel CP1-ECPRTC-16, Cable E0118262 i Panel CP1-ECPRTC-27, Cabl.a EG104796 Panel CPX-ECPRCV-01, Cable EG021856 PanelCP1-ECPRC3-02[,CableNK139853(nonsafety) 4
- Panel CP1-ECPRC3-04 was incorrectly identified as CP1-ECPRC3-14 l
in the September 18, 1984 letter. The TRT verbally advised V TUEC of this information. 2. Action Identified by NRC Accordingly, TUEC shall reinspect all safety-related and termination cabinets in the cable spreading room to verify that associated terminations in the control room panels and in the their locations are accurately depicted on drawings. Should the results of this reinspection reveal an unacceptable level of i nonconformance to drawings, the scope of this reinspection effort i shall be expanded to include all safety-related and associated g terminations at CPSES. [ 3 3
===3. Background=== It is nderstanding that this issue involves cable l termi acio which are not in agreement with the draw.ings as to i the locatiod of the conductor on the terminal blocks. l k i At CPS, the specif cables identified a have been i re,tnagected and the "as built" configurations revfewed by Engineering. The engJ.n uo q eview has constoere design changes-d temporaiy modificacions. authorized prio e TRT ication'. ( j f The results of this av are as follows: The TRT review and subsequent vri of the issue ..,[ .did not include a listing of all'(he documents'used to ' ([F formulate the conclus d oW-Minary review, af teryidering d sign change and drawing % it-appears j ,.j- [, g' that three f the cables are e nect actly. M v 1* 4 r
Rsvisien: 0 ?sge.2 of 4 IT* 1 EC3 !.a.4 ' :::'d) ' e :91e, a two conductor cable,'vas found to have wires ints than;ed on the terminal points indicated on the drawing. 'ha Jai; : nnection has no polarig7mir,ement th"= intar:nsnte of vires has no arfect on the operability)of the I rcuit. N One cable was found to be a designated " spare" per a properly . @(, - issued design change document (DCA 19948 Rev. 1).
- However, N'b.' '
one end of _ the,j;.able islerminated which indicates that the ( review and drawing update cycle is incomplet ?. #.d One cable was found to be properly connected in accordance ~ A - with the document revision in effect at the e4"a -\\Y \\, a, termination was made. However, a s_uMraving change \\ changed th'e color code of the conductor for no apparent [gt * \\, a " b' reason. k.__ _f --~ ---~ ~ ~', '. In the course of aormal practices, af ter construction has been n completed and the equipment is in the startup cycle, a viring check is done per Prerequisite Test Instruction (ICP-EE-8). Any design changes required per the Startup Procedure for Temporary p System Modification,(CP-SAP-13) are controlled and requested in accordance with the Startup Procedure for Design Requests (CP-SAP-14). l ?,1 g, e,,.,% -1 k TUEC has concluded that the issues identified by the TRT have no I .I I f Vj*. adverse safety significance. 4. TUEC Action Plan nized that the TRT condu nation on a sampling ba'ses. Accordingly.TUECkillconduct e-inspections of s a statisti lly representative samp1 M ter= tions in the ,,, 3; -aare _ oom and_ cable spread room panels fThe results of the gy./, re-Inspect,1ons will be evaluated by TUEC engineering using specific ' acceptance / rejection criteria based on circuit oper'=h414ev and Jeliability requirements. j pec111cally, these, N j A 'l _. / actions will cons e following: .e y A. Inspect a andom sampi of terminatio in th control room and cable spread to using the lac design' documents. The initial sample includeN of 500 Class 1E terminations in the control room and c' spread room panels. The documentation of the termination inspection vill be made on the drawings by marking any d4=creenneies between ge_nhysical_logati_on_of the_ terminal and the location shown on the drawing. I t \\ ^
- % q,y t
o i-
Re.vicion: 0 Page 3 of 4 ITEM NilMBER I.a.4 (cont'd) ^ J Y w B. Review for accurate incorporation of design changes the class 1E drawings for the control room and cable spread roon for i the sample of cable terninations. -m y C. ._ Rec emne discrepancies petween the inspection ocuments and the drawings in item B'above., D. I chang are not raconcilable and thus -conforming, ake Q appMe changes using existing procedures. c-/f The above sample size was selected in accordance with MIL STD-105D e to achieve a 95% confidence level. If this confidence level is t' a not achieved the sample size will be expanded in accordance with M MIL STD-105D. [ q/ll/ ,L \\ Intheabovereview,jacceptableconditions.j'whichwoutanne 4- .,/ _ adversely affee.t_ t_he m_.uiilip; cf :t; circuit. shall be the e' i / i / I fallowing: .4 j Connection to a terminal point electrically common to that k v-A. ( j J/
