ML20199H731

Forwards Procedures for Closing Allegations W/Allegers. Viewgraphs from NRC 841019 Meeting W/Util Also Encl

ML20199H731
Person / Time
Site:	05000000, Comanche Peak
Issue date:	10/16/1984
From:	Shao L NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:	Wessman R NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML17198A302	List: ML20197H985 ML20197J181 ML20197J210 ML20197J980 ML20199G851 ML20199G855 ML20199G862 ML20199G869 ML20199G882 ML20199G891 ML20199G896 ML20199G905 ML20199G916 ML20199G923 ML20199G929 ML20199G935 ML20199G941 ML20199G947 ML20199G958 ML20199G965 ML20199G972 ML20199G975 ML20199G982 ML20199G990 ML20199H008 ML20199H014 ML20199H022 ML20199H029 ML20199H036 ML20199H051 ML20199H056 ML20199H061 ML20199H067 ML20199H072 ML20199H083 ML20199H091 ML20199H098 ML20199H118 ML20199H122 ML20199H124 ML20199H129 ML20199H135 ML20199H144 ML20199H150 ML20199H155 ML20199H158 ML20199H162 ML20199H209 ML20199H215 ML20199H225 ... further results
References
FOIA-85-299, FOIA-85-59, FOIA-86-A-18 NUDOCS 8607070006
Download: ML20199H731 (68)

Text

ks DCT 1619M MEMORANDUM FOR:

R. Wessman, Member, Comanche Peak Task Force FROM:

L. C. Shao, Deputy Director, Division of Engineering Technology, RES

SUBJECT:

PROCEDURES FOR CLOSING COMANCHE PEAK ALLEGATIONS WITH ALLEGERS Since there are more than 50 allegers in this project, we should have a systematic and effective procedure to close out allegations with the allegers.

For instance, certain allegers' allegations could be closed out through phone conversations while allegations of more important allegers should be closed out with actual interview.

I have developed the enclosed procedures and would like to use them for closing out the allegations that we are working on.

Let me know if you have any comments.

Original Signed by L C. Shat L. C. Shao, Deputy Director Division of Engineering Technology Office of Nuclear Regulatory Research

Enclosure:

As stated cc:

D. Eisenhut T. Ippolito J. Gagliardo R. C. Tang A. Viette S. Hoa D. Jeng C. Hofmeyer R. Hubbard DISTRIBUTION R. Minogue D. Ross G. Arlotto L. Shao DET READ DET SUBJ 0 eh DD/DEVRE5

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10/14/84 Procedure for Closir.g Allegations With Allegers 1.

TRT reviewers prepare sunmary form listing all allegations (see Attachment 1).

2.

Project coordinator groups all allegations for each alleger (see ).

3.

Project coordinator and TRT reviewers decide whether contact with alleger is to be by meeting or telephore conference call.

4.

Project coordinator makes contact with alleger to inform him of our intent to review the information relating to his allegation (s) and establishes date for a meeting or telephone conference call.

l 5.

Project coordinator arranges details of meeting or call with alleger and TRT reviewers.

6.

TRT reviewer or other project representatives discuss with the alleger the NRC's understanding of his allegation (s), the approach to resolution and the conclusions reached. The alleger will then be asked to respond to our findings and either indicate his agreement or identify any concerns he may have with the findings. All telephone calls and meetings will be recorded and transcribed.

7.

TRT reviewer assesses alleger's response and recontends whether additional followup is required or allegation should be closed out.

ENCLOSURE 1 l

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D TUEC MEETING WITH NRC STAFF OCTOBER 19, 1984 AGENDA INTRODUCTORY REMARKS M. D. SPENCE CPRT PROGRAM OVERVIEW J. T. MERRITT ISSUE-SPECIFIC ACTION PLAN L. M. POPPLEWELL PRESENTATIONS '

C. R. Il00 TON M. R. MCEAY I

A. VEGA R. E. CAMP i

SUMMARY

J. T. MERRITT CLOSING REMARKS M. D. SPENCE j

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CPRT ORGANIZATION i

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OF PROGRAF 1 PROCESS TYPES OF ACTIVITIES PHASED REVIEWS i

SAMPLING TECHNIQUES 1

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COMANCHE PEAK RESPONSE TEAM

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PROGRAM M ANAGER CPRT AT. MERRIT T. Jr.

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CIVIL ISTRUCI PROTECTIVE COATING MECHANICAL QA#GC TESTING PROGRAMS lesSTfL LEADER LEADER LEADER LEADER LEADER LEADER R.E. CAMP R.lL TOLSON C.KMOENLMAN A.VESA C.R. HOOTON LM POPPLEWELL l

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SUMMARY

OF PROGRAM PROCESS 1.

RECE!PT OF NRC-TRT REQUEST FOR ADDITIONAL INFORMATION.

2.

PRELIMINARY REVIEW OF ISSUE BY CPRT PROGRAM MANAGER, SENIOR REVIEW IEAM AND APPROPRIATE REVIEW IEAM LEADER.

l 3.

ASSIGNMENT OF ISSUE COORDINATOR.

4.

OBTAIN ADDITIONAL, CLARIFYING INFORMATION FROM NRC-TRT TO ENSURE FULL UNDERSTANDING OF THE CONCERN (IF NECESSARY).

5.

DEVELOP ACTION PLAN TO RESOLVE CONCERN USING GUIDANCE EROVIDED IN ATTACHMENT 2.

6.

ACTION PLAN APPROVED BY APPROPRIATE REVIEW IEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW IEAM.

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IMPLEMENT ACTION PLAN.

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IDENTIFY ROOT CAUSE AND POTENTIAL GENERIC t

IMPLICATIONS.

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CONCURRENCE OF APPROPRIATE REVIEW IEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW IEAM IN ROOT CAUSE DEFINITION AND POTENTIAL GENERIC IMPLICATIONS ASSESSMENT.

10.

DEVELOP REVISED ACTION PLAN (IF APPLICABLE).

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11.

REVISED ACTION PLAN APPROVED BY APPROPRIATE REVIEW TEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW TEAM (IF APPLICABLE).

12.

IMPLEMENT REVISED ACTION PLAN (IF APPLICABLE).

13.

DEVELOP ACTION PLAN RESULTS REPORT USING GUIDANCE PROVIDED IN ATTACHMENT 3.

14.

