ML20206U935
| ML20206U935 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/19/1984 |
| From: | Hofmayer C NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | |
| Shared Package | |
| ML19284C882 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8607110260 | |
| Download: ML20206U935 (200) | |
Text
- _- - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ _ _ - _
b p!Y -)
SEER WRITEUP DOCUMEriT C0tiTROL/ROJTE SHEET 11egation riambers dbW .
u bj ec t a f Ai i eo a t i o n [Ap f (l/d fk'l462/1Sh.1'b L&M ra'Hin UM E SYD b bd d
.RT Group [dt5dsD Alo // ~ SAMrnic ($'SMW/fdUS1'rutb M
~
U '
huthar: C. //. No Yrr2dN4 t' V
This sheet will be initialed by each reviewer. It stays with all revisions to the SSER writeup and serves as a routing a'nd review record. It will be filed in the work package when the writeup is published.
Draft flumber Draft' 1 2- 3 4 5 Author
, Group Leader
(
o Ms44 8
N .-
'y#)OKO . SM j
, n/ GNICfd pCp',,c/g, hjp) y/)z ,:x . ( ( Wea ed Tech. Editor 27 " '
Wessman/Vietti '
- , f/. I
~
~J. Gaoliardo p 1/;y T. Ippolito l ,
Revision fiumber Final 1 2 3 4 5 Author Tech. Editor '
Grouc Leader J. Gacliardo e T. Ippolito i
V h
Administrative l O Writeup integrated into SSER -
9 Potential Violations to Region IV Workpackage File Complete d* f Workpackage Returned to Group Leader .
{
4 A II ~
y eye c e'd "
Og %'
)
T= r , ,
f f *:)9 Li, p u
'~ * * ' ' ' - :
O 860624 .'
-)
h 12 M i
i _ -- - - - - - - - - - - - -
e :
~ '
Draft 7 - 10/22/84
' AC-41 Category 11/CP3 SSER
- 1. Allegation Category: Civil and Structural 11, Seismic Design / Construction
- 2. Allegation Number: AC-41
- 3. Characterization: It is alleged that there was poor workmanship regarding
~
the use of elastic joint fill'er material ("rotofoam") as a temporary _ spacer during construction to maintain the required air space between seismic Category I concrete structures, l 4. Assessment of Safety Significance: The implied safety sigr ificance of this allegation is that if the use and removal of elastic joint filler '
material is not proper k the validity of the seismic analysis results for seismic Category I structures could be questioned.
- TUEC informed NRC Region IV on November 23, 1977, of this allegation, which TUE,C received anonymously- in a telephone call on November 22, 1977.
A Region IV inspector reviewed the allegation during an inspection con-ducted between November 28 and December 2, 1977, and concluded, based on the information available to him at the time, that all temporary rotofcam had been remcled'from the areas identified. The matter was le'ft open pending a Region IV review of the Brown & Root (B&R) QA/QC inspection and documentation program, which was being initiated to assur'e that the required seismic gap between Category I structure's was be16g maintaineif.
Rotofoam was used as a temporary spacer during construction to maintain this gap. Once the concrete hardened, the rotofoam was removed to elimi-nate any load transfer or dynamic interaction between buildings. If the relative motion between buildings was small and the presence of rotofoam was constdered in 'the dynamic analysis of the building,' leaving the roto-foam in place may not have had a significant impact on the dynamic per-formance of the buildings.
,,-L.Ji.:g,- -
.f . .:.t*:,f-l
0
_g_
During an inspection between January 3 and 13,1978, the Region,IV inspector reviewed B&'R procedure CP-QCI-2.4-9, " Inspection of Elastic
~ %
Joint Filler Material Removal," Revision 1 (December 12, 1977))and B&R .
inspection reports for December'15, 1977 and January 3,1978, and had no further questions regarding this matters -
The NRC Technical Review Team (TRT) attempted to obtain a further clarification of the concerns expressed by the alleger; however, neither
, TUEC nor the Region IV office had records of the alleger's tel'ephone
- - conversation other than what is stated above. The TRT determined, however, that prior to the time the allegation was made there was a misunderstanding as to whether or not the retofoam sho'uld remain in place as part of the final construction. A letter from Gibbs & Hill (G&H) of
- September.6, 1977 (GTT-15431 indicated that construction was proceeding on the basis that the rotofoam could be left in place. The letter
~
further stated that this assumption was not made in accordance with the
! facility design drawings'and design corcept and that expansion joints j
above grade should ' consist of a eargppbetweenbuildin'gs,i.e., free of rotofoam. As noted in the CSb & M41 letter, it was intended that [
the rotofoam be left in place below grida. Since construction had proceeded above grade, TUEC instructed F4R, in a letter of October 7, 1977 ~
(TUS-5012), to remove the rotofoam. As noted, B&R proc'edure CP-QCI-2.4-9 ,
was also implemented to e, rig removal of the rotofoam. ' Based on" discus-sions with TUEC and GL~ & lMll engir eers, the TRT found that the roto-foam was to be left in place for the expansion joints above grade between the Safeguards Building and the Reacte r Building. '
If properly implemented, B&R procedure CP-QCI-2.4-9 should have provided an adequate inspection record for derronstrating that the air gap between '
buildings was adequately maintained. However, the TRT fou'd n on1y t'wo inspection reports relating to this procedure (the December'15, 1977 and January 3,1978, reports refereiced). These reports did not fulfill the complete inspection requiremen'.s of CP-QCI-2.4-9. Fur'hermore, t this i procedure was deleted on July 18, 1978 (B&R memo IM-14835). A G&H memo e e *
. . . .- . . ; *.~, L; ,- . : .
.e -
.. ....c+ u.: *; y'_;
e i was made on of January 30, 1978 (GHF-2390) indicated that an inspect on '
h November 23, 1977, and stated that the removal of the rotofoam fro However, the memo only related to construc-subject areas was acceptable. d evidence of the tion at that point and did not provide any documente inspections that were made. *
/
I 19, 1978 (IM-12934); discussed an A B&R interoffice memo of February d the inspection of the seismic gap between the Auxiliary Containment Building for Unit 1.
l and/or l
- s. I of rotofoam was'not completed and requested furth engineering evaluation. indicating
}
matter; however,'the TRT found no formal documentation the resolution of this matter.
, de 4
i Between September 14, 1978, and October i Category 17,I 1978, structures. aB l
additional inspections of'the air gap between seism cIn five Six different areas were inspected. f inspector indicated unsatisfectory conditions due toofthe ' p
~
l foreign material'in the' air gap, such as wood wedges, rock ~
These unsatisfactory inspection reports were .
' concrete', and rotofoam.
NCR C-83-01067 '
g l
i , officially, resolved on April 18, 1983, in responsethat to " field investi- .
i The disposition of this NCR note (April 13, 1983). d" Based on h t field gation reveals that most of the material has been remove
~
discussions with TUEC engineers, it is the TRT's f these understan investi-investigations were made but that no permanent gations were' maintained. March 24, 1983, which of field measurements made between Marchliary 15 and indicated that investigations of the airThese gapmeasurementsbetween the Au Building and the Fuel Building were conducted. ided to the appeared to indicate that,the required' air gap was d not prov f
813-foot, 6-inch elevation (theindicating required whether an ele CP-QCI-2.4-9).
condition, TUEC could not provide any documentationhis nonconf U '
engineering analysis was performed to justify t 1
- .,,' '**,\~':-}I'
. ; ,v .. ,.,l* ' , - . _* . . . - . .
1 ~
,r: .
i .. .*. *
~ *
..._ ..\*. , . .
a . . . , . M, _. .-
e
. . l ,
The TRT attempted to whether the material was subsequently removed.
inspect the air gap between the structures butinstalled. could not because cases the final joint sealer or roof flashing had alr~eady been In several areas between the Auxiliary Building and the Safeguards Building, the air gap could be observed and appeared to be clear of a In one doorway between the Safeguards Building ,for Unit 1 obstructions. 'the air gap and the Auxiliary Building at the' 830-foot, 6-inch elevation i
However, a wooden board and other was clear to an observer looOng up.
debris were observed when viewed straight in and downward.
j .
- s. -
i Based on the review of available
, 5. Conclusion and Staff Positions:
inspection reports and related documents, on field observations,
- discussions with TUEC engineers, the TRT cannot determine whether an
~ Field adequate air gap has been provided between concrete structures.
j investigations by B&R QC ins'pectors indicated unsatisfactory k condi due to the presence of debris in the air gap, such as wood wedges, ro The disposition of the NCR relating to '
clumps of concrete and rotofoam. h t of the this matter states that,the " field, investigation reveals t at mos However, the TRT cannot determine from this material.has been removed." debris remaining report (NCR C-83-01067) the extent and location of the 4
between the structures.
Based on discussions with TUEC engineers, it isdtheereTRT's unders that field investigations were made but that no permanent recor s w In addition, it is not apparent that the permanent maintained. ~
installation of elastic joint filler material ("rotofoam")h between the Safeguards Building and the Reactor Building, i and
' lysis below grade fo other concrete structures, is consistent with the seism ldings, c ana as these assumptions and dynamic models u' sed to analyze Report (FSAR). the bui The analyses are delineated in the Final Safety Analysis TRT,'therefore, concludes that TUEC has notB28 adequately which demo 3.8.1.1.1, 3.8.4.5.1, and 3.7. . . ,
compliance with FSAR Sections ~
t seismic
require separation of Seismic Category I buildings to preven interaction during an earthquake.
f t . ,,
. -* -,'_ -.[, - O._ ._ .o
'.g
i
- i s-l i
- 3
' c s r
,.. L.: .
1 _
+
a r
- 3 ( .
- c# ;- ,
z, ;
r '. tn - - o, . c -
e g
' _ j
_,7 < m
,s 1 s
- c; ,
+ _
e .t - i. ,
e v y,
,; -.w
- fi<c r e. i' ,t
- , ty i>y
' dl ':
- ._.* _,"sa .
5 ,
- i. - .
t . .;
c C. [:it' the t ;7 c5ure '; t~c .
,te-.C ." ,',-. C u i r]; See , , 1-i u
- f. ; : I
- .- v nU- c,U"IA
-y
. . . - * =, 'v 6 2~~' bc s c. -
.._.c. v4 Lr **. . - '- t.
?.
i t w 8 fb R. ) '}:. l*. g , f .&, j.%.v } <.f+. .J' l..) / C g.
..:< n . % .? N . y e4 ;
(,.,, )Pi
..'l E.v[ % .1,
- l ..
- fc . .[h b
' ^
- . h,.
h M &y s.v.Q -[ W y[ .[-}2f 1: f. [ . ::. ;'.hA3. . / I.- _ 1. (1 N. T . w.-
* : '.Fi c,p!% ,jN yr.
.')
- - ' . - m ,;
- h. . 2 ~
M rh [, . ) [ - [' Q '~ ..- - *.- :: . 's .: , ; e+ . y: y . .. G j Q u. g4 %:h. d.f 4^{Qh 4 a . c' S I I, h .. s. , ..2 r.P ., c.-,. . * ' aw , .,, , . _ *
$ b2 h . .c.; ^ 4 ,,: ,
n . c
#h,.
.y , . . + ,
. %g ?c. w&. 4' : .g, :,n%' . . . ,
.a %s I- .,
. .po ;
3...y4 . . .; p. I { r.
,f.; . ' . 5 j b C,'_w
.,l
- a gi . .
* ,-..w.,x r ,,
'c, . 6 . , .s..- 7;
+
) :
i
</ .
dv .f.. . '(<,". gj . .,."..%.' c " ' . , , [ N .:.. Aw. 3 .. a s . ' .f ' ? .,.; D ; . f: & f t . , I
- . .j*l f* .b_,j, v,
. h: [3 .s u{< . . . p#s %;.. s'.,khp 4 . '. .f."
r .. L
, , .m.: . - p_l,,..,. _ r
.L -
'~'.
n a
, dva .
. l(%.g g4 .m. ;..
,q , .. :-
.y a g; g r y. .y .
5, : , , ,
. ~~*l' ' J. , E
' C, ..-7 w 4d. . % <x
.a .- _M..
0 . ..a
.[,- .jy ,.
% C;r-f*f ^[' , 'y .,~. -w * ,. ' .45 ,.. ., - v ~N O ! .y -, . . ' x.. -..~a. :
5f.'
~~
Yb. . . ; m%. ..,. .c , ; .'. ,'
- ( N' ya .m,.
.+ .
.. ,~ p f
+ v. n y .
m .' - ., ,
,- .w.e. . '.y..
. , ~:,. -l r W- s.:. .g
.,e s . [ -
. .? 7 - ., a ,g2nV-
. .s . .y .9 .;n! s +,_ . . - ;,3=yi. .f ~' . . c ;p:
..n >v - .
n.%. 78, s /g . b f) Syj i .
.. ; ;e %- . a -- : 4'
. " ~m. . '.
$ ~ ' ..e o. . 4,
[. v)+s[ .' A P*~ . I. e
- ' , Y. # .a... '.O. -. .-
~ .- ..
' p '.i -f $ ; # ' Q ..n'sj.Q
...,w -
e ,f.+-r n* 'S ,j,* T.'y h k'[ fdgHFf. , I' ..,.s . I ee > y,$.~ 4.'y ., gt!> 1 6o .-:,p.a,. t..- ' .:. , J Q p * 'l'
.. e )yy *m?f 7 f[AEWE A* { j N j. T , !Q . ~ e- , .-
' . -; .'. . ~-
j - y .f. ( ' ' n. - <:.- ri e 4 .
-c
" ,i ' , I t.{4 1 .
. ,,1
~
Q^ ' ? { ; ).* 1 f+4' ,, 6,.- ,, , .9 D, 'f' ..
..h: <* .+ .
. . ,- 7 ,' '
f &> ,*i*f[ '_
- ,;; .u:~
$. e , , - - ..~
.p
,-~x .<.
- . ,. . ,". s
~,. ; . v. y ' . . '
'. * .'" g . >yo ,
J, b ? . ..' ; ..
- .;** -[ *
- g% - .
- ~. '(. g
; , y
'ff ~-
. .,[
s.1
# -w~ * ,,g * .
. , 9 ;i p f 1,*- g4 a
~p
.'[' '"% - :.
E .m . g_ e,? Q}.
'4 n
.: i
,:.yll$-, -, ,ltt
- e. ; ..pf _,g. '-. "f,}. , .. . e'y
.at' - ' , _ ' _ . . _ L . ; .y. = i... +
# [ u w sQ n; 4e, -' * , . .)
..e sr '4.. ,2 ..
z
',4
. ,,' * . [ ig .
q' * ;; Y '. ' ~ - k n , , x'., .: p.- : .,..W
, 7 3 _*_ .v. - .'
4
.; p f
+ . a _;.jp ' 4 - ..a .'... ~ -3'
?
. . y . ,. g:,,- '~....: .. -
s
, " m
- qj b
- s. o q q m
. >w#
S.' < " - ,% R- %. -.* . ,. ...
..y '.h; .
' , ~
R.f: "Q,, _ .'_e 1
.. . y :Y:by , .
' p. : . . .
.f
- 9
%, s.. w , . .h ,
- v. .e (-
.t . f 4- .[
s .
'g,,.bp. , . ' 'y ,,
.-. , . . . . '.#.: ~.n ',j t e. q ,',@4,, e
. ..,,,L.
}v% . - , , .. .*- ,,- , .
~~ . :- ... .y -/c , . ~
;*;:&s r., . g .n. 7.fy ' ,- ~ > L. ' ,.-.y-'W, < ft, 3 ? ,.
5
~
..~.v , g-.;r a
+ ^ . .,. g - w . . - . m.
,hg t -
-* ,. - ': .v.9- ' .
.p,'y ,,'~p?7} N
- v. , '. ,.e ; , . , . a.
. . +. , . n, .'., , -m . . % + e.
- +3 t. *
- g. ,
3*. ,g,..,-4 . g' .
.=4..,,<. ,-. * + , ' .,y- 4.* .ya., .. w -;. ,- ). . '
- t , , .
, ,. g . , s
* , 'w4. . Q g'.. *(1' ,' *, .. ~ .
, W.'"TQ +
*<. ; %- ,.,a?
e
~5.fhk .
. (. ,. S
'., f,
,~.
* ' a ,', . .s.j;.
- s. $
.s tn 3 ,, v
.,W ;. vvg 3p .-[,j.-{ s.
t'
.,;- . . '~c..+ 'n " , f- '. :} h y'..: .
,'%% .y g '
- f. = . y e 4 .; j:
4 % . , y
. . .. . g g'
, %5.* . . - ., 4 . .
# v .. A
,r m. :.
. l , , } 'm.} .. $... ',,k..., g; +' L
~
; w..- .g '= - N4 'h . . . g. . .
'.' . :. - .: --' .p, .. r ga:.
S -
. l. , . l a.
- -j. >. n6, a.. t} '., zz .) j. 4.Vv e
.s ; , ,W: : . ,. . -.- d . n 8d .,..4 O 'd .(. ~, ,,-
4 . ...,.s -v :s;.. :t.: .c..%
.n .
t- 3f r, . ft .
.i
- n. ~ ~. '
^
. ~ :.;(s . I. 0, ' . 1 . w. -
M,.o.y . 9, ;. ., .gf . Q+g , [D hh i$& y ,* , t
-a , y , A e <., 9
.~. s, g i p. . ., -,. :: . . . - .
z
., . .(. . . . , . , ..
.Ih
<+
m v, . x e. .ityn., . .' ',. 1 t
... y 'j .*
.e 4 e,
s q. f
,a ,
w,
.-'.q ?
. - 2 ;; ._,mp,
- 7. w.-
- pA
, . A ag.,w- y- , :
+. fe.
m m. w w 1
a
- g -
' " . al f
,,a. K. '~' p..-
e[ ~d' p..y . %) f _gR, - ..
; ?. .m.t 'Y
' , f .' . .. .52y9 h f[,, d .'
s -4 s f.,c :
): ,.,y.,,,([
A.f ,s.:4
-= '.k ~'~ p ;p. v,i 'p ; y _ L ;~. 3. % ,. ~. . ,,;. w p ~.-wn.
' ' .c
_ ~u - T. L;. - T- *' '
-' ; . h ,-_ ' "
. .,"4... j . . . ..1--' , , s ;k . ,- 'f' -. $,ehr.n- -Y
, ts- ,
.v
* - p @, r" , si
. .,F... y i,*. ,
N g.
' . n , ; n. , , n. -V ' , p
,f .,[f .,, '
s - ' s, / " ,a
~ ? * . .
[o . ;. . e
.* ,,. x- ,
+ t .A
- W4
, y , ;"' s ,.y.',' ' ;
n , .
-, t w%. , . . j-..,'e ,- .a , ' . 'j..
~ %, .. ,, , . ,N,.> ,
Nz
' a. $ g&p+.V'. :j", *.
,g'?
....i -4
_.,c. . py= - &l8. 9 *
,,5
- r -~- - < ,. '.'. _ p- ,--,e
;~
.. ; 'n. s, fiig N -
;. t '.{.j!
r- ._'? ,1 ,* -'.- f. .~h . .. .F # . . ,#( Y'
/ .Q. ' ' * , . :. , , ,.. ~ ' . , . .
a ' ' , , . [ '."f ,e . '.'3 .'- f .i '2 c .)
' 7 # '
Y* ,,. '
~ .
/- g' - *
- T
- t'
.f
%,u g
t
.. +
' ',5 ~ .
8,4 5,. - J
>f . , ' ( W' , t i.. .'9'"
4W,t ,,}4* q .. <
' : .., 3 ~ k' % .
' lsg ;"*t- ' . , .-* d :ge '
p pp ..s f 4 ' \*.'..",.-
~g
*" I yg .., '
% 4+ . , h^
,,,,n~%..,, h' ' [-' ' . t Iy!* ' ' ' 'i '9 %f ; ,_ ' .g
.y . - t s :
L.,..' q' '
- .:. . - . i a ,,,,
;, ,j _a :.]^3'Q v,
1k .1_ . , a.v, ., J'.."~
' #- % ,j.,, , - j- $.h[' v .,.9 e
?, . .. , - '. l ' ' ,. l4' .;. ;
p.K , . . . '"
- - l.f g ': :n ; - , . :l . . . u .; .
.&,,. . %. & l. , :,:l- -
r ,
. p _.
- , *' i 4 Q*, -( , .,..
u G,pp .w j - , ( , ,l*$ , ,
- s..,.
y
~.\ *. @eT,~ ., . , . ,.a,.f ., - . j , . .s,a i . , r >
;, ^; g c.,
,,' y k.y
, *.,, ' l ' ', )., - ,
,. ;'4,p .. * .
Fw 1 _, n .
.g .
['. %n.,? ,-).g_ i'. , . ~p{ gf-
-.s.
9, , ,,
,, . .,W Q ' ,,
e ~
\, , , ,, $ ' , } ., ' * - - ,
,g., ,,".f '._j, ~gj , .
,',..R,., c.
. w:3W
. p ..s*
a g.
, . ~ . . , _ j'
+ .
- ; q.,,, .
; :.' ^r 4 A ' .g i , -
. ? %.
,( ; ~ y[ ' . ,} 7'e c q. l n'.
K
. [- _ !w 1y
'9 . y,3 ;-
+-[ -: a v .. c %
l
- g. :
,s _ ; : r'y ., q c ,'
y-
, . -- . ' :e , .c., < r. . b. 4: y- - ' . .
..:.n . s.
,',.l . .
[,? .2[ w . 7 _ F . 4;9 * [.)
'}. ,, ;.
"- _- ar
*1' .- ..
fi $ %' U. I y .' .-. .,
.Y C f 2(' 4 '
' ,Mh
- W ~ ' % . '.
' ~
J
'3..
'. ['_ y-< -
.. ?
e s ' :4 s q.,'z-i i
$ 4..' -.[- . _ - %,, . . S ~ o. -
. , ;.., . - ., ,3 g..,..," 5 ,- *,. s- 4.f
; I r n p
\'@ .'- _ g .'. ; .- -- . . - , .- .4 g 4 k . f
.,s .' ,
n' I ' [ . ! . y ;. :
> :- -- ,! 1) . ,. -i . -.. +
'l "4
- s. .;.gQ..,.. ,_ , .
. .u f .
s_ ~ . . .
-,, ..5. . . . ..e n ., g .
.w
,.g i
,, y a:.s. .
' .. ' . ,; ' n m, s. t
- y, ..:.',.,,1..
.. -p v.
-ur~g :
s,- ., -
. - . v ,. .
...,,-,5, b *,%;- m-
,f'u ..'.AL~. .. ,, . r: r .~;^ j ; .
;-[% g- f , .-c,* f ,. . % ,
a, ,,
' L - ,,
, . y. , **
.y,.. .v. . , . . . .
p}:'?.:. ,. w ..,< .- i.. . ~ . . . . > , - . . n.
~g ,_r \ ,l
~ .'- ,. ,
- $,6 u? i . .
p . 3. ~9
~
. , ' . , . _...j ., .-
.~ .. . n (.: . , .
~ , y,.ef .. . + ,
,s
, ,,g ..pe ,,
+, m, ,- Af(, ,- - .
v ;. *y . a- g r, L. 9.,_ f. 5, x
. a w.,,- .,,v-7,. ' Qy 1..'>t'.
?
- -, . % ., y . >- 2.
.g.: c
%,',+, .* ,,
.} - , i .r
. ,* 4 , . , ; '-
- 4,llq.;* g' .
. .. m
.,, t
- y. : ,- . , + '.. ,
. .: c
- p- . *, ;,,;c. , -vi . , .
y.. -
- s. .
U ' h,.I ~ ' . . t i *[. ' ~ ~ gg ,
. f.. y, -.
n
.,.. ,s a,.,. 7;.-4e '.A ,$...h[.
f..., a- (
' ,,.; , 4 ;t-
,,t,.,.4,.r% - 1 t, , ,s ' /> . .y.,.
s
,.; + 3*, y. Ap. - J 3
) .. ~
a ['fg , -j
., . _,
- P .
%W
.- , ; - ' . ' ' ,* }.<c '; x'Q
- u. .n, .
- ...*:... $' \ s .')W
,s .
v,s,.*.
. p. ., W. ^
- v. .. . . .f m
.Q. -V.., - .4*. ' - .- .. .
, ., -s .
- g. .
. :. . y..' - ' , - '. . ~ *. .. K .. y. ....: ,.
E ,. _ ..
- ;* . .?- r,
+y, ~ -y%f;. . ; , y, a ,. O. - n - %i "a
- A
. +f.?. de - .-k,'.
,; '. '.. g .+ L, - . . -
j l
~ .: .3 s, . %. < L;,.
.y% , ~. . . . . , (. . . ?
x. y
'., .p4. .
t.w . . , .1 .r. wa - :I s My ' . ,~uA g n - ',i @.& , ..-,-" , , .. u..p? wf. -
. .. . . ;~ .,
5.. s .. . , .. w " . ,. ' + % ;%. e ,. .n M;g ;3* . :...M.7 1,5 e){i 6... ! s -C .
._.4:n' ; y, .p, , - r .c .- y - -- 6.,,
- 4. r' c i, .--
v - +. -
+
- f u%y}.,
z's 4 . : ,;, q.
%, i ..
A . * ;. ,_ .s < .
^ . y
, ,
- y' y,' 1 . .,-
.. t . , g. ,. .
. }. .M : . -
.-<.s .
m y y ,. . ~. - ' . ; .; _
.. a.
+ ;
; , 3 ;
- z.
L + . .t;- ,p% .
- 3 r4.,
o . n.,7 ..; xt- ,y;
? .
.-.,.a -
~k
,t , 4
))
. . . ,, . . . ' ' . , _.- g a . s"i %
- s. . e S. .
.u . , - ... ..
< . , . f .,, - 6,4 , p %e .. , , - >
,. . .>-. .<r $;by t .,,. ,
,y,,.. _ . .-' ,. *. , Q; , *
- ', ' +
~3sg s.
. .&. 8 f. g .3 9)*eC ;. . ,K. % f. ,
,5, st *: 3.
- ". ,aJg %.
s>
,...,;si~~^'*,,-~+-*y ,.
s'.e.(,~' s .. y -Q e.r* , . ..f sr
, '. .- , ',..,.\*
. './ , ' ' +'
.-
- n . ~~ N ;
. g_
*h p . :'f h
.1 -.' .f . - k, i 's r.
*=g . ,.* , ,.Q 7 - . , k4%. i .~- 3....x. '
o,- A'"'. T+" .4. .# 3..,. p.. ,&,
.-.-f- * .j., tV
- r . . k .1.3 W 3
.. ; ~,
s ,,., . . . t 8'. p g
e g . 'h % .. ' . . . , ' -c ;
;', s%,n,b. : *' O > ~ <. .
,4 S . 5. *3 r i 1., '
. ; N( - ,
[. . . . - i..- .
?, .
N. z.(.) .' .* g, O. s,w.l ' %w ,, y ._,s. - (g',(7 .W,'?*. i 'r ' .. o a,.g-
.,. ' * +-
. . . . :+ .,%. . , . .O i.. : lQ .W *
.~ ~. ,&.~ f. & f,r.. Y'.W h Wa%t ,~ ,f *li
- .c,"'.4,y' 45. . 1.. .,: *::
. ,e
,4 . t[,
p.u. ' w. . *:.,.w. . u 4
.s e
-J'
~
g," e '.' ._ . ..
. lj N ,, - ,
f .'
, . * . lf* .y
,' p'i'\ '. W .
'[* l l '..
4 0 ?y
};-
i' l j g :.Y h k lh f h
&a. f ~& wl 1 l . h f f.s,.j% ; ,w.-w. .u m 4 ~ m% d ,
&..v.
s.nmsw 4 +. w}l D - w% , . nu .e i
- A
-h-- p g 9 4 )
-u h_
e ', c
+ c. - ,,
r Y
- ^9, 6 L *i/
C , 2 a
,, , , (-
- 2R, }'
- s. )1 ;
}, -
+ .
e
/5 o
4 i ! 3. CP-QCI-2.4-9, " Inspection of Elastic Joint Filler Material Removal," Revision 1, dated December 12, 1977.
- 4. B&R Inspection of Elastic Joint Filler Material Removal, dated January 3,1978 and December 15, 1977.
- 5. 'GTT-1543, dated September 16, 1977.
- 6. TUS-5012, dated October 7, 1977.
- 7. IM-14835, dated July 18, 1978. ,
- 8. IM-12934, dated February 19, 1978.
~
, 9. IRC-7706, dated Octob'er 17, 1978. _ ,
s- 3
- 10. IRC-7707, dated October 11, 1978.
- 11. IRC-0320, dated September 14, 1978.
- 12. IRC-0319, dated September 14, 1978.
- 13. IRC'-7705, da'ted September 20, 1978.
- 14. IRC-7708, dated October 3, 1978.
- 15. NCR C-83-01067, April 13, 1983.
- 16. 8&R Field Measurements concerning "As-Built on Concr.ete Inside
~
Seismic Gap @A-F," 5'pages, dated between March 15 and 24, 1983. *
- 17. GHF-2390, dated January 30, 1978.
- 10. This statement prepared by: -
/rrth /9 C. Hofmahr, Tk Date -
Technical Reviewer Reviewed by: L. Shao, Date Group t.eader Approved by: V. Noonan, 'Date Project Director
.. :a. . -:
. . ,;. . .. -(t . , _. ,.,;-: .7. f ..;. ; . s;g .: .. . 1 '. '. . -
*..: w , *:: .<.-
- s ..* -
- M.t
I- 17 r' ) p'a}'/ C' ' j SSER WRITEUP DOCUMEtiT C0tiTROL/ ROUTE SHEET , Allegation fiumbers b C - 3 o . AE3 7 ad AIX-17. Ac 7:3 Ac-3 4' c-col' oc co4' /%-a Subject of Allegation re k ' i - P' 3 % 6 me kd ,, w . 6 . ,. a c.vJ 4r > 1 n l TRT Group - Author: M - < < tj L5 g w4 k 's This sheet will be initialed by each reviewer. It stays with all revisions to the SSER writeup and serves as a routing and review record. It will be filed in the work package when the writeup is published. Draf t Number Draft 1 2 3 4 5
%L 9-U . CC.9-It-M CI] D 18//d' Author 0WN &5lSti N L%T)Q 9ht114 -t ,i Thl- blST Group Leader WE/U pf/) 4//r]&t/;M ll/w WW7 Tech. Editor I (GEDME '~
C4 Al // Wessman/Vietti J. Gaoliardo T. Ippolito _ Revision Number
' ~
Final 1 2 3 4 5 . Author Tech. Editor Group Leader J. Gagliardo T. Ippolito Administrative Writeup integrated into SSER Potential Violations to Region IV Workpackage File Complete Workpackage Returned to Group Leader t r- .i :n ep, A 0%' '. i u ../.
.v c.e -
. ,i 2o'3 9 ,
1 .w - _- A _Q- W-
I . DCP5 - SSER AC-30, etc... DRAFT 5 - 10/24/84 SSER
- 1. Allegation Group: Civil and Structural No. 6 Rebar Improperly Installed or Omitted
- 2. Allegation Number: AC-30, AC-37, AQC-12, AC-38, AC-39, AC-49, DC-003, DC-004, and DC-005
- 3. Characterization: It is alleged that rebar was not properly inspected upon receipt at the site (AQC-12 and AC-37). It is also alleged that reinforcing steel (rebar) was omitted in the following locations:
- a. A 6 ft. x 6 ft. section of concrete in the Safeguards Building (AC-30).
- b. The Unit I containment structure wall, specifically horizontal
" tie" reinforcement (AC-38).
- c. Four column faces in the wall along column line EA of the Auxiliary Building (AC-39).
g __ -e A * #8*. * *
- In addition to these allegations, the Region IV resident inspector requested that the TRT review the following possible reportable design deficiencies involving reinforcing steel (rebar):
- d. With regard to DC-003:
(1) Rebar was omitted in a reactor cavity concrete placement between the 812-ft. and 819-ft 1/2-inch elevations in the Unit 1 Reactor Building. (2) Brown & Root con.struction requested a change in the i configuration of two rows by nine layers of No. 9 reinforcing bars (2 x 9 - #9), as shown on drawing 2323-51-0572, Rev. 4, to a continuous circular arrangement. (3) Because of interferences with 14-inch diameter sleeves, the horizontal tails of No.11 vertical reinforcing bars within the triangular columns surrounding the reactor cavity were modified to clear the sleeves. Also because of extreme congestion within the columns, stirrup details were modified.
~
..- - . :L:.2 s . . > . ~
- e. With regard to DC-004:
(1) Six No.10 additional horizontal bars were omitted from a beam above a construction opening on column line KA between 6A and 7A in the Auxiliary Building. (2) Nine No. 9 and two No. 4 additional reinforcing dowels were omitted around an elevator shaft door in the Unit 1 Reactor Building.
\
- f. With regard to DC-005:
. (1) Forty-six No. 9 dowels on the face of the wall in the excess letdown heat exchanger room in the Unit 1 Containment structure were omitted.
(2) Ten No. 8 additional horizontal dowels were omitted from a beam over a construction opening in Safeguards Building No. 1. (3) Brown & Root construction requested authorization to substitute No. 5 vertical wall rebars in lieu of the No. 8 well rebars required in two corners of a wall in the ! Auxiliary Building. _ _ . _ _ _ _ _ _. . .x ._ - -
. . . z. m .
_. m m. .
- g. Finally, it is alleged that reinforcement was installed upside down in a building near the Unit 2 containment structure (AC-49).
- 4. Assessment of Safety Significance: The allegation that rebar was not properly inspected upen receipt (AQC-12 and AC-37) relates to the use
, of weldable reinforcing steel associated with the installation of radial shear-bar reinforcement at the base of the containment structure. At this location, Grade 601 inch x 4 inch steel bars were joined by full penetration butt welds to No. 18 ASTM A615 Grade 60 reinforcing bars. Gibbs & Hill specification 2323-SS-10 required that a special chemical analysis be performed on each heat of reinforcing I steel which was to be welded. Upon receipt, this reinforcing steel could be identified by the results of a special chemical analysis attached to the mill report. QC personnel would then paint one end blue. It is alleged the No.18 Grade 60 reinforcing steel was used prior to ! the proper inspection upon receipt by QC in 1975. The TRT reviewed testimony taken during an interview in which the alleger stated that the QC inspector was pressured into hurrying the inspection process and that the reinforcing steel that was used prior to QC inspection was subsequently inspected and signed off by the QC inspector. The TRT reviewed the receipt inspection reports for all No.18 reinforcing bars reviewed in 1975 and determined that three shipments were
received that had a special chemical analysis attached to the mill report. The receipt inspection reports for these three shipments were signed off by QC, indicating that an inspection had been performed. However, the TRT could not determine from its review whether any reinforcing steel was used prior to QC inspection. The TRT's safety assessment for the remaining allegations and reportable design deficiencies are discussed below:
- a. During an interview with the alleger, the TRT learned that the allegation of missing rebar in the Safeguards Building actually referred to the return pump station at Squaw Creek Dam (AC-30).
For the detailed assessment of this allegation, see Civil and Structural No. 12, AC-29.
- b. This allegation (AC-38) was first reviewed in NRC Region IV Inspection Report No. 79-25, which refers to the omission of horizontal tie rebar in the Unit 1 containment structure, and concludes that the alleger was referring to an occurrence in the Unit 2 containment structure rather than in Unit 1. This event occurred shortly before the alleger terminated his employment and it was assumed by the Region IV inspector to be the event to which he referred. The omission of horizontal shear tie
reinforcement in Unit 2 was originally investigated in Region IV inspection report 79-18, which notes that this reinforcement had been omitted near the junction of the containment wall and the hemispherical dome and was subsequently placed at a higher elevation. An analysis by Gibbs & Hill (G&H) concluded that the structure would be capable of carrying the design loads with the reinforcement in the as-built location. The TRT reviewed all 33 concrete pour packages (101-5805-001 through 101-5805-033) pertaining to the main concrete placements in the Unit I containment wall. These pour packages contain rebar placement checklists which document the results of inspections performed by B&R QC confirming the placement of the reinforcing bars to the applicable drawings. The TRT found three placement inspections in which the reinforcing bar placement was initially checked as unsatisfactory; the problems were then corrected and the placement was signed off as satisfactory. The other 30 inspections performed were all checked as being satisfactory in that there were no deviations from the drawings,
- c. On October 27, 1977 a Nonconformance Report (NCR) C-805 was issued reporting the omission of twelve No. 8 vertical wall rein-forcing bars at four column locations in the wall along column line EA of the Auxiliary Building (AC-39). The reinforcing steel had been omitted between the 810-ft, 6-inch and 831-ft elevations
and involved four separate concrete placements made from May to October 1977. This information was submitted to G&H engineering for resolution. G&H performed an analysis which showed that the columns remained capable of carrying the design loads without the missing reinforcing bars and further directed that the bars be omitted from the columns for the remainder of their height through 873-ft, 6-inch elevation. 4
- d. (1) The reinforcing steel that was placed between the 812-ft and 819-ft, 6-inch elevations in the reactor cavity wall oftheUnit1ReactorBuildingwas$ompletedandinspected to drawing 2323-SI-0572, Rev. 2. After the concrete was placed, Brown & Root received Rev. 3 to the drawing showing a substantial increase in reinforcing steel over that which was installed. G&H engineering was informed of the omission by Brown & Root Nonconformance Report C-669.
G&H engineering replied that the omission of this additional reinforcing steel did not in any way impair the structural integrity of the structure. G&H stated that the additional rebar 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 l
I reinforcing steel was placed in the next concrete lift above the 819-ft, 1/2-inch elevation. G&H stated that this was done to partially compensate for the reinforcing steel omitted below and to minimize the overall area subject to possible cracking. The TRT requested documentation to indicate that an analysis was performed supporting this conclusion. The TRT was subsequently informed that an analysis had not been performed. (2) In response to Brown & Root construction's Request for Information or Clarification (RFIC) RBCR-37, Design Change / Design Deviation Authorization (DC/DDA) No. 832 was issued stating that the configuration of the 2x9-No. 9 reinforcing bars (two rows by nine layers) as shown on drawing 2323-SI-0572, Rev. 4 could be changed to a continuous circumferential arrangement. The TRT reviewed this drawing and determined that these bars were among
, those omitted in the concrete placement between the 812-ft. and 819-ft,1/2-inch elevations and subsequently placed above the 819-ft, 1/2-inch elevstion (Seed (1)
- 2 r___ __*_ _ :: a - c: ~2 w _.
~ ~ ~ '
- ~: 'L
^
.~: T: :%
_g_ above.) Revision 4 shows each of the four sets of No. 9 bars used to form the configuration required were to be bent in two places to form an approximate circular configuration when placed. The DC/DDA stated the bars could be bent to a specified radius to form a true circular arrangement. The change, therefore, only affects the way in which the bars were bent and does not reduce the load carrying capacity of the structure. (3) During the placement of reinforcing steel within the triangular columns surrounding the reactor cavity at the 826-ft,11-inch elevation, interferences were encountered. The horizontal tails of the No.11 vertical reinforcing bars were interfering with 14-inch diameter sleeves already in place. The TRT reviewed DC/DDA No. 6918 and the attached sketches which showed that six bars were cut l and replaced with bars tailed up to achieve total anchorage and three bars were bent down to clear the sleeves. Also, due to congestion problems, the design of the No. 4 stirrups surrounding the ten No.18 circular bars was modified to allow for installation. The stirrup design
. -. :~. r, v a .: s y W* , e f. '
i was modified to a two-piece design rather than one piece, as originally designed. This modification was permitted only within the triangular columns.