- if i'd _ _
Interchangesofleadstcterminalsthatconnectcontkeks, a g[,/ J B. coils, and other devices that have no " polarity" 4 requirements. The interchange of these leads in no way 'b--affects._the operability of - C. Use of cable / conductors of'a size 1 ' than specifie Additionally,\\ unacceptable \\ conditions v ch could adverselv affect I I the proper operability or the circuit shall be the following: b, $ (, \\ [ C/' ' A. Connection to a terminal point not electrically conmen to ., c./? that specified. B. Interchange of leads that affects the operability of the /g circuit." '3 t C. Use of emble/ conductors of a size s han specified. l i i CorrectionofdrawingsfoundtobeinerrorduringtheanyIneering 7revsevvillbecon led in accordance with engineering pfocedure / CP-EP-4.6, " Field Design Change Control". -These corrections will be incorporated in the drawing update program utilizing drawing ~ update procedures TNE-DC-7, " Preparation and Review Design . Drawings", and INE-DC-8, " Design Verification of Field Design Changes". i i. [ s h 1 l l r
f Rcvisien: O Page 4 of 4 ITEM NUMBER I.a.4 (cont'd) Field inspections will be conducted under quality control inspection procedure QI-QP-11.3-28, " Class IE Terminations". Inspectors will be trained and certified in the use of QI-qP-11.3-28. The Issue Coordinator for this item is W. I. Vogelsang - CPSES Project Electrical Engineer. The QA/QC contact for this item is M. Warner - Quality Engineering Supervisor. 5. Schedule The quality control of the vendor samples and subsequant markings of the drawings will be completed by December 1,1984. The engineering review sill be complete by December 15, 1984. If the sampling / review process finds non-conformances in excess of the acceptance criteria, additional scheduling vill be deteloped. P
.1 p>*'*%< . ~.. UNITED STATES [ $ s,,7 '; NUCLEAR REGULATORY CCMMISSION ..w .I wAsamcron. o. c. 2osss t m 22 as MEMORANDUM FOR: Vincent 5. Noonan, Director Comanche Peak Technical Review' Team THRU: Jose A. Calvo, E&I Group Leader 'Jr f Comanche Peak Technical Review Team FRCM: Evangelos C. Marinos, E&I Group Ccaanche Peak Technical Review Team
SUBJECT:
PROJECTED STAFF RESOURCE NEEDS FOR MAJOR TASKS, CP ElI TRT In the coming weeks a more intense effort will be recuired to meet the presently scheduled and anticipated tasks in the Electrical and Instrumentation area. Therefore, in order to assure timely' responses to the project needs we have prepared for your review our resource needs, as indicated below: Task Descriotion Exoertise Staff Effort Prepare Affidavit Electrical /0A 2 weeks for Board's concerns regarding Start-up QA (see E. Marinos memo to you dated February 25, 1985) Action items from the Electrical I week J. Ellis Mtg. (11/7/84) AE-55, 56 FOIA reauest (1/11/85) Electrical /QA 2 weeks CASE's REQUESTS FOR Electrical /QA 2 weeks ADMISSION (NRC Letter 9/18/84) anticipated affidavit Close open items, NUREG-0797, Electrical /QA I week Supplement 7 (AQE-34, 35, 37) Witness F Affidavit Electical/QA 'I week ) (Evaluation allegation that DCA-19264 was issued to L go[3 authorize butt splices against procedure) MJ 3,. f y%lt. % \\ %,i %s %.J J N L t \\ ~
t' 22 194
- v. Noonan ~
TUEC's document control review planned for 2/25-28/85 Electrical /QA 1 week (Witness SRTA-3's Books) Review TUEC's Action Plan for addressing issues in 3 weeks NUREG-0797 Supplement 7 Response to anticipated inquires from CASE on Electrical /QA 2 weeks NUREG-0797 Supplement 7 /nticipated participation at Hearings & preparation Electrical /QA of affidavits 4 weeks Issue Supplement 8 to NUREG-0797 (Integrate Electrical /QA-Applicant's reinspection 5 weeks results, other staff evaluations ~ including those from Region IV) D C-Evangelos C. Marinos, E&I Group Comanche Peak Technical Review Team e 4 m
.h _L i 9' fg/c,r* Y- - _ f_'
- /
~ ./ LM ..t' 4-~. ' e./. f '/ c7 a r.d-- .q. _. f m L ~ f a~, t/' A 4 e w6; A n PL.& A. 4 by l ^ 62..:.J.1Lloo ( X&&Q.22.clze r.._. : ~ ~ I l l '2 &a J _. p #ap 4/a,_cr egr zxr--. l ^ C2.As14.~ a~, w a W L D L L. ~ EG ~ n/ / ~dt M.Auft/: % - u h 4. L J.a a / @A K t u. A -h Ja., p - ~ i L. <L.Zu.a -/ x-a. s a a a a' y..f.a kyp.@A m /M __n k E- _ pped. ~4-A Mp_m w_un_n-~.... Aj~ - hf A / l4,,,i' / /tka - g*'ha:O.by6 acu.3 A. 4 ~ L 6 rx - Dia W < uah J. FAda.M-G l?yt&~) M -57, 5 ?, N.TA jug,>} {,4 &s) JA}i fo/ .z. wee di 9 c %d I
aS w A eo* ic CA S f } A fd &/ FJ 7! OY.<-.cS,8# 1 w a lu / c r Asm:.uc /J,. A C. ff SV).
