ML20207E387

Informs That Util Delivered Listed SRT Approved Results Repts to Vs Noonan.Wg Counsil Forwarding Repts & Revised Table of Contents Reflecting Issuance of Repts Encl. Related Correspondence

ML20207E387
Person / Time
Site:	Comanche Peak
Issue date:	12/22/1986
From:	Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
To:	Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel
References
CON-#187-2069 OL, NUDOCS 8701020168
Download: ML20207E387 (2)

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"E ' 'f.*.'v"=".".'" December 22, 1986 L

7, Peter B. Bloch', Esquire Dr. Kenneth A McCollom Chairman -

Administrative Judge Atomic Safety'and Licensing Board .1107 West Knapp

'U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075

• Washington, D.C. 20555 'a Dr. Walter H. Jordan Elizabeth B. Johnson' Administrative Judge Oak Ridge National Laboratory 881 West Outer Drive P.O. Box X,' Building 3500 Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50-445 and 50-446 -O

Dear Administrative Judges:

Applicants have this date delivered to Mr. Vincent S. Noonan the following SRT approved Results Reports:

VII.a.7 Housekeeping and System Cleanliness -Rev. 1 I.b.1 Flexible Conduit to Flexible Conduit Separation -

Rev. 1 1.b.2 Flexible Conduit to Cable Leparation - Rev. 1 861222 0 h h 0500o443 PDR ,h j

to 1

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-:: Administrative Judges-

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December 17, 1986-Page Two y

'These reports should be placed in sequence behind the tab "QA/QC" for VII.a.7 and " Electrical" for I.b.1 and I.b.2 in the results ,

reports binders previously transmitted. Also enclosed is a revised Table of Contents reflecting the issuance of these reports.~ In addition, enclosed is a replacement copy of Results Report V.a. Pages from its attachments were inadvertently omitted in the previous copy.

Respe fully submitted, Robert A. Wooldridg RAW /msi.

Enclosures cc: Service List I 1

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' cont.7A1: LOG NO. TXX-6184 lp FILE N0. 10068 l!< ~

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p TEXAS UTILITIES GENERATING COMPANY

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wiwamo.cou .it December 19, 1986 4

Director-of Nuclear. Reactor Regulation ATTN: Mr. V. S. Noonan', Director

' Comanche Peak Project Division of Licensing

-- U. S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 CPRT RESULTS REPORTS

Dear Mr. Noonan:

We transmit herewith the following SRT approved Results' Reports:

i V II . a'.7 Housekeeping and System Cleanliness, Revision 1

~I.b.1 Flexible Conduit to Flexible Conduit Separation, Revision 1 I.b.2 Flexible Conduit to Cable Separation, Revision 1 These reports should be placed in sequence behind the tabs "QA/QC" for VII.a.7 and " Electrical" for I.b.1 and I.b.2 in the results reports binders previously transmitted. A;so, enclosed is a revised Table of Contents reflecting the issuance of these reports.

The files which contain supporting documentation for these Results Reports have been reproduced in their entirety and are available for public inspection in our Dallas office. Anyone wishing to inspect these files should contact Ms. Susan Palmer (214/979-8242).

In addition, enclosed is a replacement copy of Results Report V.a. Pages from its attachments were inadvertently omitted in the previous copy.

gO A DIVERION OF TEXAB UTELITIES ELECTRIC COMPANY

k. -

y Decembd.r19,198'6i

- Page 2 We'shall'~ issue- further .Results Reports on a pericdic basis as they are approved by the CPRT Senior Review Team.

Very truly yours, k).c;,. Ce '/

W. G. Counsil By: [ .au M N M _

JAin W. Beck Ece President, Nuclear Engineer ing

' WGC:tj Enclosures-s c-w e-p y m-w -ep -=-ee-e+e---ew--wee--q-y--- ,.-.y -

- > - --- -- ~ - - - e--- -. - - -

TABLE OF CONTENTS COLLECTIVE SIGNIFICANCE REPORT Later -

COLLECTIVE EVALUATION REPORTS Later -

RESULTS REPORTS Electrical I.a.3 Butt-Splice Qualification - Revision 1 I.a.4 Agreement Between Drawings and Field Terminations

- Revision 2 I.a.5 NCR's on Vendor Installed Amp Terminal Lugs Revision 1 I b.1 Flexible Conduit to Flexible Conduit Separation

- Revision 1 I.b.2 Flexible Conduit to Cable Separation - Revision 1 I.b.3 Conduit to Cable Tray Separation - Revision 1 Civil / Structural II.b Concrete Compression Strength - Revision 1 Testina III'.a.2 JTG Approval of Test Data - Revision 0 III.a.3 Technical Specification for Deferred Tests

- Revision 0 III.a.4 Traceability of Test Equipment - Revision 0 III.d Preoperational Testing - Revision 1 l

v.f.

i cr . TABLE OF CONTENTS (cont.)

} s

i. _ Mechanical b V.a Inspection for Certain Types of Skewed Welds in NF

[ Supports - Revision 1

,- V.c Design Consideration for Piping Systems Between F Seismic Category I and Non-Seismic Category I Buildings - Revision 1

( V.e Installation of_ Main ~ Steam Pipes - Revision 1 k 0A/0C I.d.2 Guidelines for Administration of QC Inspector Test

- Revision 1

.I.d.3 Craft Personnel, Training - Revi.sion 1 VII.a.4 Audit ' Program and Auditor Qualification -

Revision 1 VII.a.5 Periodic Review of QA Program - Revision 1 VII.a.6 Exit Interviews - Revision 1 VII.a.7 Housekeeping and System Cleanliness - Revision 1 VII.a.8 Fuel Pool Liner Documentation - Revision 1 VII.b.2 Valve Disassembly - Revision 1 DSAPs

- Later -

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~-_

COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: 1.b.1

Title:

Flexible Conduit to Flexible Conduit Separation REVISION 1 1

0 i

$1ssm di1014AL Isdue Coord@ tor // Date '

d_ d et C / M [h eviewTpaLeader Datel /

f. / 2.f/c /f f.

John If Beck, Chairman CPRT-SRT Date

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Rsvision: 1

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Pags' 1 of 37 ,

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,77 .RESULTS REPORT

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• ISAP.1.b.1J l

Flexible-Conduit to Flexible Conduit Separation I+ 1.0(DESCRIPTIONOFISSUEIDENTIFIEDBYNRC(NUREG-0797, Supplement

'_No.17,.page J-42)

"The TRT could find no evidence that an analysis was performed to support the practice that allowed certain. separate safety- and nonsafety-related flexible conduits inside control room panels to j -be in direct contact with each other or to be separated by less

-than~1 inch, as required by Section 5.6.2 of IEEE Standard 384..."

2.0. ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Item 6.'a), (

page J-43)

"TUEC shall' accomplish.the following actions prior to fuel load:

Reinspect all panels at Comanche Peak Steam Electric Station, 2

in addition to those in the main control room for Units 1 and 2 ,that contain (1) redundant safety-related conduits, or (2) safety- and nonsafety-related conduits. TUEC shall either

.7-(') '

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-correct each violation of the separation criteria or

. demonstrate by analysis the acceptability of the conduit as a '

barrier for each case where the minimum separation is not met.

This analysis shal1~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 7

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."

3.0 BACKGROUND

i The main concern expressed by the NRC-TRT-team is that the SERVICAIR flexible metallic conduit

• used in the control room panels has not been shown by analysis to qualify as a barrier **.

Both IEEE 384-1974, "IEEE Trial-Use Standard Criteria for Separation of Class IE Equipment and Circuits," and IEEE 420-1973,

• The flexible conduit used for separation inside the control room panels is SERVICAIR flexible metallic conduit (referred to in this

report as SERVICAIR flex or flex).

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• • As defined in IEEE 384-1974, a barrier is "a device or structure O' interposed between Class IE equipment or circuits and a potential b source of damage to limit damage to Class 1E systems to an

acceptable level."