- e. (1) On October 26, 1977, a nonconformance report (NCR)
No. C-809 was issued by Brown & Root reporting the omis-sion of six No.10 additional horizontal reinforcing bars from a beam over a construction opening on column line KA between 7A and 6A in the Auxiliary Building at the 831-ft, l 6-inch elevation. G8H engineering issued DC/DDA No. 558 i l in response to the NCR. G&H engineering stated that the I i reinforcing bars were not required provided that one of the following conditions was met: (1) shoring remained 7 within the construction opening until the slab above 1 831-ft, 6-inch elevation and the wall along column line KA above this elevation reached their design strengths, or (2) slab shoring remained adjacent to the construction opening until the concrete used to close the construction opening had reached its design strength. The intent was
- to provide adequate support to the 831-ft, 6-inch slab from either the wall above, the wall below, or from shoring. The disposition of the NCR showed that the shoring was left in the construction opening until the
.,m______ _ - - - . .
concrete wall and slab above had cured. The TRT reviewed the design change and solutions proposed and finds the approach taken to be satisfactory. The TRT also reviewed drawing SAB-00711, which showed that the construction opening was closed with concrete pour No. 002-4810-042 on January 30, 1979. (2) Brown & Root issued NCR No. C-810 reporting the omission of nine No. 9 and two No. 4 additional reinforcing dowels around the elevator shaft door in the Unit 1 Reactor Building at the 832-ft, 6-inch elevation. G&H DC/DDA No. 477 indicated that the nine No. 9 dowels were to be drilled and grouted in place, and that the two No. 4 dowels could be placed without doweling into the slab. A l review of the safety implications of the omitted reinforc-I ing bars, by Texas Utilities Electric Company (TUEC) Design i Engineering showed that cracking of the concrete in this area could have occurred during conditions such as a l seismic event if the reinforcing steel had not been l ' , placed. The review concluded that the cracking would not have affected the safety of the structure.
- f. (1) On October 31, 1977, NCR C-811 was issued by Brown & Root reporting the omission of 46 No. 9 dowels on the face of the wall in the Excess Letdown Heat Exchanger Rcom in the Unit 1 Reactor Building. The civil QC inspector involved stated that the reinforcing steel had been installed and checked but that it was subsequently removed to allow for the installation of steam generator lower supports and reactor coolant pump tie supports and not replaced. G&H engineering directed that the dowels be drilled and grouted in place.
(2) On October 21, 1977 concrete was placed which was to have contained ten No. 8 additional horizontal reinforcing dowels that were to run over the top of a construction opening in the Unit 1 Safeguards Building. NCR C-815 was issued by Brown & Root reporting this omission. In response to the NCR, G&H engineering decreased the size of the construction opening in the 7-5 wall by placing a vertical construction joint 1-ft, 6-inches from the east face of the C-S/7-S column. Decreasing the size of the opening allowed the ten No. 8 reinforcing bars to be placed with sufficient anchorage length developed by hooking the ends down into the 1-ft, 6-inch space. The
e TRT reviewed drawing SSB-1065, which verified the decrease in opening size, and also showed the concrete pour numbers (105-4810-018 and 105-4810-034) for concrete placed in the 1-ft, 6-inch space and in the wall over the opening to the 829-ft, 6-inch elevation. A check of the rebar checklists included in these pour packages showed the rebar installation was' inspected and accepted. Drawing SSB-1065 also showed that the construction opening was closed with concrete pour No. 105-4810-019. (3) Brown & Root construction issued request for information or clarification (RFIC) C-1987 on November 3, 1977, which requested authorization to substitute No. 5 vertical reinforcing bars in the wall 5-ft, 4-inches north of column line 3-A for the widths of the column line F-A & G-A walls (corner bars) in lieu of the No. 8 bars shown on the drawings. In assessing this issue, the TRT reviewed drawing 2323-S-0751, Rev. 15, which showed that the vertical bars in the wall 5-ft, 4-inches north of column
. line 3-A between F-A and G-A are No. 8 at 8 inches center to center (8 9 8") each face and that the horizontal reinforcing is No. 6 9 8" each face. The TRT also reviewed drawing 2323-5-0746, which showed the walls along
column lines F-A and G-A north of column line 3-A to be secondary walls. Drawing 2323-S-0785 gives the rein-forcing requirements for secondary walls when the rein-forcing is not otherwise noted on the elevation drawing. The walls along column lines F-A and G-A north of 3-A are 1 foot thick and require No. 5 9 8" each way in each face. The No. 5 bars as installed in the walls along column lines F-A and G-A are, therefore, acceptable. Drawing 2323-S-0785 also indicates that where two walls intersect, the types of vertical corner bars used should be based on the thicker and/or more heavily reinforced wall. The four bars in each corner should therefore be No. 8 based on the reinforcing in the wall 5 ft, 4 inches north of column line 3-A. The TRT reviewed DC;?n! 518, Rev. 1, dated November 9, 1977, which also verified that the No. 5 wall bars were acceptable and further stated that the No. 8 vertical wall bars were to be installed in the corner as required. The TRT also reviewed concrete pour package 002-4831-017, which showed that the reinforcing steel
- installation was inspected and accepted and that the concrete was placed on November 11, 1977.
_ _ _- _n________ . - - - ____ _ _ _
- g. The TRT reviewed the April 10, 1979 transcript of a Region IV interview with an alleger and identified an allegation that reinforcement was installed upside down in a building near the Unit 2 containment structure (AC-49). However, during the interview the alleger claimed that the problem had been corrected prior to concrete placement.
- 5. Conclusion and Staff Positions: For allegation concerning improperly inspected rebar, the TRT concludes, based on the fact that the reinforcing steel used was accepted by QC, that this issue has no effect on the safety of the. structure.
The TRT reached the following conclusions for the remaining allegations and reportable design deficiencies:
- a. Allegation AC-30, which refers to the return pump station at Squaw Creek dam, not the Safeguards Building, is examined in Civil and Structural No.12, AC-29.
- b. For AC-38, the TRT concludes that the horizontal shear bar reinforcement was placed in the Unit I containment wall as required and further agrees with the conclusion drawn in the Region IV inspection report No. 79-25 that the allegation refers r c__._...
t to the Unit 2 containment structure, where the G&H analysis showed that the structure would be capable of carrying the design loading with the reinforcing steel in its as-built location. Therefore, the TRT concludes this issue to have no safety significance.
- c. The TRT reviewed the G&H analysis and agrees with their methodology and conclusion (AC-39). The TRT, therefore, concludes that this allegation has no safety significance.
- d. (1) The TRT cannot determine the safety significance of this issue until an analysis is performed verifying that the reinforcing steel in the as-built condition is adequate.
(2) The change made to the No. 9 reinforcing bars did not affect the load-carrying capacity of the structure. (3) The TRT finds the modifications made to the interfering bars to be acceptable and to have no adverse effects on the safety of the structures. _ _ ~. -
- e. (1) The TRT finds that the omission of the additional reinforcing bars will have no adverse effect on the safety of the structure because shoring left in place until the concrete had cured made the additional reinforcing steel unnecessary.
(2) The TRT concludes, based on the fact that the reinforcing steel was subsequently placed as per the disposition of the NCR, that there is no adverse effect on the safety of the structure. i
- f. (1) The TRT concludes, based on the fact that the dowels were subsequently installed as per the disposition of the NRC, that this incident has had no adverse effects on the safety of the structure.
(2) The TRT concludes that by decreasing the size of the construction opening which allowed the reinforcing bars to be placed with sufficient anchorage length, this issue has
, no safety significance.
(3) Based on the fact that the No. 8 vertical wall bars were installed in the corners as required, the TRT concludes this issue to have no safety significance. W H
' ' " " * " --~ g - . p ______'o@ *_ , _ _ _ '
- e w **
*9
- c-
- g. The 7 T ccccludes that sirce this instance of imp rc; e rl, I irctalled rebar was corrected prior to ccr:: rete plex ' '. , t' s iss e has rc ad.erso ef fect cn the sa fety of the s t r_ _ + s,
- 6. pctions Fquired: With regard to item c.(1), TUEC shall prc.i:e an cr.al.vsis of de e -built ccnoitior, of the Unit I reactor cavity that verifies the adequacy of the reir. forcing steel between the E12-ft and E19-ft, 1/2-inch elevaticns. The ar.alysis shall ccnsider all re:uired .
l l Icad cob 7tior.s. Prior to len ;: er c:eraticra, TUEC sha .1 ' s 'c r the ar.alysis and submit i t for W revie and apprcval.
,,, ., a y.-. e '
- y. ; - - @, ' -,,.g f e %'
{F ,pf .. ',,: _~cb'. 7 u ,f) : 'f' gg ',. , /f [ ',l! 4l{f ' ' ? / '
,'.3', f1 \ ,J ,. b 22 1-
, . . . " , . . 97
-.( ,
,f%, . Op. , . }}.,. l '. ~%
y 3 ,, f ,. - . ;\. . ': ,,q - T.:,. .h, A.._l, . ' .. ., , . ;n ;: '- . < g ?.: .
] .,'t}a '; 3^ :: ; 6, ,.;'<-{.q_b.h[,'y . .W %
+ sg. ' , : . . j , y --s' , , , . ;',, ,
. ', 4 f f . - e. Y . .. , _ - 't 4 _k .9
. 't
? ' :..! y4;:
Q* ' c. . .% Tc , ;. - % )s. - ?<.'*
.
- i .; _ . . . . .ll ' . ,. } ;. . ..l. %gcy.r e (
/ $,1: .+;. , .- . ;f3RR, f)f,_oy. .!l R; ank; '.. ' Qq,l. *;.
_,,b.if h? .. .* ..l ' ,' :[.< 'Ty..<G. ;: . .b
.\.;g p:N ',';-s. .-4 : .i
.p. ,g,j. g ;h[_c
+
,... s , . .* 2 -i sn . ?. ., s c- ,.L
- . s A'; * ,
3'. v. : . - _e
;, / ., ,: - ,l .- . 1. -
}'...
.y ' {'.
7 , ,
, , . , . ', . . - , _s : 7,,
'...,.f;.-
, ,'e> , [ '( 5, -f'
- .< . e -
V - ~ w <c'.q. 1. ..s.. . : ; . p' *Yk ,i ,.5.k
.-Q> [.L %.\ . '.' i YI *v *s 6',, 4- .l'. , . w . - . .' y * " ' ' ' . ' L'g . . . , 5
.4
-:S
~ . - y , .4 s a,%. 1 , 'f. . .: n9 .' ?.. ' .'.. p:
c .. n q . ./ ,:t. .' l , . :;:.'.. 7
.,...1,. , p n.; .c ,.- g . s.s - . -
3 e. ..1, , s. s e,s, .; b . .s...:. :::s 5 v
- p. -- . . e , ,s : w . -. ;. ;+ . yh,
._ e. , .- . L. T.ta. v. s n<: s . L a . : . e. 7. :n . :;<. .. e.
. - . g.
..x
.s..
ll ,
.,h.... - l "
.. .r
-{'
t . r.
. .. .-%.. <+ - . ,_r.. . .
. }. ',. *;-. ., . s b' . ,s. . ;: : . ll , z ...a .c
. .g. m * .&..J 4. c .'* v . . ' ,
. ;q.
j - ..
~
y , : y/ ~-;~ ~ w. ,, . . .y, :- x?
- , ll [% ..A
.f . ::, *: g.sq: y* . + ,9 '. ::. .fa . 9 W ys.i. * * %vt'.,, .. m _ . =Q .. .
Y . - s:
,,j.q. m
._. p.h. ~ . n . '. .- . . . . y ;nnt 'Qe,. s. f. *
~~**
', s ., '.% ,; -:
L s
), ' m ; _ ',[.l wQ . l y j. ,f,i; 9 'g ,, . ' '
s; ;.. lf. '} .
. ',!'.K, f Q:. l1,[- j -.. ',, .r.9i ' .
.',, . ~ ~ '^> ^ *:* , ,
m.,.. .. 1
.;' .- . ' . 9. . 4 . ', ,' ,flj k . , , f. [. .. '. -,gr_.i.. 9;. . y.
v- ,
. ~.:,',.' < ...
. h y '..w; , ,./ ~- *1 '
.'(' ,e s-y.: 'L - > ,p . . , , %.' h . . j J, .
s** O' ; ? , g
..' . 6 a :,
.Y% .;hij$ s.. ..y- ..:5. .l . .nh- l: "J . y ll l.,
X, ' . ;;,. ; f y .); yi-M c.: : ;. .. , G
.,.17..-..
. ' .. - .. - . s. i. : z .
u ' ,.2
.y.,
- w. .. . ~ ::. o . l . :.~.a W *, ,*. . .m, m . .@s
. . ' 9,:
'd,'.,,*,-'.'4*.
J - . .y ei ;- . '
,Ji, ' .'a ./ei,
t i : ,l .
; . . s.
s 1.
? Nf@;.,Q .
- " 4. Y ', i .'. h' p.x v; . s :igL..e.-; s f. ?~ '. y%
z.. L . ; :yYlE l&' fW {. .. ,'; nt.u' -l . . p ,' ' ;? ' . L:R l ' p,Q f . b ..n .;;. & s.l W. ? .:!..:.
. \
- i. ; n . . :: :
... . . . : .:. ~ 6 v. n., - :.:. + ;rb:n ;
R.- ,.
'_; 'js +?e' " '
lw. ; . ~ n; . .; .E. ;p . .: ,.
.p* ;. ; ,;',_ . . y . <
p . (---.'<
. , , ;. . ; :.,.; ;f;=
-w .m _' .,
.. _ _ . . ts V) g*.
.I
, .. _ . . _.*- 5 ,c
. f..A_.i.. , . . ,,
../..,,
. . , ' + .,m. . ".; , . :..
.-(c.
. . - ' n .u~+: h. . . , .- - s;
, 9 ,,. . . , :
j' ~ .. * ..t v. .y . ~ y.- ..: . , , s.,,. , , .. ;
.a.....'y
), t t i
g.
. ['t. .,g *
. . . . . . -. , ..: ...u l
- n. . . s , . .
. y c p, z . . , s. . . g ra. , . ., 9. . .. , . . .
.,3 ,
y . %, . . .'sf 44.
. n.;$$ W.. : i ' . , g 4 -Y ,
Y g5 l.. p ..d"f. 'l.c..., l *b.~- .Q;'f.vl.-f': * .f
, . T. k, . '
'^
f;.. ~ . . y ,9 6 v c - : R.
, f.fx w . a..l{ > ;, . . ; &Y W?f. . . r l{;9.
I
.( cl, rf d.f - lgf!f.
,A ml w a la, nze: h.j.'. f
? - ;,_'
.x wn gwsm ,
~ n::
h :.
~
yk;$W . f; .C : % ; m : M~
- w. m. L. d:.pf y p '.:A I ,? .e w ?! @ .
A .~..o... ~*w;g.v. ~ .:3.? y %w
- v. m:
4y.1 1'y.. . . ,y M w,.... v. o , g ya% r.e md=..m. m'..3 3. a ' w nm 1 1 l m.q,. _y
..e...v;q:% p~ g .h w n e e
1
4
- 8. Attachments: None.
- 9. Reference Documents:
- 1. Irnproperly inspected rebar:
(1) Testimony A-4 84-006. (2) . Drawing 2323-52-0505. (3) Gibbs & Hill Specification 2323-55-10. (4) , WES-12 Radial Shear Bar Fabrication.
- 2. Inspection Report 50-446/79-25.
- 3. Inspection Report 50-446/79-18.
- 4. DC/DDA 5536, Rev. 1.
- 5. Calculation Package SRB-122C.
- 6. Concrete Pour Packages 101-5805-001 through 101-5805-033.
- 7. NCR No. C-806.
f 8. Drawing 2323-5-0757. f 9. DC/DDA No. 486. l 10. Gibbs & Hill GTT-1697.
- 11. Gibbs & Hill TWX-1035.
- 12. Calculation SAB-124-C1.
. . - - - - . .a
1 l
- 13. Drawing 2323-S1-0572 Rev. 2, 3, and 4.
- 14. NCR No. C669.
- 15. Gibbs & Hill GTN-19823.
- 16. Drawing 2323-S1-0572 Rev. 2, 3, and 4.
- 17. Drawing 2323-SI-0574 Rev. 2, 3, and 4.
- 18. DC/DDA 832.
- 19. TWX - 1154.
- 20. DAX - 123.
- 21. DAX - 133.
- 22. RFIC-RBCR-37.
- 23. DC/DDA 6918.
- 24. Gibbs & Hill GTT - 4837.
- 25. NCR No. C-809.
- 26. Gibbs & Hill GHF-2078.
- 27. Gibbs & Hill DC/DDA 558.
- 28. Drawing 2323-5-0745, Rev. 13,
- 29. TWX-1067.
- 30. DAX-38.
- 31. Drawing SAB-00711.
- 32. Pour Package 002-4810-042.
- .- _-_ _______.____.___________.,--,___.x
k I
- 33. NCR No. C-810.
- 34. Gibbs & Hill GHF-2165.
- 35. NCR No. C-811.
- 36. Gibbs & Hill GHF-2183.
- 37. NCR No. C-815.
- 38. Drawing 2323-S1-0622, Rev. 20.
- 39. Gibbs & Hill GHF-2186.
- 40. Drawing SSB-1065.
- 41. Pour Packages 105-4810-018, 105-4810-034.
4
- 42. Drawing 2323-S-0718. Rev. 3.
- 43. Drawing 2323-5-0785, Rev. 7.
1
- 44. Drawing 2323-5-0751, Rev. 15.
- 45. Drawing 2323-5-0746, Rev. B.
- 46. DC/DDA No. 518, Rev. 1.
- 47. Pour Package 002-4831-017,
- 48. RFIC-C-1987.
- 49. RFIC-C-1975.
- 50. Region IV Record of Interview, 4/10/79.
.e & _ - . _ _ , - . ._ __ . . _ . _ . _ ._'. . _-
_. . - __. - - . - . .~ . .- - .. . - - . . - , . - - _ - . - 4
- I i '
j
< l
- 10. This statemer.t prepared by:
Terry Langowski Date Reviewed by: Larry Shao Date Approved by: j Project Director Date i F i l 4 3 i i i l l l 1 _ . _ . _ . . _ . . . .m. .
'! Document Name: 1 J., , SSER TEST PROGRAM 1 Requestor's ID: ,
r - PAT g. Author's Name: . Chet Poslusny Document Comments: 11/8/84 Final draft, rev 1
,;t
. ? .
~~
f
... - q s 4.9
. tF -
y ' Vf
$fo)-
o
/
l h f ,S l u/ kyf V *
)@'t , .
i% 4 V yq _ = _ b- -%-- -- - .
Final Draft, Rev. 1, 11/7/84 CP1/SSER Test Program SSER
- 1. Allegation Categories: Test Program No. I and 2
- 2. Allegation Numbers: AT-1, 2, 3, 4, 5, 6, 8, 9, 10, 11, 13, 17 'j
'l
- 3. Characterization: It is alleged that the NRC Atomic Safety and Liceiising Board (ASLB) can not make the required findings under 10 CFR 50.57(a) and TUEC caa n t be granted an operating license for Comanche Peak Steam ,
Electric Station (CPSES) Units 1 and 2 because of the following: (1) - TUEC failed to conduct an adequate prefueling hot functional test (HFT) . progFam,-in that not all components or modifications were installed which require hot f.unctional testing; (2) TUEC did not intend to check some (omponents and systems until heatup to hot standby or during power , escalation; (3')'TUEC and the NRC Region IV staff failed to notice this . condition and did not keep the ASLB informed of the problems encountered;' ... (4) numerous problems were identified during the conduct of the thermal expansion test, as evidenced by Test Deficiency Reports (TDRs) 853 and 855; (5) that the HFT was conducted without consideration of acg.ident conditions; (6) TUEC and the NRC Region IV staff were willing to accept deficient test results; and, (7) that the ASLB cannot rely on the NRC staff to monitor the test program or any reinspections.
- 4. Assessment of Safety Significance: The implied s'ignificance of these allegations is that if the. HFT program was improperly conducted, the ,
adequacy of the plant to operate safely may not be assured. The NRC requires that a preoperational testing program on a nuclear power plant be conducted to demonstrate that plant structures, systems and components nteet their safety-related design specifications, as stated (n'the utility's Final Safety Analysis Report (FSAR), before the plant goes into operation. The Technical Review Team (TRT) qonducted indepen-dent reviews on 17 of 25 complet.ed test records pertaining to HFT (which is a preoperational test) and interviewed cognizant TUEC personnel during 6 , . ,,. .
e .
. the course of this review. he revie'w' included follow-up inspeftl5ns on test deficiency reports (TDRs) that were generated as a result of testing deficiencies found prior to and during_,HFT. The TRT also reviewed pertlnent Startup Ad.ministrative Procedur6s, NRC Inspection Reports, the pre-operational test index with schedule, and a system / subsystem turnover 1
definition and target date index. The TRT reviewed this documentation . E
/r l
against the FSAR and the applicable NRC requirements and guidance (10 CFR 50 and Regulatory Guide 1.68).
- a. The TRT found that the HFT was conducted with severa M or com-ponents and equipment not having been inst'alled at the time of the ,
test and with modifications , remaining to be comp 1rted aft'er the ,
..t e s t,., ,
~
,Ther'e arc syltem'walkdown inspections conducted by Brown & Root Quality Control, TUEC Startup, TUEC Operations and the NRC to verify inst'aTlation of components and. supports. The TRT reviewed NRC .. .
Construction Appraisal Inspection Report 50-445/83-18 (inspection conducted January 24, 1983 through February 4, 1983), Inspection
. Report 50-445/83-23 (conducted May 23, 1983 through June 10,1983) and Inspection Report 50-445/84-16 (condu'cted May 14, 1984'through June 20, 1984). None of these inspections indicated that any s 7
undocumented hangers and supports were found missing. Therefore, y the TRT had no reason to question the adequacy or completeness of the documentation used to identify missing supports during HFT (or any other time). I The TRT found that all equipment required by HFT procedures was either installed, or documented as not being installed on a Test Deficiency Report (TDR) or Test Procedure. Deviation (TPD). A TDR is documentation of components and equipment which are found to be
.. ' deficient oF defective at the time of the test and fdr which some
! action must.be taken to correct the problems'; a TPD is an approved I change or deviation from the procedure as originally written. TDRs and TPDs become a part of the completed test record which must be reviewed and approved by the TUEC Joint Test Group (JTG). i
e
. Approximately 95 percen't of the 'T' DRs issued relative to HFT d5cumented piping and equipment supports and restraints not installed prior to -
the start of the test. For example, see TDRs 680, 722, 746, 747, 837, 1006, 1032, 124.3, 1244, 1665, 1674, 1724, 1786, 1799, 1851, 2034, 2106, 635, 709, and 732. TPD-1, issued against ICP-PT-34-05, " Steam Genera' tor Narrow Range Level Verification," identifled that a .
.]
substitution was made for steam generator water level detectors. // TPD-2, issued against ICP-PT-22-01, " Process Sampling," identif_ied that three radiation monitors were not installed at the time of the , test and were not needed to meet the test objectives. In every case reviewed by the TRT, missing components and equipment _were_identified and documented in the completed, test record. Any outstanding testing which remained because components and equipment were not"inslalled at the time of the test was tracked by a deferred preoperational testing program schedule implemented by STA-805, RevTsttn 0, " Deferred Preoperational Testing." STA-805 is a CPSES .. administrative procedure. TUEC's decision to proceed with the HFT despite missing equipment appears to have been made to minimize the economic impact of delaying the testing program. Many other power
~
plants have taken a similar approach in this regard. All preoperational tests, including HFT, which TUEC committed in the , FSAR to perform prior to fuel loading and which are candidates for post-fuel load testing, must be submitted to.NRC for review and approval prior to issuance of an operating license. Those which NRC approves for post-fuel load testing will then be required by NRC, as a condition of~the operating license, to be satisfactorily completed prior to the reactor being taken critical. The TRT also reviewed a master data base compu'ter printout of work' items requiring thermally hot plant conditions to retest. As alleged there were modifications
.. '(about74)Imostofwhichwereonhangers,snubbersandotherpipe-supports, that required HFT conditions for" valid retesting.
9
- - + - - - - , - , . . - ,-- , - - - - - - - , . , . , - - - . , , - - - - - - .
Thus, the TRT found that while some components and equipment were not installed during the HFT, they were documented and tracked to be included in testing which, if approved by NRC, will be performed after fuel is loaded into the reactor core,
- b. In asses' sing the allegation that TUEC does not intend to check or -
monitor some components and systems until " heat-up to hot standby" or "dur.ing power ascension," the'TRT reviewed Integrated Plant-Operating Procedure IP0-001A, " Plant Startup From Cold Shutdown to - Hot Standby." As in the case for HFT, this. procedure specifies , that the plant be taken up to normal operating pressure and tempera .
,ture using reactor coolant pumps as the heat source. Whether all ,
--lift.iten.s are done before or after fuel load is not safety significant because the fuel is new, i.e., unirradiated. Additionally, some pre-
. dperationalh.estscanbedoneonlyafterfuelingbecausethereactor core must be installed. Examples of these are: ISU-022A, "RCS
- ~B6iindary Pressure Test and Leakage"; ISU-022B, "Incore Moveable ,,. ,
Detector System Alignment"; ISU-021A, Pr'essurizer Spray & Heater Capacity Test"; and ISU-228A, C'ontrol Rod Drive Mechanism Operational
- Test." -These tests, and tests on components and equipment not '
installedduringtheinitial(prefuelload)HFT,werescheduledto D be conducted after fuel load but before the reactor is placed'into g operation (see paragraph 4.a above). The results of this testing V ljV h must be satisfactory prior to reactor initial criticality.. There are no HFT items scheduled to occur "during power ascension" except those that req' uire reactor power. For example, steam and feed water
~
piping does not achieve design temperatures until there is sufficient flow, which on'ly occurs at power.. Accordingly, this portion of k thermal expansion testing cannot be completed until that tine. Section 14.2 of the FSAR and Regulatory Guide 1.68 specify those
/ tests which are to be accomplished during power ascension.
~
- c. It is alleged that neither TUEC nor the NRC Region IV staff noticed that major components or items of equipment were not installed prior
~
to HFT and failed to keep the ASLB informed of the problems encoun-tered.
=
The TRT reviewed HFT-related TDRs and the master data base to determine whether TUEC had documented all outstanding work on the master data base for the Lead Startup Engineer to review prior to each test, and that components not installed at the time of testing, but needed for eventual system operation, were documented, as , requiredbyCPSESadministrativeprocedures,onTDRsorTPDs. For * ')/j example, as discussed in paragraph'4.a above, there were 20 TDRs identifying the missing hangers and supports associated with - ICP-PT-55-11, " Thermal Expanst.on." Each was initiated by the - Startup Group, and evaluated by TUEC. engineering for its impact on the test results. TUEC performed calculations and installed . temporary supports and weights during'the test so that supports .,- which.in normal operation would interact with other supports would not,. yield er_roneous data. The TRT aTso determined that the reason for no documentation in .
'AEC'5nspectionReportsindicatingtheRegionIVstaff'sknowledge ..
of missing components was because they w'ere documented and tracked in accordance witih th'e TUEC adm'inistrative. procedures which provide for such possibilities, and because they,were included in planned and documented future testing activities. It is not unusual for an applicant for an NRC operating license to defer certain prerequisite equipment installations in order to proceed with HFT. However, the - NRC routine inspection program verifies that a viable system exists and is being implemented to document and track such missing equipment and that the equipment is satisfactorily tested when it is finally installed. This was done by NRC's Region IV staff during various routine inspections of TUEC administrative procedures and was con- , firmed by the TRT during its review, as described in the preceding sections. b During the TRT review of the test program, no information surfaced [7 that was considered relevant to.any issue now pending before the ASLB Comanche Peak hearing. The purpose of a prerequisite and h*I preoperational testing program is to prove that the design and h construction of the plant is such as to provide reasonable assurance
p SL 6 /4 U #
~
[fp a&W W that the health and safety of the public is protected when't'h'e plant goes into operation. ASLB notification, in this case, would only have been required if the testing, program revealed a problem which could be considered a safety issue or which could not be resolved to the satisfaction of the NRC. Therefore, at the time of the TRT review, 'no ASLB notifications were required concerning the testing - .
//r programs.
~
- d. It is alleged that 60 percent of the test points of ICP-PT-55-11, .
" Thermal Expansion," failed the acceptance criteria, that the traceability of the measuring devices was lost'because they were not logged with the data, and that TUEC engineering had provided ,
.no justification for the "use as is" determination on piping which did not meet expected values. >
The TRT staff-determined, through discussions with TUEC personnel an'd'Sy a review of the completed portions of ICP-PT-55-11, that ._ . about 28 percent of the test points (referred to by TUEC as
~
" monitoring locations") failed the acceptance criteria for reasons that were not totally unexpected in the course of an HFT. TDRs were issued to document all test failures so'that TUEC could pro' vide corrective actions and establish retest requirements. Additionally, about 12 percent of the monitoring locations were not measured because of missing equipment at the time of the tests; about 7 percent were invalidated because equipment was removed during the test; and about 3 percent were invalidated because of modifications to equipment after the test. Therefore, about 50 percent of the monitoring-locations still required measurements. Those which must l
be measured'under HFT conditions are included in the testing program l proposed for after fuel load and were submitted for NRC approval. The allega'tlon also stated that although temperature'swere taken and logged during the test, the specific meitsuring device used at l each monitoring location was not logged, therefore, the calibration of the measuring device could not be traced to the monitored location. The TRT staff found that the completed test data packages did contain
f. the calibration data for the measuring devices used, but as' alleged, the devices could not be traced directly to specific monitoring locations. While pursuing this matter, the TRT conducted interviews with TUEC personnel who participated in the testing and found that a test coordinat6r maintained a log which tied the devices to the . specific'monito.r.ing loca..t. ions; however, the log was not a part~of - y the official test package. The TRT pointed out to TUEC that while
~~ 4' thed5ect.connec s not rei;uired by the test procedure as.
written, the da included as part of the official data J . package. A TRT review of representative TDRs, including TDR-853, 854, 855, ,
~
1033,1034,1035,1112, and 1113 identifying questionable data or j deficiencies revealed no cases where TUEC engineering had not
~
- provided'back-up da.ta and/or calculations supporting a justification for the "use as is" disposition of a TDR. .
- e. It is alleged that in conducting the HFT, TUEC considered only normal operating conditions and-did not consider a,ccident con-ditions, such as loss of-coolant accident (LOCA) or an earthquake.
During its review of test procedures, the TRT found that TUEC ' tested
- safety systems with consideration for accident conditions to the .
extent possible by simulating certain parameters such as temperature, pressure, flow, etc., that might be encountered during an anticipated accident or emergency condition. Moreover, the NRC does not require testing under actual accident " conditions. Each applicant for a permit'to construct a nuclear power plant must include the principal design criteria for the proposed facility in the application. The principal design criteria
. ' in 10 CFR 56, Appendix A, establish the necessary design, fabrication, construction, testing and performance requir'ements for structures, systems and components important to safety which provide for reason-able assurance that the facility can be operated without undue risk to the health and safety of the public, including during accident
n . gu , conditions, such as LOCAs and earthquakes. CPSES is desigiie'd' and constructed with the systems and features needed to mitigate the consequences of an accident, and , takes into account lessons learned from past experiences with other plants.
! f. It is alleged that TUEC and the NRC Region IV staff were willing . *1 a to accept HFT results which were deficient. k TRT review of the completed HFT and other preoperational test .
1 documents indicated that with a few exceptions as noted below, no l 4 deficient test results were accepted by T0EC. Final acceptance l ' {b h ' j A of HFT test results does not occur until the Joint Test Group (JTG)
.has, conducted its review of the data and approves the completed test i 3D package. The TRT found three mino_r, questionable' items in a sample o'f'i7ou'toI25JTG-reviewedandapprovedprocedures. These items were: - -
.. . n (1) Preoperational test procedure 1CP-PT-02-12, " Bus Voltage and Load Survey,'" inte'nded'to demonstrate,that during all modes
- . of plant operation, optimum current and voltage will be present at all the buses and subsequent equipment. Aprereguliite
- condition (paragraph 6.5) of the procedure required certalin transformer taps (TIEB1, 2, 3, & 4) to be set at -5% and others I
(TIEC3 & 4) to be set at -2.5%. During the test,'the, voltage
- acceptance. criteria (paragraph 2.0) could not be met and the ,
procedure was changed, in accordance with administrative require-
~
ments, to specify -2.5% in lieu of -5% and +2.5% in lieu of l
-2.5%; respectively. However, engineering review and evaluation l
i of the tap changes after the test was completed resulted in the l requirement to return to the originally specified transformer taps. As a result, the completed test record contained data that Yas taken with incorrect tap settings. In' addition, j , voltages recorded in paragraphs 7.8.2.1 and 7.8.3.1 did not meet the acceptance criteria (paragraph 2.0) of the procedure. l l
^ ,---w.r r--.., , ,- me,.- __-.,-,_..,_,__,-es--_-.,y,----.,w-. , .- , -mr --.._._y,__,__ _ _ _ - - _ - . _ _ _ _ , _ - , - _ , - - . - , , , . _ . - . - . . - - _ , - - _ _ - -
. . r (2) Procedure ICP-PT-34-05, " Steam Generator Narrow Range'L'evel Verification," intended to demonstrate at hot, no load con-ditions, that the narrow range level channels for each steam generator indicate properly at the upper and lower instrument taps, and compare properly with each other for actual changes in' steam generator water level. Level detectors 1-LT-517, 518,- .
*j:/
and 529 were not available at the time of testing and thus r te.mporary equipment was sub'stituted. The test was performed with the temporary equipment. After the test, the specified . detectors (from a different manufacturer) were installed. The Joint Test Group (JTG) approved the completed test package con-taining dat,a taken with temporary detectors. The orily retest ,
~
. _, specified after installation of the specified detectors was a cold calibration which does not meet the objectives of the test.
~~
(3) Procedure ICP-PT-55-05, " Pressurizer Level Control," intended to '
- *~~ 1emonstrate the control aspects of the system in conjunction ..
with the chemical and volume, control system. In addition, there was a note on Page 12 of the procedure that stated, "This test is provided to verify the capability of the pressurizer level control system to monitor pressurizer level oveF the range of installed instrumentation and to observe that all alarm and control functions are operational." A prerequisite condition . (paragraph 6.13) required the plant to be in hot standby. During conduct of pressurizer level indication testing, in accordance with the procedure (paragraph 7.1), the System Test Engineer noted that a level detector (1-LT-461) was registering marginal readings. He documented this and recommended a cali- ~ bration check of the detector. Aft're the test was completed, this was done, and it was determined that the detector was out of calibration, and attempts to calibrate it were unsuccessful. The cdrective action was to replace the detector and perform a cold calibration. The JTG-approved te't s record contained level data that were taken with a detector that was subsequently proved to be out of calibration, thereby invalidating the test data.
i When the TRT effort began, the RC Region IV staff had not'yet begun their inspections of HFT completed test packages. This NRC inspection effort has as an objective to ass,ure that all test data are either within previously established acceptance criteria, or that deviations
.are properly dispositioned. Since the Region IV review had not yet begun, the implication that the Region IV staff was willing to accept '.
deficient results was not appropriate. 'tIl
- g. It is alleged that the ASLB cannot rely on the NRC staff to monitor .
the completion of any additional test and reinspections due to the lack of candor by both TUEC and the NRC Region'IV staff, which calls , into question their credibil,ity and/or competence. , Duri g its review, the TRT found TUEC personnei arid Region IV staff c'aridid a'nd forthcoming. Since the Region IV staff had not yet begun their inspection of HFT-completed test packages, it was premature to 41Tegli that the ASLB could not rely on the NRC staff to monitor the ,, completion of any additional tests and inspections., There were no findings that indicated a lack of candor on the part of TUEC or the NRC Region IV staff during the conduct of the testing program or brought into question the credibility or competence of eitfier.
- 5. Conclusion and Staff Positions: The TRT found no information during review of these allegations which would preclude the ASLB from making a decision pursuant to 10 CFR 50.57(a). There were no significant deviations or vio-lations of NRC requirements identified during the course of HFT to support the contention that it was deficient. Although the HFT was incomplete, TUEC's plan to complete it after fuel, loading and prior to initial criti-cality appeared technically sound and without any safety implications as it was then constituted. However, it will be necessary for TUEC to obtain NRC approval to deviate from certain limiting conditions of the CPSES Technical Specifications since these were written for an operating power plant. For example, Section 3.7.9 requires snubbers to be "0PERABLE" before heatup above 200*F. There are snubbers which must be tested with
. the plant at normal operating temperature before they can be cohs'idered
, "0PERABLE", which is what HFT accomplishes. Since the reactor core will l not have been irradiated, the TRT does not consider such a deviation to be of safety significance. The HFT portion of the preoperational test program appeared to be accom . . plishing it's intended purpose, that is, to identify problems such that
- f ,
they can be corrected prior to reactor operation. There was no evidence l found that either TUEC or the NRC Region IV staff'was willing to accept , deficient test results and it appeared that the overall objectives of the ' CPSES Unit.1 preoperational test program would'be met, thus providing . reasonable assurance that the plant is properly constructed and that its ' f operation,will not pose a threat to public health and safety. While some of the allegations had valid bases, none were considered to have overall
~
safety- signif'icance nor generic implications. i
- 6. Actions" Required:
l .. . J j a. Section 1A(B) of the FSAR commits TUEC to ,complet,e all preoperational I testing, including JTG review and aprpoval, prior to fuel load with
! exception of those tests which cannot be' conducted until th'e core is installed. This subject is discussed in Section 4.a of this report. -
l '
- ' Now that TUEC is obtaining NRC approval to conduct some of this ,
1- , testing after fuel load, TUEC shall commit t having the JTG, or a 4 , similarly qualified group, review and approv all poit-fueling [l l preoperational test results prior to declaring the system operable in accordance with the technical specifications. I ..
~
- b. Section 4.f of this report. refers to thr'ee preoperational tests con-l ducted during HFT that the TRT determined were not completed to the extent required by the objec.tives stated in the test procedures.