- ~ia.y & s.lld/dF l
&e. $b ...JNuallGA - /. 4se.cd 5y,4A. b a'lff-7 _ fad 6-%35,37). p a r' m s ' cyld L P' sAA.eJ as -t~e.ed 6s M aAL... %A OcA-ingi a t E M / h m L ay. L O y k. a- &#_.. - -.. -.-.-.-.... - - -. p L o ci d u t e-- ) 7 y f c I _ e lc ~ l l _~ ___lM&/dg. _l. ._ _ & &/z ~~ ~ '~ sk--L A, L, e &n,c c,/ -< b t z.s-rr /_N ~ cw.a..k f.sv.-lcu 7t/EC.7 A N e.e b s 3 /L ~ a.Jkva; n Ws A Alck Fci-0797 / Y/ n. 4-7 e . 'cy. ?. u 2k n/ cph e! D.&d GA 7_ c'e.a lu -fV~ %*i f ~ CAf5 pu re := 5 - c 797 sn byAJ 7
e W ^ ir fM b4 & m u/' w v. pywn - _. -. l .F' , e h,-, ,e g e 4 e. w e+ e64 een, e k AJox'rg-0797 T. G.A fwdJ
- 'D
- w'*.6 e
/ W e e gg g 94 4P
- W
- '*"E4 6
M'9'.+M6 .e W e ga g iM.4 6*.G le .N ye ee me e,. ap., e sun., m .g,, ,,g,,,, h8 M' 9 O6 w .h4 4 w$ e. gu. g e me p. m,, e e 9 4
4 e ,h,l 1 5. s.
- s un
,/,? 3 d,u, c m
- r. -. -
m e n e i n.> ma rs .J r/m-c-f ri is,.r /r :1, * ,;- v s2 Mwit ec.;;*.' N, e~ 7' =/ Cf s,s s 1 ?,* $ S P e'n,,f a asse a. 'r .G s. :*-es. 7/r er 'e.- / m.c 7/ w w t-W/:= ,~:2 /.9 as! e : '*/ f5 M uar N wie sv a.a (7, <.-n is >,r,ua c -- m, a c : wer e,;,.n n nen >. ar e : n.= u : mz, / t.//e W 0 pa:" [YS$ PC rd 7"O /Z c#2*e e v L*~ 7-try [ / 7., J'&^72.r / lu e :.r rJ -77 e l/e er'a e YO6^C' c-e a.eu e r i., r_-f-b5earrieo e e n -rp,u:e..? ,a . i. e rnx ,w cey?., ,A s [g "pi t ~jt,./ C <- ~2't l7 l" C C *./ d e-> ~t M * *J C-W tt L c-W W C l7/ C O2rt >Y) Mt 7 72,* p rf cu o t-f D ~~ Mf' +d l2.l s f,DPc, c Hr /fu O - O n M v' c 'a.) o e f gyas ee s t J
- u
/ slc,o y 1y7 rn2.c i4,,e 7~~~,,, (?ae thrit e D G,, ~, / />i~w c r ~ c-et ) n n , w,,- C /.firn'i m o ' t Bo a.x r, / w.s, Frac >-. e e re- /., Y:-.
- a..*<,
.fwc-C-r-?n o 77 f>rr-Du 2 /.<JC t*'e 23 L.*, 22, "/ g ~ ((4 e re r- % r, f. j ~ .: : -m c=6e /3 y pe.s e. m n f: ~R ~~, d/llG C j ~ /h-e-v e - e. ~ >, e u lc >> ~nr c-u , a,, , ik - p e +.v r, . n. :s-i i l
4 6 P% 4 W 0 p 4 /. c 0 s', , ' ' " / sie^/ /*oa -*. e .o* -?.,
- (r j}. -
/*;'/?*f o*.*s r s n. n,,,.*..- w o Pr 4> 7, pf g..,. ~ sd W o p,s-- f. 9 a - ~ r / '~ ~ g / / 3: -- 2 +, 2 ~ y/ * % yK u 6 E* m e s .g f' ' s _ ~, - / 10-l{ I O 1 J 1 - -,.,}}