ML20202B029

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Rev 7 to QI-QP-11.3-2, Cable Tray Hanger Insp. Related Info Encl
ML20202B029
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/19/1979
From: Dick L
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML18052B537 List: ... further results
References
FOIA-85-59 QI-QP-11.3-2, NUDOCS 8607100182
Download: ML20202B029 (18)
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-7 1.0 REFEREi:CES 1-A Procedure CP-QP-11.3, " Electrical Inspection Activities" 1-G Procedure 35-1195-ECP-10 " Class 1E Cable Tray and t! anger Fabrication and Installation" 1-C Specification S-52.01-1060, " Welding Specification for Field Fabrication and Erection of Structural Steel, Part B-A'?! D1.1" 1-0 35-1195-CP-CPii-0.3, " Preparation, Approval and Control of Operational Travelers" i

1-E 35-1103-CCP-22, " Structural Steel Erection" 1-F Procedure CP-QP-15.0, "flonconformances and Daficiencies"

-G 35-1195-CEI-20, " Ins tall ation of 'liil ti' Drilled-In Bol ts" 1-H Procedure CP-QP-18.0, " Inspection Report"-

2.0 GEf:ERAL The purpose of this int.truction is to supple., ant Referen e L-A and to provide detailed instructions to be followed by tha QC inspection personnel for fabrication and installation ir.4ecticas of cable tray har.gers and for surveillance of field welcing activities.

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3.0 It!STRUCTI0 tis 3.1 FAGRICAT10 t IriSPECTIOil i

Fabrication of cable tray hangers (DSR shop fabricated hangers) t

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shall be in accordance with Reference 1-C.

Fabrication inspec-tions shall be performed on safety-relcted c:ble trey hangers.

These inspections shall consist of, but are not linited to, i

the follcuing items:

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a. Rcnde.a surveillance shall be per[orrad ca a minio.u:n of l

once per shift basis.

This surveillance shall inclu.'e the following:

i 1.

Verify FSE conformance; Criteria:

The FSE sheet used for hanger fabric?. tion shall confora i

to the applicable GSH drawings.

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Verify welder quali fication; 3

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The WPS, Ulm and Helder Symbol shall be recorded. All j

velders shall be qualified to the welding pro:ci;re und2r which they are welding.

This shall be cheded by l

l referring to UES-16.

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b. Final inspactions shall be performed en all safety-related cable tray hangers as follows:

1.

Verify caterial acceptability; j

Criteria:

Verify that certified material i:. being used during fabri-cation by perfonning a material traceability verificatica and recording the heat number and n:eterial type. ilo heat

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number verification is required for uni-strut typa naterial.

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Verify hanger dimensions and marking; Criteria:

All hanger assemblies shall be permanently marked with the tik. !;o. and shall conform to the dimensions speci-fied on the applicable FSE-00159 sheet.

3.

Verify hanger welding; Criteria:

A visual inspection of all welds shall be perfor ed to verify c:cpliance with requirements of Reference 1-C.

Fabricatien inspottions shall. be documented per Referencu 1-H on Figure 2.

3.2 FIELD WEL0ifiG II:5PECTI0i!

9 Field fabricaticn of cable tray hangers shall be in accordance with Reference 1-B.

Field welding inspections shall be cerformed I

-. g en all sa fetv-rela te,d_ Class 1E cable trar hangers.

These inspec-l tions will consist or, but are not limited to, the foll:. ting itecs:

a. Verify field welding; Criteria:

A visual inspection of all field welds shall be performed to verify compliance uith requiremants of Reference 1-C (Class 1E only).

Field welding inspections shall be docuented par Paragra;h 3.5b on Figure 1, Construction Operation Traveler - Opera-tion III.

flonconforming conditions shali be documented and controlled per Reference 1-F.

3.3 IriSTALLATI0i! IH3?ECTI0il3 Installation of ccble tray hangers shall be in accordance with Reference 1-8.

Installation inspections shall be nerformed on all safety-related Class _1-E cable trai/ hangers.