ACTION PLAN RESULTS REPORT APPROVED BY APPROPRIATE REVIEW IEAM LEADER, PROGRAM MANAGER AND SENIOR REVIEW IEAM.

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IMPLEMENT NECESSARY ADDITIONAL CORRECTIVE ACTION i

(IF APPLICABLE).

16.

IMPLEMENT NECESSARY CORRECTIVE ACTION TO PREVENT REOCCURRENCE IN THE FUTURE (IF APPLICABLE).

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17.

ASSESS ACTION PLAN RESULTS REPORT AS PART OF l

COLLECTIVE SIGNIFICANT EVALUATION.

18.

IMPLEMENT NECESSARY ACTIVITIES STEMMING FROM THE COLLECTIVE SIGNIFICANCE EVALUATION.

19.

SusMIT FINAL REPORT TO NRC.

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INTRODUCTION OF SPEAKERS,

ELECTRICAL / INSTRUMENTATION LEADER L. M. POPPLEWELL QA/QC LEADER A. VEGA ISSUE I.D 1, l.D.2 COORDINATOR CIVIL / STRUCTURAL LEADER C. R. HOOTON ISSUE Ic, IID C0ORDINATOR M. R. MCBAY TESTING PROGRAMS LEADER R. E. CAMP l

ITEM I.A.1 HEAT SHRINKABLE CABLE INSilLATION

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DESCRIPTION OF NRC ISSUE CONFUSION AS TO WHEN THE WITNESSING OF INSTALLATION OF HEAT SHRINKABLE SLEEVES WAS TO BE DOCUMENTED ACTION SPECIFIED BY NRC CLARIFICATION OF PROCEDURAL REQUIREMENTS ADDITIONAL INSPECTOR TRAli;ING ASSURANCE THAT SLEEVES ARE INSTALLED WHERE REQUIRED a

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ITEM I.A.1 BACKGROUND IRS DO NOT CONSISTENTLY INDICATE WITNESSING OF INSTALLATION AS AN ATTRIBUTE POSSIBLE UNCERTAINTY EXISTS AS TO WHEN DOCUMENTATION IS REQUIRED NO INSTANCES OBSERVED WHERE SLEEVES WERE REQUIRED AND WERE NOT ADDRESSED BY INSPECTION REPORTS TUEC ACTION REVISE INSTALLATION PROCEDURE REVISE INSPECTION PROCEDURE TRAIN AND CERTIFY INSPECTORS INITIATE INSPECTION SAMPLING PROGRAM TO ASSURE SLEEVES ARE PROPERLY INSTALLED i

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i ITEM I.A.2 INSPECTION REPORTS ON BUTT SPLICES DESCRIPTION OF NRC ISSUE LACK OF DOCUMENTATION OF BUTT SPLICE INSPECTIONS SEVERAL SPECIFIC EXAMPLES CITED ACTION SPECIFIED BY NRC ASSURE THAT REQUIRED INSPECTIONS HAVE BEEN PERFORMED-AND DOCUMENTED VERIFY THAT BUTT SPLICES ARE IDENTIFIED ON DRAWINGS VERIFY THAT BUTT SPLICES ARE IDENTIFIED WITHIN THE APPROPRIATE PANELS

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ITEf1 I.A.2 BACKGROUND ADDITIONAL INSPECTION REPORTS REVIEWED REQUIRED INSPECTIONS WERE DOCUMENTED TUEC ACTION PHASE I REVIEW ALL INSPECTION REPORTS FOR THE 12 CABLES REVIEWED BY TRT REVIEW 12 ADDIT 10NAL CABLES IF DOCUMENTATION EXISTS, CLOSE REPORT l

ITEM I.A,2 TUEC ACTION (CONTINUED)

PHASE II - FURTHER REVIEW IF PHASE I DOES NOT CLOSE ISSUE REVIEW DRAWINGS AND DESIGN CHANGES SHOWING SPLICES INSPECT TO ASSURE THAT ALL BUTT SPLICES ARE PROPERLY INSTALLED IN APPROPRIATE PANELS

ITEM I.A.3 BUTT SPLICE QUALIFICATION DESCRIPTION OF NRC ISSUE LACK OF SPLICE QUALIFICATION REQUIREMENTS VERIFICATION OF OPERABILITY OF CIRCUITS IN WHICH SPLICES OCCUR ACTION SPECIFIED BY NRC DEVELOP PROCEDURES TO ASSURE QUALIFICATION TO SERVICE CONDITIO ASSURE THAT SPLICES ARE NOT LOCATED ADJACENT TO EACH OTHER

ITEM I.A.3 BACKGROUND INSTALLATION PROCEDURES DO NOT ADDRESS OPERABILITY OF CIRCUITS SPLICES

- START-UP AND TEST PROGRAM ADDRESSES CIRCUIT OPERABILITY INSTALLATION PROCEDURES DO NOT ADDRESS OUALIFICATION OF SPLICES SERVICE CONDITIONS

- MILD ENVIRONMENT CONDITIONS

- SAME CONSTRUCTION AS TERMINAL LUGS

- LOW POWER APPLICATIONS AS PER FSAR NEW CRITERIA IN SER FOR FSAR AMENDMENT 44

- REQUIREMENT TO STAGGER SPLICES TUEC ACTION CONTINUITY CHECK TO BE ADDED TO CONSTRUCTION INSTALLATION PROCEDUR QUALIFICATION DOCUMENTATION WILL BE DEVELOPED INSPECTIONS WILL BE PERFORMED TO ASSURE SPLICES ARE APPROPRIATELY STAGGERED s

ITEM I.A.ll AGREEMENT BETWEEN DRAWINGS AND FIELD TERMINATIONS DESCRIPTION OF NRC ISSIJE PHYSICAL LOCATION OF SELECTED CABLE TERMINATIONS DID NOT AGREE WITH DRAWINGS ACTION SPECIFIED BY NRC INSPECT ALL SAFETY-RELATED TERMINATIONS IN CABLE SPREAD ROOM CABINETS IN CONTROL ROOM CABINETS VERIFY LOCATIONS ARE ACCURATELY DEPICTED ON THE DRAWINGS

ITEM I.A.4 BACKGROUND NRC SELECTED CABLES REVIEWED DESIGN CHANGES REVIEWED TEMPORARY MODIFICATIONS REVIEWED FINDING ISSUES HAVE NO ADVERSE SAFETY SIGNIFICANCE 4