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RESULTS REPORT

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ISAP I.b.1 (Cont'd) 3.~01 BACKGROUND-(Cont'd)-

"IEEE Trial-Use Guide for Class:1E Control Switchboards for Nuclear l LPower' Generating Stations," recognize metallic' conduit as an acceptable barrier in lieu of a minimum six-inch separation between n ' redundant

• cables. .Since-SERVICAIR flex is a metallic conduit, it

- was judged by 'the Project lto be an acceptable barrier in accordance

with the Standards, and no specific testing and/or analyses was

, considered necessary.

-In the construction of nuclear power plants, it is necessary to.

ensure that isolated-failures of individual safety systems do not

'cause consequential damage to and possible failure of redundant safety systems. In the area of electrical cabling, this assurance historically has been provided by specifying and enforcing

. requirements on the minimum allowable physical separation of

- redundant, safety-class cables or by requiring the use of physical barriers to protect redundant cable trains. The specified

. separation must be maintained throughout the length of each cable.

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IEEE 384-1974, "IEEE Trial-Use Standard Criteria for Separation of Class IE Equipment and Circuits " IEEE 420-1973, "IEEE Trial-Use

,  ! Guide'for Class IE Control Switchboards for Nuclear Power Generating Stations," and Regulatory Guide 1.75, Revision 1

" Physical-Independence of Electric Systems", which are generally  ;

accepted as the documents governing electrical separation 1

. requirements and which are applicable to the CPSES (Comanche Peak i Steam Electric Station) Project, indicate that within electrical J panels and cabinets, " metallic conduit" is an acceptable separation '

. barrier in lieu of physical separation. As a result, rigid l metallic conduit has been recognized by the nuclear industry as an j

acceptable barrier inside electrical panels.

However, there are situations where maintaining sufficient physical separation is difficult or impossible and for which rigid conduit is an unsuitable alternative. Hand switch modules in the CPSES control boards are an example. By design, these modules have redundant cables in close proximity to each other. Additionally, it is required to have slack in the cables attached to these devices to accommodate routine maintenance and adjustment of the l controls. As a result, rigid metallic conduit cannot be used to solve the separation problems associated with these devices.

• All separation requirements in this report are for redundant i cables. The word " redundant" as used herein means that the cables requiring separation belong to different trains, i.e., Class IE train A, Class 1E train B, or non-Class 1E train C.

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<4< Pags. 3 of'37' ,

']. .RESULTS REPORT

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.ISAP I.b.1

.(Cont'd)

I .

13.0EBACKGROUND:(Cont'd) ,

This same situati6n has arisen elsewhere in the nuclear industry

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[and has been:successfully resolved by the. installation of SERVICAIR flexible metallic conduit as a barrier. ' Af ter obtaining IEEE

< .-323-1974 and'IEEE 344-1975 environmental and seismic qualification f data for the SERVICAIR flex and after. discussions with the supplier of the control boards (Reliance Electric Company), TUGC0 issued design change documents at. Comanche Peak specifying the use of L SERVICAIR flex as ' a barrier.

When the Project criteria were modified in November 1979 to specify

. the use of:SERVICAIR flex, its use was limited to the main. control boards. .The use of SERVICAIR flex was expanded in October 1980 to

include all panels' supplied by Reliance Electric Company (procured

under Purchase Order CP-0605 to Specification 2323-MS-605, " Nuclear Safety Related Control Boards"), which include the control room control boards and vertical ventilation panels. In November 1980,

-a Design Change Authorization (DCA) was issued to the Electrical Erection Specification 2323-ES-100 that listed SERVICAIR flex as c(q .-)- metallic conduit, thereby allowing its use as a separation barrier in all electrical panels. For the reasons stated previously TUGC0 undertook no specific effort to qualify this material as a barrier.

The~above facts notwithstanding, the NRC-TRT expressed a concern that SERVICAIR flex used in the CPSES control boards had not been qualified as a barrier through appropriate analysis and/or testing.

This action plan was designed to address the TRT's concern by demonstrating the adequacy of SERVICAIR flex as a barrier.

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objectives of this action plan were 1) to determine, by testing and analyses, the minimum acceptable separation distance between cables of redundant trains, each enclosed

'within SERVICAIR flex and 2) to reinspect all panels which contain redundant cables that could violate the final separation criteria

• for SERVICAIR flex to SERVICAIR flex.

• The final separation criteria (see Table 1) are the separation criteria developed as a result of this action plan. See DCA 21,446 Revision 1, to Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details" and Section 5.4.

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- Pags - 4 of 37 ff -

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.. RESULTS REPORT _

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ISAP I.b.1

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'(Cont'd)

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74.0 [CPRT ACTION PLAN _ (Cont'd)

. , TheLfollowing tasks wer's implemented.to achieve these objectives:

Circuit evaluation and thermal analyses to demonstrate '

the adequacy of SERVICAIR flex as a barrier Testing to' demonstrate the adequacy of SERVICAIR flex '

as a barrier ,

Inspections of cables in the control room control boards and vertical ventilation panels for adequate ,

separation i Procedure / Drawing revisions to incorporate the final separation criteria Examination of panels other than the control boards and vertical ventilation panels for the use of SERVICAIR P ' flex.

b The majority (over ninety percent) of the SERVICAIR flex is located in the control room control boards and vertical ventilation panels. Therefore, the analyses, testing, and inspections described above were based on the circuits and configurations present in these panels. The remaining Unit 1 and common area panels with two or more trains were examined by the Electrical Review Team ta identify the location of all SERVICAIR flex.

4.1.1 Analyses 4.1.1.1 Circuit Evaluation An evaluation of circuits in the control boards and vertical ventilation panels was performed to determine the maximum current available for the control circuits. This information was used to help establish the test conditions for the testing described below. In addition, this circuit evaluation was used to determine those circuits which contain multiple series protective devices and those circuits for which the maximuta

() faulted current is insufficient to result in heat damage to the subject circuits

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'/ y RESULTS REPORT i

- ISAP I.b.1 (Cont'd) f4.0 -CPRT ACTION PLAN.(Cont'd) themselves or adjacent cables. For these

-circuits, less stringent criteria for separation from other redundant circuits may be used. This is allowed per Paragraph 5.6.2 of IEEE 384-1974. The circuit evaluation

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specifically addressed the modular wiring to

~nand switches where the required cable slack creates difficulties in maintaining fixed spatial separation. Other circuits that are ,

in close proximity to the hand switch module wiring were also included in the evaluation.

No specific circuit evaluation was planned for circuits contained in panels other than the control boards and vertical ventilation panels. For those cases where SERVICAIR flex is used in panels outside of those evaluated,

. - the acceptability of SERVICAIR flex as a

.'( )-

barrier requires further evaluation on a case-by-case basis.

J '.

4.1.1.2 Thermal Analyses Thermal analyses, supported by the results of tests described in Section 4.1.2, were performed to determine the adequacy of SERVICAIR flex as a barrier. These analyses were based en the heat transfer characteristics of the cable and SERVICAIR flex and apply to this action plan, " Flexible Conduit to Flexible Conduit Separation," as well as Action Plan I.b.2, " Flexible Conduit to Cable Separation." '

4.1.2 Test Program 4 A two-part test program was conducted to determine the adequacy of the SERVICAIR flex as a barrier.

The first part of the test program was designed to determine the ability of SERVICAIR flex to carry a short circuit current without inflicting damage to cables contained in adjacent or touching SERVICAIR flex. In this test, two flex conduits were placed

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RESULTS REPORT ISAP I.b.1 mi (Cont'd) s

~4.0. J CPRT ACTION PLAN (Cont'd) perpendicular to one another, touching at one point.

One lead from the current source was attached to one SERVICAIR flex;-the other lead to the other SERVICAIR

' flex. Test currents representative of the maximum possible fault currents from the control boards' and

' vertical ventilation panels' power supplies were applied during the tests. The test current flowed along one flex,'across the point of contact, and then along the second flex (both flex conduits were isolated from ground). A cable was inserted in one of the flex

^

conduits to serve as a " target" cable to enable monitoring of_any damage incurred _by cables contained

, in SERVICAIR flex due to the current in the flex.

