ML20137M187
| ML20137M187 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/31/1984 |
| From: | NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | |
| Shared Package | |
| ML20136F476 | List: |
| References | |
| FOIA-85-59 ZAR-841231, NUDOCS 8512030631 | |
| Download: ML20137M187 (14) | |
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- S NUCLEAR REGULATORY COMMISSION (NRC)
ELECTRICA'. AND INSTRUMENTATION (E&I)
TECHNICAL REVIEW TEAM (TRT)
SUPEARY REVIEW OF ALLEGATIONS FOR COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
UNITS 1 AND 2 TEXAS UTILITY ELECTRIC COMPANY (TUEC)
AUGUST 31, 1984 i
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1.0 ELECTRICAL AND INSTRUMENTATION (E&I) TECHNICAL REVIEW TEAM (TRT)
SUMMARY
1.1 Scope and' Characterization of Allegations The allegations in the E&I discipline' concerned most aspects of construction activity including equipment installation, specifications drawings, procedures, personnel training and qualification records, and inspection.
The E&I TRT reviewed 51 allegations; 19 hardware and 32 quality assurance /qualitycontrol(QA/QC$related. Also, the TRT reviewed one concern identified by the special review team (SRT) regarding the overloading of cable trays due to the installation of "thermolag" material.
Most of the hardware and QA/QC-related allegations were general and were characterized as indicated below.
Hardware-Related Allegations. These allegations concerned with:
Loose and improper-sized lugs;
-fheexistenceofcablebuttspliesinpanelswithout authorization, without documentation, or in violation of procedures;
-[ableterminationsnotconformingwithdrawings;
- [roblems with the cable tray seismic supports design change.s.
spacing, and connections to cable trays;
- [he addition of higher sides to cable trays;
- [he clearance of process pipes from cables in cable trays;
-[ooseconduitfittings; 5 :... -. -..... -
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,C'able tray overfill;
- [ ables spliced in trays;
- /mproper.'c'able dressing;
- /he violation of the cable separation criteria between separate cables, trays, and conduits;
-[heinconsistencybetweentheelectricalerectionspecification and regulatory requirements; and
-[henonseismicsupportinstallationoffieldrunconduit, drywall and lighting located above the suspended ceiling in the control room.
QA/0C-Related Allegations. These allegations concerned with:
The va.lidity of the generation and disposition of electrical NCRs;
-[lectricalQCinspectorsthatwereinadequatelyqualified,that received help to pass certification tests, and experience requirements were " pencil whipped";
[evisionstotheprocedureforpost-constructioninspectionof electrical equipment and raceways made to accomodate numerous problems with loose lighting terminations and to omit requirements;
[he inconsistency of ihrocess inspection procedures with the requirements for installing wire butt splices and equipment separation;
[njustified reduction of inspections in the procedure for reverification of seismic electrical equipment mountings;
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rocesselectricalinspectionsper/procedurewerenotbeing conducted;
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- /nspection. reports were being written without reinspections; and
-[ackoftrainingpersonnelinstallingcabletraysupports.
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1.2 Electrical and Instrumentation TRT Action Plan In order to minimize duplication of effort and to establish an l
l inspection plan that can be easily managed and be flexible enough l
that can readily acconnodate future concerns, the allegations were I
consolidated by subject into nine separate categories. Whenever an allegation raised issues common to various subject categories, it was assigned to all the applicable categories. During the assignment of QA/QC-related allegations to subject categories, a practice was established, whenever sDecific *nuinment location information g
l was available, to also allocate the same allegations in the_
l hardware-related categories so a direct inspection of the equipment installation involved will be performed. The nine allegation I
categories are as follows:
I Electrical cable terminations; f
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- [ectrical cable tray and conduit installation;
- flectrical equipment separation; l
-[ontrol room ceiling fixture supports;
- jllectrical nonconformance report (NCR) activities;
-[lectricalQCinspectortrainingandqualifications; i
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- /lectrical cable installation;
-[lectricalprocidures;and t
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-[lectricalinspectionreportiinspectionremovalnotices,and iprocessinspections.
The last category comprising of two allegations was deemed more appropriate to QA/QC TRT and thus, the E&I TRT findings were transferred to them and used as an input to the overall programatic oa review of this subject.
i Work packages were prepared containing the source & documents, and approaches to resolution for each of the nine allegation categories.
In order to establish a base that bounded the general concerns raised by the allegations and to assess whether these concerns had or similar future ones will have generic implications, random samples of installed electrical equipment were taken and the inspection _
efforts were concentrated in those areas of the olant having the greatest concentration of safety-related electrical equipment _;
namely, the control room, cable spreading room and certain areas of the safeguards buildings. Biased samoles were also taken based on specific information obtained from the allegers and from trends found during the TRT review.