TUEC ACTION CONDUCT SAMPLE INSPECTION OF 500 SAFETY-RELATED TERMINATIONS i

REVIEW DRAWINGS FOR ACCURATE INCORPORATION OF DESIGN CHANGES RECONCILE DIFFERENCES, IF ANY, BETWEEN INSPECTION AND DRAWING REVIEW l

EXPAND SAMPLE AS NECESSARY IF ACCEPTANCE CRITERIA IS NOT ACHIEVED 8

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i ITEM I.A.5 NCR'S ON VENDOR-INSTALLED AMP TERMINAL LUGS DESCRIPTION OF NRC ISSUE NONCONFORMANCE REPORTS CONCERNING VENDOR LUGS IMPROPERLY CLOSED ACTION SPECIFIED BY NRC

'E REEVALUATE AND REDISPOSITION ALL NCR'S RELATED TO VENDOR LUGS 1

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ITEM I.A.5 BACKGROUND EQUIPMENT INVOLVED FROM 2 VENDORS GE ITT GOULD-BROWN BOVERI LUG VENDOR CONTACTED IN 1981 AND IN APRIL 198/1 LUG VENDOR GAVE SPECIFIC CRITERIA NONCONFORMANCES DISPOSITIONED USING VENDOR CRITERIA TUEC ACTION ALL DISPOSITIONED NONCONFORMANCES REGARDING BENT LUGS WILL BE REEVALUATED

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b ITEM I.B.1 FLEXIBLE TO FLEXIBLE CONDUIT SEPARATION DESCRIPTION OF NRC ISSUE MINIMUM SEPARATION REQUIREMENTS NOT MET MAIN CONTROL BOARDS SAFETY-RELATED CABLES WITHIN FLEXIBLE CONDUITS ACTION SPECIFIED BY NRC REINSPECT ALL PANELS CONTAINING REDUNDANT SAFETY-RELATED CABLES AND CORRECT ANY VIOLATIONS OR PROVIDE ANALYSIS SHOWING THAT THE FLEXIBLE CONDUIT IS ACCEPTABLE AS A BARRIER

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ITEM I.B.1 l

BACKGROUND Sw!TCH MODULES ON THE MAIN CONTROL BOARD REQUIRE SLACK IN THE CABLES FOR*

i REMOVAL / REPLACEMENT i,

REMOVAL FOR TESTING l

REMOVAL FOR ADJUSTMENT FLEXIBLE METAL CONDUITS USED TO PROVIDE APPROPRIATE SEPARATION SUFFICIENT DOCUMENTATION DOES NOT EXIST QUALIFYING THE FLEXIBLE CONDUIT

.I AS A BARRIER l

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PROVIDE SUFFICIENT-DOCUMENTATION, INCLUDING ANALYSES, NECESSARY TO

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QUALIFY THE FLEXIBLE CONDUIT AS A BARRIER e

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ITEM I.B.2 FLEXIBLE CONDUIT TO CABLE SEPARATION i

DESCRIPTION OF NRC ISSUE l

MINIMUM SEPARATION CRITERIA NOT MET IN MAIN CONTROL PANEL BETWEEN:

SAFETY-RELATED CABLES AND SAFETV-RELATED CABLES WITHIN FLEXIBLE CONDUIT SAFETY-RELATED CABLES WITHIN FLEXIBLE CONDUITS AND NON-SAFETY-RELATED CABLES

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SAFETY-RELATED CABLES AND NON-SAFETY-RELATED CABLES i

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4 ITEM I.B.2 ACTION SPECIFIED BY NRC REINSPECT ALL PANELS CONTAINING SEPARATE CABLES AND CABLES WITHIN FLEXIBLE CONDUIT AND CORRECT ANY VIOLATIONS i

OR PROVIDE ANALYSIS DEMONSTRATING THE ADEQUACY OF THE FLEXIBLE CONDUIT AS A BARRIER j

ITEM I.B.2 BACKGROUND ISSUE CONCERNS CABLE IN FREE AIR TO FLEXIBLE CONDUIT SEPARATION TUEC ACTION PROVIDE ANALYSIS TO CONFIRM THAT INSTALLATION IS ADEQUATE AND ACCEPTABLE I

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ITEM I.B.3 CONDUIT TO CABLE TRAY SEPARATION i

DESCRIPTION OF CONCERN ANALYSIS SUBSTANTIATING SEPARATION BETWEEN CONDUIT AND CABLE TRAYS HAS NOT BEEN SUBMITTED To NRC ACTION SPECIFIED BY NRC SUBMIT ANALYSIS 1

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1 ITEM I.s.3 I

I BACKGROUND i

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ITERIA BASED ON IEEE 384-1974 AND REG. 6UIDE 1.75 gRA"!

DOCUMENTS EXIST WITHIN G!ssS & HILL SUBSTANTIATING THE SEPARATION l

l CRITERIA CRITERIA WERE NOT SUBMITTED FOR NRC REVIEW TUEC ACTION t

SUaMIT GinsS & HILL DOCUMENTS l

SUBMIT SANDIA REPORT O

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i ITEM I.B.4 i

BARRIER REMOVAL i

1 DESCRIPTION OF NRC ISSUE CERTAIN BARRIER MATERIAL IN MAIN CONTROL BOARD HAD BEEN REMOVED ACTION SPECIFIED BY NRC REPLACE THE BARRIER MATERIAL ASSURE THAT REDUNDANT FIELD WIRING MEETS MINIMUM SEPARATION CRITERIA

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I ITEM 1 B.4 i

BACKGROUND i

VENDOR-SUPPLIED BARRIER MATERIAL HAD BEEN REMOVED i

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REWORK CABLES TO RESOLVE SEPARATION CRITERI A DEVIATIONS I

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J ITEM I.C ELECTRICAL CONDUIT SUPPORTS DESCRIPTION OF NRC ISSUE NON-SAFETY-RELATED CONDUITS OF ALL SIZES WERE OBSERVED IN SELECTED SEISMIC CATEGORY I AREAS WHICH DID NOT APPEAR TO BE SEISMICALLY i

SUPPORTED SUPPORT INSTALLATION FOR NON-SAFETY-RELATED CONDUITS LESS THAN OR EQUAL TO 2 INCHES IN DIAMETER APPEARED INCONSISTENT WITH SEISMIC l

REQUIREMENTS COMPLIANCE WITH REG. GUIDE 1,29 AND FSAR SECTION 3.78.2.8 IS REQUIRED WHICH DEFINES THAT NON-SEISMIC ITEMS SHOULD BE DESIGNED SUCH THAT THEIR FAILURE WILL NOT ADVERSELY AFFECT THE FUNCTION OF l

SAFETY-RELATED COMPONENTS i

ITEM I.C ACTION SPECIFIED BY NRC PROVIDE THE RESULTS OF SEISMIC ANALYSIS WHICH DEMONSTRATE THAT ALL NON-SAFETY-RELATED CONDUITS AND THEIR SUPPORT SYSTEMS, SATISFY THE PROVISIONS OF REG. GUIDE 1.29 AND FSAR SECTION 3.7.B.2.8.