According,"TUEC shall review all complete preoperational test data l . l packages to ensure there are no other instances where test objectives were not met, or prerequisite conditions were not satisfied. The l . l i mmr,4--v,-r-w,,e--,e,.ex-,-m, ,,ynn_ ,,-m_ -_,,vv.-w, ,,m., - - e-m-,n _ a, ..,..-,e, , - -w-.. .,.- - + , - -e--,,--,
! three items identified by the IRT staff shall be included, along with appropriate justification, in the test deferral packages pre-sented to the NRC. , ! c. The TRT determined, as indicated in 4.d of this report, that the data ' in 1CP-PT-55-11 " Thermal Expansion," did not include information
'Y
! needed to trace the measuring devices to the monitored locations, but the information was available in'a log maintained by THEC. TUEC shall incorporate the information contained in the. log into the cfficial 1CP-PT-55-11 data package so that the traceability is maintained, and l l shall also establish administrative controls to assure appropriate test and measuring equipment, traceability during future testing. ,
- d. The TRT pointed out in Section 5 of this report th'at in order to
) conduct preoperational tests at the necessary temperatures and i i pressures- af ter fuel load, certain limiting conditions of the 1 ) pr6Fo' sed technical specifications cannot be met, e.g. , all snubbers
~
will not be operable since some will not'have been tested. l 1 j Accordingly, TUEC shall evaluate the required plant conditions for v/' the deferred preoperational tests agains't limiting conditions in the proposed technical specifications and obtain NRC approval where deviations from the technical specifications are necessary. i i l l P P r N. J
.m ,m_
I l l
* '~
e
.. + l h .% l{ k:o f '
- T- --
- 0. $ . ;l >.,,,' % g .r ;Q x.:4.*qqb & = [Q [- .k-%.s lla >
.A 4. $-n' s\:, 'w f * * .s. i
_4, . 4 .. vi,. .
, 7 , t;}, Y j '
- .Q n - ,.: 7, i . , , /*. . t ,. . 5,j w .
' g - ' .. 4.
. ,a .'..- ,a 6, y- r +s y ' - - J. g '.,e *-
si
. ;4y ,
l
; V ' Ti , ,y j, j ' ' g[ ' .f 4 ".
*k. . =, I ,., 4. m t, . 6,7 k , J g [* ' , . .1. Q.. _ A'
.'[.x, ., ' W . h ?",
- a- '.,4 .. - ; % ;
i
'g '; l
;. -q3._. ~g_qf- - l,.,[l ,,L < ... .,; ' f .&
).., .- 1
_{u. .,~,L.y
. ss "; .: ...:, '.h y , <}f , j,.: q, ', p*.}, ,,'
g ., y .y ,,p.,m, t- m
;, z., ,. 3 -. . . ._
(,p
? .b *; .
'%gw. .
'F- ' .'
3' Q ':. ; ' . >
*~..'. hf,.., }
- > . n i+,', . g' -Y '. - S : \. . % *k"%'h 5'"-p * *-N&*' vld d ' l,* ' * -
,- 1 p' . .,,
I.,t ; .; i,,,.f .. (3'.'<g. S' wf. ,,.2---- .- T.q. w;.. s '- Z '.s, g.i - (--, . ' . , , A
.,t * .'..-.- ?. '**- +,
#l ,,' '_gf
- lM,l
~1 f . * . . . .
e
'? . _ . . . 7' .. ' 'N lg ,- ?. :: - c '
1; ;' .f w, .r .* r . 3 , , , . .
' g-[g h f,, ,.y ',
-: ' '; . I. . 'Y : h *; 9 b j l, " .Y \ ' ." .?
..s., ~~ Y' ? . ' .?.*. ' ',!
' l' . i ...y e - d
, ,, i & - :
'Q:& ,. . , ml .".: .Q, l. ,;, - ..", ;j .
; l' (..? - ** *f . . . . , Y; .,I-Q r p- f J ~ w$ ,[ *, 03 -b . #.7 ,, * .[; , , ,.t ,e-
'..'_p.: , .. 7.j , ,
'- .g, lJ- .,, .v t '- ,, v,, ff . . ~ y, ...qts
- p .
-.. r m g . ,.cgesu . ,,.-
... . . s ..
L,.* b. ,.
; ,j .
p .- - , y , , , .4. .,, y 4 ;4 s,- ,g t"* * ]',' . M.7 ' j.* _' %M-+.' - , )'uyf,'^": .'. '.. a * %a .y g ' . . . ,, '* ,l . %..'%- . { * $3 p - Jc 6 :
' , * ,[ [ * .V; __. ,: D.~
.-% .~.+..M'.
_ L. y -
.e- ,
..W A1-..
. s.Asl.
r
., s>. g.'t. g. o. ' . .,n L 4. . p- ..E. . . ~ .. -
G-% ,;; f.f 1 % - : A ,, - v
'.-ul ' ; _ ' -N , " '. a '~N
?'s 1 ,_\ '$ - , . A'
- n _%.H s' ;. *%, 't ,,
4 Q %. l 2 i" - - {5%
&,4.f ,o $.f,,hl;(Q :, m . . , g. . f g f, .,,A' ,,$ ,
l
- e n' I y #'f. . ,*'.p ., :_.
y .- g - . , . ' .f ' l' . s l -
'_yv e I
..$ _ is, u. e ;
e'
>.. 'g s, y. *.
;e. .
.- 4 b L ,.....3 w
~ . % .s; ...- . = .
s & s . l a
- ,-?
s.. ,. .g ,, *.%. ,
.- ,;y
*r g ,. e6.s. , ,-
I
,--ac' ..'W. 7
- .C g. .? f, . . , , . ' * ~ 7 '4 . l* s. 4 % , pp ggg;
<-' 7" ,- ' l
,1 -- MG ,. ,
7; . J..:< ;J v1, .i' , " ' y .s:j, zfc.s * .. g , ff A*7-W-- ..: ,[, , ., .. . .g.u\ ~.;e _hd. j ;,,# ,/ 1% .[t,
.r
_y_.... g er.*gg,M.a
.4.. ..'_t,, p*, ag#
f:,g. f r .
, & ; .yd .'g; .T p , + : t . .m N<;';a,.,,..- ,y ,p.
f h*$b.N ....,hmeN'S 0' -d .hk $ ' ' ? -~ e - - k [..,% .: ?.. .; ) . f f h,
- M.. e.?M -p.. . :;f.%. . ;sf : _w, y-.~.. .,. ;;.. ~.~. .g
,.: . ,..z.3 L, > '_ ' :p:
a e. .,&g.,
..,.y
. .. ;, ,.m . n u.. .
- g. y.
c y 3.1 4 .. . . , . _
. r '.
. . t . . .
K V- ' '
# n gt. : . J m - g- .<,,,..,.a ^ ; im f.. '1.
, L. , e', ,. f w,,g., ; .y . . .s ,.
~.6, g
',7 g
c .n A,7., w' 4 fc _'.A;, Ay.. . c p0; - h . . . , .?
- 8-i !&&.l ,[ t. l. ',{ .% _t , ',j,N.:~.l.:i*.{;l1.5: '
Tf[ k 4 &,.hj w m. pc M I .$. ! .. U'.RkI N.j.. h N 13 m a i Y .. ' y og m.e. - '. - ,( '
;. ; ,,g
, -ys .g.m, ,,ygg_
- y. ,p' y.-
. y T S-
..g 8 .g 3.. .
-j ' , '
4 , [yc' N, [AMg.4 % 'yW N."% , . '; r p .d, . 4 .' .l. --
' 5 ' ' "y
'iN.
,[" , ~?. , ' ' '."' ]' \ q [.
i t. 4 . t -
- g
k'IM ;g f ! -I ,J h h 1' .:
M.y . ' Q'g . i, % . ,f'_ ,. ' ly ",, .c ;. g
# .a -
, ' j' ! ..
2 ,, k% % .$g b./ .[K % vg yf.:
~
; - . s .; . : ".. [e4.f,.[, y,*,:% '
4' e c;:,...y., , , , , , . , y - lQ,;yiv w +:+,. pTAc.; ; g g$hQ 4 #.. mj_., , 4. .Q* i.,. 4. 7 m 8 S- . "Q 6 # 7.
' . .y-Le . O%7 f p . 7 7'
'Y y%. ' , f,.s;. r a g, .; ' . ,s..?. : M;.L, q:
3.,s.. '.-
. %,-L. :
- ~ , % -
M. %& $.*:Q ,. :s.. $ h,,. Ti;; \_.
- q. k i '. ).',
. . ".: ~- ^ *7' ' ' '
- Q"* *, \ r g,1 : -- :(l n'"fj.l:. > . . . ?. ' ,
.ll .
; ..{:, 3 ?* ' " s } ' [* f vn g -
. .a v.F ,g%v %:.
h , g %~ 3 _ 4.. . ; %..~~n.w% @m n .
+. 3 m o n m w e . A n ..: n tm.i.. O.
.m , v Y
. A'n "
.,. .m r . - ie ., vgyi, ' -, ...\. .. . -: .. f*? :
W .- mm, ,6 e . p. ;4,3 . ,t y. - j c .. . a e r .. ->-s . e . kv . $v- ! y j , y ., s y 6.4 .. 4 %.n w 5.a.y m, N_f;,' .x m, h c . ..L c :q e tw .
'[
D b b h,.w $. , w$ $ a
, ~ -w k,k h:$ k Y. ,$ h , ~ .xb 5 ,. , 4
,a) fhx ; ' .
w j 1 ~. ,' . y tn &.:'t.2 F ggAgg.. .ygp Q~m%,
.%_ ~ ...,
03q]@g y $Wy."y g,ulyg.mw.. l$ g -3e. Pr i.<-kL . ..? d' . y '. 3 ' 3..>t
..# 9m, i . p;p.ph..?wm. .e , gf tQ i, " .;1 .
w,,Q.\, g &. M.., -s. .m tw-.
#sg'g[.,n. Wjr. -tMy*7g:?.
%g. .c- l , .
y "
~h :. ;hh j, },- l . b K '. k- i ,- -Y'[ b .n , j . .,;.
- q ,
v .x p a: -
,w.u . 7 %m.,,. m. o, w.. .. p , Q..; ... +q. . .1 e. ba . p a, . um. s,, .
,n
- . : 1 ,s q.. .x. .- .
t :u , , . Q '.ag y ,-.y,t.,- .s'., r x ,, ' w ,t,~ g,,,,
-. c .-
'r
%' .7,4. p * ; .
. .n r_ . --q...r..-._..,,c
; v k *. . .; -s A* ~
+- -s. y ,. . #c?',_~ ,. , . r u.
.c . :
>y .
'; g.
n
, . '.}i,WQ
,X A,f i'4-. ~
,<. O, E di . L , ; .+ C,-c _ '- '*- & .* f s. f ':
I ' *\ . .' ',':.-- lj. W,% . IQf_,? Ol,&[ jA > W.4}D,. ., J h ;g. .. 9.k- ; W ; f*( , #4fel @n g}j & [ l Q ? h@.8 y*Y,f. '-Q'y n ,S &
Q ,,M6dp u . p,@.
N. ^ , ,, i . m- :.,, c. - n.
'1 I g e ,
3. F A %{.:
%,.7,; 1 ',i1 %, Q ' M
. i
' W. .. h gC:#91 .
Y.$ /-6,.., ".4 ,py?I VMt:.&-;O.> (*f44. ' P ; 'ff? .
-eV. V k:%
- i % 'v i %..w;?k :. W . '; a e 4 *. %. p.?. p; '.< t , .s ?
hWhk.w-khh?."N$ _ s. 5.-
%hl Yh,&hf. - f
.r y..m .;. n- w -
! #g .i l <1%q ) ,-.- f( j,.gi, (. q ~ ,jfd
. . fg y .o. , .. ,
.) .p d ,;'[M --:. q '
x - {.- .
~
'M lg..: -
.,,,e m. , a a . ; '.N :f *
,.4 i
. x ' ' 75]- .'- f,- ' 5.-: . c 1
. .f, y j
< a - ..% -i. p ~:f 1.6 "y ,,< -
.L';. =--' + -v - ' '
. , . u .
. ',x *.- j- - ' _ 3. ,.g,...' ~- ; , %&.w t - :
.' ; " ./ *3
. . ,. c =,;6) .?~( N.. , ..n '
W {y..C.,,( . ,.,',.x y' .% y ,, $ ..
]: ' ~ 1 ..
",(", . . . . ';,~;. . * -< .. ; 3, 2 L' . .
r, .g ,1 . .r .c ; a .-
......3 A
t , '
, js .~ : %. .t v...
.s
, 4, -
.t .
y_ .e , . . ,8 , b . .. J . . t,.-
'p 4- .o L
- 5. <
9; . . , t e,3 l,g
.j .t ,. ,.
c
,p , ;
y
~j- ./ w..A_t ;
/,,,_;,,.
4A,- j,. y; 4 .+ "aq 3 - , (+ $ ; S -
~ ., .i.. ~, ,~ . .i ,y -
-,.? -
,.,.,,,,-w..y_,,. ,
,. 1. ., . ,
f w ,.f.8., 9 .; ."> .. . ,w L.U+ u . :; =,
) .Iy1.. , -( ; _ ~ r.
- 7 : % . F "E,.~.;c -
"xE, .'- . ,.?V. '#. . d(! ..., ; h;i
.. , . , . , ..- , : _e.
..+ - -
e ...)., . . ... .-
,m... ;4 3. .y,.;,m.
u;,:. " . - y._,q r
- z. . ,, . ,. .-
e., p "v.. _' 3 . . ..% w.7, 4.: .
' - ' ." ~.
p- up. y / ;.. ='_- ;t
'i j'. f . M-: m - ,. + ; :> ; .
- ,(M. ,. ' u n ;. 54w . , .a>;,T n,
(Lyf;; . ~- =.g& -.e ;,' ' f; .
. w: ' -4mA .- ..g, ,: ., . . u-
.". 5
.- y a . , ~(f-. M = Vc o ~. ~.',c
- i ..
- c. n.. r . .. 44 , , ..g.y.H . , ., / -
- . . .,f. .9. _. :..., .
, v. '. .?
.4 , 3. .y . y ,..%3,
, . .. . 9 ., . , .
e m., o,. s s <.. y
.v:. . .....m. ,-m e .. , - , -- . . . ..- .. -
.-g
-:p'- . p; .: ;.. L y. r. . : :my
- g. e . gp;. ; .. + .
_ . . . . . . . . . , _. , _ e ._ 4gn.. --: .-. _ _. .-.: .g, 3
..f
_. ,, e ww e.y , , h.- -
+ , h)\
~. g 4 .' -y {N : :s. *^Yc ' -
g,,> ;
.z -; . -
. . A ;' ., ~[ .I ' jkW I T g
'Y,,
_- [ -s
./ Y CL
.F
)' s
,'. 5 h . . .-
1 - y
."?
Y,, ) ,o p . ,;
.{.
,y .f,-, .p. . } }gh .d , Q , 4' . , , . " . , "
' .. . ,+ . e ., g. 5 g, ,. .
s ..i ., 4
,,
- m
-sig ; , N. , , , y. u
,.t,,. g,
,n. * . , .m
. ,. 7. . " .n , g ;
(g y;+r, -ocq,p .p, . ,1...c.. p, .g w, . -j,3 a,s.y ,4.u,a .:., 4 t ,
. * ;.s -re.
- , . . + : o s, s .+. - . :. .: , a q, p .;n L .> . . - , . ,;,.......-~.
'8 g .. :
- b. , ,. '
. . . - -,..e r 4' : ,,\ {y. . ., n.m. .;. ,.. .5e.. .,.. .' . * ,..,.r'.
, . : . ;w 5.c.
e.% r-
- r. :? . : sx y ; :..M.! y.'. -
-. a i>,
1 . , 1 s . . . m,,. j ,<. ;vn-
. < .. .; Q.
{ M .e. ; ,;,y ..,. - ..,.; y 4.,.
.,3 .
- .. ... A r&. , ,.q: w;*s.j .-.
c>^ ,e, w .
- . . . . , . -=-<- .,., +
4 . , s. . .. ... + ,. . .: . . . :.
. + . , ,. "
,, n c , .', ,,-
. z a >
. . ,,. s ..
- w f ,.*.. .. :.
.e ,. .
..h .
, ,, 1_-
,. , - ' ,'f.R
, y os-pg}. . ;- j.. * -,'.g., q ,,4 , ,., y, j.,_ p. y -4 c, _ se .
..g 3y, }. . .q ,,. .,~, . - . , 3 j - - .. .,1. .z,,4 ., 7,3 7
. 1 I#
c, y. va ., p' .:..
- _>+r . o.1g 6 %
.s...
.( .;_.,. . - .3 . . , , .,. '.% ,.1 ., ,. . 2 y_
ygsi0,.>,uy . -{; . !p. p, i,.: - c .. -
.c 2,. + p.
c.: ,,.t- w
, .c , . . . .- ....:- . . .
u.-. 1., . - . .s .y, -
.o . ,
_f ' : W - % . ~. L ,.o . . c .., 4 d
. f. <; . ;, ':, . . .;- .$
.u,..p-V;*;gh. .. ,, ' \ t -.
.r.- .H..'.'.. #F. - -::.,.;
F',s.4~..... r..
- v. . ..-. -
< / ( .=.. . , .
V;
. .. m . ,>
.1 , m A,
. %s-.,w
[ q 4. ; fb *e. . i .ymM,l% q, j.,'.2
. y *[
. n,.%
7
- s. N. 1 % , ,g,;,):
.f@e yd3 ,. ,t *s4 . ..
j., . . . ,/:.y .. i : ym
; , /g.
.m ,
3;
= ;
., , s n '.:4 . 3 +a.q .
k, , h.' A ' y --djh: '
- s v ?A 7 ; 3 ce.N a f.f._ < , ' L-l b?' Y .
r,r.u, ,. 4 ; w p g. .
,. j .u ,.
n1~e. . (> 3. n...b.- - . yp ,,<
., ,,. uf S.
.. c. .; ) z. ..,, ;,g;_... . . 4. . ,, ., .r, 9, ..
,,.,j,,. - : 7. s.y ug, ,s.t.. p:7,,; g.
. ....,. , . , , , . ., ,g f ,
Jp g, .4 .. .r .1 ..g.e t ., s , ,
- , 4. .. - .
.. ' , . ..,- g, . . 4
. .. . t. , , , . ,
W, . .. .3;, ,
%. s.,.4 ,- + .- y, +.
.n.
. Q,,f. ' s.e'::b y> :. - , -
- n._ . ? * ' '
p . j', "<.5- . 3 ; q ..A
' ' , y.4,. w . .. 4 v,,. 4
- " . ,. . Q. t
' s. .,,,3,. .p iv. ,,>) ',-;. q& D. .
H, m .; .nfw. f , .G 4 +. . '. , ', , . ' ,'.'J , qM / :t'b;s e -%
^
; Y:: jy a, r? 4- .3. 4 ., .
;p.Q.W, s sp< 4. . > %. y;,,cs..
. . , , , O. y .y:.- $' ..
% c,-: .g , e. q # .., .y .. v r. -
,3 g( Q : M; yE 7 7 Ty[. . y '
N,, ,[ ' ' ' (( ff. Y[ .f: " [, 49 w .t p, a :, .
- . . . . & k.: , . ;f, ' 'f~' -; 5 ,
h..
. . .. . . c+. .'! *J, .. go.
t .,..e;; <2^1,p n. n.. sg ,,. N.v . w ,. y,3
%.,g . ng . . tno_ . : .. .s s.. .n s,,
p.t j'.,v.Q, ? ,:, . ,g[ _
",h..-.,,... . {.y
,. q . ),'.'s y M., j . ~, , .T. .. . ,. g . l . '. ( f ,.
'.s , .
.m ,... . .
fb, h i hg . r .bbkhh. ., . .sM N,d. b d ~ ~ l hhhhhhihhhhhkhW b mmmm ummummm .m
o- o a
- 9. Reference Documents: .
- 1. ICP-PT-02-12 " Bus Voltage and Load Survey" (Rev. 0/2-7-83)
- 2. ICP-PT-02-13 " Power Transformer Load Test" (Rev. 0/.2-1/83)
- 3. ICP-PT-02-14 .
"480V Switchgear Transformer Load Test" (Rev. 0/2-7-83) s
- 4. ICP-PT-22-01 " Process Sampling System" (Rev. 0/2-1/83) . .
- 5. ICP-AT-22-02 " Secondary Sampling" (Rev. 0/9-27-82) '
- 6. ICP-PT-22 03 " Post Accident Sampling System" (Rev. 1/4-8-83)
- 7. ICP-AT-28-01 "Feedwater System" (Rev. 0/1-21-83) ,
- 8. ICP-PT-34-02 " Steam Generator Safety and Relief Valves" (Rev. 1/3-11-83)
- 9. ICP-PT-34-05 ,
" Steam Generator Narrow Range Level V'erification" ,
(Rev. 0/3-4-83) ,
- 10. 1CP-PT-37-03 " Auxiliary Feedwater Turbine Driven Pump" (Rev. 0/2-18-83)
- 11. ICP-PT-45 " Containment and Pump Room Coolers" (Rev. 0/3-25-83)
- 12. 1CP'-~PT-55-02 " Hot Functional Test Sequence" (Rev. 2/2-18-83) .. .
- 13. ICP-PT-55-03 " Pressurizer Relief Valves" (Rev. 0/1-7-83)
- 14. ICP-PT-55-05 "Pressuriier Level Control" (Pev. 0/2-25-83)
- 15. ICP-PT-55-06 " Spray and Heaters" (Rev. 0/1-21-83) 16, 1CP-PT-55-09 " Reactor Coolant Pump's" (Rev. 1/4-8-83)"
- 17. ICP-PT-55-11 " Thermal Expansion" (not completed) (Rev. 0/12-21-84)
- 18. CP-SAP-21,Rev.2 " Conduct of Testing" (3-7-84) .
- 19. CP-SAP-12,Rev.2 " Deviations to Test Instructions / Procedures" (3-18-83)
- 20. CP-SAP-16,Rev.8 " Test Deficiency and Nonconformance Reporting" (12-7-83)
- 21. STA-805, Rev.0 " Deferred Preoperational Testing" (4-23-84)
- 22. IPO-001A,Rev.1 " Plant Startup from Cold Shutdown to Hot Standby"
- 23. CPSES Final Safety Analysis. Report (FSAR)' Amendment 59,7-14-84)
- 24. Regelatory Guide 1.68, Revision 2, August 1978 " Initial Test Programs for Water-Cooled Nuclear Power Plants" 25.. 'NRC Constrdition Appraisal Inspection Report 50-445/83-18 dated April 11, 1983.
- 26. NRC , Inspection Report 50-445/83-08 dated June 30, 1983 i
- 27. NRC Inspection Report 50-445/83-23 dated July 27, 1983
l
. ~
- 28. NRC Inspection Report 50-445/832 22 dated May 25, 1983 .
- 29. NRC Inspection Report 50-445/84-16 conducted May 14-June 20, 1984
- 30. NRC Inspection Report 50-445/83-2,6 dated June 15, 1983 '
- 31. AT/PT Test Index with Schedule, Unit 1 and Common dated July 2, 1984.
- 32. System / Subsystem Turnover Definitions and Target Dates, dated . ..
February 7, 1984. 'f
- 33. Citizens Association for Sound Energy (CASE) proposed Contention No. 26 of October 13, 1983. .
- 10. This statement prepared by: , , ,
Ward F. Smith , Date TRT Reviewer Reviewed by: . .
- " ' - ~ . Richard R. Keimig Date Group Leader Approved by:
Vincent S.'Noonan Dats'
~
Project Director b e B
- o. m.
O 8
{, I . Document l'ame: J , SSER TEST PROGRAM 4 Requestor's ID: U
)
PAT .. Author's Name: - Chet Posiusny Document Comments: 11/8/84 Final ciraft, rev.1
. ,h e
(A
/
. . . . . ~
#y J
+' -
p / 4/ oy;9* . f' ey /
~
A ,y
) },\
f*gVy 6 ([>) plG
'( f f 9 6' 7' p
j c .
. s....
..:i!
m } ,\ I.,.,' C - :( h ?L'
f* ~
. Final Draft, Rev. I 11/7/84
( SSER Test Programs /CP3 6 . SSER
- 1. Allegation Category: Test Program No. 4
- 2. Allegation Nu'mber: AT-7 -
'j t
- 3. Characterization: Itwasallegedthittheleaksencounteredduring-the containment integrated leak rate test (CILRT) were numerous and of such -
magnitude that they will have to be corrected and.the test repeated before
' fuel loading. .
~
- 4. Assessment.of Safety Significance: The implied significance of this N allegation is,that the containment building might not be capable of meetthg its 1ntended safety function of acting as the final barrier against the reTease of significant amounts of radioactive fission products
~
tothe'*environmentinthee'ventofanaccident. , A condition for an operating license' for a' water-cooled power reactor, such as Comanche Peak Unit 1, is that the primary reactor contatnment ,
' building meets the leakage test requirements set forth in 10 CFR 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water-cooled Reactors." .
Appendix J of 10 CFR 50 requires preoperational testing of the overall leak tightness of the containment building (CILRT or, Type A test) and establishes acceptance criteria for the test. The testing is conducted to assure that total leakage through all designated penetrations and building flaws, if any, does not exceed the value specified in Appendix J or the Technical 3pecifications (which are currently under review by the NRC as part of ,the licensing process).
~
Both 10 CFR 50, Appendix J, and the Comanche Peak Steam Electric Station Final Safety Analysis Report (CPSES/FSAR), Amendment 12, dated October 8, 1980 specify the use of the American National Standard (ANSI) N45.4-1972,
d
-2
(
"LeakageRateTestingofContainmentltructuresofNuclearReac'f.o'r~s,"
March 16, 1972, to carry out the test. A later revision of the ANSI standard (ANSI /ANS 56.8, " Containment System Leakage Testing Requirements)" p,rescribes essentially the same test procedure for the CILRT as ANSI N45.4-1972 but prescribes another method for calculation of the leakage
~"I r,a te . ANSI /ANS 56.8 has not been endorsed by NRC and is not prescribed ,
in 10 CFR 50, Appendix J.
/
f The TRT reviewed the as performed CILRT procedure, 1-CP-PT-75-02, .
" Structural Integrity Test and Integrated Leak Rate Test," Revision 0 and
'the resultant test data to determine compliance with Appendix J and the proposed Technical Specifications. The TRT determined that, as alleged,
'~
numer.ous le,aks were detected during the first two of three attempts to measure the containment building leakage rate. On each of the first two attempts, whe'n iE was determined that the leakage rate would exceed the mutmum allowable rate, the test was terminated, the c'ontainment pressure ,'
- reduced-to a safe level for entry into the building, and the suspected . . .
leaks corrected. Prior to the third attempt., te:,t personnel identified three containment electrical penetrations (E-49,, E-62, and E-68) for which the individual leakage rates were excessive, but for which a method to stop the leakage was not th'en apparent. These three penetrat' ions were isolated prior to the third test and documented on test deficiency' reports for later disposition. The results of the third CILRT attempt were con- . sidered. satisfactory by TUEC. The CILRT was observed'by two NRC inspec-tors (reference NRC Region IV Inspection Report 50-445/83-04) to ascar-tain whether the test was conducted in accordance with the approved pro-cedure. The NRC inspector also independently calculated the leakage rate using the method defined in ANS N45.4-1972 and Draft 3 of ANSI /ANS 56.8-1981 to determine the validity of TUEC's' test results. Subsequent to the third test, the.three isolated penetrations were indi'vidually le'ali tested to establish their specific leakage rites prior to repair. The ,cause of the leakage was identified as improper assembly ,- ! of the penetration seals. The penetrations were reassembled and
- individually leak tested again with satisfactory results. In addition to i
these three electrical penetrations, four other penetrations that needed
i . ( ,
. -3 tobeopentoconducttheCILRTwereindividuallyleaktested.'T'h"e measured leakage rates from the repaired electrical penetrations and the measured leakage rates from the four p,enetrations used to conduct the test were added to the measured leakage rate from the CILRT. This addition was insignificant and did not alter the least significant digit '
.intheprevio~ustotalleakagerate. The total resultant leakage rate was :.
*9 less than the allowed maximum for the containment building under the (
proposed Technical Specifications and 10 CFR 50, Appendix J. -. During the third test, test personnel recorded data and calculated contain-ment building leakage rates as prescribed by ANSI N45.4. These leakage , rates remained consis,tently lower than the maximum allowed in'10 CFR 50,
~
Appendix,J and the proposed CPSES Technical Specifications. However, the calculation of the containment leakage rate included tri the summary report submit'tedto'thelRC,asrequiredby10CFR50,AppendixJ,(" Comanche Peak Steam Electric Reactor Containment Building Unit One Preoperational
. IntegraGd' Leak Rate Test," 1983, Docket Number 50-445. Texas Utilities
- Generating Company and addendum, July 1983) was performed using the method prescribed by ANSI / ANS 56.8. This value was consiste.nt with the value
- calculated by using the method in ASNI N45.4 and confirmed that the con-tainment building leakage was less than that' allowed by the CPSE'S Technical Specifications and 10 CFR 50, Appendix J.
- 5. Conclusions and Staff Positions: The TRT determined that while, numerous leaks were identified as alleged, these leakage paths were documented and the leakage was stopped prior to the successful completion of the CILRT, with the exception of three electrical penetrations and the four
~
penetrations which'were needed to conduct the test. The leakage rates from these penetrations were later added to the total leakage rate. The preoperational leakage rate was calculated and found to be lower than the maximum allowed by NRC regulations, a determination verified through independentca151ationsbyNRCinspectors. Therefore, tile containment _.k. -
. l
) ', -4 i building was proved to be capable of meeting its interdad u.fety func:f s . f The method for calculating the leakage rate was as prescribed by ANSI /N {
- 56.8-1931. While this method differs from that prescribed in ANSI N"5.4-1972, because of the stable and consistent data cbtained during the ccr.-
l duct of the test, the leakage rate which resulted from the use of the csi-I culation method in ANSI /ANS 56.S-1981, would be essentially equisalent to . l the results which would be cbtained using the method in 'NSI N45. "-1972. Yi 1, .l
~
gll }i However, it is the TRT's position that TUEC should have obtained NRC authorization to utilize a calculational method not endorsed by the NRC [r( to report the results of the CILRT. Further, the TRT considers that i conducting the CILRT with three electrical penetrations isolated, while f i /' perhaps technically insignificant with respect to the test results, is f [ contrary Io the purpose of the pre-operational CILRT and should not have [2 been done without' specific approval of the NRC staff. / q -
'N This allegation has neither safety significance nor generic implications for purposes of this review. Thetwo,problemsd.escr.ibedAvepgQ,?
' forwarded to the NRC Office of Nuclear Reactor Regulation (NRR) for reso- . lution. - i Actions Recuired: Prior to fuel loading, TUEC shal'1 identify and justify G. { to the NRC staff why the preoperational CILRT (Type A test) was conducted , with penetrations isolated and why TUEC used ANSI /ANS 56.S rather than ANSI /N45.4 to calculate the leakage rate. TUEC shall also identify arc justify any 'otner deviations'or differences between the CILRT-as perfor ed,
-and-the-applicable requirements.or commitmants [4wt. A5gg d.f?yp..,_% C:
I q
- l . . . .
t i .
-5 l l
1 l
- 8. ettac.aents: None ,
*/
- 9. Reference Cocuments: l l
l
- 1. Ccmanche Peak Steam Electric Station Final Safety Analysis Report, Amendment 12.
l
- 2. 10 CFR 50, Appendix J.
l ; l 3. ANSI ?!45.4-1972. , ) 4. . ANSI /ANS 56.8 - 1981.
- 5. Ccmanche Peak Steam Electric Station Preoperational Test Procedure i
1-CP-PT-75-05 Structural Integrity Test and Integrated Leak Test, Revisicn "0." Test p v ferred beginning January 12, 1953 and ccmpletad I l FebFOIry 8, 1933. , l t;RC Region IV Inspecticn Report No. 50-445/33-04, i l 6.
- 7. Comanche Peak Steam Electric Station Reactor Containment Building Unit One Preoperaticnal Integrated Leak Rate Test, 19S3, Occket Number 50-445, Texas Utilities Generating Ccepany.
- 8. Comanche Peak Steam Electric Station Reactor Containment Building Unit One Preoperational Integrated Leak Rate Test Addendum, July {
1983, Docket Number 50-445, Texas Utilities Generating ~Ccmpany.
- 9. Citizens Association f:r Scund Energy (CASE) proposed Conter. tion f l
No. 26, October 13, 1953.
4 , t -6 .
~
- 10. This statement prepared by:"
Arthur Mackley Date . TRT Reviewer i l a Reviewed by: *
',]
i Richard R. Keimig Date Group Leader i
~
l Approved by: . l Vincent S. Noonan Date i Project Director ~,
. . . .
- r j
i i
- i
- 4 .
6 . 8 bs
, . e . r** *
- 1 .. .
,i . , i f . .. 3 i j i 1 . 1 . L ) i i r J. j. f
. t a
q . .... . l . T l I i b l
? uccumar.: name: ,e ,,. s.- N AT-14 ' - SSCR ALLEGAi!O. ' p fl i ' Requestor's 10: _ g PAT Author's Name: Chet Poslusny Cocument Comments: 11/8/84 Redraf t 15, space l c 'r/ 9 e 6 5 a ee t* e b 4
\/
H f, '
**i ,o ,
'. %) 1 i.,. s w > '
o
- w,9-.' ' /;
Final Draft, Rev. 1, 11/7/84 CP2; SSER Allegation AT-14 i
~
SSER
- 1. Allegation Category: Test Program Category No. 5
- 2. Allegation Number: AT-14a, b, c, d *j t
3., Characterization: It is alleged that prerequisite testing was perfarmed by craft personnel not qualified in accordance with ANSI N45.2.6, "Quali- - fication of Inspection, Examination, and Testing Personnel for Ruclear Power Plants;" that System Test Engineers- (STEs) were signing,for tests . that were conducted by craft personnel when in the majority of cases the , STEs'Were not present during testing; and that test documentation was made to.look.as if the tests were performed by STEs, when in fact they were ierformed by craft personnel and the STEs only reviewed the data. ,
. ... --. \'
- 4. Assessment of Safety Significance: The implied safety significance of i ..
this allegation is that'if prereaufsite testino activities were performed by craft personnel not trained and qualified in accordance with industry standards endorsed by NRC, err' ors could be made which could invalidate the $ p'rerequisite test results. However,thiscouldonlyhavecausehproblem during conduct of the subsequent pre-operational tests which followed. The CPSES Final Safety Analysis Report (FSAR), Section 14.2, describes the
. initial test program! It is implemented by TUEC~through a series of administrative procedures contained in the "Startup Administrative Proca-dure Manual." The initial test program is divided into three successive phases: (1) prerequisite testing; (2) preoperational testing, and ,
(3) initial startup testing which occurs after the license is issued for fuel load. The allegations address the prelicense categories of " prerequisite" testing , and "preoperational" testing. " Prerequisite" tests'are performed prior to -
"preoperational" tests to verify, the complete installation, cleanliness, and initial operability of individual plant components (this test cycle is
1 L
- also referred to as initial checkout)', using a series of generid 'ihstruc-tions contained in the "Startup Prerequisite Test Instruction Manual."
These tests involve checks of electrical resistance, transformer polarity, relay and circuit breaker operability, motor rotation and initial' opera-tion, initial pump operability, systems cleanliness, and piping support adjustments. Prerequisite testing involves work' normally within the . . expertise of journeyman craft personnel, and'TUEC utilizes them in this capacity under,the direct supervision'of an STE. The STE must certtfy the initial conditions of a prerequisite test are satisfied. He is responsible , for the proper conduct of the test, and must verify and certify that the results are complete and satisfactory. ,
~
"Preoperational" tests follow the " prerequisite" tes,ts and are conducted prior to fuel loading to demonstrate the capability of components, systems or str0ctures'to 5eet safety related performance requirements in the FSAR, which is accepted by the NRC. These tests'are performed by STEs who are qualified'tb ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel." "In order that component problems can be identified and corrected prior to the start of preopdrational tests, the erequisite
~
tests discribed in the previous paragraph are performed , an initial check of individual components to better assur'e their c srability during conduct of the preoperational tests that follow. In assessing the allegation that TUEC used craft personnel to pe,rform pre-requisite testing without an STE present, the TRT. Interviewed startup . management and support craft management personnel, and reviewed 35 prere-quisite test records. TUEC representatives stated that they permitted STEs to utilize craft. personnel to perform those portions of prerequisite tests that the STEs considered within craft personnel expertise, based on know-(^ t ledge of the craftsman's capabilities'as determined by direct observation by the responsible STE, TUEC's position was that these employees are not "testpersonnel,"'butrathergre"craftpersonnel,"andaisuch,theywere not required to be qualified ANSI N45.2.6, as sta'ted by that standard. X A The NRC has accepted that position as consistent with TUEC's FSAR commit-ments to ANS! N45.2.6 and NRC Regulatory Guide 1.58, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel."
h TRT reviews of craft personriel record's' revealed that they were fe'itiving c appropriate indoctrination training. For example, the Electrical Test Group (ETG) craftsmen were indoctrinated in 10 pertinent startup administrative procedures and 14 gentric prerequisite test instructions. TheTRThelddiscussionswithselectedSTEs,ETGcraftsman,andETGmanage- . ment, and observed ETG craftsmen at work. No apparent training or quali- 5 fication deficiencies were found for the type of work they were performing. In some cases the ETGs' knowledge of the components and test equipment , directly contributed to the success of the test. It was alleged that documentation of prerequisite testing mis 1'eads the
~
' reader to,,believe an STE conducted the test when in , fact it was performe
, by craft support personnel. The TRT's review of the 35 test records inter-
, yiews.with startup test personnel confirmed that craft personnel did, in fact, conduct some of the testing where appropriate. The craft signatures ,'
on the datr sheets supported this finding; however, the STE was still .. . responsible for the test and he verified satisfactory completion and signed the data sheets. This is not prohibited by TUEC's adm,1.nistrative proce- , dures, except that craft personnel performed verificatt'on and signoff of initial conditions on some data sheets', which *is a function that"must be done by the STE per section 4.10.9 of CP-SAP-21 " Conduct of Testing." Further investigation revealed a memorandum issued by the Lead Startup . Engineer on March 31, 1983, countermanding this requirement in CP-SAP-21. The subject of the memorandum (STH-83084) was "ETG Personnel Schedule Change," but it also indicated that craft support personnel (ETG) may verify prerequisites for Prerequisite Test Instructions XCP-EE-1 and XCP-EE-14. Publishing such a memorandum in lieu of executing a properly approved change to CP-SAP-21 is .in violation of CP-SAP-1, "Startup Administrative Procedures Manual," section 4.4.3.1, which requires a permanent or interim change to be, approved and issued to all manual ho.1ders in accoidance with CP-SAP-1. It appears that as a result of the memorandum, 24 of the 35 tests reviewed by the TR'T had prerequisites improperly verified by craft support personnel. Fifteen were XCP-EE-14, but nine were XCP-EE-24, " Fixed Battery Pack Operated Emergency Lighting Units," which were not even authorized b' the y memorandum.
. 5. Conclusion and staff positions: As a'1'leged, TUEC utilized craff ' personnel who were not qualified to ANSI N45.2.6 standards to support prerequisite testing activities. However, this practice is permitted by ANSI N45.2.6, as augmented by NRC Regulatory Guide 1.58 (Regulatory Position 7)l which permits personnel who do not meet the ANSI Standards to engage in data-taking and plant and equipment operation provided they are supervised by a I qualified individual and that they have sufficient training to ensure an ')
acceptable level of performance. Based on its review the TRT finds.that the craft personnel used to support prerequisite test activities were , sufficientlytrained,byvirtueoftheirfourneymanrating,toperform these activities. Additionally, even though they were not under the con- ~ stant supervision of an STE, whic,h is not required by ANSI N45.2.6 and , Regulatory Guide 1.58, the TRT considered that because the prerequisite test results they recorded were reviewed and certified by the STE responsi-ble for the test,and were approved by a test engineer with higher qualification than.the STE, adequate supervision was exercised. Allowing the STE to sign for data recorded by the craft personnel (and, thereby, having the documentation appear as if the testing was performed by the STE), is consistent with the procedure which directs the conduct of testing activities. This procedure was wid'ely disseminated diisite and was contained in TUEC's system of manuals and procedures. Therefor ~e, the TRT concluded that there was no intent to deceive anyone on the part of TUEC and that the practice as implemented was satisfactory. * , This allegation has neither safety significance nor generic implications.