The second part of the test program was designed to determine the ability of the SERVICAIR flex to act as an effective, thermal barrier between a cable (within

'yy SERVICAIR flex) experiencing an overload condition and t ,) a redundant cable either exposed and one inch away or contained within an adjacent SERVICAIR flex. For this test a source cable was placed inside a one-inch SERVICAIR flex and subjected to several different currents. A target cable was placed inside a 5/8-inch SERVICAIR flex which was in contact with the one-inch SERVICAIR flex; a second exposed target cable was placed one inch above the one-inch flex. Surface temperatures of the two pieces of flex and the exposed target cable were monitored throughout the test, as well as the temperatures of the faulted conductors.

The test procedures were written and tests conducted such that tha test results are applicable to the control room control boards and vertical ventilation panels. The procedures for the test program were prepared by the Third-Party Adviser, in conjunction with Gibbs & Hill, and approved by the Electrical Review Team Leader prior to implementation of the test program.

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_Ravision: 1 Pago 7 of 37 ,

RESULTS REPORT

%) .

ISAP I.b.1 Y

(Cont'd)

4.0 CPRT ACTION PLAN (Cont'd) x.

4

.- 4.1. 3 Investigations / Inspections y

4.1.3.1 Preliminary Investigations

~

Concurrent with the above testing and

. analysis program, an inspection of the Unit I control boards and vertical ventilation panels was performed to determine the extent

.to which SERVICAIR flex was used ks a barrier.

Separation guidelines ba.td on preliminary, conservative separation distances were provided by Gibbs & Hill for review and approval by the Electrical Review Team i 'F Leader. Third-party inspectors inspected the control boards and vertical ventilation

w. panels using these guidelines to determine

-() the extent of potential modifications required for compliance with the final separation criteria.- In addition, this investigation provided input as to the types of cable insulation used in the control boards and vertical ventilation panels. This '

information, in turn, was used to determine l the scope of the testing and to identify

-additional circuits that should be included ,

in the circuit evaluation described above.

l These inspections involved all aspects of )

cable separation, including the issues i addressed in Action Plan I.b.2, " Flexible Conduit to Cable Separation," and Action Plan I.b.4, " Missing Barriers."

The intent was to compare the CPRT third-party inspection findings against the final separation criteria. Those third-party findings that did not meet th e final separation criteria were to be reported on Nonconformance Reports (NCRs).

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, s RESULTS REPORT

?( '- J3 o ., .ISAP I.b.1, 4

(Cont'd) r-4.0 ' CPRT ACTION PLAN'- (Cont'd)

'4.1.3.2 ~ 'TUGC0 Inspections Prior to issuing NCRs'for the findings identified by the CPRT third-party, TUGC0 validated the findings,'using the final separation criteria. For those findings which clearly violated the final separation criteria, NCRs were issued. Another group of

-findings were acceptable when compared to.the final separation criteria, since some of the

~ attributes of the final separation criteria were less stringent than those used by the ,

CPRT third-party. For other findings where l the minimum separation distance was reduced l by the final criteria, it was difficult to ,

determine from the third-party reports if the less stringent, final criteria were met, I

.since the actual separation distances had not

-[-<'1 been recorded.  ;

l l

To resolve this issue, the Electrical Review Team Leader initiated, through the TUGC0 Coordinator, an inspection of all third-party findings that did not clearly violate the final separation criteria, l

Since the final separation criteria had changed to be more restrictive than the previous Project criteria, it was decided that a reinspection of the panels for those g-separation attributes that were revised to be more restrictive be performed concurrently with the above validation of the CPRT third-party findings. This inspection would i provide the inspection of record for the control boards and vertical ventilation l panels.

4.1.3.3 Third-party overview 1

In addition to the above TUGC0 inspection, there will be a post-construction inspection j . performed by TUGC0 after all rework resulting from outstanding Nonconformance Reports for

O Action Plans I.b.2 and I.b.4 has been

! completed. CPRT third-party personnel will 4

overview this final inspection.

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s' Revision: 1 Page 9 of 37 .

RESULTS REPORT ISAP I.b.1 (Cont'd) r '. '

4.0 CPRT ACTION PLAN (Cont'd) i

, g i s-4.1.4 Revisions Procedure / Drawing \

f Based on the resUitsl ofat.he above analyses and se esting, TUGC0 revised Drawing 2323-El-1702-02, " Cable and Raceway Separat, ion Typical Details" to ' reflect the final separation criteria. This drawing provides the separation criteria used by the Project.

The applicable QC inspection procedures were also revised to reflect the prpper documents that specify the final separation cr$teria. '

These document changes were reviewed by the Electrical Review Team Leader, as discussed in Section 5.6.

4.1.5 Examination of Other Panels for SERVICAIR Flex A 100% examination of all panels in Unit I and common 0 areas containing two or more trains was performed by the CPRT Electrical Review Team to determine where SERVICAIR flex was used outside the-control room control boards and vertical'ventilaiion panels. Since this action plan addresses the use, % SERVICAIR flex in the control boards and vertical ventilation panels only, the acceptability of S,ERVICAIR flex as a barrier in other panels requires further evaluation on a case-by-case basis by TUCCO. The CPRT third-party overviewed this evaluation for enose cases where flex =

was fouad in panels other than the control boards and vertical ventilation panels.

i 4.1.6 Use of Results For Unit I and common are'ap,,if any ' deviations from the final separation criteria were roced during the '

third-party and TUGC0 inspectiona, they' yould have been identified and dispositioned on Nonconformance Reports, and rework perforued as required. In addition, NCRs were issued for all cases where SERVICAIR flex was used outside the control boards and vertical ventilation panels. For Unit 2, installation proceduras and QC inspection procedures have been or are being revised to ensure that personnel are aware of the' required separation criteria. This, in turn, will result la panel ccafigurations that meet the specified requireme.nts. ,

Revision: 1 Page 10 of 37 .

RESULTS REPORT ISAP I.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective work scope.

4.2.1 TUGC0 Comanche Peak Project '

4.2.1.1 Revised QC inspection precedures and will '

revise craft procedure to include new criteria resulting from tests and analyses.

Will retrain craft and inspection personnel to the new criteria.

4.2.1.2 Revised Dtaving 2323-El-1702-02, " Cable and Raceway Separation Typical Details", and -'

other related documents, to reflect the final separation criteria.

() 4.2.1.3 Performed reinspections for the Unft I control room control boards and vertical ~ '

ventilation panels for those final separation attributes which have been revised to be more restrictive as a result of this action plan.

4.2.1.4 Processed NCRs that were generated in -

connection with this action plan.

4.2.1.5 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed the analyses, circuit evaluation, .

test results and revised QC inspection procedures Will review revised craft procedure. ..

4.2.2.2 Ccmpleted 100% examination of all panels with two or more trains to identify cases where SERVICAIR flex is used outside the control room control boards and vertical ventilation . .

panels.

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d Revision: 1 5 Page 11 of 37 ,

2 RESCLTS REPORT O m IS AF 7.b. I E (Cont'd) ]

b 4.0 CPRT ACTION YLAN (Cont'd) _I t

4.2.2.3 Reviewed the inspection reports and NCF, j generated as a result of this action p1in. J 4.2.2.4 Reviewed and approved the test proced,res and 1 _

test report. E L

4.2.2.5 Reviewed changes te Drawing 2323- El-1702-02, 3

" Cable and Raceway Separation Typical i Details", and other related documents, which "

reflect the final separation criteria. 1 4.2.2.6 Reviewed documentation of training of TUGC0 -

Proj ect inspectors to final separation E criteria '

e 4.2.2.7 Will overview ths WGC0 post-construction k inspection of the Unit I control room control boards and vertical ventilation panels.

Q -

O 4.2.2.8 Deteru.ined root cause, generic implications j

and safety significance, as required. m 9

4.2.2.9 Personnel (prior to October 18, 1985)

-i Mr. M. B. Jones, Jr. Review Team Leader q Mr. E. P. Stroupe

?

Iseue Coordinator

]

4.2.2.10 Personnel (starting October 18, 1985)

Mr. J. J. Mallanda Review Team Leader I E

Mr. R. J. Bizzak issue Coordinator $

E Mr. M. B. Jones, Jr. Third-Party Adviser $

Mr. E. P. Stroupe Third-Party Adviser 4.2.3 CFRT - QA/QC Review Team -

4.2.3.1 Inspected Unit I control room control boards j and vertical ventilation panels which have B SERVICAIR flex for compliance to separation 5 guideliner (see Section 4.2.5.4).