VERIFY THAT NON-SAFETY-RELATED CONDUITS LESS THAN OR EQUAL TO 2 INCHES IN DIAMETER, NOTINSTALLED IN ACCORDANCE WITH THE REQUIRE-MENTS OF REG. GUIDE 1.29, SATISFY APPLICABLE DESIGN REQUIREMENTS.

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ITEM I.C BACKGROUND SEISMIC SUPPORT WAS PROVIDED FOR NON-SAFETY-RELATED CONDUIT GREATER THAN 2 INCHES IN DIAMETER FOR AREAS OF CATEGORY I STRUCTURES WHICH CONTAINED SAFETY-RELATED EQUIPMENT IN AREAS OF CATEGORY I STRUCTURES WHICH CONTAINED LIMITED QUANTITIES i

OF SAFETY-RELATED SYSTEMS, ALL NON-SAFETY-RELATED CONDUIT, GREATER THAN 2 INCHES IN DIAMETER, WAS NON-SEISMICALLY SUPPORTED AND WAS EVALUATED BY THE DAMAGE STUDY GROUP AND SEISMIC RESTRAINT PROVIDED IF IT WAS DETERMINED THAT THEIR FAILURE WOULD BE DETRIMENTAL TO SAFETY-RELATED SYSTEMS NON-SAFETY-RELATED CONDUIT 2 INCHES OR LESS IN DIAMETER WAS NOT INCLUDED IN OUR SEISMIC SUPPORT PROGRAM OR DAMAGE STUDY EVALUATION BECAUSE OF THE FOLLOWING:

SMALL MASS LIMITED SPANS BETWEEN SUPPORTS i

TYPICAL SUPPORT DESIGN INTERVENING MEMBERS INTERACTION CRITERIA

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ITEM I.C i

TUEC ACTION PLAN PROVIDE

SUMMARY

DOCUMENT WHICH DELINEATES THE PHILOSOPHY AND IMPLEMENTATION OF THE UAMAGE bTUDY EVALUATION OF NON-SAFETY-RELA I

CONDUIT fBQVIDESEIjMICANALYSISWHICHVERIFIESTHESTABILITYDURINGAN d5; OF THE z INCH AND UNDER DIAMETER CONDUIT WITH THE PRESENT SUPPORT SYSTEM FIELD VERIFICATION THROUGH A SAMPLING PROGRAM OF THE INSTALLED CONDUIT SYSTEM TO VERIFY AS-BUILT CONFORMANCE TO ANALYTICAL ASSUMPTIONS

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i ITEM I,D,1 I

QC INSPECTOR QUALIFICATIONS DESCRIPTION OF NRC ISSUE LACK OF SUPPORTIVE DOCUMENTATION REGARDING PERSONNEL QUALIFICATIONS IN THE TRAINING AND CERTIFICATION FILES FOR ELECTRICAL QC INSPECTORS LACK OF DOCUMENTATION FOR ASSURING THAT REQUIREMENTS FOR ELECT INSPECTOR RECERTIFICATION WERE BEING MET 5 SPECIFIC EXAMPLES CITED G

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ITEM I.D,1 i

j QC INSPECTOR QUALIFICATIONS f

ACTION SPECIFIED BY NRC TUEC SHALL REVIEW ALL ELECTRICAL QC INSPECTOR TRAINING, QUALIFICATIONS, CERTIFICATION AND RECERTIFICATION FILES AGAINST THE PROJECT REQUIREMENTS TUEC SHALL PROVIDE INFORMATION IN A FORM THAT CLEARLY SHOWS THAT THE REQUIREMENTS HAVE BEEN MET BY EACH ELECTRICAL QC INSPECTOR l

I IF AN INSPECTOR DOES NOT MEET REQUIREMENTS, TUEC SHALL REVIEW THE RECORDS TO DETERMINE ADEQUACY OF INSPECTIONS AND ASSESS IMPACT ON THE i

SAFETY OF THE PROJECT S

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s ITEM I.D.1 ADDITIONAL NRC COMMENTS t

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IDENTIFIED DEFICIENCIES HAVE GENERIC IMPLICATIONS TO OTHER CONSTRUCTION i

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ITEM I.D 1 BACKGROUND CPSES PROJECT REQUIREMENTS ORIGINALLY DERIVED FROM 10CFR50, APPENDIX B

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CPSES PROJECT REQUIREMENT REVISED IN 1981 TO REFLECT SUBSEQUENT COMMIT-MENT TO ANSI N45.2.6 AND REGULATORY GUIDE 1.58 CPSES ASME INSPECTORS CERTIFIED UNDER A SEPARATE PROGRAM INDEPENDENTLY REVIEWED BY ASME-AUTHORIZED NUCLEAR INSPECTOR (AND, CPSES QC INSPECTOR CERTIFICATION PROCESS REFLECTS A MORE CONSERVATIVE APPROACH THAN THE COMMON PRACTICE IN THE NUCLEAR INDUSTRY TUEC REVIEW OF SPECIFIC EXAMPLES CITED BY NRC-TRT INDICATES THAT SUBJECT INSPECTORS MET PROJECT REQUIREMENTS i

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i ITEM I.D,1 TUEC ACTION TUEC IS CONDUCTING AN EXPANDED REVIEW OF 9C INSPECTOR CERTIFICATION RECORDS AGAINST PROJECT REQUIREMENTS AND WILL ASSURE THAT TRAINING / CERTIFICATION FILES ARE COMPILED IN A FORMAT THAT CLEARLY AND CONCISELY DEMONSTRATES THAT PROJECT REQUIREMENTS ARE MET SCOPE OF REVIEW WILL INCLUDE ALL ELECTRICAL OC INSPECTORS WHO HAVE EVER WORKED AT CPSES AND ALL OTHER QC INSPECTORS (EXCEPT ASME INSPECTORS)