Tnese inspections w.ill consist of, but are not limited to, the following items:

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a. Verify hanger location and installation (Class IE hangers only).

I:on-class IE hangers shall have all inspecti:n points in operations I & Il co'.:pleted except fur location and elevation.

Criteria:

The location and installation of cable tray hangers shall be in conformance with the latest approved Engineering drawings and/or instructions.

b. Verify expahsion anchor size & installation.

I Cri teria :

The si e and installation of expansion anchors shall be as f

shown on the latest engineering drawings, and shall be in conforrance ui th Paragraphs 3.1. 2. 2, 2.4.5, 3.1.1.1, and i

3.1.4.1 (Thread Engagemant Only) of Reference 1-G.

f I:0!E : /il holes within a radius of four (4) tics the l

dicreter of the bolt shall b2 patched. All holes patched in accordance uith CCP-12 are not to ba considered as abandoned holes.

c. Veri fy bolted connections secure.

Criteria:

All bolted connections to uall or ceiling shall be r>.de with apprnved hardware and all connections shall be ccmplete and secure. This does not include expansion anchors which are veri fied in the prcceeding s tep.

The bolting togethcr of structural steel shall be perforr.ed in accordance with Section 4.2, of Reference 1-E.

Installation inspection shsll b3 documented per paragraph 3.5a on Figure 1, Construction Operation Traveler - Operations I and i

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flanconforming conditions shall be docu :ented and controlled par Reference 1-F.

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a. Installation inspections shall be documented on Figure I, Construction Operation Traveler - Operations I and II.

As each inspection point is verified, the QC Electrical Inspec-tor shall initial or stamp and date appropriate point for acceptability.

Af ter total acceptance of each operation, the,

1 QC Electrical Inspector will sign or stang and date QC Accept- [

ance line.

Item IB shall.be perfomed as per paragraph 3.4.

b. Field Welding Inspection shall be documanted on Figure 1, Construction Operation Traveler - Opera. tion III. As each

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inspection point is verified, the QC h'elding Inspector shall After total acceptance of each operation, the QC Ueldingin h

j Inspector will sign or stamp and date QC Acceptance line.

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step assured Texas Utilities of the timely notification of any items concluded h.

to have a definite potential for impacting plant safety.

Each of these basic steps of Exhibit 3.2 is further described in the following subsections.

3.1 DOCUMENT COLLECTION Cygna collected and reviewed documents in two stages.

During the first stage, the review teams identified those central documents which guide the design control process, such as the SAR, QA manuals, and project procedures.

Reviewing these central documents provided an understanding of how the work process was structured and directed.

During the second stage of data collec-tion, the review teams identified and gathered those documents needed to complete the review.

To facilitate the review process, the review teams conducted the implementation review at the most convenient work location, typically where the documents were kept.

This-enabled the teams to develop a better understanding of both the documents and the methods used in their AppendixCcontainsalistofall$cumentsanddrawingsreviewed

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by Cygna Energy Services during this Independent Assessment Program.

3.2 REVIEW CRITERIA A key element in the review was the development of review criteria to measure These review criteria the adequacy of the design and design control process.

' were a composite of licensing commitments, CPSES requirements, industry codes and standards, and Cygna engineering and design experience.

These review criteria provide a means for measuring the adequacy of a system. design and ca A-85-59 design control process, Texas Utilities' and Gibbs & Hill's QA programs werk eval ated using a matrix criteria which compared the key elements of their design control program to 3-2 Utilities Services, Inc.

l anche Peak Independent Assessment Program inal Report TR-83090-01, Rev. 0

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When a discrepancy is noted, it is recorded on the checklist and then reviewed by at least two members of the project team.

It is the resonsibility of these team members to evaluate (1) the completeness and accuracy of the discrepancy, and (2) the potential design impact.

If the information is both complete and accurate, and if the discrepancy has potential impact on design, an Observatton is recorded.

3.3.3 Observation Record Completed Ob'servation Records are shown in Appendix F.

The observation number is a unique number sequentially assigned to each observation within a checklis,t.