- 6. Action Required:. TUEC shall rescind memorandum STM-83084 of March 31, 1983 which was issued in conflict with CP-SAP-21, and take action to ensure that there are noalso other memoranda issued whichtest conflict w
~
cedures. TUEC shall ennduct a review of all other prorequisite records to deteriine those that had prerequisites signed by craft person- >
~
nol, and assess the impact of those improper verifications on subsequent 4yf testing. -
l . { l ,. ~ ',".f '.} j {'{ 7 .,y 'f,.:,, 'z { 'g:' : , , .
~
J , , s' ., .. g( . j. 4; , . Y . ' .. . .*~ . ; .-r -
>4 - < .. , , . , , .
, '~
p- ..,
.g ' ' :' ' f: 4 y . -- .# . '.. i.i .c V
4 _ 4.) ' , .. i i. '- 7 . t, 4 f]f
'1 ~ tl . '- '
- :,.S~ , h;2#'s,'c, ,. ,} } . .# '['. . -
; ,8 -[~
\
^,f :, .: . }~
- : n .
u , s ,, .
. . , . 1. , ; ,
f ' if , ,
't 4,
,[ d i-. . :: ' -
i
. e;.; .,e { * *.. M , ".= .-i : . , p 5 '. -
;-. v, .
, . y .
e. r..
.. . . . . , , .,. - y,
, ;. .,. ? -
..x, ;,- - ..
%, a, : s, . -
" ,\ ,4' - . . ,-a.+ <
r -_A
- t . ;- ,< . , . , ,
.+ , a
- ' A '. I. -, , . ' .- - ,., . . ..
. ;. . .: . ;f- - . . ' : , e
.g- y ,
.,$ y ...- 4
,4 ,' , . . - =' 4 . . / ,,- , ,. a
. f, re . ,,- 3. . s -
v i ,.! '. , M . . .
.,a..s .?*. ,,
*.l' ,N.5 s g n. - .
4, . . . -.
.s
~ , -
g -'g. , . 4 . 2
.n ?-
,.'g- ,* -
* * -v .. .v . .
i.- .
*..- 6 ,, g .; ( >+
f . $ -., .
'c ' k , ,, 7 d - - ., . . ,
.' '[.,.s.. b'.'
. . ., , , , . , ,j4,
- p. .. ,,.',- ' . ' . _*, . . \/.
,,'s. - , ; ..,,a . '
, ' , - - - ,. , Q-
,, . , , , ^J.
,l . , '
\
1,
,"l..,
,-. .p_. -; :
f', Z 1
- . , .,-(
. *8-a .,
9 , , , bi : .,
+f4m ; $ et '
6 c.
,...4 , -
* , . ,N' _ - < - .' . .
.' . , , . -. j py ,. ' . w ,, , ..- ,,,,$.
- * , 4 4 .. ;
,r
$- v,.4
.;, ,w' .
y.",, t.- l, . .. ' '*
- .,..,j
'e 4' .'.. - , . ;A a *' :;-,
-i .'- . , . ' ,)
,a C x F.'..
j
.g' -
P
,:E ,, -
\ .
4 ', r M* s . ge- h,y,
',..,.l, , '? #-
' ,'s a-3,.. ,. ,
- u. '. .'s
- p. j ,' ' ;i ' . 9 ey tv . ,. - -[d v. g -y r,..'.- rite>
s
, o *
!-. ~'o.u' .' en,1 '. %g. - n~ ' . %,e:V.e :9; .c+
H.@. 4, s .. a.o.t-W,: .4 . vF. ?
- b : .* .- ,'; -
8 . -
'?
v.- l
.. , u.e. .- .- . ..e.y ,g . . ,_
;.- v-
,r c ..1,yn n
h 4, . A w ., ... . . - p + rm . >, ' 1 - .
"a e,. , - - y 9,4 g+, , , g .
1 74ryn, , , a 4 9 8
$ /
,/
5 6
, +,
9' ( - ,
- e. .
, - 9
, - (
. 6.
+
8
\
b4
+
e N i
v'
- 8. Of fice M:-morandum STM-53034 of $ arch 31, 1933,
Subject:
ETG Persenrel Schedule Change.
- 9. CP-SAP-11 " Review, Approval and Retention of Test Results" (Rev. 5 -
January 4, 1983).
"g
- 10. CP-SAP-19 " Training / Qualification Requirements for Startup Personnel" .
(Rev. 5_ ,May 6, 1983). -
- 11. CP-SAP-10 "Startup Program Quality Assurance Plan Implementation" (Rev. 2 - July 9, 1982). .
a . .
- 12. CP-SAP-16 " Test Deficiency and Nonconformance Reporting" (Rev 8
- December 7, 1983). ! 13. egulatory Guide 1.53 " Qualification of Nuclear Power ?: ant Inspdction, Examination, and Testing Personnel" (Rev. 1 - September ..
1980)
- 14. "Startup Prerequisite Test Instruction Manual" (a compilation of generic prerequisites).
- 15. Affidavit of GAP, Witness H.
- 16. GAP handwritten notes by Billie' Garde from conversaticns with Witness H.
- 17. Regulatory Guide 1.8, " Personnel Selection and Training."
i
- 18. ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Pe r s o n n e l . "...
l f
-~. - . - - _ . . . _ . _ -_ _ __. _ __ _ _
s ., s .. ,
? '
- 10. This statement prepared by:'
Ward F. Smith Date . TRT Reviewer i 4 Reviewed by: - Richard R. Keimig Date <f Group Leader _ a Approved by:
- I Vincent S. Noonan Date
' Project Director f
.L .
. .a.s**** ,
.j t
= .
. .6
'I s ..
I n I i . . g t O O T 1 J j .. j . 1 1 I i l l
. Document i:ame: ,g g SSER AT-15
+ 3 6 Requestor's ID:
PAT O. ( , h-Author's ? ame: Chet Posiusny Document Ccmments: 11/8/84 Redraf t 1: space , i O f.
.l t
4 9 e e he e O 4 0 e f /', ] /..s
- t, 'sa. ,! ..I . .
^
K @//t
6 , Final Draft, Rev. 1, 11/7/84 g SSER AT-15
^
SSER
- 1. Allegation Category: Test Program No. 6
- 2. Allegation Number: AT-15 ,
- f
- 3. Characterization: It is alleged that the preoperational test prografiiis flawed because (1) there is a dual numberirig system and many system test -
engineers (STEs) for electrical / mechanical plan.t systems may test one system, or'one STE may test a part of many systems, a conditio.n causing . overlap, confusion, and the possibility of omissions, (2) STEs are not . provided with'a " computer printout" which informs them of all tests required, on a. system, (3) calculations for' instantaneous trip settings on approximately 100 breakers had not been performed correctly, (4) portions ,
^
of prerequisite tests are being used to meet Final Safety Analysis Report . (FSAR) commitments, (5) a ' system can pass through both the prerequisite .. . test and the preoperational test without ever undergoing an energi..d functional test; and, (6) STEs are not provided with current design information and, therefore, must spend too much time researching,and validating drawings.
- 4. Assessment of Safety Significance: The implied safety significance of these allegations is that if safety-related systems described in the FSAR
.are not fully tested, there is no extra assurance'that the systems will meet their intended safety functions.
l The TRT reviewed"the " prerequisite Testing" method used by TUEC to ensure , that the systems were ready for 'preoperational testing. Through a series of generic tests, such as XCP-EE-1, "Megger Hi/ Pot Testing," XCP-EE-8,
" Control Circuit. Functional Testing," or XCP-ME-1, " Initial Pump Op'eration," TUEC verified that construction was, completed as required for the preoperational test program. The prerequisite tests consisted of~such items as . initial instrument calibration, system piping flushes and cleaning, wiring continuity and separation checks, hydrostatic pressure
6,
- Test Program No. 6 s
~
tests, and initial functional tests of components. These tests f'acilitate the safe and orderly progression to the preoperational test program, as outlined in Regulatory Guide 1.68, and,as committed to in the CPSES FSAR. There are additional comments on the conduct of prerequisite testing in Te'st Program Category 5 of this SSER. - The TRT discussed TUEC's process for STE plant system assignments during '7 an interview with startup management p'ersonnel. Each STE was assigned to at least one system, although the more complex systems had two or three . STEs assigned, with one STE designated as.the leader. These assignments were documented on a " System Assigninents" sheet, which the STEs used to keep track of who was, responsible, for each system. , The TRT found no evidence that indicated confusion, gap's, or overlaps i betwee'n systems and subsystems because of STE assignments. As documented in CP-SAP-2 "Startup Program Organization and Responsibilities" and CP-SA'P-21,'" Conduct of Testing," the STE was responsible'for ensuring that ,, assigned systems were properly tested and that the tests were coordinated with adjacent systems tests. The STEs were respons_ible for cooperating with other STEs when the scope of testing overlapped into subsystems under their responsibility. The " subsystem definition packages" provided to all l STEs facilitated this cooperation. The same applied to cases where startup work authorizations (SWAs) applied to more than one system. The master data base, a multi-functional computerized tracking s'ystem, showed outstanding work or deficiencies on ail subsystems by code. The STE had the resources and the training'to keep the coordination between STEs and plant systems under contro1. , The alleger also ~ implied that the numbering system used to identify sub-systems was a " dual" system, that is, the same component or terminal could appear on two adjacent systems if it were on a boundary, thereby causing confusion. Th6'TRT determined that it was not unusual for this to happen, but if a work item was gene ~ated on such a component and it appeared on the master data base under a system assigned to an STE who did not have responsibility for that component, it would be necessary for that STE to I --
i .
- Test Program No. 6 cooperate with the STE responsible for that component to get-the'w6rk item closed. This. degree of cooperation was common among STEs and did not appear to be a source of problems. The TRT found no evidence that indicated confusion, gaps (missed tests), or overlaps between syst' ems and subsystems because of the " dual numbering system."
e As alleged, STEs were not provided with a computer printout that informed 'f them of what. tests were required on a* system. The STE was responsible for
' determining what testing was required based on design specifications , .
drawings, the FSAR, and other applicable documents. When the STE, the group leader, and the Joint Test Group (JTG) agreed on the testing require , ments, a computerized, test index was published to track the nuinber, name, , and status of all tests. The index was m,ade available to all STEs and was reviewed by the-TRT. In its investigation of the allegation related to incorrect instantaneous . breake~r TrTp settings, the TRT found that prior to September 1980, a total .. + of 74 molded-case circuit breaker instantaneous trip settings were adjusted to the specific values required by the design drawirigs. None of these breakers were safety related. Early in prereiiuisite testing, a few "nuis-ance" trips were encountered, i.e., some break'rs e instantaneously tripped at locked rotor current values, which was not proper. Startup test 4 engineering correspondence and discussions with Gibbs & Hill', Inc. (G&H), . the design architect-engineer, resulted in a revision to XCP-EE-14,
" Molded Case Circuit Breaker and Thermal Overload Relay / Heater Testing,"
'which is the generic procedure for determining, testing and recording these settings. The revision, which changed the method of determining the trb settings, included consideration of'the motor starting KVA, horse- "
power, voltage, and full-load current which we're not accounted for in the previous revision, and therefore, this revision was more accurate for a particular motor. The TRT reviewed the specific data associated wi+.h the tr.ip-setting caiFulations alleged to be erroneous, which were found by the electrical test group on or about March 15, 1984.' The data of concern involved 21 breakers that were initially set in accordance with G&H design drawings. While comparing the iristantaneous trip settings from G&H with
t Test Program No. 6 settings calculated in acco ance with the revised version af XCP'-EE-14, l the TRT found that, on the average, the calculated values varied by plus l or minus 10 percent. During interviews with startup engineering personnel the TRT learned that TUEC considered this variance to be insignificant when it was identified because (1) the XCP-EE-14 calculation method was placed in effect subsequent to using G&H values; (2) the equipment was . - j not safety related; (3) the variance resulting from calculating with the ~7 newer XCP-EE-14 method was minor; and, (4) no nuisance instantaneous trips were occurring on breakers which remained at the previous settings. The . equipment involved included the turbine building roof exhaust fan, cir-culating water traveling screen, polymer mixer, and other similar compo-nents that are not safety related,. The alleg tion also implied that because some prerequis'ite tests were not
~
repeated as p' art of the preoperational test, portions of prerequisite tests were being used-to prove FSAR commitments. FSAR Section 14.2.1 states that prerequisfYe testing is one of the three major phases of the testing .- . activity at CPSES (the other two are preoperational and initial startup Vd testing). This section also states that prerequisite testing will be con-W ducted in order to verify the integrity, proper installation, cleanliness,
~
p4 \ and initial functional operability of componen'ts. The alleger stated that a " system" can pass through both prerequisite and preoperational test progra'sm without ever undergoing an ener'gized func-tional test. The TRT found that there'were cases.where some circuits, such as those for lights indicating valve and breaker positions, may only have had continuity checks during prerequisite testing without having been specifically checked during preoperational testing. However, the TRT learned in interviews with startup personnel that even when such circuits were not specifically tested, the circuits would be ver~ified duririg the preoperational testing of 'the components they served. For example, when a given preoperatTo'nal test requires a remote-operated valvd to be opened, the operator would expect to see a change in the' indicating light. If this did not happen, the operator would indicate the abnormality to the
i . 1 Test Program No. 6
~
STE so that corrective action could b'e'taken. Most of the time'whe'n this happended, it was a burned out bulb, which the operator replaced on the spot. If not, the STE documented it for resolution. The TRT considered this approach to be reasonable. It is alleged that system drawing packages were being delivered to the . 2 STEs with design change authorizations (DCAs) several years old that were i not updated on the design drawings; that packages were being received by STEs with DCAs issued against other packages; that print changes were , arriving with no DCAs in the packages; and, that there was no procedure to ensure that the STE had the proper documentation to conduct a valid test. , The TRT interviewed three STEs who were responsible for major fluid and _
~~
electrical systems at CPSES. At each interview the STEs commented that the substance of the allegation relative to outdated design drawings was c.orrect 'in the pa's't, but that some improvements were since made. That portion of the allegation dealing with the lack of procedures could not be
- substantiated because those interviewed insisted that there were always
. procedures to ensure the STE had proper documentation. CP-SAP-21, " Con-duct of Testing," Section 4.9 required the STE to use current information when he prepared to conduct' a test. Thus, the responsibility was placed on the STE to ensure he was working with current documentation. 'To accom-plish this he was required to go to the document control center and' update the documents. 'This was very time-consuming and burdensome. The STEs who , were inter'iewed v told the TRT that after much discussion with TUEC manage-ment the documents given to STEs had improved greatly and, at the present time, only the "less important" systems, such as vents and floor drains, are causing the STEs a problem. Even though the STEs are now being issued current drawings.in a controlled manner, DCAs are not being promptly
~
transmitted to them upon issue. .Therefore, th'e STEs have more current drawings at present,-but they still must go to the document control center for DCA updates.
- 5. Conclusion and Staff Positions: The TRT found no' deviations or violations of NRC requirements regarding the alleger's concerns over the prerequisite and preoperational test programs'at CPSES, even though some of the allega-tions were substantiated.
i . ) . Test Program No. 6 ducaAms . i, With regard to the specificg characterized paragraph 3 of this se'c'tlon of the SSER, the following conclusions were reached: . (1) The " dual numbering" system and STE assignment methods did not cause confusion, gaps or overlaps in testing. The STEs appeared to be in . full con' trol'of the systems for which they were being held - responsible.
'4r (2) The STEs had sufficient information to determine what tests were .
required for their assigned systems and were sufficiently trained to make that determination. In addition, TUEC pointed out that there were backup reviews performe,d by startup personnel of greater. ,
~
. experience and training, as well as the ultimate JTG reviews.
(3) Calculat' ions", where required, were performed properly for the instantaneous trip settings on molded case circuit breakers, and the
. -disparities found by the technician were acceptable. .
(4) Portions of prerequisite tests were not being used to satisfy FSAR commitments other than addressed in the FSAR, but, rather h c N b M d the success of subsequent preo;ie' rational tests whiih in assurtag part satisfy FSAR commitments. (5) Though all parts of all systems may not be incrementally and specifi-cally subjected.to an energized functional test, the'preoperational test program subjects all systems committed in the FSAR to an ener-gized operating condition as a minimum such that failures would be detected. Thi's is an acceptable approach. (6) STEs are now provided with current design information by virtue of their access to the document control center for updates, however the day-to-day'c'hanges are not delivered to the STE in his place of work. No problems appear to have surfaced as a res' ult of the STEs having to pursue design information updates on their own initiative, however the TRT considers the intent of 10 CFR 50, Appendix B, Criterion VI was to have this information delivered to the STE's workplace.
-/- -irst .t rog re. *:: . 6 e
The TRT concluded that these allegations have neith2r safety significance nor generic implications.
- 6. Actions Recuired: TUEC shall establish measures to provide greater assur-
+at ance that STEs and other responsible, personnel \are provided with current controlled design documents and change notices. . ;>
~
- 8. Attachments: None.
- 9. Reference Documents:
i I ..
- 1. XCP-EE-1, "Megger Hi/ Pot Testing" (Rev. 7 - June 4, 1982).
- 2. XCP-EE-14~, " Molded Case Circuit Breaker and Thermal Overicad Also Rev. D, Ke'f'~y7 a heater Testing" (Rev. 9 - March 23,1983). ,_
Rev. 1, and Rev. 2. I l l l t 3. XCP-ME-1, " Initial Pump Operations" (Rev. 6 - March 1, 1983). l
- 4. XCP-EE-8, " Control Circuit Functional Testing," (Rev. 6 -
February 22, 1983).
- 5. System Assignments, April 25, 1984.
- 6. CPSES Final Safety Analysis Report (FSAR) - Amendment 50, July 14, 1984. y 9
- 7. Regulatory Guide 1.68, Revision 2, August 1978, " Initial Test Programs for Water-Cooled Nuclear Power Plants."
- 8. CP-SAP-2, "Startup Program Organization and Respcnsibilities" 1 (Rev. 5 - November 1, 1933).
i CP-SAP-21, " Conduit of Testing" (Rev 2 - Mar:n 7, 195 ). 9.
.s ~
Test Program No. 6 h
- 10. CP-SAP-19, " Training /Qualificatien Requirements for Startup' Personnel" (Rev. 5 - May 6, 1933).
- 11. AT/PTTestIndexwithSchedule,bnit1andComon(July-2,19S4).
- 12. Affidavi~t of GAP witness H
. 'I i
- 13. Handwri.tten notes taken by GAP (Billie Garde).from conversations- ,
with witness H, and Witness A.'
- 14. Completed XCP-EE-14 test data sheets (quantity 74). ,
- 15. Dwg._2323-El-0010,0013,00i4&0015" Normal 480VMCCSOneLine Diagrams".
- 10. This stsE55ent prepared by: ..
Ward F. Smith Date TRT Reviewer ,, Reviewed by: Richard R. Keimig Date Group Leader
- Vincent S. Noonan Date f ,
Project Director i ? i
' r
' qsl Document fame: " t SSER TEST PROGRAM 7 A
i O
' Requestor's 10:
PAT - Author's Name: .
,Chet Poslusny
\%
Document Comments:
- 11/8/84 Final draft, rev. 1
. 'l r
O e e eg W e
,.9 # *"
.e
# De O
Cjn c , ,. 3 y)}.p?,
- s. q.-. . - - ;<, .
I ff E-9Q
Final Draft, Rev. 1, 11/7/84 l
- cp3/SSER AT-16 l 1
~
SSER j
- 1. Allegation Category: Test Program No. 7
- 2. Allegation Nu[nber: AT-16 *
{ .
'lp
- 3. Characterization: It was alleged that.TUEC y.r, m a management had mO y a tendency to interpret their commitments to the Final Safety Analysis j {[
Report (FSAR) and to NRC Regulatory Guides (RGs) liberally rather than h conservatively.
. b .
/
\
Asses'sment of Safety Significance: The implied safety significance of d P 4 . ver .,y this allegation is that such tendencies could lead to plant c 5J:tM gw g at a standard below that required by the NRC, which in turn could Y adversely affect public health and safety. The primary basis for this allegation appeared to be that the IUEC Start 7 up Group did not require craft personnel who support testing activitics or perform installation checkouts to be qualif.ied to ANSI N45.2.6-1978. l The TRT review of that allegation, ' presented in Test Program Category 5 of this SSER, concluded that while qualifying those personnel to ANSI N45.2.6 may have reflected a conservative management attitud,e, TUEC did not commit to that level of qualification in the FSAR. ANSI N45.2.6-1978, Section 1.2 leaves th'e imposition of its requirements to the discretion l of the employer for personnel who perform work which is well within their normal craft expertise, e.g., calibration and installation checkouts. l Additionally, that work was performed under varying degrees of supervision l by qualified System Test Engineers (STEs) who were held fully responsible for the correct performance of that work and'for the review of data recorded.' .... In order to determine if there were any other bases for this allegation in the testing activities area, the TRT reviewed FSAR Chapter 14, which describes how the testing program is to be carried out, and the RGs to l
o
. which TUEC committed. These were coEpared with TUE"'s Startup Administra-T tive Procedures and Startup Quality Assurance Plan which prescribe, .in @'
detail, the conduct of the testing program. In addition, the TRT reviewe dur related to the test program in Test Program Categories ^1, 3, 4, 5, 6 an 7 f this SSER. With the exception of some minor deficiencies
'dentified i in Test Program Categories 1, 4 and 5, the TRT did not find i; any substan'tive evidence that the Startup Group interpreted FSAR commit- '7 ments or RGs in a nonconservative manner. _
The TRT found, however, that some of the decisions made by startup manage-ment may have appeared to be less than conservative ~ Through discussions with startup management personnel, the TRT perceived this to tie due to the I heavy.wo@loadandschedulepressuresinherentina,testingprogramof such magnitude. These burdens apparently resulted in decisions by startup i j management, in th'e interest of expediency, to delay some aspects of a particular test to-a later date when the workload and impact on schedule , would-bE Tifssened. The TRT found several examples of this with respect to - preoperational testing. - One such example was the TUEC decision to conduct the Containment Integr-ated Leak Rate Test (CILRT) with three electrical penetrations fsolated.
- While it is technically reasonable to do that (as long as certain controls are maintained), it is preferred that this test be conducted with the .
containment building as close as possible to the configuration it would be in during normal plant operation, i.e., with no penetrations isolated. An allegation concerning how the CILRT was conducted is discussed in detail in Test Program Category 4 of this SSER.
~
Another such example concerned pre-ciperational tests which were originally scheduled to be performed prior to fuel load, but for which TUEC was seeking NRC approval to defer unt.il'after fuel load. The Hot Functional Test', in particiifar, ts. discussed in detail in Test Program Category No.1 . of this SSER. These decisions were apparently made because of schedule considerations and, while not the most conservative course of action, nevertheless, were acceptable fr'm o the point of plant safety. l t L
- 5. Conclusion and Staff Positions: The TRT found no substantive r353.:n to believe that TUEC startup management has a tendency to liberally interpret FSAR commitments and tlRC RGs.
As discussed above, startup mana sment has made decisions which.the alleger could have constructed as less than con-servative. The TRT found the programs that TUEC had implemented for cen-ducting and inspecting precperational testing, as verified by i;RC staff . routine inspection of testing activities, were sufficiently ccmprehensive '7 to reveal all safety significant or generic problems. Acco rdi ngly , _thi s i allegation has neither safety significance nor generic implications. l l
- 6. Actions Required: None. .
- 8. Attachients: ' fione .
- 9. Re fe rence' Yocumen ts : .
- 1. t:05-103-1, " Guidance for Assessment and Distribution of Industry Operating Experience Reports" (Rev. 2, February 15,1984).
- 2. CPSES " Final Safety Analysis Report" (FSAR), Amendment 59, July 14, 19S4.
- 3. Memorandum STM-83054 dated March 31, 1983 to all startup engineers, subject: ETG Personnel Schedule Change."
- 4. ICP-PT-75-02, " Structural Integrity Test and Integrated Leak Test,"
(Revision 0).
- 5. CP-SAP-1, " Conduct of Testing," (Rev. 2, March 7,19S4).
- 6. Affidavit of GAP Witness H
- 7. GAP handwritten notes by Billie Garde l
l L - - - - - _ _ _ _ _ . . . _ _ _ - - - - - - - - _ _ _ _ - _ _ _ __ _
C , e
~
- 10. This statement prepared by:' .
Ward F. Smith Date . Reviewed by: Richard R. Keimig Date . Group Leader ',9 Approved by:
. Vincent S. Noonan Date Project Director
-me e 8 4
me e e 9 e e G
, ,e . f
- O e
, a 9 pg .
I% S e O e S C e
. =e O
O e 4
l - ,
- /s.v
~
a q Document L ee: AT-18 TEST PROGRA!! CATEGORY 8 E Requestor's ID: PAT Author's Name: A. Vietti/kb i s Document Co:dments: ey , .) 11/8/84 Final Draft, Rev. 1 c.
\
i xL i k ~
=
c%'.,
=
e
*"6e
~ ,
" {a)w;, j'., .
-7
( k_idct
E , 11/7/84
. Final Draft, Rev. 1, 4
AT-18 Test Progran Category 8
~ * "
SSER -
- 1. Allegation Category: Test Programs No. 8
- 2. Allegation Number: AT-18
- 3. Characterization: It is alleged that quality assurance / quality control
- (QA/QC) surveillance of test program ~ activities was minimal. -
- 4. Assessment of Allegation: The imp 1'ied safety significance of the allega-tion is that QA/QC surveillance may not have been sufficient to ensure .
that the testing program met its objective, that is, demonstrated that ,
~
plant structures, systems, and components were capable of performing their intended safety-related functions. Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50) Appendix B,' , Criteri6h XI, requires a testing program to be identified that will demon-strate the satisfactory performance of safety-related structures, systems, and components, and that the, testing be conduct _ed in accordance with written procedures which incorporate the requirements and acceptance cri-teria of applicable design documents. Appendix B, Criterion X," requires an inspection program to be established to ensure that activities affecting quality such as testing of safety-related structures, systems, and compo- . nents, are carried out properly. The NRC Technical Review Team (TRT) reviewed the programs that Te'xas Utilities Electric Company (TUEC) had established and implemented in order to meet these NRC requirements. The TRT's review o'f the prerequisite and preoperatf6hal testing programs is described in-Test Program Categories 1 throug f this SSER. 2 f 2-i The TRT also reviewed TUEC's QA/QC program for inspection of testing activities. The QA/QC inspection program is described in the Comanche PeakSteamElecEricStation(CPSES)FinalSafetyAnalysisReport(FSAR), Chapters 14 and.17, and is augmented by the CPSES Startup Quality Assur-ance Flan. This plan delineates responsibilities and measures for accom-plishing and controlling testing activities. TUEC's Manager, Quality 1
g , Assurance, was responsible for verifving proper implementation of the plan. This responsibility was assigned to the Construction and Startup/ ( g Turnover Surveillance (CSTS) group which was located on the plant site and reported directly to the Manager, Qual'ity Assurance. / In order to determine the extent of this group's surveillance of testing, ,3 activities,- the TRT reviewed CP-QP-19.6, " Surveillance of Construction and /f/ Startup/ Turnover Activities" and referenced documents which prescribed the method for, anil frequency of, conducting surveillances of174 hon-ducted during 1982, 1983, and the first half of 1984, as well as 5 un-planned surveillances (out of 37) conducted duririg 1983 and the first half of 1984. The TRT found that a surveillance schedule, which was updated
~
monthly to accommodat'e changes in the testing schedule, dictated the fre-
~'
~
quency of the QC surveillances by the CSTS group. The schedule was prepar_ed by the CSTS ' staff and approved by the CSTS Supervisor as required 15y CP-QP-19.6., The schedule required surveillance of certain aspects of each.preoperational test scheduled and a minimum of 30 percent of the prerequisite tests associated with each preoperational test. In interviews with cognizant CSTS personnel, th'e TRT found that the sampling of the prerequisite tests was such that each test would come under surveillance at least annually. These prerequisite tests are generic and are performed to verify such things as complete installation, functional operability, and cleanliness. Preoperational tests, on the
~
other hand, are performed to verify that structures, systems, an'd compon-ents meet their safety-related design functions. Therefore, the smaller sample -size for prerequisite test surveillance is appropriate because the preoperational t;ests are the NRC-required performance proof tests and the TRT found that these undergo considerable surveillance. The surveillance schedule also covered reviews of the administrative pro-cedures by which"the testing personnel conducted their program. These ! reviews were scheduled to cover each administrative procedure at least annually. t
)
J The TRT also found that a detailed checklist was prepared fgr esch sur-veillance by the .ssigned CSTS inspector. These checklists r e f <: r e n c e d v.d included applicable drawings, procedures, and regulatory requirements, such attributes as the qualifications of testing personnel, verificatica of equipment performance characteristics, proper doctunentation of test results, and. direct observations of testing activities to verify adherence , to procedures, use of correct revisions to applicable testing documents, j5, and proper ccmpletion of prerequisite conditions. Additionally, the TRT ~ observed the use of QC " hold points" in their review of preoperational test procedures which was conducted in conjunction with a review of allegations in Test Program Categories 1, 3, and '5 of this SSER. This
~
indicated to the TRT that the CSTS group also performed specific reviews . ! of these procedures b'efore the start of a particular test. In addition to the surveillances listed above, th; TRT also reviewed five audits (out of seven) conducted by TUEC's Dallas QA group between late 1982,and the first half of 1984 to determine the extent of invc'vement by ] TUEC Corporate QA in the testing program. These audits were fcund to be i comprehensive, and the frequency at.which they were conducted was consis-tent with that established by DQP-CS-4, "Proced'ure to ' Establish and Apply This is a System of Pre-Award Evaluations, Audits, and Surveillances." ' also commensurate with the safety significance and pace of the preopera-tional testing activities as described in NRC Regulatory Guide 1.33. The TRT concludes that the frequency and
- 5. Conclusions and Staff Position:
' degree of TUEC's QA/QC inspection of testing activities was apprcpriate, commensurate with the safety significance of the specific activity under Accordingly, this surveillance, and in compliance with NRC requirements. ,
allegation has neither safety significance nor generic implications.
- 6. Action Recuired: None.
S. Attachments: None.
. - - - - - . - - . - - . - -, . . - - . - . _ _ . . , - , - - __,-,,-----.n - - - , ,- -
, ---,w- -
e
- 9. Reference Documents: ,
(1) 10 CFR 50 Appendix B, " Quality Assurance Criteria for Nuclear ' owe r Plants and Fuel Reprocessing Plan'ts (2) ' Comanche Peak Steam Electric Station Final Safety Analysis Report ,', (FSAR) , Chapters 14 and 17 through Amendment 50, July 1984. /*[/ (3) TUGCO-Dalias Quality Procedures / Instructions Manual, June 28, 1984. (4) Comanche Peak Steam Electric Station'Startup Quality Assurance Plan, Revision 1, January 19, 1983. (5) TUGC0' Quality Procedures Manual, Procedure CP-QP-19.6, " Surveillance o_f-Construction and Startup/ Turnover Activities," Revision 5, May 15, 1984; Rev.i.sion 6, June 20, 1934. (6) TUGC0 Quality Procedures Manual, Procedure QI-QP-19.6-1,
" Surveillance Defic'iency Reports," Revision 0, May 15, 1984.
(7) TUGC0 Quality Procedures Manual, Procedute CP-QP-2.6, -
" Certification of CSTS Personnel," Revision 2, May 15, 1984.
(8) DR (Surveillance) Nos. 83-004, 83-012, 83-020, 84-005, and 84-009. (9) DSR (Surveillance) Nos. 82-002, 82-003, 82-010, 82-015, 82-023, 82-026, 82-029, 82-033, 82-040, 82-047, 82-063, 82-066, 82-072, 83-001, 83-002, 83-007, 83-010, 83-013, 83-022, 83-024, 82-027, 83-028, 83-035, 83-039, 83-049, 83-053, 84-001, 84-008, 84-032, and 84-036. (1,0) TUEC-DallasQA Audit Nos. TSU-1, TSU-2, TSU-3, TSU-4; and TSU-6. ('ll) NRC Regulatory Guide 1.33, Revision 2, 1978.
s 5
=
(12) TUEC-Dallas Quality Procedures / Instructions I:anual, Procedure DQP-CS-4, " Procedure to Establish and Apply a System of Pre-Award Evaluations, Audits, and Surveillance," Revision 10, June 4, 1984. (13) TUEC-Dallas Quality Procedures / Instructions Manual, Instruction DQI-CS-4.6, " Conduct of Internal, Prime, and Subcontractor Audits, ' Revision 7, April 13, 1984. ,l',f (14) Handwritten notes taken by GAP (Billie Garde) with witness H.
- 10. This statement prepared by: '
Arthur Mackley Date
~
~
. TRT Reviewer Reviewed by;..--- " ~
Richard R. Keimig Date Group Leader Approved by: Vincent S. Noonan Date . Project Director E e
1 D .c ui,e n t f:am.e : C)
". 55ER TEST PROGRAM 3 , ,. o % Requestor's 10:
PAT . Author's flame: / Chet Posiusny gf/ Document Comments: [ 11/8/84 , Final draf t, rev.1
.)'
r
~ .
,l, '% p.,
[ e *.* : e n- ,-.:,s DU
5
.* Revision 3
[ - CP1 sser at-12
.. s SSER
- 1. Allegation Category: Test Programs No. 3
.j,.
- 2. Allegation Number: AT-12 ;
f
- 3. Characterization: It is alleged that unless ordered to do so by th1! NRC Atomic Safety and Licensing Board (ASLB), Texas Utilities Electric Company -
(TVEC) wil_1 not conduct a testing progr'am on Unit 2, but will rely instead on the results of the Unit 1 testing program to support Unit 2 operation. .
,~ ..
- 4. Assessment.of Safety Significance: The implied safety significance of this allegation i_s that safety-related structures, systems, and components assoc'iated with Unit 2 would not undergo a testing program to verify that the plant has b'een' properly designed and constructed to assure public health and safety. .
._f . .
The NRC Technical Review Team (TRT) reviewed TUEC's preoperational testing program fo'r Comanche Peak, Unit 2. TI)e TRT reviewed TUEC's Final Safety Analysis Report (FSAR), Chapter 14.0, " Initial Test Pro-gram," and found it to be consistent with NRC Regulatory Guide (RG) 1.70, '! Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," and RG 1.68, " Initial Test Programs for Water Cooled Nuclear Power Plants." TUEC is committed in the' FSAR to meeting both of these regulatory guidelines. Regulatory Guide 1.68 requires that all structures, systems, and components that are important to safety be
~
tested. . The Comanche Peak FSAR Chapter 14.2.1, " Summary of Test Programs and Objectives," sta,t,es that the purpose of the startup program for Comanche Peak Steam Electric Station (CPSES) is to assure,that the installed station structures, systems, and components will be ' subjected to tests to verify that the plant has been properly designed and constructed and is ready to operate in a manner that will not endanger the health and safety
[ of the public. The FSAR fo'r Comanche' Peak encompasses both.Uniti'l and 2. Accordingly, this statement does not imply that testing will be conducted only on Unit 1. Figure 14.2-3, "Preoperational Test Schedule," and Figure 14.2-4," Initial Startup Test Schedule," indicate that the respec-tive schedules are applicable to both Unit I and Unit 2. The TRT als'o reviewed TUEC's "AT/PT Test Index with Schedule, Unit if
- 2-CPSES," (July 18,1984). This document provided an index of acces-tance acceptance tests (ATs) and preoperational tests (pts), including ,
test numbers, revision numbers, and procedure titles for the projected Unit 2 testing program. Due to the uncertainty of when Unit 2 construc- . tion will be completed, this document does not show a projected schedule. '
~
The_T_RT compared the Unit 2 index with RG 1.68 and with the Unit 1 index and found them to be consistent. Only systems which were shared by Unit 1 and-Unit 2'and"were fully and successfully tested during the Unit 1 testing program were not scheduled to be tested during the Unit 2 testing . program.~ Examples of these " shared" system tests (which were listed on " '
- "AT/PT Test Index with Schedule, Unit 1 and Common," dated July 9, 1984) included: Waste Gas System Leak Check; Control , Room He,ating and Ventilation System; Telephone and Radio Systems; Primary Plant Ventilation System; Primary Plant Ventilation Supply System Cooling. The control ro6m heating and ventilation system is typical of the commonality of these systems.
Units 1 and 2 share the same control room, and it has one heating and , ventilation system. Because the heating and ventilation system was tested when Unit I testing occurred, it need not be tested during the Unit 2 testing cycle. In fact, this system will already be in operation when Unit 2 testing takes place.
- 5. Conclusion and Staff Positions:. The TRT concludes that this allegation I
is without basis. TUEC has consistently indicated to the NRC staff that Unit 2 would undergo a testi.ng program subject to NRC requirements. Acco'rdingly, th'il allegation has neither safety significance nor generic implications. .
- 6. Actions Required: None.
l
r !. . l s,i
- 8. Attachments:
- AT/PT Test Ir.dex rith Schedule, Unit II - CPSES, July le, 1954 l
AT/PT Test Index th Schedule, Unit I and Common, July 9,1984
- 9. Reference Documents: _
- 1. 10 CFR 50
- 2. CPSES FSAR, Chapter 14
- 3. RG 1.70 l
- 4. RG 1.68 '
- 5. .AT/PT Test Index with Schedule, Unit II - CPSES, July 18, 1934 AT/PT Test Index with Schedule, Unit I and Com. hon,- July 9,1934
~
6.
- 7. NRC MC 2513 ^
- 8. NRC MC 2514 f . Citizens Association for Sound Energy (CASE) proposed contention
- 9. ..
No. 26, October 13, 1983 i (
- 10. This statement prepared by: ,
Richard R. Keimig Date Group Leader Reviewed by: Richard R. Keinig Date o Group Leader Approved by:
~~
Vincent S. Noonan Date Project Director I r
?* h! >$ ' f Y ) 0 l-
'q -
(30J.,i Yg\ l M p f _ ,d O k
- 1. Allecation Grouo: Electrical / Instrumentation Category No. 1 - Electrical Cable Terminations .
- 2. Allecation Numbers: AE-13, AE-16, AE-18, AE-22, AE-26, AQE-12, AQE-36, and Parts of AQE-7, AQE-8, AQE-37, AQE-39, and AQE-46.
- 3. Characterization: It is alleged that:
Terminal lugs of improper size and type were utilized on cables in
/ various panels and that improper cable splices existed within certain
/
panels (AE-13).
- Loose bus bar and ground wire connections existed in a safeguards
/ panel (AE-16).