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RESULTS REPORT

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'n ISAP I.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3.2 Will perform overview inspection (see Section 4.2.2.7) as determined by the Electrical Review Team.

L 4.2.3.2 Personnel Mr. J. L. Hansel Review Team Leader 4.2.4 Third-Party Adviser 4.2.4.1 Prepared test procedures.

4.2.4.2 Supervisad the tests.

4.2.4.3 Issuad a report of the test results.

4.2.4.4 Reviewed the circuit evaluation, as required.

() 4.2.4.5 Personnel Mr. L. D. Bates Third-Party Adviser 4.2.5 Gibbs & Hill 4.2.5.1 Performed circuit evaluation and thermal analyses.

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4.2.5.2 Assisted in preparation of the test procedures.

4.2.5.3 Reviewed and approved the test report.

4.2.5.4 Prepared separation guidelines for CPRT third-party inspectors.

+

4.2.5.5 Prepared final Project separation criteria.

4.2.5.6 Assisted in tha QC inspections, as required.

, 4.2.5.7 Assisted in the processing of NCRs that were generated in connection with this action plan.

4.2.5.8 Personnel (v~')

e Mr. S. P. Martinovich Principal Electrical Engineer

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Page 13 of 37

) RESULTS REPORT v .

ISAP I.b.1 (Cont'd) c 4.0 CPRT ACTION PLAN (Cont'd)~

' s-t 4.3 Qualification of Personnel Where inspections required the use of certified inspectors, qualification at the appropriate level was to the requirements

-of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants." CPRT third-party inspectors were certified to the requirements of the third-party employer's Quality Assurance program, and specifically trained to the CPRT Program Plan.

a Where tests required the use of certified test personnel,

,i qualification at the appropriate level to the requirements of 4

. . , _ ANSI N45.2,6 and Regulatory Guide 1.58 was not met. These

- 'I requirements were not part of the CPRT Program Plan at the time of testing. However, the qualificatiera of the individual supervising the tests were considered by the Review Team Leader to be more than sufficient to render the tests k valid.

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Third-party participants in the implementation of this action plan me*. the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. CPRT activities performad by other than third-party personnel were governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures The'following CPRT procedures were developed in support of this Action Plan:

4.4.1 Procedure I.b.1-001, " Cable /SERVICAIR Heat Transfer Test".

4.4.2 Procedure I.b.1-002, "SERVICAIR Short Circuit Test" 4.4.3 Instruction QI-004, "CPRT Action Item I.b.1 - Flexible Conduit to Flexible Conduit Separation; CPRT Action i Item I.b.2 Flexible Conduit to Cable Separation".

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RESULTS REPORT l

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ISAP 1.b.1 (Cont'd)-

4.0 CPRT ACTION PLAN (Cont'd) 4.~ 5 Acceptance Criteria 4.5.1 The acceptance criterion for the tests and analyses was that SERVICAIR flex be shown to be a barrier which provides adequate protection at the minimum (or less) separation allowed by IEEE 384-1974, IEEE 420-1973 and Regulatory Guide 1.75, Revision 1 January 1975.

4.5.2 The acceptance criterion for the as-installed condition "is that the SERVICAIR flex meets the final separation criteria (see Section 4.2.5.5).

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4.6 Decision criteria If the tests and analyses results did not qualify SERVICAIR

- flex as a barrier, qualified barriers were to be installed or 6" separation provided and the applicable documents revised to indicate the revised minimum separation for SERVICAIR flex.

.5.0 DISCUSSION OF RESULTS A chronology of the major activities discussed in this Results Report-is provided in Attachment 1.

5.1- Summary The first objective of this action plan was to determine through testing and analyses the minimum acceptable separation distance between cables of redundant trains, each enclosed ,

within SERVICAIR flex. Since SERVICAIR flex was used mainly in the control room control boards and vertical ventilation panels, the program described below was based on the circuits in those panels.

The first step was a circuit evaluation to determine the maximum credible overload or short circuit current that should be used in the subsequent testing. In addition, various circuits were evaluated to determine if they could be shown not to cause damage to adjacent cables either because they were incapable of carrying high currents or because they contained multiple protective devices in series.

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RESULTS REPORT a v! -

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ISAP I.b.1 ji (Cont'd)

- 5.0 < DISCUSSION OF RESULTS (Cont'd)

An investigation of the cables' in the control boards and vertical ventilation panels was then undertaken using preliminary. conservative-separation guidelines. This ,

investigation provided an assessment of the extent to which -

SERVICAIR flex was used as a barrier. Furthermore, the investigation provided data on the type of cable insulation used, i.e., Tefzel* versus non-Tefzel.- Internal wiring by -

Reliance Electric is all Tefsel-insulated; field wiring to the terminal blocks in the back of the panels is mostly non-Tefzel. The' field investigation provided preliminary '

confirmation that the majority of the areas where separation could be a problem involved only Tefzel cable. Therefore, the t

, testing that was performed during the same time frame as these investigations was limited to Tefzel cables. Those circuits that most cormonly used non-Tefzel cables were assessed relative to the circuit evaluation that had already been performed and' additional evaluations were performed to justify less stringent minimum separation distances for these additional circuits.

A two-part test program was conducted to determine the adequacy of SERVICAIR flex as a barrier for Tefzel cables.

The first test was designed to determine the ability of SERVICAIR flex to carry a short circuit current without inflicting damage.to cables contained in adjacent or touching SERVICAIR flex, even if the short circuit current passed from the SERVICAIR flex containing the faulted circuit to the SERVICAIR flex in contact with it. The second test was designed to determine the ability of SERVICAIR flex to act as *

.an effective thermal barrier between an overloaded circuit contained in the SERVICAIR flex and either a redundant cable contained in SERVICAIR flex touching the first piece of flex or an exposed cable one inch away. The case of an exposed cable one inch from a flex containing a faulted circuit was performed in support of Action Plan I.b.2.

Subsequent to the testing program, parametric computer analyses were performed to determine the effectiveness of SERVICAIR flex as a thermal barrier for a range of configurations. Parameters such as current level, flex size, flex length, and flex orientation were examined to determine the effect that these parameters would have on the maximum flex surface temperature.

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• Tefsel is DuPont's registered trademark for fluoropolymers used for, among other things, conductor insulation and cable jacketing.

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/~N- RESULTS REPORT Q ); .

'ISAP 1.b.1 O.

(Cont'd)

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5.0 DISCUSSION OF RESULTS (Cont'd) i The second objective of this action plan was to reinspect all

. electrical panels which contain redundant cables in SERVICAIR flex thatfcould violate the final separation criteria. The CPRT third-party identified nonconforming conditions involving separation of SERVICAIR flex to SERVICAIR flex in the control

, boards and vertical' ventilation panels based on the preliminary, conservative separation guidelines developed by

'Gibbs & Hill. When the. final. separation criteria were

, developed. TUGC0 QC. inspectors performed a validation of the CPRT third-party findings and a reinspection of these panels

-to the. final separation criteria.

l For panels other than the control boards and vertical l ventilation panels, the CPRT Electrical Review Team performed an examination of all multi-train electrical panels to determine where else SERVICAIR flex was used. Since the

, testing and analyses that were performed to show that SERVICAIR flex is a barrier were based on the circuits present

() in the control boards and vertical ventilation panels, the use of SERVICAIR. flex in other panels would require further j evaluation on a case-by-case basis to demonstrate the '

acceptability of SERVICAIR flex as a barrier.

. 5.2 Testing A two-part test program was undertaken to determine the adequacy of SERVICAIR flex as a barrier when Tefzel cables contained therein are subjected to electrically-initiated failures.