CURRENTLY WORKING AT CPSES e

ITEM 1.D 1 TUEC ACTION (CONTINUED)

PHASE ONE REVIEW OF ALL AVAILABLE DOCUMENTATION CHECKLIST WITH PREDETERMINED ATTRIBUTES i

CERTIFICATION

SUMMARY

FORM I

PERFORMED BY TUGC0 AUDIT GROUP (TAG)

PHASE TWO EVALUATE CERTIFIC*.110N RECORDS NOT VERIFIED IN PHASE ONE I

SPECIFIC EVALUATION CRITERIA BASES FOR DECISIONS DOCUMENTED PERFORMED BY SPECIAL EVALUATION TEAM PHASE THREE IF INSPECTORS ARE FOUND WHOSE QUALIFICATIONS CANNOT BE DEMONSTRATED, REVIEW OF INSPECTION RECORDS WILL BE PERFORMED TO DETERMINE IMPACT ON SAFETY OF THE PROJECT PERFORMED BY TUGC0 QUALITY ENGINEERING

ITEM I.D 2

. GUIDELINES FOR ADMINISTRATION OF QC INSPECTOR TESTS NRC DESCRIPTION OF ISSUE LACK OF GUIDELINES AND PROCEDURAL REQUIREMENTS FOR TESTING AND CERTIFYING ELECTRICAL QC INSPECTORS ACTION SPECIFIED BY NRC TUEC SHALL DEVELOP A TESTING PROGRAM FOR ELECTRICAL QC INSPECTORS WHICH PROVIDES ADEQUATE ADMINISTRATIVE GUIDELINES, PROCEDURAL REQUIREMENTS AND TEST FLEXIBILITY TO ASSURE THAT SUITABLE PROFICIENCY IS ACHIEVED AND MAINTAINED S

ITEM I.D,2 BACKGROUND CURRENT PROCEDURES ALLOW QE PERSONNEL TO DEVELOP TESTS APPROPRIATE TO THE SPECIFIC CIRCUMSTANCES ADDITIONAL GUIDELINES WOULD REDUCE POTENTIAL FOR INCONSISTENCIES TUEC ACTION RELEVANT PROCEDURES WILL BE REVIEWED AND APPROPRIATELY REVISED TO PROVIDE MORE DEFINITIVE GUIDELINES l

THESE PROCEDURES PERTAIN TO THE TRAINING AND CERTIFICATION OF ALL INSPECTORS CERTIFICATION TESTS CURRENTLY IN USE WILL BE REVIEWED AND APPROP REVISED TO REFLECT MORE DEFINITIVE GUIDELINES i

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ITEM NUMBER II.A REINFORCING STEEL IN REACTOR CAVITY DESCRIPTION OF ISSUE IDENTIFIED BY NRC 4

A PORTION OF THE REINFORCING STEEL WAS OMITTED IN A REACTOR CAVITY CONCRETE WALL PLACEMENT BETWEEN EL. 812'-0" AND EL. 819'-0 1/2" ACTION SPECIFIED BY NRC TUEC SHALL PROVIDE AN ANALYSIS VERIFYING THE ADEQUACY OF THE AS-BUILT CONDITION THE ANALYSIS SHALL CONSIDER ALL REQUIRED LOAD COMBINATIONS

ITEM NUMBER II.A BACKGROUND INVESTIGATED DOCUMENTED OCCURRENCE OF REINFORCING STEEL OMITTED FROM A UNIT #1 REACTOR CAVITY CONCRETE PLACEMENT.

REINFORCEMENT INSTALLED PER REVISION 2.

REVISION 3 ISSUED AFTER CONCRETE PLACEMENT ADDING REINFORCEMENT.

REINFORCEMENT ADDED AS A PRECAUTION AGAINST CRACKING OF CONCRETE WHICH MIGHT OCCUR IN THE VICINITY OF THE NEUTRON DETECTOR TUBES SHOULD A LOSS OF COOLANT ACCIDENT OCCUR.

BROWN & ROOT ISSUED NON CONFORMANCE REPORT CP-77-6.

GIsaS & HILL EVALUATION INDICATED OMISSION DID NOT IMPAIR INTEGRITY OF THE STRUCTURE.

REVISION 4 ISSUED TO PLACE A PORTION OF THE REINFORCEMENT IN THE NEXT CONCRETE PLACEMENT.

TRT REQUESTED DOCUMENTATION OF ANALYSIS PERFORMED SUPPORTING GIssS & HILL CONCLUSION.

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ITEM NUMBER II.A TUEC ACTION PLAN AN ANALYSIS OF "AS-BUILT" REACTOR WALL WILL BE PERFORMED.

AN ANALYSIS WILL BE PERFORMED TO DETERMINE WHETHER THE STRUCTURAL INTEGRITY OF WALL IS COMPROMISED.

GIBBS & HILL WILL PERFORM THE ANALYSIS AND DESIGN REVIEW THE CALCULATIONS.

AN EXTERNAL ORGANIZATION WILL PERFORM ADDITIONAL DESIGN REVIEW OF CALCULATIONS.

EXPANDED REVIEW OF ALL INSTANCES OF REBAR OMISSIONS WILL BE PERFORMED TO CONFIRM THAT IN EVERY SUCH CASE PROPER ENGINEERING EVALUATION AND DOCUMENTATION DOES EXIST.