It contained a description of the discrepancy, the requirements, and an initial assessment of the potential design impact.

Each observation record was prepared by the orig'inator of the observation and then reviewed by a qualified person assigned by tt'e Project Manager.,

Based on this review, an evaluation by. the Project Team, consultation with Cygna specialists, and discussions with Texas Utilities.

technical and quality assurance staff, an OtRrervation Record Review was then prepared.

This review record documents an assessment of' probable cause and resolution of each observation.

This determination was approved by the Project Manager and the observation originator.

3.3.4 Potential Finding Reoort Completed Potential Finding Reports (PFRs) are contained in Appendix G.

Each PFR was assigned a sequential number starting with 01.

On this form, the cognizant reviewer recorded a description of the observation, an assessment as to the extent of the observation plus an evaluation of the design and safety impact.

The PFR was then review'ed by the Senior Review team for completeness and accuracy.

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If the Senior Review Team determined that the observation did indeed have a definite potential impact on plant safety, the finding would have been reported to Texas Utilities and the NRC by the Project Manager.

3.4 PROGRAM AND IMPLEMENTATION EVALUATION Reviews of the CPSES design control process were divided into two areas:

Program adequacy Extent of program implementation e

The assessment of design control program adequacy was performed on Texas Three elements of the Utilities and Gibbs & Hill, the architect / engineer.

program (design analysis, design change, and interface controls) were used to assess the extent of program implementation at Texas Utilities and Gibbs &

Hill.

Additional confirmation of the program implementation was achieved through an aq-built walkdown and design review.

Each review team consisted of at least two inklyiduals jointly capable of performing and reviewing the work.

These review ' team's were guided by the review criteria matrices and checklists descibed in the previous subsectfons.

Members of the teams performed the initial reviews,. completed the matrices and checklists, and originated observations.

In the program matrix area, the reviews concentrated on the following areas as essential to plant safety:

Design input control Design analysis control e

ie Drawing control Procurement control Internal / external interface control e

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  • Design verification Document control e

Design change control e

e Corrective action Internal / external audits and surveillance e

The matrices and checklists developed ensured that tL governing criteria would be met and that any deviations would be noted as observations.

In the technial implementation review, the Cygna teams assessed the adequacy of the design analysis for che following areas:

P.ipe Stress, Analysis e

Check input data (pressure, operating ' modes, anchor movements, dynamic loads)

Verify that the computer model useshthe proper geometry, section properties, supports, components Ensure special features are considered (Valve stem frequencies, nozzle load checks, local stress analysis for lugs)

Review stress report data (load cases and combinations, valve accelerations,. piping displacements)

Pipe Support Design e

Review input data (required support stiffness, support type, piping deflections and loads)

Review design calculations (welds, members, standard components, 3-7 Texas Utilities Services, Inc.

Comanche Peak Independent Assessment Program L*) [,; g a llillilillllllllillllllllllill Final Report TR-83090-01, Rev. O i

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EXHIBIT 3.1

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TERMINOLOGY Definition Term A listing of key items to be checked during the independent Checklist The checklist provides a guide to the assessment.

reviewer; it is neither all inclusive nor limiting.

The A compilation of acceptable procedures and standards.

Review Criteria adequacy of the design and design control process is measured against these criteria.

Identification of.an item in apparent nonconformance with the project review criteria and judged to have potential Observation An observation 'does not imply an assessment design impact.

with respect to design adequacy.

Any observation which is judged to be inaccurate as a Invalid Observation result of further review.

An accurate and complete observation as judged by the Valid Project and Senior Review Teams, which requires further Observation -

review to assess design impact.

A valid observation having a p'6te'ntial impact on plant Potential safety as judged by the Project Review Team.

Finding A review of selected systems or elements of the total plant Vertical Review design.

A quality assurance review of design control procedures and Horizontal Review their implementation.

A potential finding verified by the Senior Review Team to t

Definite Potential have a potential impa plant safety.