The Comanche Peak Steam Electric Station (CPSES), Unit 1 was primarily used as the source for the various documents and construction records required for the review of the concerns and for the inspection of the installation of the equipment involved. In some cases, the CPSES, Unit 2 was utilized as the source of documentation and the base for the inspection of the installation, when some of the installation 1
details could not be examined in CPSES, Unit 1 because the installation was completeg1 % the '51 ct ;c: c' - nlatina
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5 Daily meetings were held at the team level to assess progress, adjust inspection strategies, and provide a forum for the members of the team to' interact with each other as a group aus discussing problems and arriving jointly at their resolution.
Similar daily meetings were held at the project level where team leaders inter-acted with each other and with the project director and its staff.
In evaluating the allegations, the E&I TRT utilized various project documents, including specifications, engineering dtawings and analysf;,
Re a s o a 954 IV procedures, instructions, 9tf inspection reports, and applicable sections of the the Final Safety Analysis Report and regulations 1
pertinent to the allegation or sample selected for inspection.
The E&I TRT also reviewed construction records such as design change authorizations, construction work packages QC inspection reports, nonconformance reports, deficiency logs, lists and reports, and QC inspector training and certification records. In addition, QA/QC, engineering, purchasing, craft, and craft supervision and training Pes. a v e c were interviewed.
Direct inspections of the installation of the equipment involved in the allegations was also performed.
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the E&I TRT communicated with selected allegers to clarify allegations to determine whether they have new allegations and to discuss TRT findings.
The QA/QC-related allegation categories were limited in scope to m e s e., e u u r the electrical and instrumentation - e and the results of the subject category evaluations were utilized as inputs to the overall programatic review on these subjects performed by the QA/QC TRT.
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Therefore, the final resolution of.these QA/QC electrica related allegation categories was governed by the results of the overall I
lg programatic review of these subjects. Any adjustments to the con-clusions in the original evaluations resulting from the programatic
- I reviews were reported in supplemental evaluations, if required.
t 1.3 Electrical and Instrumentation TRT The electrical and instrumentation TRT was made of seven members 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 activities. The team members included two representatives from the Office of Nuclear Reactor Regulation, one from Region IV office, three from a national laboratory, and two from consulting firms.
1.4 Evaluation Results for Electrical and Instrumentation Cona. erns Details of evaluation results in the electrical and instrumentation discipline are contained in nine supplemental Safety Evaluation Reports (SSERs) one for each subject allegation category. The E&I findings concerning the SSER for Electrical Inspection Reports, InspectionRemovalNotices,andIhrocessInspectionsweretran'sferred to the QA/QC TRT for consideration in the overall programatic review on this subject.
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Each SSER lists and characterizes all the concerns raised by the allegations and.'the special review team.
An assessment of the safety significance of the concerns as well as the generic implications of the findings; and the root cause of each situation, as appropriate, were also presented in the SSER. In addition, each SSER included sections on conclusions and staff positions; actions required from the Texas Utility Electric Comany (TUEC); potential violations; and reference documents. In some cases, the TRT evaluated an allegation, found it to be of no safety significance, 4
but discovered a new concern unrelated to the original allegation.
These new concerns were also assessed and reported in the appropriate subject category, i
Electrical Cable Tray and Conduit Installation hnd Cable Installation.
These two allegation subject categories concerned mainly with problems regarding cable tray seismic supports; clearance of process pipes from cables in cable trays; loose conduit fittings; cable tray overfill; and cables spliced in trays. After reviewing documentation and inspecting random samples and specific items of alleged questionable installation of equipment, the TRT found no problems with the concerns raised by these allegations or the special review team. The TRT concludes that these concerns have neither safety significance nor generic implications.
Electrical Nonconformance Report (NCR) Activitid nd Electrical C)
Procedures. The allegations contained in these two categories 3,_ _
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concerned primarily with the improper generation and disposition of electrical NCRs a'nd the omission and changing of requirements from
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electrical 1nspection procedures without proper justification.
Based on the examination of specific and random samples of NCRs and information obtained from the interviews with QA/QC and engineering personnel; and the review of procedures and information obtained from meetings with selected allegers, the TRT found no evidence of discrepancies in these two QA[QC-related categories.
The TRT concludes that these QA/QC electrical-related allegations have neither safety significance nor generic implications. However, the results of these two evaluations were further assessed by the QA/QC TRT as e.I part of its overall programatic review as these subjects. Any adjustments to the conclusions in the original evaluations resulting from the programatic review were reported in supplemental. evaluations, if required.
The evaluations for the following allegation categories identified problem areas with potential generic implications and equired actions applicable to both units of CPSES. TUEC shall accomplish all these acti'ons prior to fuel load of each unit.
i Electrical Cable Terminations. Most of the allegations in this hardware-related category concerned with loose and improper-sized lugs; the improper use of cable butt splices in panels; and cable terminations not conforming with drawings. The TRT inspected selected samples of safety-related terminations, butt splices inside sur n-
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9 panels and vendor-installed terminal lugs in General Electric (GE) motor control centers, reviewed pertinent documentation, and interviewed selected allegers. The TRT found that various aspects of cable terminations did not meet established insta11ation' requirements. The TRT concludes that significant safety concerns exist and as a result, TUEC shall accomplish the following actions:
Reevaluate and redisposition all NCRs related to vendor-installed terminal lugs in GE motor control centers.
i Develop adequate installation / inspection procedures to assure the operability of those circuits containing butt splices, that the wiring splicing materials are qualified for the service conditions, and that splices are not located a@ent to each other.