Cables were being butt spliced inside panels in violation of procedures (AE-18). Cable butt splices existed in panels without authorization or without
/ being documented on drawings (AE-22).
Cable termination connections were icose and improper-sized lugs were being used on cable terminations (AE-26). Cable terminations not in conformance with drawings were accepted by quality control (QC) personnel (AQE-12).
/ Vendor-installed terminal lugs were excessively bent (AQE-36).
Certain quality assurance / quality control (QA/QC) matters related to cable terminations were improperly implemented. The general concerns expressed in these allegations are within the scope of the above allegations and are addressed below as appropriate (parts of AQE-7, AQE-8, AQE-37, AQE-39, and AQE-46). (~ r ~. , - hj'. " i
,C L O '
'i s.
- 4. Assessment of' Safety Significance: .
Sample of S'afety-Related Termination Installation. Since many of the alleged conditions identified in AE-13, AE-16, and AE-26 were located in equipment containing nonsafety-related cabling, the Technical Review Team (TRT) sampled safety related installations to determine whether similar conditions existed within them. Sixteen safety related items (control panels, annunciator cabinets, termination cabinets, motor control centers, and switchgear) were inspected for the following items: t
- Proper siz'e lugs used relative ~to cable size and screw size (AE-13).
- Tightness of bus bar and ground wire coinection's and terminal lugs on terminal blocks (AE-16). ,
,.y. .. . -
- General workmanship for such items as shaved lugs, proper washers, and bend radii (AE-26). -
The TRT found no unacceptable conditions with the terminations inspected. Butt Splices. Allegations AE-13, AE-18, and AE-22 concerned butt splices in panels that could be in violation of regulatory requirements and site - procedures. The practice of butt splicing cables in panels is allowed on a limited basis, as specifed in Section 8.1.5.2.4 of Amendment 44 to the
- Final Safety Analysis Report (FSAR). The NRC staff reviewed TUEC's justi-fication for permitting butt splices inside panels (correspondence from M. Srinivasan, NRC, Power Systems Branch to B. J. Youngblood, NRC, Licens- .
ing Branch, July 30,1984), and concluded that the practice is acceptable on a limited basis, subject to the following conditions: j
- That adequate provisions be included in the installation procedures to verify operability of those circuits for which splices are being used,.
l l
1 _3 That the wire splices used are qualified for anticipated service . conditions, and .
.That splices are staggered within the panci so that they are not adjacent to each other in the same wire bundle and pressing against one another.
The TRT inspected, in detail, numerous butt splices in safety-related - panels to determine whether they were installed in accordance with the requirements st;ated in Texas Utilities Generating Company (TUGCO) procedure QI-QP-11.3-28,' Revision 21, " Class IE Cable Terminations." The TRT also interviewed one alleger to clarify one allegation concerning butt splices. Theses'plices were found to be in conformance with all procedural require-ments, with the following exception. All sp'lices' inspected were missing the " nuclear heat-shrinkable cable insulation sleeves," as required by paragraph 3.2.15 of the procedure for 600-volt control and ' instrumentation connections. Due to this recurrent condition, the TRT reviewed the QC inspection reports for 12 butt splices and found the following:
- Nine of these splices were documented on the inspection form designated in paragraph 3.3 of the procedure for post-installation inspections instead of on the correct form designated for witnessing-type inspections. It should be noted that all splices were required to be witnessed by QC personnel per paragraph 3.1.d of the procedure.
- Six of the nine incorrect forms contained handwritten notes by the inspector indicating that he had witnessed the splice; however, no reference was added to indicate that the installation of the heat-shrinkable sleeves was required to be witnessed.
- The remaining three of the nine incorrect forms did not indicate that the splices had been witnessed.
s
.b For three splices which were documented on the correct forms, the forms all contain an "N/A" (not applicable) handwritten by the -
inspector on the line indicating that the installation of the heat-shrinkable sleeve was witnessed. Nuclear heat-shrinkable sleeves are commonly required only in "high radia-tion" areas, and their absence would constitute a condition of safety i significance. The butt splices inspected by the TRT were found inside - control, annunciator, relay, and termination cabinets which were not I located in "high radiation" areas. 'Thus, the requirement to cover the ! splices with nuclear heat-shrinkable sleeves did not apply to them. How-ever, as indicated above, the TRT determined that the QC electrical l inspectors did not know when installation of the heat-shrinkable sleeves was required to be witnessed. Should butt splices exist in enclosures in J
"high radiation" areas, the absence of these sleeves would constitute a ,
condition of safety significance. This lack of awareness of where the i heat: shrinkable sleeves should be insta11ed, as reflected in the QC l
'inspectionform,whencoupled'withthehigi[percentageofmissedand/or improperly documented inspections requiring witnessing, indicates that f craft and inspection personnel lack familiarity with these procedural requirements. This apparent lack of familiarity may be indicative of poor training. (See Electrical / Instrumentation Category No. 6, " Electrical QC -
Inspector Training / Qualification.") Nonconformance of Cable Terminations with Drawings. Allegation AQE-12 involves QC inspectors " buying off" terminations that did not conform to drawing requirements. In view of the lack of specific information con- , cerning this allegation, the TRT selected 380 cables, involving 1600 individual terminations, and inspected them in detail with respect to I drawing requirements. This inspection revealed that six cables (five of which are safety-related) were not terminated in accordance with current drawings. These six cable's are: W* a a de oa
s (1) E0139880 in panel CPI-ECPRCB-14, - (2) E0110040 in panel CP1-ECPRTC-16, . (3) E01182'26 in panel CP1-ECPRTC-10,
,(4) NK139853 in panel CPI-ECPRCB-02 (non-safety),
(5) EG104796 in panel CP1-ECPRTC-27, and (6) EG021856 in panel CPX-ECPRCV-01. Terminal Lugs. Allegation AQE-36 involved vendor-installed Amp Product - Corporation (APC) terminal lugs in ITT Gould-Brown Boveri, 6.9 ky switch-gear being' excessively bent in the area between the ring and the barrel. The TRT discove' red 16 nonconformance reports (NCRs) (E-84-01066 through E-84-01081) issued early in April 1984 which documented this condition. The TRT review of TUEC action taken regarding these NCRs revealed the following:
. The NCRs described the APC lugs either as being bent in excess of 60
, degrees or twisted.
The documented record of a telephone conversation between TUEC and the representative of the lug manufacturer (reference letter VBR-16624) states that lugs bent to 90 degrees one time are to be considered acceptable; that lugs bent to 120 degrees could be accept-able after utilizing an engineering evaluation by the end-user; and that although lugs bent to 120 degrees would not maintain their full mechanical strength, they would maintain their electrical character-istics. This acceptance criteria for field bent lugs was changed by APC due to the'dispositioning of NCR E-84-00972 regarding General Electric (GE) motor control center (MCC) thermal overload relay replacement program. The TRT findings regarding the closure of these NCRs were as follows: The disposition block of the NCR form states that rr.any of the lugs are " determined not to pose an equipment serviceability problem.'"
.P
s . However, there is no reference to or evidence of an engineering evaluatton, as required by the lug manufacturer prior to a change in the acceptance criteria on NCR E-84-00972. Only the " bent" condition of the lugs has been addressed by both the vendor representative and TUEC engineering. Neither the mechanical strength nor the electrical characteristics were ever addressed with respect to " twisted" lugs. - These NCRs- have been improperly closed in that the full scope of the identified problem was not addressed and the "use-as-is" dispositions were not adequately justified.
- 5. Conclusions and Staff Positions: The TRT concludes that significant safety
~ ~
concerns exist in the following areas relative to cable terminations: . The, adequacy of butt splices in safety related panels (AE-13, AE-18 l & AE-22). The acceptability of vendor-installed terminal lugs in ITT Gould-Brown Boveri switchgear (AQE-36).
- Safety-related terminations which are not in conformance with current drawings (AQE-12). -
l The adequacy of QC inspections and supporting documentation, parti-cularly with respect to termination activities requiring witnessing by QC personnel (AQE-12 & AQE-18). 6. Actions Required: O[$ ' [ TUEC shall accocplish the following actions prior to fuel load: p (1) Reevaluate and redisp'osition all NCRs related to vendor-installed l terminal lugs;in ITT Gould-Brown Boveri switchgear taking into con-gg sideration the ' effects of twisted a.s well as bent lugs, and perform .h{ l6h - L. . - . . . .
l l and document the results of engineering analyses to justify any resulting "use-as-is" dispositf orts.
.(2) . Develop adequate installation / inspection procedures to ensure the t
operability'of those circuits' which contain butt splices in panels to i ensure that the wire splicing materials and methods used are qualified l}Asyf " p fori anticipated service conditions, and to ensure that splices are [- VI staggered within the panel so that they are not adjacent to each other in the same bundle. . 1 (3) Reinspect all safety-related and associated terminations in the con-trol room and in the termination cabinets in' the cable spreading room.
~
This sNall be done in accordance with all current design documents to ensure that terminations are in accordance with design requirements. i y TUEC shall submit the results of this reinspection to the NRC for g[ e," g . review. Should the results of this reinspection reveal an unaccept-able level of nonconformance to drawing requirements, the scope of this reinspection effort shall be expanded to include all safety-l ~ related and associated terminations at Comanche Peak, Units 1 and 2. (4) Physically identify all butt splices in panels; clarify procedural requirements with respect to the areas in which nuclear heat-shrinkable sleeves are required on splices; ensure that such sleeves Sk are installed where required; ensure that all QC inspections requiring p,h witnessing for splices have been performed and properly documented; and, in view of the previously stated deficie,cy concerning ccmpliance , Q ~ with drawing requirements, ensure that all butt splices are properly identified on the appropriate design drawings, f.e. , wiring diagrams. __ _ _._. _ _ _ . . - - . . - . . , . - , , - , . - - - - =
i I w
\
- 8. Attachments: None.
- 9. Reference Documents
- 1. Comanche Peak Steam Electric Station (CPSES)'FSAR, Section 8.
- 2. Procedure QI-QC-11.3-28, Revisien 21, " Class IE Cable Terminations."
- 3. Nonconformance Reports E-84-01066 through E-84-010SI.
- 4. QC Inspection Reports: ET-1-0005396 ET-1-0005395 ;
I ET-1-0005394 I ET-1-0007162 ET-1-0005393 ET-1-0006776 ET-1-0014790 ET-50419 ET-51218 ET-51217 ET-33666 ET-33669 l
I e _ g_
- 5. Drawings: 2323-El-0171-02, Revision CP-1 2323-El-0171-04, Revision 11
~
2323-El-0172-16, Revision CP-2 2323-El-0172-27, Revision CP-3 2323-El-0174-12, Revision CP-1 2323-El-0172-02, Revision CP-1 2323-E-1-0174-01, Revision 18 2323-El-0174-03, Revision CP-4 2323-El-0159, Revision CP-3 Design Change Authorization DCA-19264, Revision 2 6.
- 7. Correspondence from M. Srinivasan, NRC, to B. J. Youngblood, NRC, July 30,1984. .
- 8. IEEE Std. 420-1973, "IEEE Trial-Use Guide for Class 1E Control Switchboards for Nuclear Power Generating Stations."
- 9. NRC Regulatory Guide 1.75 Revision 2, " Physical Independence of Electric Systems."
-10. NRC Invesi.igative Report 50-445/82-29 and 50-446/82-15, December 21, 1982.
- 11. NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5, 1981.
- 12. NRC Inspcction ' Report 50-445/83-24 and 50-446/83-15, August 19, 1983.
- 13. TUGCO, et al. , Hearing before ASLB, Septembe.r 15, 1982, page 4871-4877.
- 14. Confidential Affidavit of GAP Witness (Paragraph 6), June 27, 1984.
- 15. GAP Notes of April 1984 (Confidential), GAP Witness H, Paragraphs 6 and 16.
e 1 9_S._.'_. _ _ _ _ _ _ _ _ _
I
- 16. NRC Inspection Report 50-445/80-16.
- 17. CASE letter to NRC, Region IV, August 4, 1982.
- 18. Deposition of GAP Witness H (In Camera) TUEC's Discovery Deposition, Volume II, July 20, 1984, Pages 339-564.
- 19. Initial Deposition, Telephone Conversation with GAP Witness H, -
July 31, 1984.
- 20. NRC Speci 1 Review Team Report, July 13, 1984.
- 21. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on Issues Resulting From Interviews with Electrical Inspectors,"
May 22, 1984. -
- 22. Deposition of GAP Anonymous. Witness,'J'uly 2,5, 1984, Pages 58,503-58,591. -
- 23. Deposition of GAP Witness, July 16, 1984, Pages 53,003-53,263.
- 24. NRC RIV Summary of Comanche Peak Open Issues Tracking System, -
July 13, 1984.
- 25. NRC Construction Appraisal Team (CAT) Insr2ction Report 50-445/83-18, 50-446/83-12, April 11, 1983.
- 26. TUGCO, et al., Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; (June 13, 1983, Pages 7733-7755; June 15, 1983, Pages 8160, 8231, 8261-8263; June 16, 1983, Pages 8358, 8367, 8368-8373.
j . . 1
- 27. NRC . Interview with SRT A11eger A-3, September 6, 1984, Pages 17-27,,
j 30-43, 75-79, 91, 92.. ,
4 11 -
- 10. This Statement Prepared by: -
Wil.liam S. Marini Date TRT Reviewer Reviewed By: Jose A. Calvo Group Leader Date Approved By:
; Vincent S. Noonan Project Director Date e *. e
' . lt.'..
. s
.. .9, 4
I l 9 1 1 1 l I . 1 I .
y :: N \- e
- 1. Allegation Group: Electrical / Instrumentation Category No. 2 - Electrical Cable Tray and Conduit Installation ,
- 2. Allegation Number: AQE-10, AE-1.4, AE-27, AE-29, AE-31, AH-14, and Parts of AQE-3, AQE-4, and AE-24
- 3. Characterization: It is alleged that, in general, there were problems with:
V The design; changes on cable tray supports (AH-14).
# The additio'n of higher sides to cable trays (AE-29).
- The clearance of process pipes from cables in cable trays (AE-31).
v
- Loose conduit fittings (AE-27). -
/ Ths training of personnel installing cable tray supports (AQE-10).
/
- The cable tray attachments to the seismic supports (AE-14, AH-14).
~
The spacing of the seismic supports for cable trays (AH-14).
~
Tile material traceability for cable tray supports (AH-14).
- 4. Assessment of Safety Significance: The Technical Review Team (TRT) deter-mined that the first two concerns (changes on' cable tray supports and the addition of higher sides to cable trays) related to whether the positions of Regulatory Guide 1.29, " Seismic Design Classification," as augmented by Final Safety Analysis Report (FSAR) Section 3.2, were considered, by the Texas Utilities Electric Company (TUEC) during design of the support system for both safety-related and nonsafety related cable trays.
/ The TRT examined cable tray support installation notes and detail drawings, design change authorizations (DCAs), work packages, physical configuration drawings, and other documents pertinent to its sampling of 29 supports in the Safeguards, Auxiliary, and Control Buildings. The TRT found no significant problems with installation of the supports. The TRT also evaluated a sample of cable trays in the cable spreading room to assess the concern about the higher cable tray sides. This evaluation and its p> ,q ; e , - .
if"~ . , m, V
7 1 y 2-conclusions are presented in Electrical Instrumentation Category No. 7,
" Electrical Cable Inst,a11ation."
The third concers was the process pipe-to-cable-tray clearances as
- outlined in Gibbs & Hill (G&H) electrical specification 2323-ES-100, as amended by DCA 13045 and DCA 15917. The TRT conducted a walkdown i inspection of approximately 2500 feet of cable tray in the auxiliary building and identified 16 cases that appeared not to meet installation guidel aes set forth in the specification. The TRT examined the DCAs portatning to e.ach of the 16 cases a'd n determined that the guidelines had been met or wer'e currently in'the process of being met for all 16 cases.
3 The fourth concern was the "use-as-is" disposition on a nonconformance report (NCR) which reported two loose conduit elbow fittings on the south and east end of the Unit I diesel generator. -
. :;-p
~
I - The TRT inspected the Unit I diesel generator conduit and found two , ! loose fittings. However,the'TRTdetermine[that.thefunctionofthe cables within the fittings is of secondary importance to operation of the diesel generator and the loose fittiings would not prevent the cables j from performing their intended function. The fifth concern was the lack of training of personnel installing cable tray supports. The TRT interviewed craft personnel, craft supervisors, and training personnel to determine the availability and effectiveness of the training program and found that there was a training program for newly hired personnel or transfers into the installation which included periodic l briefings on procedure changes. This program did not, at first, appear to be effective because 7 of the 11 crew members interviewed were not I cognizant of Manual 2323-S-0910 " Conduit and Junction Box Supports," which is the primary reference manual for installation of supports. However, these seven crew members had no need to utilize this manual on their job. assignments.
#ydp d9L /y
_ - _ ~ _ . - . . . --- - - _ _ _
. . _3-The sixth concern was that cable tray attachments to the seismic suppor'ts . !
were not being installed according to. design. The TRT inspected 60 cable I tray attachments in the Safeguards Butiding and did not find any unaccept-able cable tray attachments in the sample. u,uL . The seventh and eighth concerns yat that the designed spacing of the seismic cable tray support M not adhered to during construction and
- that the supports did not have proper material traceability. The TRT -
conducted a walkdown inspection of seismic cable tray supports in the Safeguards.and. Auxiliary Buildings and compared the installed cable tray l support spacing with the designed support spacing, including material traceability for the supports. Two deviations were located out of 40 examples inspected, and TUEC engineering was asked to provide the analyses for th'ese two deviations because they were outside the designed support spacing. The TRT reviewed the analyses and found'them acceptable.
- 5. Conciusions and Staff Position: Basedon'tiiereviewofengineering
! drawings an'd direct inspection of the installation, the TRT found no indications of construction contrary to commitments made in the FSAR ! Section 3.2. The clearance requirements set'forth in G&H electrical i specification 2323-ES-100, as amended by DCA 13045 and DCA 15917, have
.been met in ev'ery case identified during the walkdown inspection. The 40 [ TRT found no problems with cable tray attachments to seismic supports, a finding which agrees with NRC Region IV investigation findings on this
~
,[ subject in Inspection Report (IR) 50-445/83-52. The TRT determined that q the cable tray support spacing met design requirements and had proper d- material traceability, except for two deviations that were analyzed by the .hg TRT and found to be acceptable.
- ! p p,o Based on the inspection of the installations and reviews of pertinent
! drawings, the TRT concludes that the allegations, as presented, have i n,either safety significanc'e nor generic impitcations.
- 6. Actions Required: None.
O e
,.----.---h, . .
g m., _ -.. -..,-_,[, -
, _ - . ,,,_.....,__.____,_...ea h,-----,-- - - - - - , - - - - - - -
- 8. Attachments: None.
- 9. Reference Documents:
- 1. Regulatory Guide 1.29, " Seismic Design Classification."
- 2. Comanche Peak, Units 1&2, FSAR Section 3.2.
- 3. G&H Specification No. 2323-ES-100, Revision 2, " Electrical Erection Speci fi cat,f on. "
- 4. RIV Inspec' tion Report 50-445/83-52.
- 5. DCA 13045 and DCA 15917. -
- 6. G&H Specification 2323-S-0910, " Conduit and Junction Box Supports."
- 7. Drawing 2323-El-602-01-S, " Safeguard Sidg Cab'le Tray Suppo.t Plan."
- 8. Drawing 2323-El-701-01-S, " Auxiliary Bldg Cable Tray Support Plan."
- 9. Drawing 2323-5-0901-sheet (sh) 1, " Cab 1'e Tray Supports."
- 10. Drawing 2323-S-0902-sh 2, " Cable Tray Supports."
- 11. Drawing 2323-S-0903-sh 3, " Cable Tray Supports."
- 12. Drawing 2323-S-0904-sh 5, " Cable Tray Supports."
- 13. Drawing 2323-S-0916-sh 15, " Cable Tray Supports."
- 14. Drawing 2323-S-0930-sh 28, " Cable Tray Supports Alternate Heavy Duty Tray Clamp Details."
- 15. Drawing FSE-00187, " Safeguard Bldg Cable Tray Support Plan EL 810'-6 inches."
- 16. Drawing FSE-001SS, " Auxiliary Bldg Cable Tray Support Plan i El 810'- 6 inches."
l
- 17. Drawing FSE-00214, " Auxiliary Bldg Cable Tray Support Plan EL 807'-0 inches."
- 18. Drawing FSE-00159-sh 1317, " Safeguard (SFGD) Bldg Cable Tray l Hanger Assembly (Assy)."
- 19. Drawing FSE-00:59-sh 925, "SFGD Bldg Cable Tray Hanger Assy."
- 20. Drawing FSE-00159-sh 1109, "SFG3 Bldg Cable Tray Hanger Assy."
i I l
I- "
- 21. Drawing FSE-00159-sh 1080, "SFGD Bldg Cable Tray Hanger Assy." -
- 22. Drawing FSE-00159-sh 1070, "SFGD . Bldg Cable Tray Hanger Assy."
- 23. Drawing FSE-00159-sh 1047, "SFGD Bldg Cable Tray Hanger Assy."
, 24. . Drawing FSE-00159-sh 5553, "SFGD B1dg Cable Tray Hanger Assy."
- 25. Drawing FSE-00159-sh 904, "SFGD Bldg Cable Tray Hanger Assy."
- 26. Drawing FSE-00159-sh 1076, "SFGD Bldg Cable Tray Hanger Assy."
- 27. Drawing FSE-00159-sh 912, "SFGD B1dg Cable Tray Hanger Assy."
- 28. Drawing FSE-00159-sh 1048, "SFGD Bldg Cable Tray Hanger Assy." -
- 29. Drawing FSE-00159-sh 1313, " Aux Bldg Cable Tray Hanger Assy."
- 30. DrawingF{E-00159,sh12454,"AuxBldgCableTrayHangerAssy."
- 31. Drawing FSE-00159, sh 5326, " Aux Bldg Cable Tray Hanger Assy."
- 32. Drawing FSE-00159, sh 1316, " Aux Bldg Cable Tray Hanger Assy." -
- 33. Drawing FSE-00159, sh 13062," Aux Bldg Cable' Tray Hanger Assy."
- 34. drawingFSE-00159,sh13193,"AuxBldgCableTrayHangerAssy." ,
- 35. Drawing FSE-00159, sh 5335, " Aux Bldg Cable Tray Hanger Assy."
- 36. Drawing FSE-00159, sh 4237, " Aux Bldg Cable Tray Hanger Assy.."
- 37. Drawing FSE-00159, sh 4210. " Aux Bldg Cable Tray Hanger Assy."
. 38. Drawing FSE-00159, sh 1296','" Aux Bldg Cable Tray Hanger Assy."
- 39. Drawing FSE-00159, sh 3918, " Aux Bldg Cable Tray Hanger Assy."
- 40. Drawing FSE-00159, sh 6477, " Aux Bldg Cable Tray Hanger Assy."
- 41. Drawing FSE-00159, sh 4114, " Aux Bldg Cable Tray Hanger Assy."
- 42. Drawing FSE-00159, sh 4115, " Aux Bldg Cable Tray Hanger Assy."
- 43. Drawing FSE-00159, sh 4116 " Aux Bldg Cable Tray Hanger Assy."
- 44. Drawing FSE-00159, sh 4117, " Aux Bldg Cable Tray Hanger Assy."
- 45. Drawing FSE-00159, sh 4352, " Aux Bldg Cable Tray Hanger Assy."
- 46. Drawing FSE-00159, sh 4368, " Aux Bldg Cable Tray Hanger Assy."
- 47. NRC OI Report'4-83-013, November 3, 1983, Page 8, Paragraph 3 and 4.
- 48. NRC Inspection Report 50-445/83-52, February 21, 1984.
- 49. NRC Report of Inquiry No. Q4-83-023, September 20,.1983.
- 50. NRC Report of Inquiry No. Q4-83-021, August 29, 1983.
- 51. GAP Notes of April 1984 (Confidential) Paragraph 33, GAP Witness
. Anonymous and Paragra'ph 4, GAP witness C.
- 52. NRC Special Review Team Report, July 13, 1984.
_ . _ - - - - , ---- .-.., - - - - , ,--7, ,
+ 1 .i -
6-
- 53. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on Issues Resulting From Interviews with Electrical Inspectors,"
May 22, 1984. ,
- 54. NRC RIV Surmary of Comanche Peak Open Issues Tracking System, July 13,1984.
- 55. NRC Interview with SRT A11eger A-3, September 6, 1984, Pages 49-50.
- 10. This statement prepared by:
George N. Myers Date
- TRT Reviewer '
1 i Reviewed by: - Jose A. Calvo Group Leader Date - Approved by: ' l Vincent S'. ,. Noonan .- .' Project Director Date e l e I l -
t
?
0
- 1. Allegation Group: Electrical / Instrumentation Category No. 3 -
Electrical Equipment Separation
- 2. Allegation Numbers:
J ) s s J '
/
AQE-6, AQE-11, AE-15, AE-20, AQE-49, AE-51, AE-53', AQE-54 and Part of AQE-44.
- d' '
- 3. Characterization: It is alleged that the:
Installation of safety related cables and conduits inside the reactor control panels in the main control room did not conform to the cable separation criteria (AE-15). Separation between independent safety related cable trays and con-duits, and between them and nonsafety related trays and conduits, in the cable spreading room did not conform to the positions set forth
- in Regulatory Guide (RG) 1.75, " Physical Independence of Electric Systems." It is also alleged that the separation requirements set forth in Gibbs & Hill (G&H)' specification 2323-ES-100, " Electrical Erection Specification," applicable to't'he cable installation in the cable spreading room was inconsistent with the separation criteria documented in the Institute of Electrical and Electronics Engineers (IEEE) Standard 384-1974, "IEEE Trial-Use Standard Criteria for ,
Separation of Class IE Equipment and Circuits," as augmented by RG 1.75 (AE-20). Ladder type cable trays did not quality as acceptable barriers; therefore, the 1-inch minimum separation criteria between separate trays and conduits routed under the trays are not applicable (AQE-54). .i Nonconformance Report (NCR) E-84-007095 concerning the separation between conduits ESB1-4 and C14K30975 was corrected without approved conduit bending equipment (AE-53).
.q . . . ,
;ty^ ]J.v,'n. .r-
- . ... .c.. a
**J
[)
+. . . .
Post-construction inspection of electrical equipment and raceways in . the fuel building revealed a deficiency concerning cable separation which was dispositioned "used-as-is" (Part of AQE-44). Yh' Conduit 22G06343 was about 3 feet below cable tray T130CCP38 located in the control room building at the 854-foot elevation (AE-51). Inspection'of the separation of cables did not follow established . procedures (AQE-6); quality control (QC) inspection acceptability g regarding separation of equipment was compromised due to the needs f produc' tion management (AQE-11); an umerous case ework hO was done u n "a M to separation (AQE-49). t . To olakse g r ,, These allegations expressed, in very general terms, concerns with cable separation and did not specifically id'entify the location of problem areas in the facility. This discussion will focus on the fy.* - ~ installation aspects of cable separation brought by these allega-tions. Quality assurance / quality control (QA/QC) matters raised by these allegations are addressed under Electrical / Instrumentation Category No. 8, " Electrical Procedures," and Electrical /Instrumenta-tion Category No. 6. " Electrical QC Inspector Training / Qualifications."
- 4. Assessment of Safety Significance: ,
Control Room Panels. The criteria governing the separation of cables inside panels are stated in Section 5.6.2 of IEEE Standard 384-1974, which is endorsed by RG 1;75. As documented in Sections 7.1.2.2 and 8.3.1.4 of the Final Safety Analysis Report (FSAR). Texas Utility Electric Company l (TUEC) is committed to provide a cable insta11ation which is in accordance with IEEE Standard 384-1974, as augmented by RG 1.75. Section 5.6.2 of IEEE Standard 384 states, in part, that the minimum separation distance between redundant Class 1E equipment and wiring internal to the control switchboards (panels) can be established by
- 0 0
analysis of the proposed installation. Where the control switchboard materials are flame retardant and analysis is not performed, the minimum separation distance shall be 6 inches. In the event these separation distances are not maintained, barriers shall be installed between re-dundantClass$Eequipmentandwiring. The criterion specifying a 1-inch separation between redundant conduits which are considered enclosed raceways is stated in Section 5.1.3 of IEEE Standard 384. The Technical Review Team (TRT) examined the electrical erection specifi-l cations, cable and raceway separation engineering drawings, design change authorizations'.(DCAs), work packages, and other documents pertinent to the separation of cables, conduits, and devices inside the main control room panels. The TRT also inspected cables,. flexible conduits, termina-tions, and devices inside six safety-related panels to determine that this equipment was installed in accordance with established separation ,'
, requirements. In addition, the-TRT inspected the separation of cable
. traysandrigidconduitsenteringthebottom'ofthepanelsfrom'hecable t spreading room. .
.Ij.
' ~
[ The TRT found that the minimum 6-inch air gap or fire retardant barrier between redundant Class 1E panel mounted devices (including their cable , or wire connections) and nonsafety related devices and their connectiongg wasmaintainedinallsixpanelsinspected,exceptforohlhase where a fire-retardant barrier had been removed. The devices involved
'were FI-2456A, PI-2453A, PI-2475A, and IT-2450, associated with train A, and FI-2457A, PI-2454A, PI-2476A, and IT-2451, associated with train B.
' These devices were located in the auxiliary feedwater panel no. CP1-EC-
[ PRCB-09. - 1 The TRT also found in_ panel CP1-EC-P nt to the six panels inspectedhotherisolated o undant safety-related field wiring not being separated ~by lifher the 6-inch minimum distance or by a barrier. / The field wiring was as: ociateo with devices HS-5423 (train B) and HS-5574 i ( M m . _ . . . . . . . . . . . . . . . . . . . . . . . . . .
(nonsafety related). In regard to the separation of cable trays and . rigid conduits entering the bottom of,the control room panels, the TRT found no deficiencies.
- The TRT found several instances where (1) redundant safety-related flexi-ble conduits inside the panels were in direct contact with each other and (2) safety and nonsafety-related flexible conduits inside the panels were also in direct contact with each other. The TRT also found various cases .
where safety and nonsafety-related cables were in direct contact with safety-related cables within flexible conduits associated with the other redundant train inside the panels. These are identified in Table 1. Table 1 Cases of Safety or Nonsafety-Related' Cables
~
in Contact with Other Safety-Related Conduits in Control Room Panels
- .f aJ ~
- 1. Control Panel CP1-EC-PRC8-02: Containment Spray System Cable No. Train Related Instrument EG139373 8 (green) Undetermined
.E0139010 A (orange) Undetermined
- 2. Control Panel CP1-EC-PRC8-07: Reactor Control Cable No. Train Related Instrument l
EG139383 8 (green) Reactor manual trip switch ' { E0139311 A (orange) Undetermined E0139310 A (orange) Undeterm'ined , i EG139248 : 8 (green) Undetermined I i i t -
Table 1, continued
- 3. Control Panel CP1-EC-PRCB-06: Chemical & Volume Control System Cable No. Train Related Instrument EG139335 B (green) LCV-112C E0139301 A (orange) Undetermined E0139305 A (orange) LCV-1128 ,
NK139605 Nonsafety CSALB-LAB
, (in bundle) .
- 4. Control Panel CP1-EC-PRCB-09: Auxiliary Feedwater Control System .
Cable No. Train Related Instrument . E0139753 A (orange) FK-2453A - E0139754 A (orange) FK-24538 ' EG139756 B'(green) FK-2454A
- EG139288 B (green)- , FK, ,2,454B .,
EG145780 B (green) FK-2454A EG145781 8 (green) FK-2460A A0138622 A (orange Assoc.) HS-2452a/H l NK130647 Nonsafety HS-2383 .
- 5. Control Panel CP1-EC-PRCB-08: Feedwater Control Cable No. Train Related Instrument l
EG140309 B (green) PK-2324 EG139757 8 (green) . PK-2328 NK13957 Nonsafety HS-211A
- The TRT discussed with TUEC and G&H representatives the apparent violation of the required 1-inch separation between separate flexible conduits and 6-inch separation between separate cables and cables within flexible con-duits inside the panels. TUEC and G&H representatives indicated that I
w -.- .__
- *** *** :.::_: :: L * ': * * . .
J. ,. l
! redundant flexible conduits in contact with each other are permitted, as .
indicated in the cable and raceway separation typical details drawings, l but cables in contact with cables within flexible conduit are not per-
- mitted. However, the TRT brought to the attention of the TUEC and G&H representatives that this type of conduit installation is permitted by
) Section 5.6.2 of IEEE Standard 384 ff such installation can be substan- ; tiated by analysis. The TRT considers the apparent discrepancies described above to be a deviation from the engineering drawings and l . inconsistent with regulatory requirements.
j CableSpreadinhRoom. The criteria governing the separation of redundant safety-related cable trays and conduits in the cable spreading room are l stated in Section 5.1.3 of IEEE Standard 384-1974,- as a'ugmented by RG 1.75.. 1 IEEE Stalidard 384 states, in part, that the minimum separation distance
~ '
- between redundant Class 1E cable trays in the cable spreading area can be determined by analysis of the proposed cable installation or, where the
~
condit'ionsofSection5.1.1.3aremet(whiNdefinesanacceptabletray system), there shall be 1 foot between trays separated horizontally and l , 3 feet between trays separated vertically. Where the minimum separation distance cannot be met, the redundant circuit's shall be run in enclosed j raceways that qualify as barriers, or other barriers shall be provided I between redundant circuits. The minimum distance between these redundant i enclosed raceways and between barriers and raceways shall be'1 inch. l 1 The TRT compared these criteria to the requirements set forth in G&H electrical erection specifications and engineering drawings, concerning cable tray and conduit separation in the cable spreading room, and identified no deviations. . The TRT also examined DCAs, work packages, and other documents pertinent to this issue. In addition, the TRT directly inspected the installation of numerous cable raceways'and five termination cabinets in the cable ' spreading room. The TRT found no deviations from separation requirements in the cable raceways and termination cabinets inspected. e
l, . Fuel Buildina Area. The TRT inspected the cable separation installation 9 in the fuel building area and found that most of the cable trays and con-duits were designated as nonsafety-related. The only safety-related electrical equipment installation in the fuel building area that needed to satisfy sepa' ration requirements was associated with the spent fuel system. The TRT found that redundant spent fuel system equipment was l located in separate adjacent rooms, except for a common control panel. After examining the separation of cable raceways in the fuel building . I area and terminations, cables, wires and devices inside the common ) control panel, the TRT found no deviations from separation requirements, j ! Potential Harsh Environment Areas. The TRT examined cable separation 1 installations in those areas of the plant where a high-energy line break,
~
could compromise the independence of redundant safety related equipment. TUEC's damage study group performed studies to determine the need"to pro- ' tect equipment, including cable raceways, that could be affected by a ~ , high-energy line break. Jet shields'were M alled to protedt[ s'afety-
- related raceways, as required. inthearea(wheretheinstallationof i jet shields was not possible, the affected cable raceways were to be
! rerouted. The TRT inspected two typical jet shield installations located in the . chemical and volume control system (CVCS) piping and valve area and steam generator blowdown area and found that cable separation in these two areas , was in acco fance with IEEE Standard 384-1974, as augmented by RG 1.75.
' Remote Shutdown and Transfer Switch Panel Areas. The TRT reviewed engineering drawings and electrical erection s'pecifications pertinent to the separation of the safety related equipment located inside the remote shutdown and transfer switch panel.s. The TRT also inspected the cables, wires, and devices (including their cables and wire connections) inside these two panels, and cables' entering the top of the panels to determine that this equipment was installed in accordance with established separa-tion requfrements. The TRT found'no devfations from separation require-ments in these two panels.
m . .
l 3 In regard to NCR E-84-007095, concerning the separation between two .
; , specific conduits located in the Unit 1 safeguard area, which was ,
]' established by bending the conduits with unapproved bending equipment, the TRT determined that both conduits were nonsafety-rel'ated and the NCR
!
- was dispositioned "use as is."
Electrical Erection Specif' cation for separation Criteria. The criteria setforthinIEEEStandh384-1974, as augmented by R. G. 1.75 and Sec- [xn
- tions 7.1.2.2 and 8.3.1.4 of the FSAR have been expressed in specific l terms in the G&H specification 2323-ES-100, " Electrical Erection l Specification.Y 1
j It is alleged that the requirements set forth in this specification . governing the separation between independent trays and rigid conduits is ! inconsistent with the criteria stated in IEEE Standard 384-1974, as aug-mented by R. G. 1.75, particularly, when ladder type trays and conduits ) wereusedasbarrierstomaintain1-inchmiIimumseparationhetwe'en separate ' trays and conduits routed under th'a trays. During its assessment of this allegation, the TRT found a requirement in the electrical erection l specification that permitted nonsafety-related rigid conduits to have a t i minimum separation of 1-inch from the top of open safety-related trays, j .This requirement also appeared to be inconsistent with the aforementioned standard and guide. ' The TRT determined that no information was included in the FSAR that sub-l stantiated these two apparent inconsistencies in the electrical specifica-l tions with respect to the IEEE Standard 384-1974 and RG 1.75. However, - the TRT found, and performed a cursory review of, a G&H analysis including
- test results for establishing the requirements set forth in specification 2323-ES-100 for separation between conduits and trays (G&H memorandum f
i EE-863, January 17, 1984, " Cable Tray conduit Separations"). In essence, the analysis concluded that the characteristics of rigid conduits are such that it constituted an acceptable barrier by itself between the cables inside the conduit and cables inside ladder or open-type trays. l l . l L *
,_ _ . _ __ _ .._ _.., _ _ _ _ _ __.. _ . , _ -_~.__ . - . - _ _ _ - ~ ... _ _ _.~. ___
-g-Based on the review of electrical specifications, engineering drawings and analyses, inspection reports, procedures, and other pertinent docu-ments,anddirectinspectionoftheinstallationofcables, conduits, cable trays, terminations and panels in the main control room, cable spreading room,' fuel building area, potential harsh environment areas, and remote shutdown and transfer switch panel areas, the TRT determined that in general the requirements set forth in IEEE Standard 384, as aug-mented by RG 1.75 and Chapters 7 and 8 of the FSAR, have been satisfied ,
in the areas inspected except for the following items: k
- TheTitTc'uldfindnoevidencethatananalysiswasperformedto o ,
support the practice that allows certain separate safety and @
),
nonsafety- related flexible conduits inside control room panels to be in ' direct contact with each other or be separated by less than, g 1 inch, as required by Section 5.6.2 of IEEE Standard 384. - W
~~ ~~
- The TRT determined that the insta11at' ion of certain safety or "
nonsafety-related cables inside control room panels, which were in direct contact with safety-related flexible conduits associated with the other redundant trains (see Table 1), was inconsistent with the engineering drawings and regulatory requirements. Because the acceptability of the flexible conduit as a barrier had not been , established by analysis, as required by Section 5.6.2 of IEEE Standard 384, the cables must be separated from the conduits inside the panels by a minimum distance of 6 inches, as required by Section 5.6.2 of IEEE Standard 384. The TRT considers the missing barrier (used to separate redundant l devices in the auxiliary feedwater panel CP1-EC-PRCB-09) and the hs h field utring not being separated by the required 6 inches (inside panel CP1-EC-PRCB-03) to be isolated cases of nonconformance l requiring corrective action but having no generic implications. i l . i i
i .