This is a Finding reportable finding to G& under requirements of 10CFR Part 21.

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4.0 REVIEW RESULTS AND CONCLUSIONS After preparing the criteria, matrices, and checklists described in the previous sections, the Cygna review team completed the assessment of the defined scope. Appendix C contains a list of the documents reviewed by Cygna.

This section describes the results of each assessment and draws a final con-clusion concerning the design of the plant.

Each phase of the assessment is detailed in the following paragraphs.

Also included are the descriptions of the observations noted during the review and their resolution.

All completed observations are contained in Appendix F.

4.1 DESIGN CONTROL PROGRAM 4.1.1 Texas Utilities Design Control Program.

-.u vw,yu m a.2p.vv1 amp NnWahurvAta5W The design control program, as-documented ~

in the CPSES QA Plan, Project Ouality ifggineering Procedures and Supporting Instructions, Site Document Control Procedures and the-Quality Procedures in total, adequately addressed the requirements of ANSI-N45.2.11 draft 2, revision 2,

" Quality Assurance Requirements for the Design of Nuclear Power Plants," as committed to in the CPSES Final Safety Analysis Report.

This conclusion is supported by the quality program matrix shown in Appendix D, which identifies the quality require-ments committed to with a cross correlation to the respective procedural controls within the Texas Utilities design control program documents.

4.1.2 Gibbs & Hill Design Control Program

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The review of the Gibbs & Hill documented design. control program resulted in no observations.

Thir$ design control program as documented in the 5

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Gibbs & Hill CPSES Project Procedure and Project Guide Manuals adequately addressed the requirements of ANSI N45.2.11 draft 2, revision 2.

This conclusion is supported by the quality program matrix as shown in Appendix D, which identifies the comitted quality requirements with a cross correlation to the respective procedural controls within the Gibbs

& Hill design control program documents.

4.2 IMPLEMENTATION EVALUATION 4.2.1 Design Change Control 4.2.1.1 Texas Utilities

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- -- *nyergm >-#vn The CPSES site document ccintrol center mas-ter log of outstanding design changes dssued against, drawings or specifications is not accurate.

M The CPSES controlled document recipient logs of out-standing design changes issued against drawings or i

specificiations are not accurate.

All drawings are not identified with a marking indi-cating that outstanding design changes have been issued i

against such.

e CPSES Design Change Tracking Group' design verifica-l tion tracking system is not accurate.

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TUSI was previously aware of these problems documented by observa-tions DC-01-01 through DC-01-03 through the various other reviews ant audits performed at CPSES.

In fact, TUSI had initiated planning for a new document control program which would alleviate the conditions existing in the Document Control Program prior to the IAP findings.

In summary, this program consists of the following actions:

A)

Establish document control satellite stations to better control the distribution of design documents including all associated design changes.

B) Develop an accurate computer manual listing of all design

drawings, listing all outstanding design changes.

This entails Texas Utilities performing a complete review of all design documents, design changes, respective Gibbs & Hill (G&H) design review records, the computer listing of design changes issued against G&H-generated design documents, and the newly developed TUSI Design ChangeWacking Group computerized design review status listing.

C) Revise the existing document control center manually operated design change and design document logging and distribution system via the use of the new computerized document control system (see paragraph B above).

The new computerized system is used as the basis for control of all outstanding design changes issued against affected documents.

Further, this listing controls the distribution of design changes to the approprfate satellite files and replaces, in

part, the satellite file manual logging system.

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The above described system, which was developed and partially instituted during the progress of the IAP is approximately 85%

complete as of October 15, 1983.

The Cygna follow-up review of a i

substantial sample determined that each of the three observations, DC-01-01 through DC-01-03, has been resolved.

For complete details of these observations, including their resolution, refer l

to Appendix F.

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In the case of observation DC-01-04, Cygna determined that the computerized listing, at the time of observation identification, was in the process of being developed / refined.

Furthermore, this listing was being utilized only as a design review tracking

, mechanism and not as a control document for a complete / accurate listing of design changes issued.