The first part of the test program was designed to determine the adequacy of the SERVICAIR flex to provide a path for short circuit current without causing damage to cables in an adjacent er touching flex. The circuit in the test set-up consisted of two pieces of flex in contact with each other, crossing at approximately 90 degrees. A target Tefsel-insulated cable was inserted in one of the two pieces of flex. One lead from the current source was attached to one SERVICAIR flex; the other lead was attached to the other

. SERVICAIR flex. The flex conduits were isolated from ground, which resulted in the current passing from one flex to the other at the point of contact. The circuit breaker test set used to supply current for these tests was preset to deliver a 2000 amperes DC current when applied to a single piece of flex. Using this machine setting, current was applied to the test circuit three times with a 30-ampere fuse in the circuit l

Revision: 1 Page 17 of 37

• A ,

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RESULTS REPORT

'ISAP I.b.1 (Cont'd)

'5.0 -DISCUSSION OF RESULTS (Cont'd)

'and three times without a fuse. The most severe cases were those run without a fuse. During the first such case without a fuse, the circuit breaker test set was preset to trip y

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automatically. For-the last_two cases without a fuse, the current was manually interrupted shortly after two seconds, which is much longer than the time normally required for a fuse or circuit breaker to open. The test current for the case of automatic machine interruption was 1560 amperes; the maximum test current for the cases involving manual interruption was 1102 amperes. It should be noted that although the test equipment was set to deliver 2000 amperes through a single piece of flex, the current in the test passed from one flex to the other (both ungrounded) and the additional resistance due to the contact point between the two pieces of flex reduced.the current. Nonetheless, the test currents were representative of the maximum fault currents that can' be postulated to occur in the control boards and vertical ventilation panels.

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The only cases that resulted.in any damage during these tests were those where the test currents were applied to the two pieces of flex without a fuse in the test circuit and without automatic machine interruption. The outer bronze braids covering the steel bodies of the flex conduits became welded together'at the contact point. Nonetheless, there was no damage to the steel body of either SERVICAIR flex. The cable inside the smaller 5/8-inch flex was not damaged. This was verified by post-test visual examination of the cable jacket for signs of Tefzel melting. In addition, megger testing of the cable did not indicate any damage to the cable.

As a result of these tests it was concluded that SERVICAIR flex could carry currents representat'ive of the maximum fault currents expected at the control boards and vertical ventilation panels without imposing damage to Tefzel cables in an adjacent touching flex even if the fault current were to flow through both of the touching flex conduits.

The second part of the test program investigated the heat transfer characteristics of SERVICAIR flex. The test setup included a source cable inside a one-inch SERVICAIR flex. A target cable was placed inside a S/8-inch SERVICAIR flex in contact with the one-inch flex. An exposed target cable was

( )' placed one inch above the one-inch flex. As current was applied to a circuit enclosed within the one-inch diameter SERVICAIR flex, the temperatures of the copper conductors and i.

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?I~'h RESULTS REPORT

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ISAP I.b.1 (Cont'd) '

5.0- DISCUSSION OF RESULTS (Cont'd) 31 the outside surfaces of the two. pieces of-flex were monitored, as well as the air temperature one-quarter inch,above the flex and the temperature of the exposed' conductor one inch above

the flex. __ Current levels were varied from fifteen to forty amperes per energized conductor (four conductors were energized co represent the worst case of concurrent faulting cof two circuits within the same flex feeding a single piece of equipment). The upper-bound current of forty amperes was selected sinet the circuits involved are protected by circuit protection devices (i.e., fuses or circuit breakers) rated at 30 amperes or less; fuses are used exclusively for protection above 20 amperes. Per UL Standard 198B, a current of 135 percent of the fuse rating will open the circuit within one hour. .Therefore, the maximum substained current for these circuits in the control boards is less than 40.5 amperes.

4U ~The results of this testing showed that the Tefzel insulation melted only during the forty ampere case, during which the

f")y

(, energized conductors reached a maximum temperature of 350*C.

Even then, the maximum surface temperature of the flex containing the overloaded circuits was only 149'C. The maximum measured temperature of the flex in contact with the flex containing the overloaded circuits was 84'C. Even though the temperature of the flex containing the target cable was not measured at the contact point, this decrease in temperature demonstrates the rapid atttauation of temperature with distance from the faulted circuits. As discussed in Section 5.3.1, these temperatures were shown to be acceptable.

5.3 Analyses -

5.3.1 Thermal (Post-Test) Analyses for Tefzel Cables Subsequent to the completion of the heat transfer tests, computer analyses were performed in which several of the test parameters were varied, such as current level, flex size, flex length, and flex orientation. This parametric study was performed to determine the maximum flex surface temperature due to a faulted circuit within the flex and also to provide quantitative answers to the following questions:

If the protection device malfunctioned, would a current higher than 40 amperes give a

'( ]) higher transient flex surface temperature prior to insulation melting than was experienced in the 40 ampere test case?

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• RESULTS REPORT

[ ;%)F ' -

, . .ISAP I.b.1 (Cont'd)

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5.0;. DISCUSSION OF RESULTS (Cont'd)

Since the melting of'the Tefzel insulation

'during the test significantly reduced the temperature of the copper conductors, and

'hence the temperature of the SERVICAIR flex,

'would the flex temperature be higher at the t current level corresponding to the point just prior to gross melting of the insulation?

How do the.results apply to the other sizes of SERVICAIR flex used at Comanche Peak (i.e., 5/8-inch-diameter flex and 2-inch-diameter flex)?

How does the orientation of the flex affect

, the results? The testing was done for a horizontal piece of flex. A vertical flex

_ would have a lower convective film

,f"sp coefficient, and, therefore, could have a os _/: ,

higher surface temperature.

What effect does the length of SERVICAIR flex have on the maximum temperature?

The initial step in the computer analyses was to develop a model and analyze it at the same current levels used in the testing program. The time history

-temperatures from the computer analyses and the tests were compared and refinements were made to the computer model until the computer results were validated by the test results. The computer model for a one-inch flex uns then used to analyze six different current levels ranging from thirty-two and one-half amperes to sixty l amperes. 'The steady-state flex temperatures were found '

for those current levels which result in conductor r

temperatures lower than that at which gross melting of  ;

the Tefzel insulation occurs, i.e. 350*C*. For those current levels which resulted in the temperature of the energized conductors exceeding 350*C, the analyses were terminated when the conductors reached 350*C. The tests demonstrated that at this temperature the i

• Although the manufacturer's stated melting point of Tefzel insulation is 270*C, a conductor temperature higher than 270*C is required to raise the outer surface of the cable jacket to 270*C.

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RESULTS REPORT ISAP I.b.1 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd) g a

insulation experienced gross melting. The results of I~

these analyses provided answers to the first two questions. The maximum flex surface temperature occurs between 30 and 40 amperes, at the current level that results in a steady-state conductor temperature of 350*C. This is the temperature at which gross melting -.

of the Tefzel insulation occurs. (pg 1

Analyses were then performed for a vertical, 5/8-inch y flex, which is the worst case by virtue of the smallest 3 convective surface area and smallest natural convective film coefficient. In addition, no axial heat flow was "h modelled, which corresponds to an infinite length of N flex. The results of this analysis gave a maximum flex 1 .

surface temperature of 211*C at 29 amperes. - -

In lieu of data regarding the temperature of a cable in m an adjacent SERVICAIR flex, the unfaulted cable protected by flex was assumed to be at the same temperature as the surface of the flex containing the faulted circuits. This i, a cons e.rvative approach.

The flex temperature of 211*C is Jess than the melting point of Tefzel insulation (270*C). Nonetheless, further study was performed to ensure that the cable would not be degraded due to the elevated temperature.

The manufacturer provides data that Tefzel has a qualified life of 1500-2000 hours at 205'C. This allows approximately two months for the operator to detect and correct the malfunction resulting in th(

overloaded circuit before the Tefzel qualified life is .

expended. The following points also provide assurance -

that a faulted circuit in SERVICAIR flex will not __

result in damage to a cable in an adjacent flex:

1) The temperature of 211*C is for the su-f ace of the flex containing the faulted circuits.

The temperature of the flex touching the flex with the faulted circuits would be lower and "

the unfaulted cable temperature within the flex would be even lower.

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ISAP I.b.1 'l (Cont'd) l 5.0MDISCUSSION OF RESULTS (Cont'd)

2) These analyses assume that the overload current will not be interrupted by protective

. devices.: _In reality, the majority of the

. instrumentation and control circuits in the

" A control boards and vertical ventilation panels contain protective devices rated at 20 amperes or less. The 20-ampere protective devices would open the circuit at a current of 29 amperes within one hour. Protective devices rated below 20 amperes would open the circuit at-a current of 29 amperes even faster. The remaining instrumentation and

>J control circuits are protected by fuses rated at 30 amperes. An evaluation of these circuits has shown either that components in the circuit other than the protective devices, such as the switchgear trip and

,i close coils, would interrupt a 30-ampere

. ( )p' current within one hour or that the circuit current would be limited to low current levels by the resistors in series with the light circuits.