% p g e-The TRT could find no evidence that the G&H analysis for establishing, '
the criteria for separation between rigid conduits and cable-trays, stated in the G&H Electrical Erection Specification 2323-ES-100, had
! been evaluated by the NRC staff for Comanche Peak Steam Electric l ~ Station (CPSES).
- 5. Conclusions and Staff Positions: The TRT concludes that the installations meet established separation requirements, except for certain safety and ["
nonsafety related cables and flexible conduits inside control room panelsf l' whichdidnotmeetminimumseparationrequirements.pheTRTcouldfind no evidence that the lack of separation was justified by analysis. The TRT also concludes that in the absence of analysis to substantiate the Ib l lack of minimum separation between separate feixible conduits inside the l main control room panels, the existing design arrangement is in violation of regulatory requirements. Furthermore, the lack of separation in the installation of certain cables and flexible conduits is also inconsistent with TUEC's engineering drawings, and documents. ' Accordingly,' both-I concerns have safety significance. '
.." " .f-1 j The TRT also concludes that installation of cables and flexible conduits j inside the panels that do not meet minimum separation requirements and i .have not been justified has potential generic implications. TUEC shall conduct a review to determine if this practice was followed in other .
areas of the plant. i I In regard to the criteria for separation between rigid conduits and cable trays stated in G&H specification 2323-ES-100, the TRT concludes that . analyses had been performed by G&H sto 'ubstantiate the acceptability of these criteria. j TUEC must submit these analyes to the NRC so an indepen-dent assessment of how these criteria were established can be made.
- 6. Actions Required: .
l j TUEC shall accomplish the following actions prior to fuel load:
- i
11 - (a) Reinspect all panels at Comanche Peak, in addition to those in the main control room, Units 1 and 2, that contain (1) redundant safety-p@ related c p ', or (2) safety and nonsafety related conduits. TUEC shall either correct each violation of the separation criteria, J y or demonstrate by analysis the accdptability.of the conduit as a g 7 barrier for each case where the minimum separation is not met. This analysis shall be accomplished in accordance with the requirements specified in Section 5.6.2 of IEEE Standard 384-1974. Furthermore, , in the event that the acceptability of the conduit as a barrier cannot be, demonstrated, TUEC shall correct the engineering drawings and related documents to indicate the revised minimum separation of conduits inside the panel for each case. (b) Either correct each of the violations of separation criteria con-cerning separate cables and cables within flexible conduits found in ,"
. contact with each other inside main control room panels (Table 1) ,
or demonstrate by analysis th'e adequacy Af the flexible ^ conduit as a barrier. TUEC'shall also reinspect all remaining panels containing separate cables and cables within flexible conduit and shall take the same corrective actions as those outlined for the cases listed in Table 1. This analysis shall be accomplished in accordance with Section 5.6.2 of IEEE Standard 384-1974. In the event that the acceptability of the conduit as a barrier cannot be demonstrated, TUEC shall separate cables and cables within flexible conduits by a minimum distance of
/ 6 inches, as required by Section 5.6.2 of IEEE Standard 384. Fur-thermore, TUEC shall correct all appropriate drawings and documents to indicate the revised minimum separat:in.'
(c) Take corrective measures to secure the barrier in the. auxiliary feedwater panel CP1-EC-PRCB-09 separating redundant flow and (M pressure instruments.
- - - - _ ._ _..__ .m -. .. . . . . . .
(d) ' - a :;r:o_* 2 ' t? o t :t 'a r. , j ,
- ^
c, t .5 _ r
. .. l j i '. l t d ir, #
2 [ -- :] Cil-_:- '
,, ai;'. rj e t'_ !, J' >
cr Ly e a'. ,t25!e Larr er.
~ (e) . it to the 5-C 'Je r alyses ' taitiati g t'e cepta ility of
'>t: ter:a st MJ in I W el"-trical erect :n apecificati;n g..e '7-tre sg arat n $
t ., : > n 4 m'e ccr kits rd c ule t _.s. . IF _e
'l ses hall te . gorted eith tFe recessary dx r ntatiun in
;uttic ent detail to parfarn in i ndependent e.aluaticn of ':s tF :e criteria were established based on the analyses. l a
~
4 (,' ,
, . , k. .
- m 9 A'
- tg' p
- a . e y
.. >. ._ ,e
- .t 9, 'y ,
,,s,-
. . ' -' agli !,
i .. -T . ,. - i . 34 f. 8"' - 'S -A -t [. 4
- 3, { h
; ' ' - + . 1 "[. # *r ', ,., Sy , f
( a *
- 3: . ' QW
* , - Q :, '. . y # ( $ .. ,;f,'"-' .'
1 y v .. ,
- s. ? . ,. . , ,. ?.. ,. , -
- .-g i.'\ ' - [ < ,l-e
;: ft s p.g%,.Z,ts . "4"' .
g._ dyA.A . f.sf.. - D .A ' h s
, .z,e ...a 3 v- .4
, 4 ,\ e.,
I. u.
, . ,- . Ai.
4 '.', % # '
..$' .J
[q
,+ . ( ,4 , $a [ g k, '6'- *,' , ,g
- k.'. e
.[ ' ,,,, ',
p ',,r f,j. ..,g[r ' tp' ,.'.+ f '
. , k' ,;j
. .-(., -., . . .. .. , .
t e go lf,..>, - g :r . . 3
'e ,,
, i ,rg-.. .g ,
}q _y . t, h- > $ -
.9 -
.c
, ,e , t 4, k'd'.
. ', , % ;y ,. , ' ' , . * .
l 7 5 ~ g,
;s'n, n. . . .
3; c. y . I g 3
,,3.. s 9.w, c -.; ,. ^ ..- .
. .. y c m., '
. +
. p ,- %.
./ .' v. t ],. .l 3
,f .
',4,. , / g .. ', . ,
d [h p. e,a :Q.? , 1'
.l - Q ,: -: . ; , t Q c ' .i . .. V ' ,' f ,, y.'? ' l ~., . p 3 , .
l[f^Q ' .gf, f.
- v y 1
4 e'
. e*g-
, g:' 9 _ 9 v-sl %, /b f, 4,, .'/ U _ $ , il. , "
y ,, * .../ ,', 3g,'W,1[g't ' '
,1 . [ .,-
{ j 'b ;,} " AM) f
. . , _, J' . ,. '. \ , , _ - 4 - ~ S
{M
'gi ', .,::" ;. (Y n; !
;. . ., - l. '
_,f ... 7- 7
- i ' ,f,g '-
' W ,n. f.]1"O,g,
(., Q y'l .' '-< : $ L '
,r4, , ., y ! s, .
k. a" ..' ,.. t..... . . .- . ,. .
.., <. *y "' ,.
,. ' r
,. Q . ',', . i- ) < -
,p' I0 , , ' ,,,i [
N' # " ? ,' j y
,p , .4, ;. ,4' d% . l* % h-$. .a :.. ' .t[y ..
.f m .y ?i ~
s.
- s ~.,
. g:1- '
t.c ,. ,,, . * *
.,^ &,2 ,1;;y/
.V,. _ . M p . ,4.g (s , , ^' .' -
A- a. W. w s
,.+r*.x....,7
_9..,
,5, k g 4, 5
-u
' Q. *, ' . . . ' g '> v m i u-n ,t- v
- (t 5 % . ,s , .9 c . ;%.,-. .'
A,,
.e -
n ., .: e .,....c
+ .. , ,.
. ,v. *i ~<>, . , yr + -.
r..s.*, a
. ..r., ;c . ,
s -y < gy- ;y. %sn. ,- r
.+
.s r w.~
.c r 1 - ~
q ,
,~ + ,,' . . go-','.,,.a 'y %.. u k
,,..,.,y.' .",, : .? . .
e'.. y., . c?. s 4
.,+ ~ap '4 .-
- l.
- s
- 4. # .a...,*,. .- u,4,4' , . .,. A .
u* , ;. . s. u. f .s " ; ; - --;,c;, s f
.,. , vf,; i / , n..
- c- .p a . a r e _ .' ,w 4.. . it, g . iI .
. .. ;. ,/ , ,f,' ,7 : .* t
; .,j .y y,,.. , :. .
,r n,
.gg., , -
.o :
~ .
- n. ,y. -. , . . . . , . . - . . , . . ,
3 , . l S. f. t t a " m n t s. : None. 6
6 e
- 9. Reference Documents _:
i i
- 1. Regulatory Guide 1.75, Revision 2 " Physical Independence of Electric l
Systems" ! IEEE-384-1974 "IEEE Trial- Use Standard Criteria for Separation of [ 2. Class 1E Equipment and Circuits" l l'
- 3. Comanche Peak, Units 1 and 2 FSAR, Section 7.1.2.2, " Independence of Redundant Safety-Related Systems" and Section 8.3.1.4, " Independence of Redund' ant Systems" G&H Specification No. 2323-ES-100, Revision 2,." Electrical Erection 4.
Specification" *
. ' :,jp .
s-
- 5. G&H Drawing No. 2323-El-1702-02, Revision 2, " Cable and Raceway i k['
separation Typical Details" E G.0
- 6. Drawing No. 2323-El-1701, Revision 11. " Conduit Cable Tray Legend, General Notes and Typical Details"
- 7. G&H Specification 2323-MS-38H, " Fire-Retardant Barriers and-Materials"
' 8. Nonconformance Report No. E-84-007095
- 9. Design Change Authorization No. 8830, October 22, 1983,
" Specification 2323-ES-100 . Revision 4"
- 10. Design Change Authorization No. 13,435, Revision 2, " Specification 2323-ES-100, Revision 1" ,
- 11. G&H Memorandum EE-865 January 17, 1984, " Cable Tray Conduit '
Separation" ,
14 -
- 12. NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5, 1981. .
- 13. Deposition of GAP-Witness H (in Camera) TUEC's Discovery Deposition, Volume II, July 20, 1984, Page 419; Page 10 and 12 of Affidavit.
- 14. Deposition of SRT Witness A-5, July 17, 1984, Pages 55032-55033.
- 15. GAP Notes of April 1984 (confidential), Paragraph 7, GAP Witness H. .
- 16. Confidential Affidavit of GAP Witness H. July 16, 1984, Pages 10-11.
- 17. Pre-filed Testimony before ASLB, May 24, 1982, Page 80.
5 -
- 18. Enclosure to NRC OI Report, 4-84-006, March 7, 1984, Pages 57-59.
, Deposition of A-7. '6 77:l>'
. . . . u. . .. u. .. i.
. 19. WRC Special Review Team Report, July 13, 1984.
- 20. Initial Deposition, Telephone. Conversation with GAP Witness H, July 31, 1984.
- 21. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on Issues Resulting From Interviews with Electrical Inspectors,"
May 22, 1984.
- 22. NRC Inspection Report 50-445/84-10, June 21, 1984.
i
- 23. Deposition of GAP Anonymous Witness, July 25, 1984, Pages' 58503-58591.
- 24. TUGCO, et al, Hearing before the ASLB, GAP Witness F September 9, 1984 (In Camera), Pages 14719-14722.
l f n....._...-. . . . . . . . . . .. . -.- .
.s 15 -
- 25. NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18, 50-446/83-12, April 11, 1983.
- 26. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding the Findin'gs of CAT; (June 13, 1983, Pages 7733-7755; June 16, 1983, Pages 8358, 8367, 8368-8373.
- 27. TUGC0 Procedure No. QI-QP-11.3-29, Revision 15, January 18, 1984, ,
" Electrical Separation."
t
- 28. TUGC0 Procedure No. QI-QP-11.3-29.1, Revision 15, February 15, 1984,
" Verify Electrical Separation."
- 29. TUGC0 Procedure No. QI-QP-11.3-40, Revision 18, May 18, 1984, "Postconstruction Inspection of Electrical Equipment and Raceways." .
~
- 30. NRC Interview with SRT A11eger A-3 September 6, 1984, Pages 53-56, 62-64, 83. . ', . }j . -
- 10. This statement prepared by:
Allen R. Johnson Date. , TRT Reviewer Hulbert C. Li Date
- TRT Reviewer
- Reviewed by:
Jose A. Calvo Group Leader Date i Approved by: Vincent S. Noonan Project Director Date l 1
.g b
7 '.
- 1. Allegation Group: Electrical / Instrumentation Category No. 5 - Electrical Nonconformance Report (NCR) Activities
- 2. Allegation Numbers: AQE-1, AQE-2, AQE-3, AQE-4, AQE-5, AQE-25, AQE-33, AQE-34, AQE-35, AQE-37, AQE-38, AQE-40, AQE-41, AQE-42, AQE-45, AQE-47, AQE-48, AE-24, and Parts of AE-22, AE-27, AQE-12, AQE-36, and AE-50.
- 3. Characterization: It is alleged that the validity of the generation and disposition of electrical nonconformance reports (NCRs) was suspect.
- 4. Assessment of' Safety Significance: The implied safety significance of these allegations concerns the quality of construction, inspection and rework.
These allegations pertain to various concerns involving the NCR program, which include: ,.,.., t
*
- The prevalence of the "use-as-is" disposition of NCRs with respect to-Gibbs & Hill (G&H) Electrical Erection Specification 2323-ES-100.
(AQE-33,AQE-47,PartofAE-27). o I
- Inaccurate evaluation in the generation of an NCR (workmanship vers s -
technical acceptance) (AQE-48).
- The closing out of NCRs by unqualified inspectors (either intentionally or because they were forced to) (AQE-4).
hujUM . d@ 9* Pressure not to generate NCRs (AQE-42). , gfW
- The traceability of "Q" (safety-related) items (AQE-35).
- Restraint cable (mec'hnical) crimp gage calibration (AQE-41).
F 0
.g i ezs4
s 7,' .
~
- Failure to follow procedures, specifications and drawings (AQE-25, AQE-40,PartofAQE-12). .
I '. , ,
- Splicing of safety-related' electrical cables in raceways (Part of 4
~1; AE-50).
*> -Electrical cables in trays with regard to cable damage (AEQ-45).
^
Electrical cable tray attachments (AE-24).
._. i .
*[ , No docume'ntation of butt splices in panels (Part of AE-22).
4 . . .. ,_. .
'?
- Otspositioning of conduit replacement (AQE-3). '
- '. ~ '
The NRC'Special Review Team (SRT) also had concerns with respect'to the "Er
, Texas, Utilities Generating Company (TUGC.0) ...'...s management response to the so called "T shirt" incident because of its potential affect on the morale of
. QC electrical inspectors, which in turn,' c'ould have affected their work-
-.manship. '(Special Review Team Report (SRT-10), July 13,1984.)
In addition to these general concerns, several allegations contained specific information about questionable NCR dispositions, which include: l
- Electrical cables.in trays with regards to cable damage, removal, l and improper documentation (AQE-1, AQE-2, AQE-5, AQE-34).
Terminal blocli rework (AQE-37). . t . .
- Bent terminal 1ugs in motor control centers (AQE-36).
* .Unauth$rized solenoid repair (AQE-38).
i
- Loose elbow termination fittings (Part of AE-27).
l i i I I 1 - .
i
- 7. The Final Safety Aralysis Report (FSAR), Sectidil7.1 " Quality Assurance i During Design and Construction," commits TUGC0 to a quality assurance (QA) program, as required by 10 CFR 50, Appendix B. FSAR Section 17.1.10
" Inspection," c,utlines the inspection planninghich will ensure that 7 construction tasks conform to procedures, drawings, specifications, codes.
- standards, and other documentation. These inspectio F Q re augmented by TUGC0 procedure CP-QP-16.0, which establishes the methods for generating and dispositioning reported items of nonconformance. The Technical Review -
Team (TRT) reviewed pertinent TUGC0 documentation to determine that the , procedures and instructions for gen'erating and dispositioning reported items of nonco'nformance were adequate. The TRT reviewed a random sample of 75 electrical NCRs and conducted. - numerous interviews with QA/QC and engineering personnel to determine
- the adequacy of the NCR program. (See also' Elect'ical/ Instrumentation ,'
. Category No. 6, " Electrical QC Inspector Training / Qualifications.") The '
TRT reviewed 25 of the 75 electrical NCRs h determine if the'QC inspector
~
who " closed out" the NCR.was ' qualified to do so. The TRT found that in all 25 cases the QC electrical inspectors were qualified and their certification files were current. Equipment installation matters raised b'y these allegations are addressed . under:
- Electrical / Instrumentation Category No.1, " Electrical Cable Termina-tions," for the alleged butt splices in panels without authorization C4d beinT documented on drawings.
- Electrical / Instrumentation Category No. 2,'" Electrical Cable Tray and Conduit Installation," for the alleged improper cable tray attachments.
- Electrical / Instrumentation Category No. 7, " Electrical Cable Installa-tion," for the alleged splicing of safety-related cables in raceways and cable damage where tray's contai,ned trash and hazardous debris.
a . l<- . _4 The TRT interviewecfjoth a' Texas Utilities Electric Company (TUEC) - electrical engineer and a lead quality engineer (QE) about the "use-as-is" - disposition of electrical NCRs. The TRT determined that for an NCR to
, receive a "use-as-is" disposition, an independent verification inspection by an electrical engineer had to be made to evaluate the reported item of nonconformance. Based on that inspection, and on an evaluation with regard to procedures, specifications, drawings, including applicable codes and standards, and other related documentation, a "use-as-is" disposition could -
be applied. Final approval of any disposition required two QE signatures. The TRT also reviewed the 75 NCRs to determine if there were any with the disposition "Use-as-is," with the explanation "not addressed in ES-100," as. alleged. The TUEC engineer also indicated that should an NCR be received
~ ~
with this type of disposition, it would be " kicked back" and would require more justification. , The TRT determined that if the nonconformance is indeed not add'ressed in ES-[00, then the document such a's'a procedOr'e or other spe[thication, that does address this nonconformance item would be required to be referenced in the NCR. Of the 75 NCRs examined, the TRT could identify no "use-as-is" dispositions which raised a question of safety,' except for the isolated cases identified in Electrical / Instrumentation Category No.1, " Electrical Cable Terminations," and Electrical / Instrumentation Category No. 2, '
" Electrical Cable Tray and Conduit Installation," regarding NCRs identi-fying bent terminal lugs in motor control centers, and reporting two loose conduit elbow fittings, respectively.
The TRT also intarviewed a TUEC electrical engineer about NCR dispositions with respect to " replace versus repair" and "workmans' hip versus technical acceptance." The TRT determined that replacing a reported item instead of repairing it as originally dispositioned would require a revision to the original NCR. The disposition of the NCR for replacement would be based on an engineering evaluat' ion. The TRT determined that on a case-by~ case basis where workmanship versus technical acceptance was compromised, the inspecting engineer would apply engineering judgment to determine that the l
, ,--m-.---.- , - - , . _ _ . . _ . __m._-- ,
') .
quality of workmanship did not jeopardize safety. (See also Electrical / Inrtrumentation Cagetory No. 8, " Electrical Procedures," regarding NCR for - terminal block rework using TUGCO's procedure CP-SAP-6).. The TRT interviewed the quality control (QC) supervisor for the calibration lab and reviewed pertinent procedures to determine their adequacy to ensure o that construction tools which required periodic calibration were being main-
$ tained. The TRT found that lab controls, procedures, and tool traceability -
. ensured that tool calibration was maintained. Adequate procedures also
. existed to' cnsure that corrective actions were taken should a tool not
, meetcalibratIonspecificationsandtolerances. The TRT reviewed NCR docu-mentation on tool calibration and found it to have been dispositioned in
~
accordance with procedures which ensured the integr'ity of the construction task. ._, The TRT interviewed QC and purchasing personnel and an electrical general foreman for construction, and reviewed pertinent documentation to determine the adequacy of traceability of safety-related (noted as "Q") items. The TRT determined that procedures and controls were adequate to ensure the traceability of "Q" items and that they would preclude the possibility of substituting "non-Q" for "Q" items. The TRT reviewed installation docu-mentation and found all the required traceability documentation.
~
.The TRT searched the records for the number of.NCRs and inspection reports written and for the amount of cable pulled for a 57-day period prior to and following the so-called "T shirt" incident. This search was conducted l
to determine if the incident had any affect on the workmanship of the electrical QC inspectors. The TRT could find no evidence that inspectors were affected by the incident as a result of management reaction to it. To' address the specific technical concerns raised in these allegations, the TRT examined the NCR ' log books and selected a random sample of NCRs pertaining to specific items of concern and determined that: l i
). '
? .
- The allegation for the excessive bending of compressio lugs Amp n -
ITT Gould-Brown Boveri switchgear has safety significance. ~This issue - is belng addressed in Electrical / Instrumentation Category No.1,
" Electrical Cable Terminations."
- The allegations for the rework of terminal blocks, the repairing of a solenoid, the unauthorized pulling of cables without paperwork, replacement of flex conduit, and cable damage (from the removal of -
bisco foam seal fire retardant material) in the Auxiliary Building has n'o s9f ety significance since in its review of a random sample of 15 NCRs on these specific issues, the TRT could not identify any
- inconsistencies or deficiencies that would entail a safety question.
[
~
V The TRT contacted the NRC senior resid(nt inspector, who had no g # additional information on these specific items.
} - -
* , The allegation for the loose elbow termination fittings (LBs) in the
~
~'
diesel generator rooms for Unit I has merit. The,TRT examined the NCR log book and found the specific NCRs for this item. The TRT also inspected the diesel generator rooms of Unit 1 and found two loose LB fittings. This issue is being addressed in Electrical / Instrumentation Category No. 2, " Electrical Cable Tray ind Conduit Installation." ,
- 5. Conclusions and Staff positions: Based on the reviews of the pertinent documentation, examination of NCRs, and the information obtained from the interviews, the TRT concludes that adequate procedures, controls, and pro-cess checks for the generation and disposition of reported items of non-l conformance exist. Thus, the TRT concludes that these electrical-related l
allegations have neither safety significance nor generic implications, l except for those previously mentioned which are being addressed in other Electrical / Instrumentation categories. F) wever, the results of this evaluation will be furthe'r assessed as part of the overall programma' tic review of all NCRs addressed under QA/QC Category No. 5, " Construction, Installation, Fabrication." Therefore, the final acceptability of f.his p1 DD.ffo*
4,
')
evaluation will be predicated on the satisfactory result of the overali programmatic review on this subject. Any adjustments to these conclust:ns will be reported in a supplement to this SSER.
- 6. Action Reauired: None.
- 8. Attachments: None.
t
- 9. Reference Documents:
- 1. Comanche Peak, Units I and 2 FSAR, Section 17.1.10, " Inspection."
- 2. TUGC0 QA Plan Manual for CPSES. .
- 3. -TUGC0 Quality Procedure Manual. ,
- 4. Brown and Root Quality Assurance Manual.
- 5. Brown and Root Quality Assurance Procedures Manual.
- 6. TUGC0 Office Memorandum, TUQ-2134, dated May 22, 1984.
- 7. SRT Final Report (SRT-10), July 13,1984.
- 8. NRC OI Report 4-83-013, November 3, 1983, Page 8, Paragraph 1, 2, 3, 4, and 5.
- 9. NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5, 1951.
- 10. GAP Notes of April 1984 (Confidential), Paragraph 16, GAP Witness H.
- 11. GAP Notes of April 1984 (Confidential), Paragraph 33, GAP Witness Anonymous.
- 12. Limited Appearance of Anonymous GAP Witness before the ASLS, September 16, 1982, Pages 5551-5552, and 5555-5557.
- 13. NRC RIV Inspection Report 50-445/83-03, 50-446/83-01, March 28, 1953.
- 14. Comments of Anonymous GAP Witness, Meeting with NRC and Sent to CASE, December 13 and 20, 1982.
- 15. Deposition of SRT Witness A-5, July 17,19S4, Pages 55,102-55,103.
TUGC0 Office Memoran'dum # TUG-2134, " Transmittal of Final Report c.- 16. Issues Resulting From Interviews with Electrical Inspectors," May 22, 1984. , 1
s. d *
- 17. Deposition of GAP Anonymous Witness, July 25, 1984, -
Pages 58,503-58,591. -
- 18. Deposition of GAP Witness, July 16, 1984, Pages 53,003-53,26,3.
,19. .NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18, 50-446/83-12, April 11, 1983.
- 20. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; (June 13, 1983, Pages 7733-7755; June 15, 1983, Pages 8160, 8231, 8261-8263, 8291; June 16, 1983, Page 8358. -
- 21. NRC. Interview with SRT Alleger A-3, September 6, 1984, Pages 30-37, 39-40', 42-44, 63-72, 75-79.
~
- 10. This statement prepared by:
James C. Selan ' Date - TRTRevilwer ;.
. . . .: t.- .
Reviewed By: , Jose A. Calvo Date Group Leader Approved By: Vincent S. Noonan Date Project Director e e l
o f
^!
'.s 3
.. o, 0- .
- 1. Allegation Group: Electrical / Instrumentation Category No. 6 - Electrical Quality Control (QC) Inspector Training / Qualifications
- 2. " Allegation Numbers: AQE-8, Parts of AQE-4, AQE-6, and AQE-12.
- 3. Characterization: It is alleged that some electrical QC inspectors were inadequately qualified, that they received help in passing certification tests, and'that their experience requirements were " pencil w' hipped."
- 4. Assessment of Safety Significance: Theimpl1}edsafetysignificanceof those$11egationsisthatthelackoftrainingorqualificationof
- g. .
electrical QC inspectors could result in inadequate inspections of , safety-relatedcomponents. Y The allegations question whether the positions of American National Standards Institute (ANSI) Standard N45.2.6-1978, " Qualifications of
' Inspection, Examination, and Test Personnel for the Construction Phase of Nuclear Power Plants," as augmented in the Final Safety Analy' sis report (FSAR) Section 17.1.2, " Quality Assurance Program," were con-sidered by Texas Utility Electric Company (TUEC) in the development of the quality assurance (QA) program at the Comanche Peak Steam Electric Station (CPSES). Regulatory Guide (RG) 1.58, Revision 1, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" endorses the positions of ANSI N45.2.6-1978.
1 bb . . . 'l_ E2 s s~
o e 2-RG 1.58, Revision 1, and ANSI N45.2.6-1978 set forth positions stating the education and experience requirements for the various capability levels of inspectors (I, II, and III). Both documents, however, state that these requirements are not absolute when other factors may provide reasonable assurance that a person can competently perform a particular task. They require that all records or qualifications shall be maintained ~
~,
by TUEC in an individual's personnel file. 2 In assessing these allegations, the Technical Review Team (TRT) examined Texas Utilities Generating Company (TUGCO) procedures, QC inspector training and certification files, testing program , requirements, on-the- , w.y.. job training (0JT) requirements, and recertification program requirements.
- TheTRTalsoconductedinterviewswiththi,w'trainingcoordinator,'tboLevel
- . , . . . . . gt;:
I QC electrical technicians, four Level II QC electrical inspectors, one Level III quality engineer (QE), one Level II lead QC electrical inspector, one lead QE, and the QE Supervisor. Procedures. The TRT found that TUGC0 Procedure CP-QP-2.1, " Training of Inspection Personnel," commencing with Revision 8 (July 1981), contained
.the education and experience requirements consistent with RG 1.58, Revision 1, and ANSI N45.2.6-1978. Revision 7-(June 1981) of the above procedure, Section 3.1.d, " Technical Training" contained the statement:
Minimum training, education, and experience requiremen'ts will,be defined in technical training outlines prepared for specific inspection activities (civil, electrical, etc.). t
3-After a discussion with the training coordinator and an examination of the technical training outlines, the TRT discovered that the education i and experience requirements were never defined, and that only the
- training requirements had been defined. After examining other related procedures, the TRT could not find any deficiencies or inconsistencies, except as noted below. .
Training and Certification Files. The TRT examined in detail six elec-trical QC inspector's training and certification files (two Level I and
~
four Level II). The examination revealed two instances where TUGC0 Procedure CP-QP-2.1, Revisions 8 through 15, RG 1.58, Revision 1,c.and ANSI -
, . w;;.: w - -
N45.2.6-1978 requirements for qualification were not being met. Specific-ally,"they included: ' "* "/ f l ' 9* (a) No documentation of a high school diploma or General Equivalency Diploma (GED) for one of the inspectors selected. The file on this inspector contained only a telephone conference note that a call had been made in 1982 requesting information from a high school'. (b) No documentation to waive the remaining two months of the required l l one year of experience for a Level I technician before the individual became a Level II inspector after successfuily passing the required exami' nations. e 9 e
- oc o o _ _n-M - _*
- _
, . t The TRT also found one case where a Level I QC technician had not passed the required color vision examination to be administered by an independent professional eye specialist. A makeup test using colored pencils was administered by a QC supervisor, was passed, and then a waiver was given.
A TUGC0 procedure allowed for a waiver on a case-by-case basis. In addi-tion to tha above, the TRT staff also found two cases where the experience requirements to become a level I technician were met only marginally. In one case no do umentation was found'in the training and certification files substantiating that the person met the experience requirements or providing the basis for determining that the person could, with reasonable assurance,- competently perform the particular task without h,aving the required related experience.
.. g; ..
Testing Program Requirements.' .The TRT examined the testing, retesting and scoring methods applicable to Level II qualification and found some guide-line inconsistencies and procedural deficiencies. Specifically, they included:
.(a) No time limit or additional training requirements between a failed test and a retest. In practice the time varied from a few days to months.
(b) No c'ontrols to assure that the same test would not be given if the taker previously fail,ed it. h _..-_-___---_.__----.--__--n _ ~ - _ _ _ _ - - .
l (c) No consistency in scoring. Two different scoring techniques were
- used to average the results when.two tests were taken. Combined ,
i test scores could vary slightly, depending on which technique was
- ' used. These slight variations could make the difference between passing or failing the tests - - a condition resulting solely from the scoring technique used. Seven out of 25 tests used one test .
scoring technique instead of the other. 5 (d) No guidelines or procedures to control the disqualification of ques-tions from the test. In one instance a. question was disqualified after the test was administered, thus allowing two people to pass the exam that they would have otherwise failed.
. . , , j;g , .
1:. i . - (e) No program for establishing new tests (except when procedures changed). The same tests had been utilized for the last two years. On-The-Job (0JT) Training Requirements. The TRT examined the DJT train-ing for QC electrical inspectors and found sufficient documentation in the training and certification files that adequate OJT was being obtained. Numerous cases were found where a portion (10%-20%) of the required OJT was being waived only after applicants successfully passed the Level II
~
examinations. e o e
- - - - - - - - - - - - : . u-
~--s-- -
Recertification Program Requirements. The TRT examined the recertification program and found that there was no required documentation to assure that recertification requirements were being met. The present system only
. l requires a simple "yes" or "no" answer from an inspector's lead QC inspec- j tor that the individual had been active in the area in the last 6 to 12 months and was knowledgeable about current procedure requirements. The lead QC inspectors did not maintain any written record of a subordinate inspector's activity.
Interviews. The TRT interviewed 11 people, including the training coordi-nator and Level I QC technicians on up to the QE s,upervisor. The TRT - determined that QC supervisor favoritism, craft harassment, and production ~ pressures implied in the allegations were at a minimum.' The consensus of those interviewed was that the training program was ade-quate and had improved over the last couple of years. Some thought addi-
- tional OJT would have been more beneficial in lieu of " book time.'"
Based on reviews of the QC inspector training and qualification aspects of f
.the electrical QA program, the TRT determined that current procedures in effect beginning with Revision 8.of the CP-QP-2.1 meet the requirements of l
ANSI N45.2.6-1978, as augmented in the FSAR and endorsed by RG 1.58, Revi-sion 1. Prior to Revision 8, TUGC0 procedures did not define the education l l l
7-t i ce TUGC0 and experience recommended in the above regulatory documen s
- 81. The TRT was not committed to these requirements until April 30,19 d that some review of the training and certification files determine itions
- supportive documentation as required by procedures and r
?
' was lacking.
I d al
! The TRT determined that the testing program lacks guidel t question dis-
' requirements cpvering, but not limited to, such items as tes f the same tests.
qualifications, scoring, retests, and the prolonged use o determined that the inspector recertification program The TRT als irements in programmatic controls to assure that the recertification
'^
requ the ~different electrical quality instructions are being met. . Based on its review of the pertinent
' 5. Conclusions and Staff Positions: is evidence documentation and its interviews, the TRT concludes ogram lacks that th i ,
'to indicate that the electrical QC inspector qualificat on pr i d' level of i
i programmatic controls which may be indicative inspectors. Spe-that the re
}
" qualification was not obtained for some electrical h t suitable QC cifically, the lack of programmatic controls to10assure CFR 50, Appen-ta proficiency is achieved and maintained (as required by P, dix B) was found in:
f I I ! 1 I
l-8-
- The supportive documentation of qualifications, as required by pro-
' cedures and regulatory requirements in the training and certification.
- The testing program for Level II qualification.
- The recertification program requirements in electrical quality .
instructions. 1 The TRT concludes that the lack of these programmatic controls in the electrical QC inspector qualification program does have safety significance . Since the training and certification program is the same for all disci-' plines (except ASME), the TRT concludes that.the deficiencies
~
requirements and guidelines in the testing program and the lack of do tation in isolated cases have generic implications to the other construc-The implications of the TRT's findings concerning the I tion disciplines. electrical QC inspector training and qualification will be further asse as part of the overall programmatic review of QC inspector trainin
'q ualification, which is addressed under QA/QC Category No. 4, " Tr
, Qualification." .
TUEC shall accomplish the following prior to fuel load:
; 6. Action Required:
O l
.. -wn- v---
_.t-
-9_
Evaluate the testing program for G electrical inspector qualifica-(1) tions and develop a testing program which' optimizes administrative ( I '
' guidelines, procedural requirements, and test flexibility (e.g. ,
'
- computer generated tests) to assure that' suitable proficiency is These guidelines and/or procedures shall achieved and maintained.
j include such items as scoring, retests, and question disqualification. (2) Review al} electrical QC inspector training, qualification, certifi-I l cation and recertification files against the project requirements and provide the information. in such a form that each requirement i.5 If an inspector clearly shown to have been met ' / each inspector. is found to not meet the training, qualification, certification, or
~ Fecertification requirements, TUEC shall then review thi records to determine the adequacy of inspections made by the unqualified indi-viduals and provide a statement on the impact of the deficiencies ,
noted on the safety of the project. These actions should be coordinated, as appropriate, with o'ther (3) actions addressed under QA/QC Category No. 4, " Training and Qualification." l l l
. _ _ - .- _ .. - _~ _ - - - __ . - . ..- - . ._. .
l..-. ._ l l
- 8. Attachments: tie ne.
- 9. Reference Documents:
(1) Comanche Peak, Units 1 and 2 FSAR, Section 17.1.2, " Quality Assurance i Program." - l (2) AtiFI ti45.2.6-1978, " Qualifications of Inspection, Examination, and Testing Personnel for the Construction Phase of fluclear Pcwer Plants." (3) RG 1.58, Revision 1, 1980, " Qualification of tiuclear Power Plant I Inspection, Examination, and Testing Personnel." l l l (4) TUGC0 Procedure CP-QP-2.1, Revisions 7, 8, and 15, " Training of l
\
Inspection Personnel." l l l (5) TUGC0 Procedure CP-QP-2.3, Revision 4, " Documentation Within QA/QC Personnel Qualification File." l l l l . 1 i l l
j i i-TUGC0 Procedure QI-QP-2.3, Revision 8, " Qualification of Electrical (6) l Inspection and Test Personnel." j
*(7) Inspection Report 82-11. i' 50-445/81-04 and 50-446/81-04, May 5,1981.
(8) NRC Investigative Report . (9) Pre-filed, Testimony before ASLB, May 24, 1982, Page 80. (10) NRC OI R wart 4-83-013, November 3, 1983, Page 8, Paragraph 4. (11) NRC Special Review Team 13, 1984. Report, July'hs -
- z
- .-
(12) TUGC0 Office Memorandum #TUC-2134, " Transmittal of Final Report on Issues Resulting from Interviews with Electrical Inspectors," May 22, 1984. i I (13) Deposition of GAP Witness, July 16, 1984, Pages 53,003-53,2'63. (14) NRC RIV Summary of Comanche Peak Open Issues Tracking System i i 1984. . l ( i I I i 1 .
12 -
- 10. This Statement Prepared by:
James C. Selan Date TRT Reviewer Reviewed By: Jose A. Calvo Date Group Leader Approved By: Vincent S. Noonan Date Project Leader, e e e E e G
O W' V'%
~ C)~ l. (s' : z. ( Ch D t-
, . . ~ , .
Electrical / Instrumentation Category No. 7 - Electrical
- 1. A_11egationGroup:
Cable Installation AE-19, AE-28, AE-30, AE-50, Parts of AQE-5 and A
- 2. Allegation Numb'ers:
and Special Review Tean (SRT)-10. 3. Characterization: It is alleged that: 3
/
Cable trays were overloaded (AE-19). d
- Cables were not " trained" in a workmanlike manner in the ing room and in junction boxes 1058 and 1059 (AE-28).
- Higher siderails were added to cable trays due to tray ~
/ e-t ditions (Part of AE-29). ,
di-
- Cable density / compaction problems existed due to tray tions (AE-30).
I
- Cables were spliced in cable trays in the cable spread 1
! / violation of regulatory requirements (AE-50).
l l
- A nonconformance report pertaining to trash in cab d (Part of cable, and improperly trained cable was improperly close J
AQE-5). 13, 1984 identified the issue of over-
' The Special Review Team Report on July i l (SRT-10).
loaded cable trays due to the installation of "thermolag" mater a l i li . [' ; ~~' aa, 1 8 3,$;e . .- s,.
. :.,. n
.r
_ J ' . ( I m.. -
q.
)
l l
- 4. Assessment of Safety Significance:
i Cable Splices in Raceways. Allegation AE-50 involved the alleged splicing "of safety-related cables in raceways in violation of regulatory require-ments. The Technical Review Team (TRT) reviewed NRC Region IV (RIV) inspection report 83-03 (November 8, 1982) and found that the RIV investi- .
.gation of the two cables specifically identified by the alleger adequately addressed this, allegation. The RIV investigation determined that one cable no longer performs a safety-related function, and the other cable has been RIV also determined that cable
~
" spared" and removed from the raceway.
. .u . . .
splicitig in raceways is not explicitly forbidden by regulatory requirements, industry standards, or site procedures, and that similar-appearing items
^
in the'same area were not splices,'but were,"in' fact, acceptable methods of repairing minor cable jacket damage. ThA'TRTconcurswiththeRIV determination. However, the TRT notes that regulatory requirements discour-age the use of splices in raceways, as stated in position 9 of Regulatory Guide (RG) 1.75, " Physical Independence of Electric Systems.',' If splices are made, the resulting design should be justified by analysis. The TRT then examined the cable spreading room, selected two cables installed in raceway, which to the untrained eye could appear to have been spliced, and inspected them in their as-installed condition. The TRT also reviewed the applicable installation / inspection records. This inspection and review revealed that there were cable jacket repairs and o e o e e. e e e- --,p n - . m ..,-e.. . _ e e
- e .....e==== , e. % . .e. m
that they were properly identified, repaired, and documented in , accordance with applicable procedures. Poor Workmanship. Allegations AE-28 and Part of AQE-5 involved instances of improper cable " training" (or dressing), poor workmanship in cable installation, and cables installed in raceways containing trash and hazard- . ous debris. The issues of improper " training" of cables and poor workman-The TRT ship in junction boxes 1058 and 1059'were inspected by the TRT. findings agree with the previous NRC RIV determination that these cables, which are nonsafety-related, were properly trained and that they exhibited These findings were discussed with - an acceptable degree of workmanship. - H. c
' the alleger who indicated that the junction box numbers may not be correct-l and provided additional information concerning the location of the boxes .