Subsequently, the computerized I

listing was completed (see discussion above) and incorporated into the newly developed document control program.

At that time, it became the master listing for design changes issued against affected design documents.

For complite details of this observa-tionanditsclosurerefertoAppendih.

4.2.1.2 Gibbs & Hill The implementation of the Gibbs & Hill design change control program resulted in one valid observation (DC-02-01).

This observation identified instances where design specifications and changes had been issued prior to the performance of design review and/or resolution of design reviewer comments.

Investigation into this area revealed that the same condition had been identified through the TUSI audit program' during 1975 and 1976. TUSI and Gibbs & Hill conducted extensive corrective action and follow-up activities throughout the 1976 through 1979 time 4-4

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. The location, size, finish and grout of the foundations for:

a) Pump CPX-SFAPSF-01 b) Heat Exchanger CPX-SFAHSF-01 c) Radiation Monitor X-RE-4863

a) Pump suction from the pool b) Pump discharge to the pool A randomly selected sample of 5 cable tray supports in Pump Room 1 e

and the adjacent area.

A thorough inspection of the interior of the Pump Room was not possible since all surfaces have been painted. However, the exterior walls, which had not been painted, exhibited good workmanship.

All other items proved to be satisfactory.

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4.4 POTENTIAL FINDING REPORTS T'

During the course of the independent assessment program, Cygna identified a

' total of thirty-three valid observations, including one which was considered to be a potential finding.

As described in Section 3.0, Methodology, an

" Observation" is any nonconformance to the review criteria having potential design impact and a " Potential Finding" is an observation considered to have a significant potential impact on plant safety.

After further review, the potential finding, or PFR, was determined to have no definite impact on plant safety and was closed.

Consequently, this PFR was not reportable under the t

guidelines of 10CFR21.

In the following paragraph, the resolution of the PFR is discussed.

Appendix G contains more detailed documen'tation for this potential finding.

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PFR 01.

In reviewing the cable tray support design within the Cygna scope, Cygna noted various technical deficiencies in each design.

While each deficiency, by itself, did not affect the acceptability of these support designs, there was no assurance that the cumulative effect would not have a potential impact on plant safety.

This PFR was closed based on four considerations:

  • Gibbs & Hill initiated analyses on the supports within the Cygna scope and incorporated the Cygna comments.

An examination of the results shows that the design margins for support components are more than 10%.

The designs within the Cygna scope of review covered 43% of the supports in the plant.

Any field changes to a particular support are reviewed and e

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approved by Gibbs & Hill.

Any subsequ)nt changes to that support reference all changes made to it, thustensuring that the approval considers all changes.

There is no potential safety impact.

4.5 CONCLUSION

The purpose of this Independent Assessment Program was to provide added assurance that the design process in place at Texas Utilities produced an acceptable design.

Cygna Energy Services has conducted a detailed review of both the design process, from the development of criteria through the final, as-built design, and the quality assurance procedures necessa'y to the control r

design activities.

While Cygna did find certain instances where the process or procedures were not apparently adequate, more detailed review showed Cygna r

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that each had a negligible impact on the plant design.

In conclusion, Cygna's review when considered 1.n conjunction with previous reviews of CPSES, shows that the design process in place at CPSES is acc2ptable and meets the j licensing commitments in the CPSES FSAR.

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PROCEDURE ISSUE REVISION PAGE TEXAS UTILITIES GENERATING CO NUMBER DATE CPSES CP-QP-20.0 3

1 of 5 3EP 15 1983

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PRESERVICE INSPECTION ACTIVITIES

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1.0 REFERENCES

1-A Westinghouse Electric Corporation Contract / Program fo r Preservice Inspection for Class 1,2 and components.

1-B CPSES QA Plan, Preservice Inspection Program, Section 20.0 1-C ASME B&PV Code Section XI,1980 Edition (Including Winter Addenda for Class 3) 1-0 CP-QP-17.0, " Corrective Action" 1-E CP-QP-18.0, " Inspection Report" 20 3 U O R.:. Z.1.; g.1 y 2.0 GENERAL 2.1 PURPOSE The purpose of this' procedure is to delineate the require-ments for QA Surveillance of Preservice Inspection activities.