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ITEM II.s 2

CONCRETE COMPRESSIVE STRENGTH NRC DESCRIPTION OF ISSUE ALLEGATION OF FALSIFICATION OF CONCRETE COMPRESSIVE STRENGTH TEST RESULTS COULD NOT BE PROVEN VALID OR INVALID i

CONCRETE STRENGTH LOWER THAN THAT SPECIFIED IN THE DESIGN MAY REDUCE THE LOAD RESISTING CAPACITY OF STRUCTURES ACTION SPECIFIED BY NRC TUEC SHOULD DETERMINE AREAS WHERE CONCRETE WAS PLACED BETWEEN JANUARY 1976 AND FEBRUARY 1977 AND PROVIDE A PROGRAM TO ASSURE ACCEPTABLE CONCRETE STRENGTH TEST PROGRAM TO INCLUDE RANDOM SCHMIDT HAMMER TEST ON CONCRETE

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IN AREAS WHERE SAFETY IS CRITICAL 1

ADDITIONAL SCHMIDT HAMMER TEST ON CONCRETE NOT WITHIN THIS SPECIFIED TIME FRAME i

COMPARISON OF THE TEST RESULTS TO DETERMINE IF ANY SIGNIFICANT VARIANCE IN STRENGTH OCCURS l

i

ITEM II.B BACKGROUND ALLEDGED FALSIFICATION OF COMPRESSIVE STRENGTH TEST NRC REGION IV INVESTIGATED OTHER ALLEGATIONS AIR CONTENT SLUMP DEFICIENT AGGREGATE GRADING CONCRETE IN THE MIXER TOO LONG PREPONDERANCE OF EVIDENCE SUGGESTS FALSIFICATION DID NOT OCCUR MATTER CANNOT BE RESOLVED BASED ON PRIOR COMPRESSIVE STRENGTH TESTS IF DOUBT EXISTS DUE TO FALSIFICATION N.EED CONFIRMATORY EVIDENCE ON TEST RESULTS

ITEM II.B TUEC ACTION PLAN i

SCHMIDT (REBOUND) HAMMER IEST, A NON-DESTRUCTIVE TEST, WILL BE PERFORMED AS REQUESTED BY TRT 327 PLACEMENTS IN CATEGORY I - SAFETY-RELATED STRUCTURES DURING TIME FRAME IN QUESTION 50 TESTS TO BE PERFORMED 50 TESTS OUTSIDE TIME FRAME IN QUESTION STATISTICAL ANALYSIS TO DETERMINE IF A SIGNIFICANT VARIANCE EXISTS BETWEEN THE.TWO DATA SETS

_.m-

ITEM II.C MAINTENANCE OF AIR GAP BETWEEN CONCRETE STRUCTURES NRC DESCRIPTION OF ISSUE ADEQUACY OF THE AIR GAP COULD NOT BE DETERMINED SINCE:

AVAILABLE DOCUMENTATION DID NOT PROV?DE LOCATION OR EXTENT OF REMIANING DEBRIS.

ADDITIONAL SITE FIELD INVESTIGATIONS WERE NOT DOCUMENTED ON PERMANENT RECORDS.

PERMANENT INSTALLATION OF ELASTIC JOINT FILLER HAD NOT BEEN SHOWN TO BE CONSISTENT WITH SEISMIC ANALYSIS ASSUMPTIONS AND DYNAMIC MODELS USED TO ANALYZE THE BUILDINGS.

ACTION SPECIFIED BY NRC PERFORM INSPECTION OF THE AS-BUILT CONDITION TO CONFIRM THAT ADEQUATE SEPARATION FOR ALL SEISMIC CATEGORY I STRUCTURES HAS BEEN PROVIDED.

PROVIDE RESULTS OF ANALYSES FOR ACCEPTANCE OF ELASTIC JOINT FILLER AND DEBRIS BETWEEN CONCRETE STRUCTURES CONSIDERING CHANGES IN SEISMIC RESPONSE OR DYNAMIC RESPONSE CHARACTERISTICS OF THE CATEGORY l STRUCTURES, COMPONENTS AND PIPING WHEN COMPARED WITH THE RESULTS OF THE ORIGINAL ANALYSES.

i

~

ITEM II.C BACKGROUND SEPARATION BETWEEN CATEGORY I STRUCTURES IS REQUIRED IN THE FSAR 4

TO PREVENT UNACCEPTABLE SEISMIC INTERACTION DURING AN SSE ELASTIC JOINT FILLER " ROT 0 FOAM" USED UNTIL OCTOBER 1977 AFTER REMOVAL - OTHER FORMING TECHNIQUES USED CONCRETE PRE-PLACEMENT INSPECTIONS DOCUMENTED AIR GAP WAS PER DESIGN REQUIREMENTS POST CONSTRUCTION INSPECTIONS DID NOT DOCUMENT CLEANLINESS OF THE AIR GAP t

ITEM II.C TUEC ACTION PLAN QC INSPECTION OF AIR GAP BETWEEN CATEGORY I STRUCTURES AND CATEGORY I AND NON-CATEGORY I STRUCTURES WILL BE REPERFORMED AND DOCUMENTED ANY DEBRIS ENCOUNTERED MAY BE REMOVED AFTER DOCUMENTATION BY OC ENGINEERING EVALUATION OF DOCUMENTED INSPECTIONS FOR IMPACT ON SEISMIC AND DYNAMIC RESPONSES IF APPROPRIATE, FURTHER ENGINEERING ACTIONS WILL BE DETERMINED FOR EVALUATION OF IMPACT ON COMPONENTS AND PIPING REMOVE ANY DEBRIS WHICH SIGNIFICANTLY AFFECTS THE ORIGINAL DESIGN CALCULATIONS REVIEW PROJECT PROCEDURES FOR ESTABLISHMENT OF REQUIREMENTS FOR MAINTENANCE OF ADEQUATE SEPARATION CONDITIONS EVALUATE NEED FOR FSAR UPDATE BASED ON AS-BUILT CONDITIONS l

ITEM II.E REBAR IN FUEL HANDLING BUILDING DESCRIPTION OF ISSUE IDENTIFIED BY NRC UNAUTHORIZED CUTTING OF REBAR ASSOCIATED WITH THE INSTALLATION OF THE j

TROLLEY PROCESS AISLE RAILS IN THE FUEL HANDLING BUILDING MAY HAVE OCCURRED.

LOSS OF THE REBAR MAY REDUCE THE LOAD RESISTING CAPACITY OF THE f

j CONCRETE FLOOR SLAB.

1 ACTION SPECIFIED BY NRC j

TUEC SHALL PROVIDE INFORMATION TO DEMONSTRATE THAT ONLY #18 REBAR IN i

1ST LAYER WAS CUT, I

OR i

t PROVIDE DESIGN CALCULATIONS TO DEMONSTRATE THAT STRUCTURAL INTEGRITY I

IS MAINTAINED EVEN IF #18 REBARS IN BOTH 1ST AND 3RD LAYERS WERE CUT.

i i

1 e

i ITEM II.E i

TUEC ACTION PLAN DESIGN CALCULATIONS WILL BE PERFORMED TO DETERMINE STRUCTURAL ADEQUACY OF SLAB EVEN IF 1-#18 IN 1ST AND 3RD LAYER IS CUT.

l A REVIEW OF THE PROGRAMS CONTROLLING REBAR CUTTING WILL BE PERFORMED.