3) The tests and analyses assumed that four conductors carried the faulted current, i.e.

two complete circuits are assumed to malfunction simultaneously. If a single circuit were to fail, the current level required to raise the flex temperature over 205'C is above 40 amperes. At this current level, fuses, which are the only 30-ampere protective devices used, would open the circuit within one hour.

The conclusion drawn from the testing and analyses is that, for the control and instrumentation circuits in the control boards and vertical ventilation panels, SERVICAIR flex containing a faulted, Tefzel insulated cable will not cause damage to Tefzel cable in another SERVICAIR flex, even if the two pieces of flex are in contact with one another. Therefore, it was concluded that SERVICAIR flex meets the IEEE 384-1974 definition of a barrier when both cables are Tefzel-insulated.

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RESULTS REPORT.

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ISAP I.b.1

.-d (Cont'd)

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, 5.0i DISCUSSION OF RESULTS (Cont'd) s 5.3.2. Circuit Evaluation for Non-Tefzel Cables

.c . Concurrent with the testing. program, an evaluation of

.the' control board and vertical ventilation panel

, . circuits was performed by Gibbs & Hill. This V . evaluation addressed the modular wiring to hand switches as well as other circuits in close proximity

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'to the hand switch wiring. The objective of this evaluation was to determine the maximum current available to the circuits. This information was used to help establish the test conditions for the testing discussed above.- Also, from this evaluation, it was determined that six categories of non-Tefzel cables ywere adequately protected by multiple protective

^

devices in. series or that the maximum faulted current was insufficient to result.in heat damage to the subject cables or adjacent cables. These six pag categories are:

' V 7 1) Annunciator lampbox cables,

$ 2) Safety System Inoperable Indication (SSII) lampbox and field input logic cables,

3) Power cords from receptacle strips on control wireways to devices such as instrument recorders, l

4) Sound-powered telephotte cables,

5) Cosalal video CRT cables, and

6) Fire detection cables.

An evaluation of the annunciator (category 1), SSII

_ (category 2), and the power cords from receptacle strips (category 3) demonstrated that a single failure of protective devices these circuits would not result in sufficient energy to compromise the integrity of adjacent safety-related wiring or devices. The circuit evaluation determined that the sound-powered (category 4) and coaxial CRT (category 5) circuits, l which cperate at voice and video signal levels, ,

, respectively, pose no inherent hazards. Fire detection 1 (category 6) cables comprise 24V de, ungrounded supervised circuits having a 13.1K-ohm series resistor 1

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[f"t , -RESULTS REPORT

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ISAP.I b.1

g -(Cont'd) 5.0[DISCUSSIONOFRESULTS'(Cont'd)

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in the loop that limits the maximum fault current to (very reall values. Ground detection is also provided for the control room fire detectors. Therefore, the separation criteria for Tefzel-insulated cables can be used for these six categories of cables.

This circuit evaluation did not include the 120-volt AC lighting and convenience receptacle wiring. This wiring is considered to be " power" wiring. The '

separation criteria for the lighting and convenience receptacle wiring were revised to reflect the fact that

- it is to be considered more stringently than control and instrumentation wiring. Thus, the criteria state that SERVICAIR flex is not to be used as a barrier for the 120-volt AC lighting and convenience receptacle wiring. Additional evaluation on a case-by-case basis would be required to demonstrate the acceptability of "D

SERVICAIR flex as a barrier for these cables.

5.4 Final Separation Criteria The final separation criteria within electrical panels for redundant control and instrumentation cables, each enclosed in SERVICAIR flex, are given in Detail 61G of DCA 21446, Revision

1. to Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details." The final separation criteria allow two pieces of flex to touch when each cable is either Tefzel or is a circuit in one of the six categories of non-Tefzel cables discussed in Section 5.3.2. Furtheruore, two pieces of SERVICAIR flex containing redundant cables may touch when one of the cables is a non-Tefzel Class IE cable, provided that the other cable is a non-Class 1E cable which is either

.Tefzel-insulated or non-Tefzel but power-limited (cables discussed in Section 5.3.2). This is a logical extension of the interpret ation of the separation criteria, which is only

, to protect Class LE circuits. For all other cables, which were neither tested nor analyzed due to their limited use, a minimum one-inch separation is required, i.e., the separation given in IEEE 384-1974 (Paragraph 5.1.4) for redundant enclosed raceways in general plant areas. These criteria are summarized in Table 1 of this report.

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. RESULTS REPORT Y] -

ISAP 1.b.1 (Cont'd) 5.0 DISCUSSION OF RESULTS-(Cont'd) 5.5 -Investigations / Inspections / Examinations The second objective of this action plan was to reinspect all s panels which contain redundant cables that could violate the final separation criteria for SERVICAIR flex to SERVICAIR flex. This program involved three distinct activities:

1) Preliminary third-party investigations of the control boards and vertical ventilation panels using preliminary, conservative separation guidelines,

2) Reinspection of the control boards and vertical ventilation panels by TUGC0 to the final separation criteria, and

3) A third-party examination of multi-train panels to identify all other uses of SERVICAIR flex.

(i 5.5.1 Preliminary Investigations

~LJ Prior to the completion of the testing and analyses described above, a CPRT third-party inspection of the Unit 1 control boards and vertical ventilation panels was performed. Since the majority of SERVICAIR flex is located in the control room control boards and vertical ventilation panels, the third-party QC inspections were limited to these panels. This inspection provided an assessment of the extent to which SERV 1CAIR flex was used as a barrier. In addition, this investigation was used to determine which additional circuits should be included in the circuit evaluation.

It should be noted that conservative separation guidelines, specified by Gibbs & Hill and approved by the Electrical Review Team Leader, were used in this investigation. As such, they were more restrictive l than the final separation criteria. Using these more  ;

restrictive guidelines ensured that all deviations to the final separation criteria that might exist would be ,

discovered. This was intended to minimize the need for  !

any subsequent inspections. l I

Based on these more restrictive inspection guidelines, the third-party inspectors identified 34 instances of O SERVICAIR flex to SERVICAIR flex separation findings.

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(Cont'd)

Y -5.0 < DISCUSSION OF RESULTS (Cont'd)

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.5.5.2 TUGC0 Inspections Prior to issuing NCRs for the findings identified by s ,:- - the_ CPRT third-party, TUGC0 validated the findings, using the final. separation criteria. For those findings which clearly violated the final separation criteria, NCRs were issued. Another group of findings were acceptable when compared to tha final separation criteria, since some of the attributes of the final

, separation criteria were less stringent than those used by the CPRT third-party. For other findings where the .

minimum separation distance was reduced by the final I criteria, it was' difficult to determine from the third-party reports if the less stringent, final j criteria were met, since the actual separation '

distances had not been recorded.

2 1 To resolve this issue, the Electrical Review Team l

- [t Leader initiated, through the TUGC0 Coordinator, an l b-/ ' -inspection of all third-party findings that did not i clearly violate the final separation criteria. j Since the final separation criteria had changed to be  !

more restrictive than the original separation criteria *, it was decided that a reinspection of the panels be performed concurrently with the above i

+

validation of the CPRT third-party findings. Only ,

those separation attributes that were revised to be '

more restrictive were inspected. For example, the final criteria require a one-inch separation between l

two pieces of flex when one flex contains certain '

non-analyzed, non-Tefzel cables; the original criteria j allowed the two pieces of flex to touch. This l inspection provided the inspection of record for the control boards and vertical ventilation panels.

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• . The original separation criteria are defined as the criteria in existence prior to this action plan, i. e., Detail 61 of Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details",

Revision 2, not including any outstanding Design Change Authorizations (DCAs).

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ISAF I.b.1 (Cont'd) 1 5.0 DISCUSSION OF RESULTS (Cont'd) 4 3 The TUGC0 QC inspection did not identify any additional

. violations of SERVICAIR flex to SERVICAIR flex.