2.2 SCOPE The scope of this procedure encompasses the

items, i

components and systems designated as Class 1. Class 2 and Class 3 which require Preservice Inspection as defined in Reference 1-A of this procedure and as covered by Reference 1-B and 1-C.

This procedure also delineates the methods of monitoring Preservice Inspection activities by others, through the di rect involvement of Quali ty Assurance personnel,

thei r activities, responsibilities and documentation requirements.

!:OlA-85-59 by, l

9 P a n v o Y'a '+

TUGCO CA Farvet No. 2 ff & I2L ;

fn.

PROCEDURE REVISION PAGE TEXAS UTILITIES GENERATING CO.

CPSES CP-Q P-20.0 3

2 of 5 SEP 15 1963 2.3 RESPONSIBILITIES The Quality Engineering Supervisor shall be responsible for verification (through Surveillance) of the implementation of the Preservice Inspection Program to the applicable provisions of ASME Section XI in accordance with thi s procedure.

3.,0 PROCEDURE 3.1 GENERAL REQUIREMENTS Preservice Inspection surveillance shall be perfonned by assigned personnel using detailed checklists prepared by 1

Quality Engineering from References 1A,18,1C,1E and the implementing procedures.

Assigned personnel shall veri fy compliance of the delineated activities through observation of work activities, discussions with inspection personnel, and review of objective evidence.

The results of the surveillance activities shall be documented on the checklist /

Inspection Report for subsequent review by the TUGC0 Site Quality Engineering Supervisor or his designee.

3.2 REPORTING AND FOLLOWUP Any discrepancies noted during the surveillance activities shall be reported to the TUSI and Westinghouse PSI /ISI Coordinators via the Surveillance Discrepancy Report (Figure 1).

A due date for the corrective action shall be provided based on the severity of the disc'repancy. A log (Figure 2) shall be maintained by the TUGC0 QA Secretary reflecting the Report Numbers, Responsible Manager, Corrective Action Due Date, Date Response Recei ved, Followup Date and, Closecut Date.

3.3 FREQUENCY The frequency of surveillance activi ties shall be in accordance with a schedule prepared by Quality Engineering and approved by the TUGC0 Site Quality Engineering Supervisor.

3.4 CORRECTIVE ACTION TRENDS The Quality Engineering Supervisor or his designee shall review Surveillance Discrepancy Reports for the need for formal corrective action in accordance with the provisions of Reference 1-D.

%g3 TUGCO OA a

PROCEOupg 1

REWSION PAGE R

0 TEMS UTIUTIES GENERATING CO.

CPSES CP-QP-20.0 3

SEP 15 1983 3 of 5 3.5 DOCUMENTATION TUGC0 Quality Engineering shall forward completed checklists and Surveillance Discrepancy Reports to the Permanent Plant Records Vault.

TUGCO OA

""3 n

I PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.

CF3ES SEP 1 1983 CP-QP-20.0 3

4 of 5 FIGURE 1 TEXAS LTTII. FRIES GENERATING COMPANY NO.:

pRCSERVffe fN9PCCTf0N 9t?RVFftiANCC DISCREDANCY RCDCRT TO:

DATE:

FROM:

By:

SUBJECT:

INSPECTION CHECKLIST No:

REQUIREMENT:

CBSERVATICN:

1 i

PLEASE PROVIDE A CCRRECTIVE ACT!CN RESPONSE BY 1

IN THE SPACE PROVIDED SELCW AND INCLUDE IMPLEMENTATICN DATElS).

i CCRRECTIVE ACTION TAKEN:

)

i

.#hk AW' MV' 5-SIGNED DATE VERIFIED DATE CC:

R. G. TOLSON, 8. C. SCOTT Form No. 3

s PROCEDURE ISSUE REVISION PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.

CPSES o3 CP-QP-20,0 3

SEP 15 196$

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