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-L ITEM II.D SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS NRC DESCRIPTION OF ISSUE REVIEW OF THE CONTROL ROOM CEILING REVEALED THAT ARCHITECTURAL I TIONS EXISTED THAT WERE NOT SEISMICALLY SUPPORTED.

NON-SAFETY CONDUIT 2 INCHES AND UNDER IN DIAMETER WAS ABOVE THE CEILIN l

IN ACCORDANCE WITH REG. GUIDE 1.29 AND FSAR SECTION 3.78.2.8 THE NO SEISMIC ITEMS SHOULD BE DESIGNED IN SUCH A WAY THAT THEIR FAILURE WOU NOT ADVERSELY AFFECT THE FUNCTIONS FOR SAFETY-RELATED COMPONENTS OR INJURY TO OPERATORS.

REVIEW OF CALCULATIONS FOR SEISMICALLY RESTRAINED LIGHTING FIXTURES A SLOPED SUSPENDED CEILINGS DID NOT ACCOUNT FOR POTENTIAL LOADINGS FROM ROTATIONAL INTERACTION BETWEEN CEILING ELEMENTS, NOR WERE SPECIFIC SEISMIC RESPONSE CONDITIONS REVIEWED FOR THE CEILING ELEMENTS.

e ITEM ll.D 1

ACTION SPECIFIED BY NRC PRov!DE RESULTS OF SEISMIC ANALYSIS WHICH DEMONSTRATES THAT THE NON-SEISMIC ITEMS IN THE CONTROL ROOM (OTHER THAN THE SLOPING SUSPENDED l

DRYWALL CEILING) SATISFY THE PROVISIONS OF REG. GUIDE 1.29 AND FSAR SECTION 3.7B.2.8.

i 1

i PROVIDE AN EVALUATION OF SEISMIC DESIGN ADEQUACY OF SUPPORT SYSTEM FOR LIGHTING FIXTURES AND DRYWALL CEILING WHICH ACCOUNTS FOR PERTINENT FLOOR RESPONSE CHARACTERISTICS.

i i

PROVIDE VERIFICATION THAT ITEMS NOT INSTALLED IN ACCORDANCE WITH THE

-REQUIREMENTS OF REG. Gu!DE 1.29 SATISFY APPLICABLE DESIGN REQUIREMENTS.

PROVIDE RESULT $ OF AN ANALYSIS THAT JUSTIFY ADEQUACY OF THE NON-SAFETY CONDUIT WHOSE DIAMETER IS 2 INCHES OR LESS.

i PROVIDE RESULTS OF AN ANALYSIS WHICH DEMONSTRATES THE FOREGOING PROBLEMS l

ARE NOT APPLICABLE TO OTHER CATEGORY ll AND NON-SEISMIC STRUCTURES, l

SYSTEMS AND COMPONENTS ELSEWHERE IN THE PLANT.

i 1

2 i

ITEM II.D i

i.

j BACKGROUND DESIGN PHILOSOPHY WAS TO SEISMICALLY RESTRAIN ALL MEMBERS WITH LARGE MASS.

1 ARCHITECTURAL FEATURES WITH SMALL MASSES, IF LOCALIZED FAILURE OCCURRED, WOULD NOT BE ADVERSE TO THE OCCUPANTS OF THE CONTROL ROOM.

l i

WITH THIS PHILOSOPHY, ENGINEERING ADVISED THE DAMAGE STUDY GROUP THAT THE DESIGN WAS IN COMPLIANCE WITH THE INTENT OF REG. GUIDE 1.29 AND NO FURTHER REVIEW WAS REQUIRED.

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ITEM II.D TUEC ACTION l

FOR THE MOST DIRECT AND TIMELY RESOLUTION, ACTIONS WILL BE TAKEN TO l

PRECLUDE ANY ITEM FROM FALLING.

SEISMIC ANALYSIS WILL BE PROVIDED WHICH DEMONSTRATES COMPLIANCE WITH REG. 6UIDE 1,29 AND FSAR SECTION 3.7B.2.8.

HORIZONTAL SEISMIC RESTRAINTS WILL BE INSTALLED TO PREVENT INTERACTION BETWEEN CEILING SYSTEMS.

9 THE DRYWALL CEILING WILL BE REPLACED TO EXPEDITE RESOLUTION IN LIEU OF VERIFICATION TESTING.

PERFORM EVALUATION ON INDIVIDUAL COMPONENTS OF ACOUSTICAL AND LOUVERED CEILINGS AND PROVIDE POSITIVE ATTACHMENT IF FAILURE IS A CONCERN.

j VERIFICATION WILL BE PERFORMED BY QUALITY CONTROL ON ALL APPLICABLE DESIGN REQUIREMENTS.

PROVIDE

SUMMARY

DOCUMENT WHICH DELINEATES THE PHILOSOPHY AND IMPL.EMENTATION l

OF THE DAMAGE STUDY EVALUATIONS MADE THROUGHOUT THE PLANT WHERE POTENTIAL INTERACTIONS EXISTED.

PERFORM A REVIEW OF ARCHITECTURAL SPECIFICATIONS AND DRAWINGS TO CONFIRM THAT ARCHITECTURAL FEATURES HAVE BEEN APPROPRIATELY EVALUATED IN OUR PRESENT DAMAGE STUDY PROGRAM.

I a

I HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE Ill.A.1 DESCRIPTION OF CONCERN IN REVIEWING TEST DATA PACKAGES, THE TRT FOUND THAT CERTAIN TEST OBJECTIVES WERE NOT MET FOR AT LEAST THREE PREOPERATIONAL HOT FUNCTIONAL IESTS ACTIONS SPECIFIED BY NRC 4

REVIEW ALL COMPLETE PREOPERATIONAL IEST DATA PACKAGES TO ENSURE THERE ARE NO OTHER INSTANCES WHERE TEST OBJECTIVES WERE NOT MET, OR PREREQUISITE CONDITIONS WERE NOT SATISFIED.