The original 34 findings identified by the CPRT third-party inspectors were compared to the final separation criteria. Twenty-three.cf these findings involved Tefzel-to-Tefzel cables; ten involved Tefsel-to-non-Tefzel cables from the analyzed categories noted in Section 5.3.2, and one finding involved a non-Class 1E, non-Tefsel cable from the analyzed categories and a non-Tefsel Class 1E cable.

All of the above findings have been compared to the final separation criteria developed as a result of this Action Plan and have been found acceptable. In

, addition, all of the above findings are in compliance with the original separation criteria.

jc As noted abov'e, there were no violations of the final

.( )_ separation criteria for SERVICAIR flex to SERVICAIR flex. However, in control board CPI-ECPRCB-04, TUGC0 QC~ inspectors noted that two pieces of flex were in contact due to a loose bracket (this finding was also noted in the third-party inspection reports). However, the discrepancy was the loose bracket; the flexes in contact with each other did not represent a deviation since they-are allowed to touch by the final separation criteria. An NCR has been issued for the nonconforming condition of a loose bracket. The Electrical Review Team has reviewed the findings from both the third-party inspection and the TUGC0 inspection and concurs with these conclusions.

TUGC0 is currently performing rework in the control room con 4 rol boards and vertical ventilation panels to resolve the outstanding Nonconformance Reports issued as a result of deviations related to Action Plans I.b.2 and I.b.4. When this work is complete, a post-construction inspection will be performed by TUGC0 QC inspectors and overviewed by CPRT third-party personnel.

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() RESULTS REPORT ISAP I.b.1 -

(Cont'd) 5.0 DISCUSSION OF RESULTS (Cont 'd) ,

5.5.3 Third-Party Examination of Additional Multi-Train Panels The Electrical Review Team requested that TUGC0 identify all other panels outside the control room control boards and vertical ventilation panels that contain SERVICAIR flex. TUGC0 examined panels purchased to Specification MS-605, which bounds the panels authorized to contain flex per DCA-8830 to '

Electrical Erection Specification 2323-ES-100. TUCCO provided a list of six additional panels that contain SERVICAIR flex. (It was subsequently determined that DCA-9086 to ths same specification defines SERVICAIR flex as an acceptable metallic barrier and does not limit its use to any particular type of panel.)

Subsequent to this response, the action plan was revised to require the CPRT Electrical Review Team to O.

examine all Unit I and common area electrical panels with two or more trains to identify any additional uses of SERVICAIR flex. Panels other than multi-train panels were not examined since a panel that contains only one train does not require electrical separation; therefore, SERVICAIR flex would not have been used as a barrier.

The first step of this examination process was to -

generate a list of electrical panels with two or more trains. To determine this, all Unit I and common electrical panel connection drawings and one-line diagrams were reviewed by the CPRT third-party. This review showed that there are no more than 115 electrical panels with multiple trains, including the thirteen control room control boards and vertical ventilation panels. During subsequent investigations it was determined that some of these panels contained cables exempt from separation requirements, some panels had been removed, some panels were not multi-train panels, etc. The r.'imber of multiple train panels requiring cable separation was ultimately reduced from 115 to 88. The CPRT Electrical Review Team examined the panels and found three that contained SERVICAIR flex in addition to the six identified by TUGCO.

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'O h RESULTS' REPORT ISAP I.b.1 (Cont'd) 5.0'. DISCUSSION OF.RESULTS (Cont'd)

, For all instances where SERVICAIR flex was used outside the control room control boards and vertical ventilation panels, Nonconformance Reports were written. Since'the analyses and testing performed for SERVICAIR flex are applicable only to the control room control boards and vertical ventilation panels, the acceptability of SERVICAIR flex as a barrier elsewhere requires further evaluation by TUGC0 on a case-by-case basis..

The CPRT Electrical Review Team reviewed and concurred with the disposition of the NCRs issued for SERVICAIR flex in panels other than the control boards and vertical ventilation panels.

- 5.6 Procedure / Drawing Revisions -

<s The primary document detailing separation requirements between ls-); redundant cables used by the Project is Drawing 4 2323-El-1702-02, " Cable and Raceway Separation Typical Details." In particular, Detail 61 provides the separation criteria for control and instrumentation circuits within electrical panels.

As a result of the testing and analyses performed during this action plan, a new detail - Detail 61G - was added to the

. drawing via DCA 21446, which specifies the minimum separation for redundant cables, where each is enclosed in SERVICAIR flex.

The applicable QC inspection procedures (QI-QP-li.3-28 and

'QI-QP-11.3-40) were revised to reference this deawing for separation requirements.

In addition, DCA-8830, which originally revised the Electrical Erection Specification but now also applies to Drawing 2323-El-1702-02, was revised to allow flex in " Reliance Control Board and Vertical Ventilation Panels (MS 605)."

These document changes involving the use of SERVICAIR flex as a barrier were reviewed by the Electrical Review Team Leader.

In addition to reviewing these documents, the Electrical Review Team reviewed the sections of Electrical Erection 1() Specification ES-100 relating to internal wiring separation, as well as the applicable cortions of the Brown & Root Construction Procedure 35-1195-EEI-8, " Class IE and Non-Class 1E Cable Terminations."

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RESULTS REPORT kJ -

ISAP I.b.1 (Cont'd)

. 5.0 DISCUSSION OF RESULTS (Cont'd)

Suggestions for enhancement of these documents were transmitted to TUGCO. The Project responded to the comments i and the Electrical Review Team concurs with the proposed actions to revise these documents to resolve the comments.

5.7 Review of Training I The Electrical Review Team also reviewed the curret t program  ;

for training of construction and QC personnel. Craft t

' instructors were interviewed to determine the extent and depth

;of the instruction given craft personnel in the area of

. electrical separation incide panels. The program is comprehensive end includes classrcom training on procedures, examinations, and " hands-on" experience. The Electrical Review Team noted that separation criteria are shown on  ;

Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical

. Details," in addition to the Electrical Erection Specification

- 2323-ES-100. .Since the instructors were not receiving 3, f controlled copies of changes to the drawing, they were not aware of the changes made to.the separation criteria for SERVICAIR flex. This has since been remedied by having the instructors-receive controlled copies of all changes to this drawing. Therefore, whenever the drawing is revised or a design change is made to the drawing, the instructors will l

- automatically receive *.hese documents.  ;

j The Electrical Review Team reviewed the QC Lesson Plan developed for QC Procedure QI-QP-11.3-28. The Lesson Plan presents the subject of separation inside panels adequately and refers the inspector to Drawing 2323-El-1702-02 for details.-

Due to the changes that are currently being incorporated into the procedures, drawing, etc., further training will be required.

5.8 Categorization of Findings 5.8.1 Control Boards and Verticti Ventilaticn Panels The CPRT third-party inspectors and TUGC0 QC inspectors, during their inspections of the control boards and vertical ventilation panels, did not O

identify any violations of the final separation criteria for two redundant cables, each enclosed in i

SERVICAIR flex.

l 1

- , .-.. - . - - - - . - . , . . - - - - - - - . _ - - - - - . . - - . - , - - - - - . - - _ , .-. - .0

vc -

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P y.$ 'RESULTS REPORT

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-ISAP I.b.1

'(Cont'd) 5.0 DISCUSSION.0F RESULTSl(Cont'd) i 5.8.2 Panels Other Than The Control Boards and Vertical

A

Ventilation Panels For panels other than the control boards and' vertical

~ . ventilation panels, the CPRT Electrical Review Team

.c, examined.all multi-train panels to determine where SERVICAIR flex had been used as a barrier. During this examination of multi-train panels, a total of nine panels were found to contain a total of 16 pieces of SERVICAIR flex.- Since the existence of these pieces of flex.is in violation of the final criteria, Nonconformance Reports were issued.

, In addition to these nine panels, SERVICAIR flex was found in'a Reliance-supplied panel, CPL-ECPRLV-17, by third-party QC inspectors performing inspections for Action Plans I.a.2 and I.a.3.- During the process of resolving a separation violation, this flex was

. I Y' removed prior to the Electrical Review Team's 3'-'f . examination of multi-train panels. Therefore, the examination of multi-train panels performed for this action plan did not-identify any flex in Panel CPI-ECPRLV-17.