/
in the plant. The TRT is currently evaluating this new information and -0 The alleger did not will report the results in a supplement to this SSER. identify which trays contained trash and hazardous debris at the time of cable installation, so the TRT randomly inspected approximately 2,000 feet of' cable trays containing safety-related cables and found no instances
'of imprcper training, trash, hazardous debris, or poor workmanship.
Tray Overfi11_. Allegations AE-19, and AE-30 involved various concerns The alleger specifically related to cable trays possibly being overfilled. The TRT inspection identified tray T130CC007 in the cable spreading room. of this tray revealed the following:
o' (a) Siderails were installed on this tray, adding approximately 2 inches , to its height and, when inspected, no cables extended above the level l 1 of the siderails. (b) Per nonconformance report (NCR) E-82-1073R1, eight spare cables were removed from this tray in January 1983 in conjunction with the removal of 42 spare cables from tray T130ECC32 due to an identified physical ray overload condition. (c) Calculation of the actual weight of cables currently installed in this tray indicated loading of approximately 22 pounds per square , foot, compared with the maximum allowable value of 35 pounds per square foot, as specified in seismic s'upporting requirements.' (d) Calculation of the square area fill of cables currently installed in this tray indicates an actual fill of 28%, compared with the maximum recommended value of 40%, as stated in IEEE Standard 422, " Guide for the Design and Installation of Cable Systems in Power Generating Stations." The TRT selected nine additional sections of tray con-taining large quantities of cables. These quantities ranged from 57 to 300 cables per tray section. The square area fill and weight per square foot values for these trays were reviewed for conformance with'the stated maximum values. The results of this review were as follows: ,
,- (1) All.nine trays were loaded at less than 28 pounds per square foot. (2) Seven of the trays had square area fill less than 40%. (3) The two remaining trays had square area fills of 41% and 42%; however, Section 8.3.3.1 of the Final Safety Analysis Report (FSAR) justifies exceeding the 40% value if cables do not extend above the siderails of the tray, and do not violate seis ic supporting requirements. The NRC staff considers this justification acceptable. This review revealed that all trays sampled comply with seismic supporting requirements and, because no cables extended above the tray side-rails, - that no deficiencies existed within the sample selected. Added Loads on Trays. Allegation AE-29 and concern SRT-10 involved the addition of higher siderails and "thermolag" material to existing cable trays, conditions which could cause trays to become physically overloaded. - Regarding the higher siderails, the TRT discovered that siderails were fabricated using 6-inch high by 16 gauge galvanized sheet metal. As such, the addition of this material would increase tray loading by approximately - 2 pounds per foot. Using the above sample of cable trays, which the TRT considers representative of some of the most highly loaded trays at Comanche Peak Steam Electric Station (CPSES), Unit 1, this added hei~ght would bring
- -_ m. _. . . . _ . . . . . ._ _ _
l 9
-g.
the most highly loaded tray to approximately 30.5 pounds per square foot,
- compared with the maximum allowable value of 35 pounds per square foot.
- Regarding the "thermolag" material, the TRT reviewed procedure CP-EI-4.0-49, _
Revision 1, " Evaluation of Thermolag (TSI) Fire Barrier Material on Class 1E Electrical Raceways." From this review the TRT determined that the - , procedure is adequate to assure that, should overloading occur due to the addition of th rmolag material, these instances will be identified, eval-9 uated, and if necessary, corrected prior to the installation of the thermolag. The TRT then selected two raceways (one cable tray and one condui't) with thermolag installed and reviewed the evaluations performed
. ~
The'TRT found that the require-in accordance with the above procedure. ments"of the procedure had been met, and therefore, determined tha't the addition of tray siderails and thermolag material poses no hazard to'the
~
structural integrity of the raceway system. l Based on the inspection of the cable
- 5. Ce,nclusions an'd Staff Positions:
installations for cable splices in cable trays, workmanship, cable tray fill, added load on cable trays by thermolag material, and review of pertinent criteria, procedures, RIV inspection reports, installation / concludes that inspection reports, and nonconformance reports, the TRT the various aspects of the cable installation on' raceway fill meet estab-Therefore, the TRT concludes that these lished installation requirements. allegations have neither s.afety significance nor generic implications. 9 0 e o e a e
* * * ,'**;.*=*,,*..._..,
ow - ee . e em
. e ,
~^ - - - _.
The results of the TRT review of new information concerning allegation AE-28 will be reported in a supplement to this SSER. ! 6. Actions Require'd: None.
- 8. Attachments: tlone.
l l I i 9. Reference Documents: ,, ,
~
- 1. Region IV Inspection Report 50-445/83-03, 50-446/83-01, March 28, 1983.
~
! 2. Nonconformance Report E-82-1073, R1.
- 3. IEEE Standard 422, " Guide for the Design and Installation of Cable Systems in Power Generating Stations."
- 4. Regulatory Guide 1.75, " Physical Independence of Electric Systems."
l S. CPSES FSAR, Section 8. ,i i l
7 8- k
. i Procedure CP-EI-4.0-49, Revision 1, " Evaluation of Thermolag (TSI) 6.
Fire Barrier Material on Class 1E Electrical Raceways." t 7, N RC Special Review Team Report (SRT-10), July 13,1984. j 8. GAP Notes of April 1984 (Confidential), Paragraph 5, GAP Witness A i l and H. k.
- 9. NRC 01 Report 4-83-013, November 3, 1983, Pages 8-9.
- 10. Limited Appearance of Anonymous GAP 3 Witness before the ASLB, September 16, 1982, Pages 5551-5552, and 5556-5557. .
. .' Tei ,
eting with NRC and Sent to CASE,
- 11. Comments of Anonymous GAP Witnes December 13 and 20, 1982.
- 12. NRC Inspection Report 82-01. -
- 13. TUGC0 Office Memorandum #TUC-2134, " Transmittal of Final Report on i
Issues Resulting from Interviews with Electrical Inspectors," May 22, 1984. 25, 1984, Pages 58,503-
- 14. Deposition of Anonymous GAP Witness, July 58,591. ,
e y += * - ~ .
*f,. % m e. ,
C ^ ++ = e _ eQ_ * .
- 3 e
- 9- !
4 13, /
? ,
Open Issues Tracking System, July NRC RIV Summary of Comanche Peak
- 15. l 1984.
50-445/83-18, i Report ppraisal Team (CAT) Inspect on
- 16. NRC Constructior .
50-446/83-12, April 11, 1983. ASL8, NRC Staff Testimony 983, Reg 17. TUGCO, et al., Hearing before the1983, Pages 7733-the Findings of CAT; June 13, Pages 8160, 8231, 8261-8263. - September,6, 1984, Pages 27-3 3 NRC Interview with SRT Alleger A , 18.
~
Date This statement prepared by: William S. Marini 10. TRT Reviewer i
?
1 Date Reviewed by: Jose A. Calvo Group Leader Date
' Approved by: Vincent S. Noonan ProjectDirector 3
i , 6
*D # **
- e+++ ..
. - ame g * -* 7 *M;
*4 l NO
g /l s - o ;) c Allegation Group: Electrical / Instrumentation Category No. 8 - Electrical 1. Procedures ..
- 2. A1 legation numbers: AQE-23, AQE-32, AQE-39, AQE-44, AQE-46, AQE-52 and Parts of AQE-6, AE-18, AE-20, and AQE-37.
- 3. Characterization: It is alleged that:
t.
- Requirements' vere extensively omitted in the procedural revision for post-constructicn inspection of electrica1 equipment and
- raceways. (AQE-23 and Part of AQE-6.) . . .
~
The number of required inspections were reduced in the procedure
/
for reveriffcation of seismic electrical equipment mounting details. (AQE-32.)
- Revisions to the procedure for post-construction inspection of electrical equipment and raceways were made to accommodate numerous t
problems with loose terminations found in the lighting system termi-
' nal boxes during past inspections. (AQE-39 and AQE-46.)
i Revision 15 to the procedure for post-construction inspection of electrical equipment and raceways omitted requirements for inspections of large pieces of equipment, such as 6.9 kilovolts l (KV) motors. (AQE-52.) i 1 I d as 3, e- :s , . ,f f ~ - ,. l- ;-= b ;'"i ' . . . , . ' ./. t, "
- o.
- Post-construction deficiencies identified in the fuel building .
and dispositioned "use-as-is" were contrary to procedure. (AQE-44.) ,
- Paper flow problems existed involving rework and modification to terminal blocks with respect to the procedures to control work on ,
station components after release from Brown & Root, Inc. (B&R) constluction to Texas Utilities Generating Company (TUGCO). (Pars of AQE-37.)
~
- Insulated butt splices were being used contrary to the in process inspection procedure fo'r cable terminations. (PartofAE-18.)
/,7, ..;p. .
~ ~
- Separation criteria between re'dundant' cable trays and conduits'in the cable spreading room were not consistent with the require-ments of the in process inspection procedures for verifying electrical separation. (Part of AE-20.)
- 4. Assessment of Safety Significance: The Technical Review Team (TRT) examined nine in process inspection procedures used during' plant construc-l tion, one post-construction inspection and walkdown proce' dure, and four turnover inspection procedures for final acceptance of station systems, structures, and equipment by TUEC startup and operations. The TRT reviewed in place procedures, historical procedure files, inspection .
reports (irs), IR deficiency logs, post-construction deficiency lists,
.-. , , , - . , _ ,,-___ _ , _ _ , m-.-_ O OO
- 0 * '" * *
)
Y o t h ( , l l
" Raceway Inspection" and " Equipment Inspection.") Before Revision 16, large pieces. of equipment were not specifically addressed in this proce-dure; however, this equipment was covered in Revision 15~of QI-QP-11.3-4.0 procedure ection 3.1.2 entitled, " Equipment Inspections." Because 6.9 KV motors are not considered to be Class IE, requirements for inspec-s tion of this equipment did not need to be covered by this procedure.
Some of the reyisions of this procedure came as a result of the many test deficiency change requests (TDCRs) based on TUGC0 procedure CP-sap-3,
" Custody Transfer of Station Components." .These deficiencies evolved from the startup performance testing of component!! and systems that B&R and other contractors had turned over to TUGCO. Other revisions were
. . -z: . . .
made to include the experience gained during the reinspection of the
.. .. cf. .
in process inspection activities. The TRT found that during the revamp-ing and issuance of Revision 15 'f the procedure, excessive and repetitive inspections were eliminated. After a review of QI-QP-11.3-40 and CP-SAP-3, as well as other pertinent electrical in process inspection and startup administrative procedures, the TRT did not find any omissions in requirements for inspection of
~
electrical equipment and raceway.s. procedure's for Lighting Termination and Wiring. The TRT found that safety-related lighting terminations and wiring were required to be .
*e-9 _..___. ..._.....=* _ _
=
inspected under TUGC0 in process procedures QI-QP-11.3-23, " Class IE - Conduit Raceway Inspections," QI-QP-11 3-26 " Electrical cable Installa-tion Inspections," QI-QP-11.3-28,, " Class IE Cable Terminations," and QI-QP-11.3-40, " Post-Construction Inspection of Electrical Equipment and Raceways." Nonsafety related lighting terminations and wiring did not require inspec-tions under TUGCO procedure QI-QP-11.3-40 or under the TUGC0 in process inspection procedures.
..t . ~.
The TRT found that the inspections of emergency. lighting and associated terminations were being performed under Revision 15 or earlier revisions ofprocedureQI-Q."-11.3-40;evenso,thehrcedurewasnotspecifically ' addressing the emergency lighting inspections. Revision 16 of this pro-cedure was made specifically to address raceway lighting inspections (Section 3.3.1). l l The TRT found that the loose terminations within the lighting termination boxes occurred as a result of an installation deficiency by craft involving the Thomas and Betts RP-12 crimp-type insulated connectors. A document change notice (DCN) was issued changing the engineering instruction used by the craft (EE-8) and thereafter the number of deficiency reports in lighting termination boxes was greatly reduced.
~ ** ~
6-The TRT found that the revisions to procedure QI-QP-11.3-40 regarding emergency 1.ighting inspections were justified to eliminate repetitive inspections of a craft installation deficiency which had already been corrected. Other Electrical Procedures. After a review of procedure QI-QP-11.14-12, ,
" Reverification of Seismic Electrical Equipment Mounting Details," the TRT could find;no requirements in Revision 0 through 4 that established a fixed frequency for reverification of inspections concerning bolt ,
tightening of seismic electrical equipme.nt mountings. , However, the~ procedure provided for reverification of inspectio,ns on a " case-by-case"
- e .
~
basis.
,3
.y.
The TRT also reviewed the following in process inspection procedures with respect to electrical equipment separation and the use of butt splices in panels: e (a) Procedure QI-QP-11.3-29, " Electrical Separation" (b) Procedure QI-QP-11.3-29.1, " Verify Electrical Separation"
. (c) Procedure QI-QP-11.3-28, " Class 1E Cable Terminations" e
The TRT determined that in process inspection procedures QI-QP-11.3-29 and QI-QP-11.3-29.1,'and post-construction procedure QI-QP-11.3-40, were used to identify deficiencies in the fuel building and that these procedures allow the "use-as-is" disposition of nonconformance reports e ee e. eee e e oes * - ee - e.. em= ee . e .ee e , eee ,.
7-(NCRs). The s fect of "use-as-is" disposition of NCRs is discussed , in Electric 1/I strumentation Category No. 5, " Electrical Nonconformance Report (NCR) Activities." The separation of electrical equipment and installation of terminations in accordance ith procedures drawings, and specifications is discussed inElectric1)I.strument9tionCategoryNo.1,"ElectricalCableTermina-l tions," and Electri 1 I strumentation Category No. 3, " Electrical Equip-ment Separation." In a T'RT review of other electrical procedures, the TRT found no omissions in requirements for inspection of electrical equipment.
~
5 .- Conclusions and Staff Positions: Based on its review of' procedures for in process inspections, post-const'ruction, and turnover inspections, the TRT concludes that no significant concerns existed with electrical proce-dures. The TR'T,.therefore, concludes that these electrical-related allegations have neither safety significance nor generic implications. j However, the results of this evaluation will be further assessed as part l of the overall programmatic review concerning procedures addressed under t QA/QC Category No. 6 "QC Inspection." Therefore, the final acceptability of this evaluation will be predicated on the sat'isfactory results of the overall programmatic review on this subject. Any adjustments to these conclusions will be reported in a supplement to this SSER. - a e e. D ese g ...e e . e e .e ee e . - no . e e e. e . .
-g.
- 6. Actions Required: None.
- 8. Attachments: None.
- 9. Reference Documents:
i.
- 1. TUGC0 Procedure No. CP-QP-11.3, Revision 4, August 12, 1983,
~
" Electrical Inspection Activities." -
, 2. TUGC0 Procedure No. QI-QP-11.3-23, Revision 11, March 6, 1984,
" Class 1E Conduit Raceway Inspections."
- 3. TUGC0 Procedure No. QI-QP-11.3-26, Revision 22, June 8, 1984,
" Electrical Cable Installation Inspections."
l
- 4. TUGC0 Procedure No. QI-QP-11.3-28, Revision 21, June 8, 1984, l
" Class IE Cable Terminations."
l
- 5. TUGC0 Procedure No. QI-QP-11.3-29, Revision 15, January 18, 1984,
" Electrical Separation."
- 6. TUGC0 Procedure No. QI-QP-11.3-29.1, Revision 15, February 15, 1984, " Verify Electrical Separation."
- , -r---,- - - , - , , - - . - - . , , - - - , - - , - - - - - - , , , - - - - - - - - - - - -
i l
- 7. TUGC0 Procedure No. QI-QP-11.3-38.1, Revision 1, February 21 - l 1984,." Installation of Class IE Electrical Equipment."
- 8. TUGC0 Procedure No. QI-QP-11.3-40, Revision 18, May 18, 1984, "Postconstruction Inspection of Electrical Equipment and Raceways."
- 9. TUGC0 Procedure No. QI-QP-11.3-50, Revision 10, February 8,1984,
" Cable Gri,p Support Installation Inspection."
- 10. TUGC0 Procedure No. QI-QP-11.14-12, Revision 4, July 28,1983,
" Reverification of Seismic Electrical Equipment Mounting Details."
- 11. TUGC0 Startup Administrative Procedure,No. CP-SAP-3, Revision 12, June 21, 1983, " Custody Transfer of Station Components."
- 12. TUGC0 Startup Administrative Procedure No. CP-SAP-6, Revision 9, March 10, 1983, " Control of Work on Station Components After Release from Construction to TUGCO."
- 13. TUGC0 Startup Administrative Procedure No. CP-SAP-21, Revision 2, February 29, 1984, " Conduct of Testing."
- 14. CPSEsStationAdministrationManual,ProcedureNo.STA-802, Revision 1, January 10, 1984, " Final Acceptance of Station Sys-tems, Structures and Equipment." .
S An -a-- - -e
5 2
- 15. NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5, 1981.
1
- 16. Pre-filed Testimony before ASL8, May 24, 1982, Page 80.
- 17. GAP Notes of April 1984 (Confidential), Paragraph 6, GAP Witness H.
- 18. Confidential Affidavit of GAP Witness (Paragraph 6) of June 27, 1984.
~
- 19. GAP Notes of April 1984 (Confidential), Paragraph 7, GAP Witness H.
*~
- 20. GAP Notes of April 1984 (Confidential).. Paragraph 25, GAP Witness'I.
~
- 'N .
. 21. Confidential Affidavit of GAP Witness H, July 16,1984,' Pages 10-11.
~
. *h
- 22. NRC Special Review Team Report, July 13, 1984.
- 23. Deposition of SRT Witness A-5, July 17,1984, Pages 55,000-55,164.
'24. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on m
Issues Resulting From Interviews with Electrical Inspectorp kay 22, 1984.
- 25. Deposition of' GAP Anonymous Witness, July 25, 1984, Pages 58,503-58,591.
7
- 26. Deposition of GAP Witness, July 16, 1984, Page 5$303-53,263. ,
l
4 . 11 -
- 27. NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18,.
50-446/83-12, April 11, 1983. -
- 28. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; June 13, 1983, Pages 7733-7755; June 15, 1983, Pages 8160, 8231, 8261-8263; June 16, 1983, Pages 8358, 8367, 8368-8373.
- 29. NRC Iriterview with SRT Alleger A-3, September 6,1984, Pages 9-12,
~
17-27, 30-40, 48-83.
- 30. This statement prepared by:
Allen R. Johnson Date TRT Reviewer
. 24. . . .
.~
Hulbert C. Li Date TRT Reviewer Reviewed by: Jose A. Calvo Date Group Leader . Approv'ed by: Vincent S. Noonan Date Project Director l e W . . .. . . . . . . . . . . . . . . . .. . ..
~
s U l* Q)*( D y .. . 2.I h (g)n & Allegation Group: Electri al strumentation Category No. 9 - Electrical 1. Inspection. Reports, Inspection Item Re'moval Notices and In-Process Inspections.
- 2. A11ecation Numbers: AQE-7 and AQE-43
- 3. Characterization: It is alleged that the number of required in process inspections pe.r procedure were not being conducted and that inspection reports (irs) were being written without re-inspections to close out inspection item removal notices (IRNs). . .
- 4. Assessment of Safety Significance: The implied safety significance of these general allegations is that a reduction of in process inspections and omission of re-inspections could compromise the quality of the installation of safety related components.
In-Process Inspections. The Technical Review Team (TRT) examined current and past quality inspection procedures in the electrical discipline to determine the number of in process inspections required. The TRT found that Texas Utilities Generating Company (TUGCO) procedure QI-QP-11.3-28,
" Class IE Cable Terminations," was the only_e3 ctrical-quality 1nspec. tion \
O 2 procedure which defined a specific number of required in .
-- process __inspec-f[9 tions. Through Revision 4 (dated July 16,1980), the procedure required a minimum of 10 in process inspections per shift. Revision 5 of the pro-f cedure (August 7, 1980) changed the quantity required to "a weekly" in-process inspection,
_o . . . . . . . ..
+
1 The TRT interviewed quality control (QC) personnel to learn the basis for the revision to the procedure. However, the individuals responsible for this revision were no longer employed at Comanche Peak Steam Electric Station (CPSES) and could not be contacted. Current QC personnel could only speculate that " level of confidence" was the basis for the change. l The TRT interviewed the project engineering manager to determine the , Class IE cable termination activity profile when the procedure was reviewed. Fro,m the discussion, the TRT determined that less cable l termination activity occurred in early 1980 compared with late 1980 to mid-19A1, when cable termination activity was approaching its peak. Comparing cable termination activity for these two years, that is, foi- . the period between Revision 4 and 5 of the procedure, with the results of the quality assurance (QA) trend reports for 1980,(third and fourth quarters) and 1981 (first and second quarters) on nonconformance report (NCR) activity, the TRT determined that adequate QA controls existed in the inspection proc.ess so that an increase in in process inspections was not warranted. Thus, the reduction in the number of in process inspections' was justified. Inspection Reports and Inspection Item Removal Notices. The TRT examined
~
TUGC0 procedure CP-QP-18.0, " Inspected Item Removal Notice Form," for its adequacy to control the inspection process. The TRT determined that this procedure was adequate to assure'that reinspections were performed, when required, to verify that the item subject to the IRN was still in conform-ance with the requirements.
4 0a. . i
-3_
j The TRT also interviewed two paper flow group (PFG) cocrdinators, a PFG IR clerk, a lead QC electrical irispector, and examined 20 irs and IRNs. The TRT determined that,because of the checking and paper pro-cessing involved with irs and IRNs, a PFG coordinator would not be able , to recognize that a signed-off inspection report had been completed without reinspection actually occurring. After discussing this issue . 2 with QC inspectors, the TRT determined that an inspection could be made, but was e"xtremely unlikely, without an inspection report in hand. Other-wise, an inspection report could be completed away from the inspection site, from which the inference could be made'that: 'an inspection had not been made. Although, there are no requirements .in the procedures to this effect, it is understood within the QC discipline that an inspection will
- 3
~ "
not be performed without all required documentation. The TRT contacted the alleger for specific information, but' no additional.information was l provided by this individual. Further, the alleger acknowledged when t . j making the allegation that this part of the allegation was based on , l hearsay information. . L \ i \ i 5. Conclusions and Staff Positions: Based on the review of the pertinent documents and interviews, the TRT concludes that the electrical-related allegation concerning completion of an inspection report without reinspec-l e tion has no safety significance. The TRT also concludes that the elec-trical-related allegation of not performing the required 10 per-shift l in process inspections has neither safety significance nor generic . l implications. However, the results of this evaluation will be further l e
- .- -_.,___.-_.,,.,_r , _ _ _ . - . , , . _ . . - . . _ , . , - . _ . _ . . _ - . , , _ . - . - - , . - - . _ - , - . - , . . , . - . - - _ . - - - - - - - - - . . , 4. - . . .-,-.- . - .
I, ' .u c assessed as part of the overall programmatic review of irs, IRNs and in process. inspections addressed under QA/QC Category No. 6, "QA/QC Inspection." Therefore, the final acceptability of this evaluation will l be predicated on the results of the overall programmatic review on this i subject. Any adjustments to these conclusions will be reported in a supplement to this SSER.
- 6. Actions Reauired: None.
- 8. Attachments: None.
- 9. Reference Documents:
- 1. TUGC0 Procedure CP-QP-18.0, " Inspection Report."
- 2. Brown and Root (BLR) Procedure CP-CPM-6.10, " Inspection Item .
Removal Notice Form."
- 3. NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5, 1981.
- 4. NRC Special Review Team Report, July 13, 1984.
- 5. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on Issues Resulting From Interviews with Electrical Inspectors" May 22, 1984.
50-445/83-13,
- 6. HRC Construction Appraisal Team (CAT) Inspection Report 50-446/83-12, April 11, 1983.
---.-n - - - - - - . - - - - - , . _ , _ - - . , , , - - - - - - . , - - - - . - . - . - - . - . . . - - - _ _ - -. -
k,, ' 5-
- 7. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; June 13, 1983, Pages 7733-7755; June 15, 1983, Pages 8160, 8231, 8261-826.3; June 16, 1983, Pages 8358, 8367, 8368-8373.
- 8. NRC Interview with SRT A11eger A-3, September 6, 1984, Pages 8, 21, 42-45, 48-79, 81-83.
- 10. This statement prepared by:
Date TRT Reviewer Reviewed by: Jose A. Calvo. Date Group Leader
'v Approved by:
Vincent S. Noonan Da.te ~ , Project Director , e e a 8 e e 9 9 e b O
. , . _ - - .-- - A
. , . -..,a ..- -.-.. - - , - - . - - - - - - ..-..--a- - . - .
/
/ ,,
j C.. (e ?c$ i 17 f/l%fbd/}
-u ,_
f, 59' /90./5-0UgmO>f
- 2. 59ir - unauzdmgJQu7a/ggfwa.
.s. % - m e m n W hae a Ti , ~
r/ /) b
-m waas
~Ast4'a uxA'l dluRLE wa .Jllu
?2'ictV+y[dousQg81ds ix uh
/au7Arj 62al' a. (/ak)47% to
- Lo c M
f- ,# $a Yae"ux,,mmu_B "4,xMn &qusu}s0 OIn7 su t, Krc'u m diit a;1/w.g aullag ~~ a, 4~ lLlfLPn ? 'o DMllLUONL y, .(. ) ] J, h . f. k h k 1 t v [f $$ &l fSS/Yb 0GYl// 0 $l0i$$NL d /ase-<J u e' n 6 iL &'67zou_jnickdZO'EJO, . 6 013 s % .
" <r allo $tw Lovu .
u&il.!&b:0tsbo[ddl6di; W M m ca m be4 W O&na Dcf/- 7o :// c2.uli v f A o ?. /e7 ef)du_ sr,(C/x Tlc >0cuh:x A d>ev - / /d76 u1A ? cau.zx A d d n 4 ( W & % v. 1 ) Z A~ & A n bauad1 atatd stocuy am aoacr g n$satsasa cgf9,Qic.f mc7 <2d</:M.n] Gy /&a% 2 u &xEuhsie!: _c , Jn' etc7xgsZh. (or) ni%&A0mc:>iz
/2 2 5 )
4 !
- (./uladA a d ,cacizdiAbuewt.
oestada sae o% o d q ou2A Mety 20 Mt.3 a2220020)y(gany i Report A </- 5 icnoua S. Qkd7 /K/tb d db/MA
/0cwd /uAccL:8 TR 6/oatent sd E , OI fD' w mL
.E) c2ad pa2Dn and 4 deg6671 6.5 a e s s- % A?ccoxue0 d 4 x u //.o o r L d
/o cHO/., Maac.o/ Gdu6ut a dloGy/t, dalAok/% avA ru.AJk c1UJBY bdu/', E26 chessau:2Ao , a /uor d'aso y~,
weLel Den-7 y/,I dl5fAo 662dhJU && & 4 h OSOL d~t &uopsazidu% ar' aso dxWa saasawL?zc1e ey .,an. G. 7727'o LV/r7 chtsbra (/ !) A' M.$6efuelisiimiiiiiim dba aClcz 'e Occ/ Lwd 65,) Ju'ich by o1 :dikoaraut. werzwaa,
<X6x-<-tinn>r Z/> pfL,d/zbr. Od.WA At. d.$u/5.r d.l w9AM%o& anduabihr60
/namu:/g amwzz4ouyi0fa,6:u tu 4 cu.bgi:Qi
9 [ . o/' ogus o71xarwn g& 60 l mal' bE dla~.Xsk 6a/ Olk&.2 l /W.;
' , . a d ie u aas alTuadu bastid 9m. "
suoo,tzt Adx,0&un ai2 &< zi a2L Bonn0 6a~4cv7 acHA n aT&.. (b) SI GbCdsl4at 04DuA1 s&< n P We ldv.uu'lw-ud(
<f' fcoat.oR,% 7zsc S&LJ
.1 dsd E[u/ s#A oculiul &T-QA //.2 fot b& D cc> a s s af ,.
u m =' jqu/f]u., a r Ws 8/ob La ,s,&o.a&A ul:0 26 saic J & by261'xt'(.?
= 9&
Goe odan. osa2a n 4Q66/sg2 au . ch wrde lzb c <L Yh *
< con & aawa, - r aaniew '
,M os n ca ms7ada2Va
&/)ci '
- a. z%s tid anon Lbd dydffOdc a>dz/ d /udAd' 6oy$0l a:{
cy case. g (e) 74vv..A Fud/dL:ed Eaddiei 70sc on amwiD d$um$u.z ?Av ernthllhhd 64% av s.nu g i a a a p:a,su su.: aao.saw oT:aTRw/ &R2tg 64 uo 5$,i &q sw .3 nibas as L OR.
P&ar Dni s ordicad -Ecoa Dctdco GJ . i IS ,7 8- 3}l2/ 8 3 - 3362 l IN78 - If1i a0 - llbo (2p)=585l,gt tjiylso - altzlas - 2M V ( 23 p') 7'321g'
~
3)19183 P.-T ~ 15 6 o (s.tN zp}
%'(ae l-n u be.Fg a twow e og Spoo eli.Al 6:cto mdLt)
)F 2blo usd u./scuJLhn j CA MU~d 5 6@ cue v.LA G1N
)
W @ u m.ca El D O<h = ,2.ssnu v s = 5000 lace: f% Log ^='12dr0401ciQ
. 2_
a l Canm Zo o mal l C" C %hp ~*k.l.le SAj lO O lo es ql9tJALavwybd O. S 000 Q cs I
& b 6 A. q k Ltt X % a Y Q (py ( kU.D.'^L ED 0'
,4-90
\ 7-00)D90 (.204thg h 2
,G37o 700,aoD(lon1/gs) 4L
,w I 'n SOO D bJIlo %d s)JL clJ R (. ,7
>,2 Z$
, e w4 cv7 & %lwW ole ~J
- 4
~ Qe , e g ugwmm.>% '
rm.c 4 C N
\
w~ a 3
)
EhwQL M% N 'biRrib & , Q cLoQd *
~
onc.p, & eugy w oT G' cElba ~Ll% g4 cAh f
. _ _ _ _ ' ' I ' __ I ~ _1 . ' **~ ' 7. __ _ $_.
[_.______ , _ _ _ . , .
a., gcE;f h TirOWr10 NOOL"J1Ce
- w'w P.O. 00X 1001 GLEN ROSE. TEXAS 76043 f m s # $ '$ 4 4 4 ( W D m a at_% ;t L g g DATF
.nwk Cway emM de;u/ L-zao s{_poshe Jod nHa cmsg/,b J
,A,, io - is- 7 7 - . Ao/pahl.y'los. t 5 i Ii.5_lI ~b.d w h chl <ayedsIA$59 is coq a f AL
~
a n .$Gs E . Ojk _.5-lbr '. -- - . . . . . . . _.A _L ob .- ... Masil s KuX~~ I~W ArZL/
. - . . --_b;xgLA,Lu,% si .% _eud ./ .
ske.A p f f LL-shS_ko INmmp%, eabw6 e - .- .- - .. ..
/9808. - . . . . . - - . . . . . . . - - . . . . . . . . - - . - - . . . _ _ _
BY - SIGNED [ , ypw. . .
.i I .g-t .,7 .
62.2 i I a
.i 4
o < . 4~ OIA-85-5a. N. L i wa $'
=- - - . -
$2 w - u ,
L MINICEL E i ) MIuICEt* t-200PR V-a g
- w. $ b CROSSLINKED ;
1 W"i+MPLASTIC F
~
1:!,
~
n e c i POLYETHYLENE FOAM k-FOAMS u ,3-S y ji,, aune, 1976 l r,w., .
.t, . .
u .... . - . . , . - . . . , . . . . , . , . , . ,
. -m '
r. 7-PRODUCT ~ DESCRIPTION
\
Minicel* L-200FR is a new, crosslinked polyethylene foam having a very fine cell structure. It combines the soft, stretchy feel of a vinyl and the light weight of a 2 PCF density polyethylene, with an appearance unmatched by_any foam on the market today. Applications are in athletic and flotati'on equipment, decorative and protective packaging and gasketing . - 3 SIZE AVAILABLE ,- 3" x 48" x 48" ?T'- APPROVALS _
-L-200FR has the following approvals: &' 20 d5*
Federal Motor Vehicle Safety Standard 302 " Flammability of Interior Materials." Burn rate required is less than 4 inches / minute. L-200FR has a zero burn rate. ASTM D-1692 - L-200FR rating - Self-Extinguishing ._. SPECIFICATIONS - TYPICAL VALUES . Density Range, PCF . . . . . . . . . . . . . ... . . . . . . . 1.5-2.4
........................ 2-3 Cell Size, Mils . ~
Compressive Strength, PSI 3-O l
@ 10% Deflection . . . . . . . . . . .......-... 6 - fa
@ 25% Deflection . . . . . . . . . . ........... 14 zon
@ 50% Deflection . . . . . . . . . .
Compression Set, %,of Original Thickness 22 Hrs. Loading, 24 Hrs. Recovery 4
@ 257. Deflection . . . . . . . . . . . . . . .. . . ... 15
@ 507. Deflection . . . . . . . . . . . . . . ....... 40 Tensile Strength, PSI . . . . . . . . . . . . . . .. . . ...
275 Elongation, % to Break . . . . . . . . . . .. . . .. . . . . 175 Max. Continuous' Service Temp., *F . . . . .. . . .. . . ... 0.25 K Factor @ 70*F, BTU-in. /sq. f t. /hr . , *F . .. . . .. . . . . 0.1 H2O Absorption, 7. by Volume, 24 Hrs. . . . ...... . . . . . 57 Buoyancy, lbs./cu. ft. . . . . . . . . . . . . . . .. . . .. .
~***-d^~- *- * * -d ~
" - - - ~
FOAM DIVISION .'.~,",6...a.""..".'~....~.wn'".".."".".,'.".i..."."'."-wn".."-
, , + w .., ,i . .
- u. .. s .$.s
. . .. ..... .. s.,-. . .e., n,,
HAVE01NDUSTR1ES,1NC. .. , w s , -.,w., .. . n. ,,*,. ~ . .a i . . d*****",,."..'.*,*,*,,*,,*.*,.d",~'"'""*# Subsidiary oi HERCULe.s~ lNCORPORATED . , , . ,,, 4 w i, w.4 ,. a.,% u ,,,
"*",,"w'**",*d'.,,*,*.d""',",,,*""**'.,"".,',,",'*",',,',',".,*',"%,,",,,,,.#
, ,,.s <,. a *. a u
., -,. -w=w. ,
AMW90"f!:n*Nh%Y[g*'i-?MW?kW2&&$M
',l
[ , bQ Wi l Q[ ' e= ;rar -=m'-"]p --
- * -a s aa - *an ** An s**,
_ 1%5 hem *46W3@n M Mis @lWSMP7 den - j r a _ _ . aw-m .f . 4
-S,twWywm@M WWif9,7i$JLMECA' @Mn;F9,QG s.m. , - ~ m
; , ;l w. . ,. . . m ..v., xt ~ men.
. .sx~t-sy w w m g w .
4 (A & .
\
lf
< i fj $ ;
Across linked polyethylene foam with , 3 Q3 % , j%
^
I l fire retardant additives available in p G l thicknesses up to 3" and sheets up to 48" y M m ; i ! by 48". 1 ( E k h ' USES ~ j , i
, f q , .,, Engineered for_use as a seismic separation 2 Q .
c ; li .
" .. joint in nuclear power plants, fossil fuel -
.' o w m3
{ j generating
- plants, nuclear fuel f ': h h !
reprocessing plants and pump storage plants. ((
- g z
! PHYSICAL PROPERTIES )li { "
l j4 1 Density range, PCF 1.5-2.4 i Cell size, mils 2-3 - ' ~
! . Tensile strength, PSI 40 l >
; Elongation, % to Break 275 ( i ! ., .
) i H/3 absorption, % by Volume,24 Hrs. ,1 ,l $ e -
l l j Service temperature range -40*F to 175* F i ' .:
~
Compression set, % of I- ; lg
] g i Original Thickness
, {in g .F l ji ,
iJ f 3 @ 25% Deflection 4 l : ,
- yj i 50% Deflection 15 i ; y
'dj ! Flam@mability approvalsMVSS 302- '
;i 5- x ;
.5 a 0:qb) ,g:q-:- .
SEISMIC CRITERIA 3% T i l d l
$j f 4 Minimum Load Transfer: Under seismic testing load transfer is as follows: @ 10% ; I l ,
deflection,3 psi- @ 25% deflection,6 psi- @ 50% deflection,14 psi. !, )i
; Joint Forming: At 2.8 psilateral pressure of concrete (placed at 2 ft. vertical lift per p j i @M ,
hour at 70*F) deflection of Kern Foam will be 2.5%. ;j j , ; I Radiation Resistance: Exposure to 10 x 10' rods with no significant change in i 'j g. ' (;l physical properties as measured by Compression and Decompression tests at 25%, ? tm ! 50%,75% compression. l i dj ' j Seismic Movement: Subjected to seismic movement of 1-35Hz, .90C acceleration, I )M. < 1 ? for 150 cycles with no damage to Kern Foam or to the adjacent concrete. j! j Sk ; I HOW TO SPECIFY i- k !t?( ' i
', l The seismic separation joint shall be Kern Foam Type I,1.5-2.4 lb. density, closed ,
V .: j csE] & i cell polyethylene foam with fire retardant additives as fabricated and distributed 1 fgi "'~ tui ,'
, l
? '
by Wilshire Foam Products, Inc. . ll 4p
!: ]h h l g.g i
=.-wn~~n .->~ m w a,7m
?& l b h $l& l gp memsmemser_wasamessuwe c
$Gb Y Y W-S$$NYN 555 $bh
~
i . o XERN FOAM 9
.h e
I 1. as ;ev2 , 3 An 't t .c
-~,
= .
- :; . g O
.m I- g V Q km samemena
, .h*
. : .x,
_;^
.-;- :~
i
&" 6 m
- -n
- 2. i~ . ?' W,p==.. 4.
- a T.
.:.U R
**d , ,
Nh
;;Q
( '.! Y g m - sw
}h"V j.k,h
,,,. NZ
--W y.
.g. pi wm MB F A m..
m- .
,~ .. . ..
..,,s., ..a ....... .;, ..
' jk DESI. . . s.
~
IC- <%9??%. ..r.4 l'l .
-l ;.;; 1.foint armi b
~
,G..(p;4fQTn ~
' M -~ l
.. . L'.c 4.Radia .
. re . . .
n . -
.. ' 'c - -
,,* v A-.
- l , e
, ., , /i. l
, . . z.m .: s . .