Reinspect all safety-related and associated terminations in the contrel room panels and inthe termination cabinets in the cable spreading room to verify that they are in accordance with drawings.
Should the results of this reinspection reveal an unacceptable Nelofnonconformancetodrawings,thescopeofthisreinspection effort shall be expanded to include all safety-related and associated terminations at CPSES, Units 1 and 2.
Physically identify all butt splices in panels; clarify procedural requirementswithrespecttotheareasinwhichn(uclearheat-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 documented; and verify that all butt splices are properly identified on the appropriate drawings.
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Electrical Equipment Separation. The allegations concerned with the violation of,the cable separation criteria between separate cables, trays, and conduits in the control room and cable spreading room; and the inconsistency between the electrical erectio'n specifications and regulatory requirements. After reviewing documentation and information obtained from interviews with selected allegers and inspecting random samples and specific items of alleged stes il questionatle separation between safety-related caibes, trays, and conduits and between them and nonsafety-related cabl's, trays, and e
conduits, the TRT concludes that the installations examined meet astablished separation requirements except for those issues that shall require the following actions by TUEC to resolve them:
Reinspect all panels at CPSES, Units 1 and 2, in addition to those in the main control that contain redundant safety-related conduits, or safety and ncnsafety-related conduits and either correct i
each violation of the separation criteria, or demonstrate by the As analysis the acceptability of the conduit ad a barrier for each case Nretheminimumseparationisnotmet.
Reinspect all panels at CPSES, Units 1 and 2, in addition to these in the main control room and either correct each violation of the separation criteria concerning separate cables and flexible conduits, or demonstrate by analysis the adequacy of the flexible conduit as a 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 trays.
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- Correct two minor violations of the separation criteria inside Awo panelsCP1-EC-PRCB-09)CP1-EC-PRCP-03concerningabarrier found removed and redundant field wiring not meeting minimum separation.
Control Room Ceiling Fixture Supports. There was only one allegation assigned to this category concerned with the field run conduit, drywall and lighting located above the suspended ceiling in the main control room whichwereclassifiedasnoheismicandassuchwereonlysupportedby wires. This allegation was assessed jointly by the E&I and Civil and Mechanical TRTs. Each TRT documented the results of its evaluation in its own SSER. The E&I TRT reviewed the electrical aspects of this allegation which included documentation and inspection of the area above the suspended ceiling in the main control room. The E&I TRT 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 d
found that substantiater the adequacy of the supports.
The E&I TRT also inspected selected seismic Category I areas of the plant and concludes that the installation of nonsafety-related conduits less than or equal to two inches in diameter was inconsistent with seismic requirements and no evidence could be found that substantiatei the adequacy of the installation.
As avesult of these findings TUEC shall provide analyses that substantiate (1) the adequacy of the overall seismic support system installation for all the items located above the ceiling in the main control room, and 4
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(2) the adequacy of the seismic support system installation for non-safety-re. lated conduit in other seismic Category I areas of the plant besides the control room.
i Electrical QC Inspector Training / Qualifications. The allegations contained in this category concerned with some electrical QC inspectors that were inadequately qualified, that received help to pass certification tests, and experience requirements were " pencil whipped." In assessing these allegations, the TRT examined electrical QC inspector training and certification files, and requirements for testing program, on-the-job training and recertification program. The TRT also conducted interviews with QA/QC personnel. The TRT concludes that there is evidence to indicate that the electrical QC inspector qualification prograta lacks progransnatic controls which may be indicative that the required level of qualification was a> et obtained for some electrical QC inspectors. Since the training and cer-A u-tification program is the same for the disciplines (except ASME), the TRT concludes that the deficiencies identified with the electrical QC inspections have generic implications to other construction disciplines. The implications of the E&I TRT findings was further assessed as part of the overall progransnatic review of QC inspector training and qualification and the results of this review was reported in the SSER for QA/QC category on
" Training and Qualification."
In order to resolve this issue, the TUEC shall accomplish the following actions:
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' s. Develop a testing program for electrical QC inspectors which optimizes administrative guidelines, procedural requirements and test flexibility to assure tha,iuitable proficiency is achieved and maintained.
, Review all the' electrical QC inspector training, qualifications and certifications files against the project requirements and provide the information in such a form that each requirement is clearly shown to have been met by each inspector. If an inspector is found to notmeetthequalificationrequirementpVECshallthenreviewthe records to determine the inspections made by the unqualified individuals and provid' a statement on the impact of the deficiencies noted on the e
safety of the project.
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i These actions should be coordinated as appropriate with other actions on the same subject addressed in the SSER for QA/QC category on " Training and Qualification."
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The E&I TRT concludes that electrical and instrumentation construction ac ivities at the site were conducted in a controlled manner except fo the aforementioned action items which the TRT believes that they ca be satisfactorily resolved.
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