THE THREE ITEMS IDENTIFIED BY THE TRT SHALL BE INCLUDED, ALONG WITH APPROPRIATE JUSTIFICATION, IN THE TEST DEFERRAL PACKAGES PRE-SENTED TO THE NRC l

~*

i HOT FUNCTIONAL TESTING DATA PACKAGES ISSUE Ill.A.1 DESCRIPTION OF CONCERN TEST DEFICIENCY i

1CP-PT-55-05 A LEVEL DETECTOR APPEARED TO

" PRESSURIZER BE OUT OF CALIBRATION DURING LEVEL CONTROL" THE TEST AND WAS REPLACED AFTER THE TEST.

THE APPROVED RETEST 4

WAS A COLD CALIBRATION RATHER THAN A TEST CONSISTENT WITH THE ORIGINAL TEST OBJECTIVE, WHICH WAS TO OBTAIN SATISFACTORY DATA UNDER HOT CONDITIONS BACKGROUND 4

~

1CP-PT-55-0; " PRESSURIZER LEVEL CONTROL" PRESSURIZER LEVEL CONTROL MAINTAIN LEVEL IN i

MANUAL AND AUTOMATIC MODE

i

~~

HOT FUNCTIONAL TESTING DATA PACKAGES l

ISSUE lll.A.1 TUEC ACTION PLAN REVIEW EACH TEST IDENTIFIED BY TRT CONCERN REVIEW THE SEVEN REMAINING HOT PUNCTIONAL PRE-OPERATIONAL IESTS NEED FOR RETESTS TO MEET TEST OBJECTIVES WILL CONSTITUTE A REJECT ONE REJECT WILL REQUIRE SAMPLE REVIEW 0F REMAINING 136 IF REVIEW OF FIRST SAMPLE OF 20 REVEALS ONE REJECT, REVIEW ADDITIONAL SAMPLE OF 20 REVIEW OF SECOND SAMPLE REVEALS ONE REJECT, ALL REMAINING APPROVED TESTS WILL BE REVIEWED i

l

6 e

JTG APPROVAL OF TEST DATA ISSUE Ill.A.2 DESCRIPTION OF CONCERN TO COMPLETE THE PREOPERATIONAL IESTS PROPOSED FOR DEFERRAL AFTER FUEL LOAD, THE JTG, OR SIMILARLY i

QUALIFIED GRO.UP, MUST APPROVE THE TEST RESULTS PRIOR TO PROCEEDING TO INITIAL CRITICALITY.

THE TRT DID NOT FIND ANY DOCUMENT PROVIDING THAT TUEC IS COMMITTED TO DO THIS ACTIONS SPECIFIED BY NRC TUEC SHALL COMMIT TO HAVING A JTG, OR SIMILARLY QUALIFIED GROUP, REVIEW AND APPROVE POST-FUELING PREOPERATIONAL IEST RESULTS PRIOR TO DECLARING THE SYSTEM OPERABLE IN ACCORDANCE WITH IECHNICAL SPECIFICATIONS l

r4

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TECHNICAL SPECIFICATIONS FOR DEFERRED TESTS ISSUE Ill.A.3 DESCRIPTION OF CONCERN IN ORDER TO CONDUCT PPIOPERATIONAL IESTS AFTER FUEL LOAD, CERTAIN TECHNICAL SPECIFICATION RE-QUIREMENTS CANNOT BE MET, E.G., ALL SNUBBERS WILL NOT BE OPERABLE SINCE SOME WILL NOT HAVE BEEN TESTED l

l ACTIONS SPECIFIED BY NRC EVALUATE THE REQUIRED PLANT CONDITIONS FOR DEFER-RED PREOPERATIONAL IESTS AGAINST THE PROPOSED TECHNICAL SPECIFICATION REQUIREMENTS AND OBTAIN NRC APPROVAL WHERE DEVIATIONS FROM THE IECHNICAL SPECIFICATIONS ARE NECESSARY i

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i TRACEABILITY OF TEST EQUIPMENT ISSUE Ill.A.4 DESCRIPTION OF CONCERN TEST DATA FOR IHERMAL EXPANSION IEST DID NOT PROVIDE FOR TRACEABILITY OF. TEMPERATURE MEASURING INSTRUMENTS IN THE MANNER SPECIFIED BY STARTUP PROCEDURE -7 ACTIONS SPECIFIED BY NRC I

INCORPORATE THE NECESSARY INFORMATION INTO TEST DATA PACKAGE ESTABLISH CONTROLS TO ASSURE APPROPRIATE TRACE-ABILITY DURING FUTURE TESTING la

e CONTAINMENT INTEGRATED LEAK RATE TESTING ISSUE III.B DESCRIPTION OF CONCERN ELECTRICAL PENETRATIONS ISOLATED DURING TEST METHODOLOGY FOR CALCULATION OF TEST RESULTS NOT IN COMPLIANCE WITH FSAR COMMITMENTS ACTIONS SPECIFIED BY NRC IDENTIFY AND JUSTIFY ANY OTHER DIFFERENCES AS A RESULT OF APPLYING ANSI /ANS 56.8 IN. LIEU OF ANSI N45.4-1972 (REQUIRED ACT' ION CLARIFIED BY NRC LETTER DATED AUGUST 27,1984)

I N

• / e

p PREREQUISITE TESTINC ISSUE III.C i

DESCRIPTION OF CONCERN INITIAL CONDITIONS FOR PREREQUISITE IESTS VERIFIED

)

BY CRAFT PERSONNEL ACTIVITY IMPROPERLY AUTHORIZED BY STARTUP MANAGEMENT MEMORANDUM i

ACTIONS SPECIFIED BY NRC RESCIND MEMORANDUM ASSURE NO OTHER MEMORANDUM ISSUED IN CONFLICT WITH 1

APPROVED PROCEDURES J

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e, PRECPERATIONAL TESTING ISSUE lil.D DESCRIPTION OF CONCERN CURRENT DESIGN INFORMATION NOT PROVIDED TO TEST l

ENGINEERS ON A ROUTINE, CONTROLLED BASIS ACTIONS SPECIFIED BY NRC ESTABLISH MEASURES TO PROVIDE GREATER ASSURANCE THAT TEST ENGINEERS ARE PROVIDED WITH CURRENT CONTROLLED DESIGN INFORMATION

/4

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