., *u. <u. , .- ,, e -
m-N , *.!, j l i n I 1 j
t
- q. -
e h (
.:::.c '
e/
'('(,%d
- - s
.. s
\
i 3 . k j i _ 3.o44 10 i
* . \'
v . .' [f N, b hh
/
i
.'01 /
(I
\
- W .*
@Y} A0i p'4
+I / -
%grd&.d oF MCESE 6LEVATt6As h5 Op (\- M 7
^
.... . , . .. ~ . . . .
, f'. *,
.,,t.... -
.=*.,..+
**% 3, , . ,
.g . 3 , ' * ** ' f ,;, f*,'. . .,s .**. ,,g,*. * . , . . , , ' . .*
a 3 i, . . +. . g
.: a
..,,,..t......., . , . . * . ..: ... . . .
. . 4 . . / .
.. . '. -s'. . . . .
. ' f!; .'d..%.'
* ,Y <.p!.
t&
..v....'
. . ." . i
~
., .*,. *p s
; f;
/
. ~,...f.r.r',.t.s %.t. %'.'/.'
c t, 4 <.;: _,y....'..;..-...,,,. p,"t, J.
..yr;;' . ;;, , ,, , ,,..y.r.
x . ':, * . . , , ,
.. . v. , 6s, .v.
j',p .
- j.~ ; f.*:,,n E
g . ', , , . , , . i j . inorarri ,,1 SS6- 007ll Sis.3
. ('. r: - sso-ce, 73/n Ed. U-ll 6,.- ];#%L-A Af' %
Re ut p siz.it u p A at4 k-7 -7Dio -Cc6 /7/77 R As (J~([ s kL F~ sVs" as af Jato L-A n.sto%"
-l ') co t sno -ce>7 12/14/17 Rd.u Onl/ /l.f, la RBaz
'lS .g. To 822 o eqp~ As. L
- d,,p
' m2. s 7?o-o// z/7/77 Es. tw.//s bk.,m k Ad L-M o._/
re : G l'k) -c>l2- 7-A f S-A + a E L. Eo 7'c'
,y% dez- 783I-ccI 9,Iz:s/77 Sld slo"as of J-A ToL-A
*N, 6J. >.~ I-A 4 tt'o' IJ. d, of 3 A
-} qb o 2-553I-x7 l2/tajj,7 f y , y ,f( g j. + o p g , g_ g i
Te EL. FA3'o
- to/n/77 l-A Qstl 6., F-A To Rss.(
'.&n' i 4 a = 583t-cos% k s tJ ,U 1a El. 8 W 0
- c.2-sealcc&, ,
C & 2. - 7 0.ht o 0 5 ' k ol7f/cse 7 C(.), fue , Y!C " flo ll, Of
, t$
& Gt4To 7-A Sh ~ sto umi-of l J/4 Ta e-e opp < /L.
L Au~ll n't-665l llj IlL.{77 l A Unil fe -- lll'I G*eh 3 A-lo 9!O" bl o P 6 A lo El., 83 7t/O " Cu2 785/-col fz5,l77 SfnJ, sti.sasIc.0 .1/4 h,L-/] 8.bn.,
/.Ag /z!S" M, of 34 m - 763I-Co2.10,l1/17 l FL Sid %"Alnll, of 6 A fo
/340 S,.sl J YA B tw~., stus
- J J A lo L A
' h c-5&lo-ctl G/ze>/77 E xt. t L il (A, L 4 B h.u , G A f 7 A l
4 upp. //a Bf. % CL 8z.7'&*' o': 7f(b Gc6 II/7,/77 8d > (),tI s%l. Foe s!E.dJihrLA i 4 1
/
l ,
1 1
'/n. .,,'/ ,;., ,,- l. / .. /. l v teai
- 1. .t ';fc 6-cl4 l#/z-3/77 Ed. LA[( % 82M'G" le l Mc'5 C16 Il[ 3/77 E_x4 LA(( fo $ 96IC RSAL
,. .I - s eos -cao fis/n Es uJI10 8 41!G" pct B%IA
,Mol ec> 3- 7 E(3-col $/3/77 (44 . C-F lo Ax bid 3, E 8f 3"Ne A ch 2.-F
< c3- 2 Pdo-o(O 2/3/77 Nw S[nfo km C f 7; /la0W
-fo 8!3 A, c02-F cco3- neto-ol2. 'ryasf77 C-Fall &>- l-F T5 CAl [
7L Cl,8 (3'M - cc5- zE10-co3 GlzS[77 f4 6 e v e< % < / k b O h ,]
% 23'o'u, o[ G-F/5'3"r, l 00 3-F in z7'3 5.of3 F '
cc3 26fo-COl 7,lG'/77 Mae f3's. 00 s-f s 8'3"c, b 60 4-F 4 23% tJ c0cV do A F e=M ' l co3- 2S l3 -co3 7,4j'77 MJ be- MTo 6" f,stofc-f[
/ C~ {f I ms z.PI5- cc.2. Bl(8l77 j MJ Fua- ?!?" hla c0//-f4 l RB62 6 4.sc o C FdNdf, u>3-2.8to-o il S/l7/ 77 Me F- 9 f9 Id. of 4 FA, P.
g 6V 2. S k eu c.-F} Ar ' i seal , u,+ wo-cot '/ut,, M k .culsLes i k..,' D-s k RBS I } kn110-007 8ll6/77 GIds F* c~ A-5 % 8-G Bel? ~, ' GSf p-s ; i.'a- IfIO- co3 E{b(11 8fu6 Wh Yve- 7-s u 85 BA.J C,l L;,, /4 5 4 B-5 - 50t & C ' * :.7 73 ceIt (;//7o MJ 56 Bif.//2- '
9 ' . e ,
.H AR ,TUCC0 (2) AM(4 ) Cli,JB ,
.. ., 13
.s.Ge J OF
..' * \ -
OfAE DJDEX OEI TICN : II COMANCE PEAK STdE :III g/ DESIGi O!ANGE NJDIORIZA 7 DCA NO. 5106 Rev. 9 (NIIL) (WIIL NOr) BE INCORPOFATED Hi DESIGi DOCUMD72 YES X X NO
- 1. SAFETI RELATED DDCUMD1T: -
0,R 0 -m qCI AUr ! 1 ORIGINA'IOR: CPPE XX ORIGINAL DESIGTER
,3 , G, o3 ";," ui .i G i.! S.: 0 N1 _Y
- 2. _
- 3. DESCRIPTICN:
2323-El-1705 Rgy. 7; A. APPLICABLE SUg/IEG/pgg,amrg 8".
- s. Demns "THIS REVISION VOIDS AND SUPERSEDES DCA #5106 REV.
Non-safety related conduits can be supported according to typical details a ttached hereto. Construction shall refer to the owner's guideline defined in CPPA-3417 to select areas where non-seismic conduit support can be installed in safety related structures. REV.1,3,5,8, & 9 are issued for clarification of notes as indicated. . REY. 2: Adds Containment Bld'g'.~ 1i 'n~er supports.
. REY. 4: Adds alternate attachments to embeeded steel weld plates of sh. 11 of 13. REV. 5: Adds page 12.of 13.
REV. 6: Adds page 12 of 13. M98 NO 7.- . . , _ ( REV. 7: Adds page 1_3 of 13. kr IY 01933
- 4. SUPIORTRG ECCUMDTIATIQI:
CPPA-2142: OCA-4693; CPPA-4865 E C Ej y r / N
' n=r/
January 3, 1983
- 5. APP.'CVAL SIGIA'IURES: N/PP/cw fA /// #b , DATE / J- 88_
A. ORIGI51A'IOR: B. DESIci REPRESDrIATIVE: mI // s/ 'l ' Lt'4 M DATE l-5'83
~
NO XX
- 6. VDIDCR TRANSMI'I'IAL RECUIRED: YES
- 7. STANDARD DISTuattrIat y- TFM 11-30 ARMS (Original) (1) i. Fav 7-82 Cuality Engineerirrg (t) , b
'Is for orig. Ibsign (1)
(/ ,* y Westinchouse-Site (1 Civil Engineering ( 1') g*QZ
-r .- c,..ur-EE fj))
.. . .-. ..... -.--.... ... . ... .. .a: . .. .. .. .. .
Page 2 of 13
- DCA 5106 Rev. 9' NOTES .
- 1) SUPPORT DESIGN IS BASED ON EIGHT FT. (8'-0") SPACING FOR CONDUIT 3/4"A TO 14"d AND TEN FT. (10'-0") FOR 2"A AND LARGER.
- 2) WHERE BENDS OCCUR IN CONDUIT SUPPORT TO BE LOCATED FROM TANGENT 2'-6" (MAX.).
- 3) WHERE CONDUIT TERMINATES AT EQUIPMENT, JUNCTION BOX, ETC. THE SUPPORT SHALL BE LOCATED AT 3'-0" (MAX) FROM BOX OR EQUIP.
DEVIATION BASED ON
- 4) SUPPORT DETAILS SHOWN ARE SUGGESTED ONLY.
SOUND ENGINEERING AND CONSTRUCTION TECHNIQUES MAY BE ALLOWED, INCLUDING BUT NOT LIMITED TO THE USE OF DETAILS AS SHOWN IN 5-91 ' REFER TO CPPA-2142 TO SETERMINE THE AREA WHERE NON SEISMIC S
- 5) FOR CONDUIT, JUNCTION & PULL BOXES AND CONDULETS CAN BE USED.
a
- 6) HILTI KWIK BOLTS SHALL BE INSTALLED AS PER CIVIL ENG
R. PROCEDURE
i CEI-20, INCLUDING THE' MINIMUM EMBEDMENT REQUIREMENTS FOR THE BO j EMBEDMENTS SHOWN ELSEWHERE IN THIS DCA ARE NOT MANDATORY, BUT ONLY l SUGGESTED. h WHEN BOTH ENDS OF CONDUIT TERMINATE AT EQUIPMENT, JUNCTION BOX,
- THE CONDUIT MAY. SEAN. A_NAXJfitLU..0E. 3,'-0." WITHOUT ANY SUPPORT. L l
8) WHENFITTINGSAREUSEDINSPANS(LB,LBD.C.BC,ETC.),SUPPORTSPAC ! SHALL BE MAINTAINED PER NOTE 1, MEASURING THRU,THE FITTIN - \ - - - - 1 i l i J . i i i s'
---,n---- -n-_,_.--.-.-n-..,--,.- ._.--.n,,,-. -w-.--- . - - , - - . . , , --. ,-----
. _ . -_._m m _ ._.__....m . .4 . __._m.. . _ _ _ . _ . _ _
a.. , - - - - -
. .. . ... . o . :.. . ..- -. - .
. ~ .' -
. . p. . -
-. r. .... . ' .
.. Page 3 of 13 ccrsus so.9
- s .
[. l .HIL'Il EOL[
* . . =y ~. i .
... ...t ,*.
. * *i. % s. . .f.l. ' . . ' ' * : } .* *. . :r.l.G ;&
. t t 8 1 4
( C O M C u l'j~
=
y' . SPAC.=R PIFE STRAF . -
- . . .:.=. .
.,.c. . . ..=-., ..:
~
~
1- WOLE PI PE ST~A A P - _- ._ . SCAEDULE l COhlOUI'i 517.E Y4 ". . . 1" lE,z"- '2 - . 5' ,
/' .S " -
HULTl A ' 'Ai'A 5CLT. p
- g a p,a *q ga 88 t* S8 .-
[OIA.x MIN. E.M5'C.: <3 3q7lg842^q IfMIN. . . . EMEED. s
~
. . , . ~ ' ., : .. .
. * *. * ' Y # l# # # # # # A ,* . * .
.e
. i. . 8,
, ,, ,. a,
.! h CONCulT SPACER, i* i REAM HOLE TO L'.L y* '
MISS WELO AROUND NELSor.4 STUO ( h _ n ' p . . CFL NEl. SON STUC # -- PIPE :aiKAP . v/ svo. wAeHEa esur ' ~ . W." # FOR %*'d d l'8 W 3/s'p .COR l'/a"p 6 2."$1 .'
. .c
. . . ; ,. r . - . -
,m... .
. . - - _ . -- - .. .- . . . - . . . . - _ . ~ :i*. _- - - - - _-_-.--- . - - ,
. L-.::-.: %... . .t: ' w - :. s
* ~ ~.
. 1 - .- -
J. *** " '
~ . - ' Q:5 ' r'. ;
.......:... .- K'..'.'.*
. ".K>.ll..'..:.:...?..:....
w. i. rm;;. 4 of 13 f. oca, ncs ze , 9 ,..
' ..- . i
_ .I.
- f. :
.~
'. t .. s. .
l- , . iF j -.,1 .
- V.
~
l'2 (M AX.) - ; _' i I b' S g/g" x G* ELTI actTx 3 :
. ._ , .* .\ - . .. -
- . .* . .e . . s .s .-
s4. 9 .. .: - * ' ~ .'< . . .* . L' Y a .p 7.* * : - .
. .. \- . ,
. .r yg.3, e v.
A*l P-2:000 CR ? lCCC. l 1,; . .
. CA. F-E:CCC UWl'iTM's
. .. .2 '
i .I .~ ' .. . . .
, p.g.356*C._g,qp _.
- . 1 . .
-- SU P P C AT..PGA C ON oulT l
~ AG AI N ST t.AJ ALL DA CEILI NG . .
w .: 3" MIN EMBEDOED FE. ...i.... H
. . s .,. - ...?
r 1.* . '. lW'. *) . ,, Ar# # . . - - , ls ') . . .
~
l h'RLLE4=.$ '- H : 'PlOOO, PSOOO OR P5000 . , l 70VER51Z,E. /9El l HOl_E 'iG. MISS -
. WELD ARCUNO picc,3 ,, ; ,
wmso. .mo . . 8/a"d ALL-THRD, rod WELDEO To
' EMBEDOED P j LG. AS REQO. EiY Fisto . -
t . .
~ '
l ALIEi<dATE 3EC t ION A-A .' - .
,.v.
.. '.u...-.
r- ' r
== .;.::m= *. {'
. . s . ' i .!. ~ .'. ..;;.h *' * *= * * * *:; I J w ==l 'E g;p.,rp . .
- ,g.
. .=".
,w,., r%. . .*
.c $.,. .a;* ,s._. =..s.._
n.,Q o.
,.,w.T",.
...;a ,
..a o ., e.n.=9s1 ;. .,.:. . y.
.. ; . 3 . _. .. ..u.
t ) .. . r,
.%. s .. ,.m,. ....r.,. .
u .%.L s %. . .e...g. .
. .. .. .~: m.. .**:n . . .% .
s **&,,e.'3g,;.*.. . ,, ;.f.ytf.ey,
, , . g _g
.s .
3'.a. .a
. ; ,4
- e. .
.r r.r. ,fe.. q. s.w ;4
.,.~., .: c.
f.w c'5 C4,+,g.s
. . w. e: ..~.4 _ e_ .n. .::.gd..
. g. .. .p. mL .
- w. :::. ,..::.-:.::e . .
3,, tr-. :. w;- .:.pv ..
.....**P. , . -r:.p}, : 4s3.;.
. pm... v .p ... en i i s..r .
,. . . =:.= . . .-. 4 .ev**. c.S.pg ; . ; i ... -..s. .
s . .*t . . = . - . . , , ,
- ws.',,
-+ - .*... - w
- Page- . of . ..*. %.svi
, , . .:.,.ye.s..'....~'e,-..
. ~cL . . .. .a. ' .,. ..: t
. . g
. .* g ...
- a. . ,. ,1. i.: ... . .;p v . *. s.f..s
. . (1. w w v
*e T. r?*'..w.a b ,. M,.. , .?:'11. .
. ? .s.
. ....r~..
e.'y.f. ,- . ..
.. $, =.
+4.1 ,.%
- g. -
u - . ee
, .e y >
. . , r .a.,, .l j,v pg.X 5106 22er i.' {$;'.'..
.l; ; ,
, l . ;; Q-O %,s.y.W4%:s.u."....Q=.t".p,y'W 51i.' .O " ( % g .-j.;.[,7..,.R, :Q'., '..
xs. c.
. . ..o . . ,
. . . Cc . . . .
- m. e .. .. s s.. ..S u
. . . - . . . . .. .. . ,c,. .
.w
= g .
I g a. .
..u. ., r
....'s ..' * . . . .s . . .. <.. ,..s .rs
.T.1 . . .... .. .
g* Ql
.. 9, .. .. s . . a> la. - (,J' T, =. .. ,
pt: .
. .....t...t
.*.. r.'.t..s. ..( ....ts. .. r ,.: . , . ..,.,
- s. .s 1.,.
... ~ ._ . s. . . .,
. . e.. .... .'.....h1 .
. .. -- *. a..
r.
...) ;. ...e. .- 8 .
. r= .
o*. .. : .&r &...
.mr n . s * ;N'.g ....be,:. ;, . GM&cQ. M. EN7""*. . . . .. *,g *..
. . ; 1 tjm .. .. ..V .m m.-
- u. a: . . f t. . 2:9 %'
.O ..'t .. s..' ..:= :: e.::: AskH.
..q g. .e's
*O .;,s . v .*
. :8.e; . qs:: i.>'? .pw..Y. .p>~
.P.%. .=.' ' . ' ' .' ~. .. . s+.N. .t. .a' . ..~.:W. .1
- .;2:
s I i
. 7..
..s
.. .. ?
;.- e- .,
.s_ .
A > . . t , e. .s. c. '.- ...
- l _, . . . . - *. .l.
g t\ . s ,:..
. -' .g p..,;g
~ ~
J' 7d
.:...........,,,,_.lI'...
~
- . r. 8- f~:".*-- .s2. . .:
i.. 1", . . . . M.
. ,. . Ls 1 ,.; .:. - ..:..,.m......
*:.......,i
, . . . . ., ,L j .
1 1. . ,
, . 3.
. .a e.. . . .
s ,:n,.w. '.s.n..
, ?,.ks a.
i- -
.. s v.x
. u. s;g* . e,.~ -
,.r.s .;. .
...: . . m. . m
. .s. =.m..i.:......
.~
. . c. ..
. - p-[cG4
,[. ..l
,.:. w
[. ..m. .. ,
. r ....
.l . .. _- ..c. , . . .F. ., ,. n,,h..
. . . '.. ;.... .-l1.jp.
WASHER (WR) -
' .e. :i.'.
[. s .. ... . . , ... ... . s. .
.. . .: . . ......... .. .. . ~ . ..
.s
. t. ! - ,y ,.ti.s
.. .. .. ,. .* ..;*. .. .s. (s*;.
. . . '. e r -
.....'s.>Q,..,
. .. rg .e.4.p ,a. t -
1.s.0.,m'~;
...;; _. =
. pg ., we.. ; *c . . . . . ,
. ... t
. . .y .r
.. . .nv . .,
q.,
- r. .
O t . . ... .
,. 9 :,'.g . ....: . . .. :.. . .
.n.e... . ...:.......
s*- s
;.,. e- . ,a,.*. ::w . -.
lj . . . .
..., .- . :c.Z.w
..%.;,. .:?.-Os9:=a - +.9 .?
....r.
- .. ,.as e . '* .* . .,; a . , ... t . ' - .
l_ , , , . 2y. .j,,3,w. L:7.g,r (, e ,s.y :.;. -. .. ,.
.:. g.,,,.77,-
e .......a... :r.. I. .-P :
-n.. .e. .. ..f . .w,.e,..n,.+
,4 :::.r. : s ;.1 p : ,, .
n .
,- t , .n
. .. ,,:. . *. 4 1q< c.:.7 (o,
- s. $ e:.sdi . , , , ' *Q:w. . ..
.. , y .. U. 8
.y;
..,...,,n.......,. .
...e..
4.
.. :s ... . ~.=,t .. .
4 s.. g ,
.- w<.. - : .c ...L. .:
9 . <. a A M . a.: .. Vt--,. ~
.. l x. .<,.
- . .:.::..:... p a.. -
.c
.I .
.a . .. . ,7 .m .
.[ .*.,
.,,.m
.e-. .:s,r.w. 2. . .- . .:-
p:.L. . t .' . - 2 a. -ls , l. .il
. J /f. :.#::.y.
.. .: q';;; s Q:ss.. ..
'.t' (
I,.L" V.s%{ .c; : Tf. . 'l : .:. C'f,7's 4. 6
.,Mm.
. l
.c..,..
... J.+ ... ............:
. . . - .. ,.,., r ..
.. ..* . - :.: a c.. . .v..r ~. .. . :. . . ,:..c. c. ..
. : r:
.... .. . . c. . .
....~.-..,,.s.e.... .:.. .,.
. .-.c.... .w::m..-c..v.
.. ... e. .
Fl ua- . CLAM;:r . -
....s.. ... .
.. ., . . . , .. ;y . .. . . - - w.
. n..
.u.: .- .:..m... ..:.~.
p.lc 6 (qc') - AN ..:..g =.:.=
- g. 2 ..=, ;
(TYR) F 4 C, C1 L . ..UT.$.UT.'.g,.g N,l ...Sa.....}. g 7, . .. m T ri s c ( T w.? p.~ wv.c.u..=n. ,r..
. O ,.Q ~ M .) .
~
- .:. . . : . r '-.:,.....- .. :: .
~-
..p. ... .. .. .. e . , . .
. .s
.u n .:.w.h.:;;. . .
. . . . ,; .w. j . -...-
...,::; :.a - .:~.. q:'.. .
,:m. . . ..; . .. . ...,;,.,. . : ..;p,,a
... Mr . . . ... .
u.
. . ,. , ~... ... .
- s. . . . . . . . . , . .
. e.m==. A*y .C~,-~l .. :. . .
- . . :. .,:. . a. . . .',,?.,..s...
-~ .
* =5 I - .... ,.....
. s.
. . ,M*.. .
.. n. .' r
._, = . . . -m -
. . :r :
. F().% c": i c. - -_. N ~a .:. .m .e_.m. N . ,
iL. I =i
._ - ._e s .
..t c .,1 . ..
..,. .~ . . - . . .
, M.SC@ACITt= 4 *]g .b CdN Ouri CR 'I. coo * -
-. 7. e N o._i G ,. - - .- . .. .
,6.5 M .hNY CON CUIT45 FOSSISLE C.e.N E'.~ Si!~:FCAT.EC ~
. 1;:': M E M S E.; - ~~
. ... - .cf . ?.
.,:.i..~k '
WJ. tS gEPL: C.GO .l.~t ( . E= .. - - b. C . O O ....
" = p = y r' t . , .- - - - .- - .,.
l ..
- .m =. m = ~ _
.- ~.~ y : -. ..., -.:.:. .;. . . ;=?.-
l , .. .M. O .F-IC'20 ;:tTTlHG5 AAE R7.PLAC ED W P-IS8 - .
-i . ' r.
. .r . .. *
,4,~
. _ . ~ :i . N .. .... + W . M_ . ..%. w. &. A...
~ .
- . :. . c
.. .;u, .. - ua. .. . . .
. . .-. , m. . . ........-. .w ... ..
c=% p.-- '.-?:
. . . 1
................a.s.....;*b-2...
* . .< ~ s . - ~ .s ? .. a * . . - **
.. =
n*
- o. -
w._ ,,s ..a.
. ... .a:
,,.q.v, .m.
_ ..~.~-*3....,., a,.e. c.-..a_.,. _.,.,$..,a
._g.. . '. W_ ..8' 3A,. ..,s3 ._ .. .i
...-. o . ..
. - :s . . . . . . . . . . .
.....a. .. s .
D **-.- -sidi'.F.E' -.%s** ':' .'. )
,** g 3;.. 't a'I 4.6 'J". 2Y."1 * .E T. N',6 f **""a . * .*'2."
"49 * * ?esey- e ;.a .S'*4A*de.
. . *. k'*[.b.
" ~'.I. d.'.. .l:.M.M ..
'? .-
J, ,e @. n.. .d'.*
. s n .n.; D.*1..s ea ..t 6..o .d
... ' s > .e : : . . .;;..}; .^ ,. .r - .
g f. 4~ ,;.u..
. . ... . . . .. m. " . . ' e [. ,yR.;.pg:,.ysj, ..
,. , 3. / ;h.R,-,. "-: M;: .; . . 7:.;:, w9. ..,.
,, n
.a - .. . .. .m,;.. :.; ~ .'.' . . . .
. Cj n.y:. . f;l m.... . ;.s,.1.,.W%. :. . . . . a ..:m. ._3.,.'k M. M.q. .. &, ..
- ~
.; . i4.6 .,.,.
......n..-..,. . ._.p .. a... . ..,m. :.. ?.
. ,.....,e, .. 1i.:.; .y . . '. . . . . . , .
c . ,. . . .............: . . s .s .. I ss > . . . - . .
. o . ....:. ,,. x.. .
. . p .,=...u s o. ...
- p. y.. .. ,.e.:.
. .z . ..:-
..._.m...~...e_ .
=.;
. e o. .- . . .:. .
n_ .n. ~~,.. .+.. e__
. .. ~..... w. ,., ,. w . . .. . ,. ....
- 4. .
.. s. . . . .. .., : .
.s.....
=..n.:-.
. ... . , , . .+
....:.....w:..
e,.
. .. .. . m . .. 11. .. . g.
. ...:... . . . - u. ._?....,.... .. ..... ..
... .e. . :.,
..... _, ... .. _. s .. . . . .
.. . . = . . ~.4,.
. .:+
4 C teh;;3 L i UC. f ...,..p. . '. 7.,-... ..ys.wa.
...~y. . .. g . .
..r.-
s -:- *
,;..S..i. ...2.,....,. .;; t. ,
..:.. . . .. . y!
. .: ,A f 5;, .,,.e
.:. .. ... . r .
r
. 7 '.3 COUPLER r . . .s < @_ . . . . . . .g.~ d!. -t 3 . ~ ->P NUT (WP) . . ... .
. ne. .9.. :_i 3. : .3-3.
.., ~. ....:, . . . . . . . . . .. . . . . . , . .
......... .,,.:.... .~,..,
. a. . . .: ..
~ .
.... s.
=
. CDCe..Os .--..... . -
r
. m g t1 fts . ; -~ .: . .. .(
EMSED.R ;,j:.: . . , .y
. go ,
. .. g,rs
. g ,
. :. ... . ;.' THREAD ED ." .re " %. 0 ~ ' i ': ~"
.:',6 : 2. .
o
. - ..~
W # , ,,W A ...
. %., . .". _. .: . . . - . ,. . . . . 7R. OO '(TYP) . . .t. l '.4
....... . _..m.
._.._......z...
_ w. ... _. .. .w.
.s_... .. . . . . _ . . .
s _ . , .:
.. ,,.: :. . . .. ; ... . . - = ..a
. v,.s. .;.
; c. .;;;
. -. .v. . . ,,. p ....... x. ~, v.,
. . < . . :a# ... . . .:.v.
. v. . ,::., : . ., , n.. :. m.. u :3. .: - m.w . w.
w.
.. :a. .
- . . ...~,.
. ,s. .. .'. . , . :: -
. ) ;&-r ' n.,.:,....;-
. .m.
,. . . .i::
u., .
., , .; :s..,.. . . -: .
.s. .:... ,.:.e_ i .,. . r, u,. .
. . .s :. ,. .. .. . . ..,...;..
. . .u.,.
a.4 m. . ; .. .
-. . ..x. ,. .. ;.. . , ... .. , . .
. . . . . .z .
....n..,....,...
4 o . . . . .
. :.. . '. ~ p [ gg [ - . . .d t.' _ ,
~m~
.. ' N(;J. i"'- %,,.
%. J, evo..-.s; f.,fv... . .,., - .
, ),. --.,.... - _ , , . _ _ - .
v- .- - . .
,g
.. nt .
. m.,,y, %s ,._ . %. .:*-* ;. . . ..,
+.==
ses e, .
, . . . et
.~..t.,. J
~* e.' ,o .g e
3.; .. ... . ;. .
. v^. . .
, .. . .:.:., . . ..e -e---- -!u .
-.. c.s. - - .
- - - -.s , . - . , _ . . . M. :o . . -
;,' 1. ;,
A ; .- . d M: . 4. ;/.,
,.t
~
.f;,,.d /d,:.. , ..... .'
. ...o...: .g t -
w i:
- 1. k ..
- .. x p ia y :.i YP). .+.s. - -
n u . .
.:.. . g :. e. .- %. ,n WASHcw 2..4-0 [NM. ) . . ._ ...-
.. .. .... .m ..,.. .
.: :,:, y .'.
...mr. . ),; .
} ..
~ ' -
.~:.Q.. . . . .
. OW ",...9.v .i.$... .' @..
. 3 . . .SUO pC A T" SY.5TE M C I .
,,.~.
- y. v_.. ,-_s _ _,_,> - , ,, i! i m.
..._-......m.~- .
. W P E-3) 6m-_= n- % =.) . - _. ._. .
. e.,.-
. . ~ .
MAxJcAPActi?: -
. A-w'+ concuy.cs..Lcco . .
. .. a. . .... .
- * * .s 1
, . . . .. . ..c..
... +. .
- . n s.a. ...... .
e. 1 i
...,S...,....,,=:,=>.,,,,,..*
, - .p . ; .,, g . . , . .v.-
I . .
- - - - - - - - - -.w
. _ . . - _ _ . _ . . . m. - . .
-- a .
.__= q
_ _ .... . ... . . . a.. ..1. .-.u...~ a.-.
' ~ - - " ' '
- 3. . . _ _ .... . ..
n s .1 ala ca..v.u r ,. 8 d.' o"(Max.) 4' d(Max.7 s c .c. . m. c_ _._
- ./,,
k d /[ NILTI y /' , . _.P-lO C, .- i1 OF 1 WASEN (TYP)] .ECLT( N F) emeecmam - CEILINQ. .. It'}.Y G -
* * * -h,,O- . .&$2Y.: 1
~
1- ..I l l 'g l .. __- . l
.-l W.
.v . .zi.
2 ut j g -
" Acr. .a l
- w. e -
I -2., . l ' F-ISS 6 ,'P-I SSI l l , af -b '
- a. 4 l e ~
'l .7 g s
ll l . 9,6 , l . . l 2 y P-' 00Q .)[ l-
; - - -? -
1 ,(Pacon l .. . 1 Tve) c a. y
/ a h! 4 --
1-,- . g.
.... !@. m . .
%.. l
. a,,
1 -
- s.. . .
t. I . _ ..m. . . . _._ _._
,i _I. - .. . _.
2
.1 K# - Y' ' 53; . 52 .
- . .y . _
.-+-nss.i.
. . p-is.w .: .
o mese cumcu.> 2'*d Wst) s.. .
. . .._. SUPPOAT' SYS i EM .
_ a. F"Op.. SU. AEh! OED CONOUI i - (,WPG.-E)
~
- - ~
- u
- MAR.C3FA:!TY: 4. .S.4. C C N P_ir[' O M I.C C C ' .
NOTE: '
, AS.LfA.4Y CcNCulT AS ;:cS51SLE Cm cE se;:r.rc:; Tsp ' " " ' '
-~lF
- M F- M 5ER . . ... .
\S REPLACEO *51 P-2:000 -
&& b~,2..RE?LhCEC EV P. 5 cot.. . ..
.... . .. . r- .
* .% w
. ,_, - . . - ----- -- ,- - - - - - - - - - - - -.w.
. . z. . . x. . . . .. . . . . - - . . . -..
1
- " l
. . ..c. . . _% ....c, m ,. . . .m. ..m..
N.: 30 Nh. .-hh ....._,,}...". y ., - ;. 7, 7 e e--- ; . .. a c a s u.. . w. . n. . , -. ... _ .. ,,, ,.... , m ,..,
.y EN8 f. 3Nb MhhE.'
. . , ~
k h :b,E.5
* : N. . .
. 't.
h^. , . .' ..
'.h'."I'Yh'k' s g: ~
g .
.h.:p..m. ..
- +.y~. . ~::,:. .d. . p.n.., :. .L. ;.,.. cca. 5m. . r.a.1 , . . . ; .
.ye ,.e.. g.n;.. ..
... ,. .. . . . . . ... .. ,.3. .. .. ...... r. a.... .m......,. .. ..,.. .9,.. ... ...: .. ..-..... ... ,. .. .. ... .. ,. ..,..,..m.....,.,.
- . .. ., s
. . . ... . . , . ....,z...,..r....
. .. w.. .- l
. . , . n *.. v. .. :::m . .,.=. ..w..
. . :. -g o lg y, :&
- r. :-:.m. . .. .. .. .m. . .., . c .. . . . .; .
n:; ...
.p....."....n. . ... m .=.w . .y.
. r- . ..
g *= " ***. .
. ... . =..mN 4 :..*.1,....g. . v. ?, ;....s??
.{
.e .;, * , . .. ,..
r.;= :. .. .Q s, (g . . .,e> . ,. :y,
. p ts. ;; y;;; n:
... . g. ... . , . .
...~.......
v.. .. . .,.,w, .1 . c. ,. ,. ,.. . . . ...t FAGE II cpl 3 ... M a x cc : .; . ., ' u. c ;.w .;.w...a. .:
- r .. .... 4 .... -
.;r . ( ALT DET .... . . .,m.
r.. ..- ,:
.n . .. .
. . . , . . . . ,c. . . ~ .. . . .
.. .g. .n. .
.2 M
'?. F:~s i- P'-f O'2G @O*hMGL--.. _.. ,. . SN., 0- [.@....:a....
.: .. -t - 4n.a
.LL. . .
= m:
- - ~
. . " . , ' ...F1nsLN G'( N.. D ,......,e..
.". a w. . . ,,
- *. . e.}{: .,,2; a :. *.- m. a..
., .. t- . . . . . . .
.ss
.& l
- p. ~. .: -- .
.,'. , 3 ; , ...r. .
h l .r
. + Y ' n m-* dp cvp.) . . . c. .... .. -
.2a0
.-s 1., .
. .. . ..;. .. l
.u. ,
en e v j ..
,h..
.. ... ,. ... ... ..e,
.. _. . a .
- 7. . . ;- .. . ..
v e a. :
. .,2:. - e .- . ,._ -
j
. . - ~ , .- . a.4.:
.~.p .. . . .
l
- g. .
I I 1 . _~.,__,__
- -_.. l. _- .. ; .
r.. - 1, .. 3 a
. .,. u . . . . . . ... . .
. ;... . . . g. . .. .. .. . -
.J ,.JE.
ad8"""f"#.. s, .f by4, * *
,,3 y .h
. . .; , [ _c,,-. ..
. . . . . . . .o o (2_II._M_l N., .
__ , ,. . .:*.. c.
. . v. -
. ,e.. l .
..... O .. ~. .c.- i . a.._ . ,:. . .... . m.
.v...~....~ .. .
. .c . .v \o
.. .. .. .p.
.M.., 8: - .f
..v... : . . q a . . . . ,. ,p.,
. .:. .w.. e. .
.n.. .a.v..
.u.a.,3. . . . . . ..
. I ?
...q.
..."t .%
~. . . s, p. .c . .* .. -
gt- . * . = .:.ay . . . ,.
. . ' . '. .[
..s :.
. ,H ;.., q...n h .,. -
e.. . ..
. . ;;- ,. . y -.. : . .; .. . .
..* ..v. ...
~ -... ..:.. . . .
.l
. - .v"c;.; .. g .:. .y.+.
. .:A. .:. ; , :* .. . e ... :.
n ....s.. y
.[.
.g.... . . ,. .
.Q n a Ga* ' ...w: .. ..'. .......;. : ..W:
^
). * :o. . .V. hRI =_5. . T::o*
- e. .--.
..[ i a, I. . ..w ,
.a
_ , . ..t 1........... . .. . - 9. .::.
.:. e,. .. : . , - .... ., . .
, n g,y. 5.g9. : .
. m,,...
.... .~
. . . . .. _2 P-Eai5 P. '2b, I b . .:.-- . . .;., .' :. -
%. .B..,. .y; .:; -
s
.. -..3. .
. l . N ~,.
.......... . . , , . .X .. _
-- . .....=. . . . . .. . .
^wge m
. - . . :; . n *-
. .< SE._ e:. AtT. DE i. 6 E . k . =. ..
.. = . -
..>.. l
..,. .. . . . < . . . = . . .. .
s .. .. . p.- I ' 'cV/ ::. r .
- ;=-t cs v. = . . ,,
92 -
'.C J.~ .
..~ / WAS4E.,R. (TYP) . . .
9I o ..
. . . J - W.'
. s
~
\. .s ,v._ s h, , .d, L ss . . . . . .
f l 1
- E , , - ,m. -t s. , .,.. ,. . .
5M 5 gm g_m-- . . a .. ...1 . JPPOd'i 5 S iEM . .kC/A.i '. ' ' [- .
@g euwwveo ccwun . *~ . '
N E5 N
. 7 i'
-(TYPE M) -
- 7. . . .
Nasos sam. . . .
.. .r. - . C.
C . W.LC t M. . . . * ... ..
. l !. D g i At L.. a a .=.. .. .
*Q Q 3y ,- .
. - ~ . .......
..; =..
*, . .* ., *. . &,==.. .. e .e ~ = _ , :~ ., ,., - Q . . -
.,,v.'..'**
. .i
___-,.;.,..a....
.. p: e. . . .
_-________e . .
..n ,
- o. .. .
e
. . . . ...:... t ... . ... . . - .s.. ..
. . .. . . e
; .., . . m**. ..:. v. ,>.....,. e. M . a.:g. . ,f. .*)2s ..:.. .....t.. ..$, ,.-.._.:-J__f,, .; a.:,:.,- a. . --~
..s.... ,.,..n...-.c. . .. . w ,s ,.. , .
- .1:.,,s.,,.ca,
. . -.
- p* g... z. ..
. . . ,.....p th,f ..*S. r s ";.
. .- .w.g_*- s r.t pt.ga.t.D.,e.f:
.. g ,Wn
. . ..e /..,.-N.,
<8
. . ... m. g::,.r.,Mwg... ,f.v. -3 q A . . w. A.J ,. .. ..n..... . . . p. ..,. n,
- p. 4. s. ...p. .a$. e. .h.cm- . . --+.rhy a
. .. <. ..:.. .w.. , tp;...r : ,.gi,+4
. )(b,r. . . . , . , . . - ...
.. . . s. M,.c.o. ,s .m. . r .,. <<.2 .. .,... . 1.:.: :.s., ;.
- 4. . . . . 2..:.:en ws e- . . :> ;:u.
. e. . . , n: w.m, . :-v : w.. .. q .1 pa3*.9<s0E
% . . ..- : s ....e.. ..e....+... . .w. .
w, . m. . . . . . . 1. M. .%. , . ,
. . . . . , . p.
- . . . . . . . .. . - %.., 1, ,..,,J.
S..r.3r .. . . ,.<f. .. r. , .,..a
- w. +.
. :e. 3 t. ,4,,. %. . %.. A W -* .V. . ,..t zu w . .e . .
. D( ,1,, g 6.y- ., *. f ,, ..
../>
.s . . e.s,.,..
r
. s.f y, ., . . y./.. 3v,if,p.
s :;-e., . ~ \
. : r ..s
... w.w w. .
. .y... *.:.4 1,q' 'ur t.W,,.,,. .u A
m w.c.. . es :.a.w. . .v . .w.. .. .- -- 4:. ., n.r.r.
..s ::.. .:.
.'*y.. ~
i :c.6 ..w . - ..d. ;;. ...: . ' .d. ..u.
.2 .; i .,.g.y. %. .. x:,.4 .r6 .y m.f
.J}}