These cases of SERVICAIR flex in panels other than the 5

control boards and vertical ventilation panels do not constitute deviations since the original criteria

. permitted SERVICAIR flex to be used as a barrier in all par.els. Nonconformance Reports have been issued as a result of the criterion change that limits the use of SERVICAIR flex to the control boards and vertical ventilation panels. The Electrical Review Team reviewed and concurred with the disposition of the p Nonconformance Reports issued for the 16 pieces of flex outside the control boards and vertical ventilation panels.

5.8.3 Observations During the implementation of this action plan, it was apparent that the criteria governing the use of SERVICAIR flex as a barrier were confusing. The Electrical Erection Specification 2323-ES-100 contained two active Design Change Authorizations (DCAs) that O, addressed the use of SERVIC8.IR flex. The first authorized the use of flex in panels supplied by

Revision: 1 Page 31 of 37 ,

1__ RESULTS REPORT ISAP I.b.1 (Cont'd) 5.0 DISCUSSION-OF RESULTS (Cont'd)

Reliance-Electric Company; the second DCA allowed flex to be used in all panels. . Even though the second DCA was issued within a month of the first, the original DCA was not revised to be consistent with the later

-DCA. 'Since the two DCAs revised different portions of the electrical specification,' the interpretation as to where-SERVICAIR flex could be used depended on the section of the specification to which one referred. As discussed in Section 5.6, the Project has committed to revise the appropriate documents to identify the panels where SERVICAIR flex can be used as a barrier.

The_second observation involved the process by which revised criteria are incorporated into Project documents. From the start of the implementation of this action plan, the intent was to qualify SERVICAIR flex as a barrier only for the control boards and 7- vertical ventilation panels. However, the engineering

(',j criteria in the electrical erection specification were not revised until May 1986. Nonetheless, QC Procedure QI-QP-11.3-28 was revised in June 1985 to limit the use of SERVICAIR flex to the control boards and vertical ventilation panels, based on the then current status of this action plan. QC procedures should always be consistent with engineering documents. In addition, the engineering and QC review of the QC procedure should have identified and resolved the differences in the engineering and QC documents.

The third observation dealt with the parametric computer analyses performed by Gibbs & Hill in determining the effectiveness of SEEVICAIR flex as a thermal barrier. During the review of the analyses by the Electrical Review Team, an inconsistency was discovered in the results presented for the 5/8-inch SERVICAIR flex. Subsequent evaluation by Gibbs & Hill attributed the inconsistency to a problem in the version of the HEATING-5 computer code used in the analyses. Reanalyses using a later version of the same code demonstrated that the error had been corrected in the more recent version of the code. Gibbs & Hill has reviewed all other calculations that utilized the HEATING-5 computer code and has determined that the

/"N factors which caused the above inconsistency are not k- present in these calculations.

w

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RESULTS REPORT 5J: "'

.ISAP I.b.1 (Cont'd) 15.0 . DISCUSSION OF RESULTS (Cont'd)

The fourth observation is that the~ craft training instructors were not on controlled distribution for Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical. Details." Because of this, the instructors

.were not aware of the latest separation criteria for SERVICAIR flex. This was corrected by having the instructors receive controlled copies of all changes to

the drawing.

The' facts relating to these observations were transmitted to the Design Adequacy and QA/QC Review Team Leaders, as appropriate, to be included in their respective collective evaluations.

5.9 Safety Significance Evaluation / Root Cause/ Generic Implication Since no deviations were found, no safety significance q evaluation, root cause analysis, or evaluation of generic fsj- _

implications were~ performed.

- The root cause hypothesized by the NRC 'is that "The lack of

. analysis to substantiate the adequacy of separation ... may be an indication of weakness in the QA/QC program concerning  !

design control." As noted in Section 3.0, the Project did not l consider specific testing and/or analyses to be necessary I since SERVICAIR flex is a metallic conduit; metallic conduit is recognized as an acceptable barrier per IEEE 384-1974 and

)

i IEEE 420-1973. Nonetheless, the CPRT Design Adequacy Program is addressing, on a comprehensive basis, instances elsewhere that may involve a lack of analysis to substantiate the adequacy of design.

~

5.10 Corrective Action Although no deviations were noted during the implementation of this action plan, TUGC0 is developing corrective action to resolve separation issues identified through Action Plans I.b.2 and I.b.4. Since this corrective action program is related to the subject of this action plan, the major elements of the program are described below.

TUGC0 has recognized the need to establish and maintain cable separation inside electrical panels for all stages of the l plant life - construction, start-up, and operations. Key elements to achieving these objectives are the establishment l

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Page 33 of 37

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RESULTS REPORT ISAP I.b.1 (Cont'd) k 5.8 DISCUSSION OF RESULTS (Cont'd)

S of clear criteria, the training.of responsible-personnel, the

. timely _ performance of. inspections, and the control of Jactivities performed after inspections have been performed.

,7'F To this end, TUGC0 is currently taking the following actions:

1) Updating all procedures, drawings, specifications, etc., dealing with internal separation to clarify the criteria, ,

- 2) Instituting a special training program to ensure that

' personnel involved with multi-train panels, i.e. craft,

-QC inspectors, engineers, start-up personnel, and operations personnel, are sensitized to the need to establish and maintain separation of electrical cables,

3) Providing job-specific training for craft, QC ,

.. -inspectors, start-up, and operations personnel to the

/~T revised documents, V.

-4) Performing a baseline inspection to ensure that the required separation criteria have been met, and

-5) Controlling personnel who access panels requiring cable separation after the baseline inspection has been completed.

_5.11 Additional Findings All additional findings including cable-to-cable and cable-to-wireway separation nonconformances noted during the )

implementation of this action plan will be addressed in the Results Report for Action Plan I.b.4. Separation nonconformances involving SERVICAIR flex and cables are addressed in Action Plan I b.2; the root cause analysis and generic implication evaluation for the I.b.2 deviations will be described in the Results Report for Action Plan I.b.4.

5.12 Unit 2 Multi-Train Panels The inspections and examinations performed under this action plan involved Unit I and common area multi-train panels.

However, the TUGC0 program outlined in Section 5.10 will also apply to Unit 2. This corrective action will ensure that the Q. use of SERVICAIR flex meets the final separation criteria developed as a result of this action plan.

m ,

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Revision: 1 Page 34 of 37 .

i f i: RESULTS REPORT

(f -

s

< ISAP I.b.1 (Cont'd) s

^ '

6.0; CONCLUSIONS TheLactions id'entified by the NRC in.Section 2.0 of this report can be separated into the following three items:

1) Reinspect all panels which contain- SERVICAIR flex,

2) Demonstrate by analysis the acceptability of SERVICAIR flex as a barrier'or provide the necessary separation, and

3) Revise the engineering drawings and related documents to -

raflect the final separation criteria.

s To satisfy Item 1, the Unit I control boards and vertical ventilation panels were reinspected. In addition, all Unit I and common area multi-train panels'that require separation of cables were examined to determine if they contain SERVICAIR flex. Since the criteria have been revised to authorize the use of flex only in the control boards and vertical ventilation panels, Nonconformance Reports were issued whenever SERVICAIR flex was used in panels b5 /- '

other than the control boards and vertical ventilation panels. For Unit 2, the TUGC0 program. described in Section 5.10 will ensure that' field installations meet the final separation criteria for

.SERVICAIR flex.

To' satisfy Item 2, analyses and testing were performed to )

demonstrate that SERVICAIR flex is an seceptable barrier for the '

rajority of the circuits in the control room control boards and vertical ventilation panels. For the remaining circuits, a  ;

one-inch separation is specified.

l To satisfy Item 3, the final separation criteria are being i incorporated into the appropriate project documents.

1 These actions, in conjunction with the completion of ongoing activities, will ensure that all concerns regarding separation of

-redundant cables, each enclosed in SERVICAIR flex, are resolved.

7.0 ONGOING ACTIVITIES The NCRs issued for the control room control boards and vertical ventilation panels as a result of deviations related to Action Plans I.b.2 and I.b.4 have not yet been completely resolved. After the NCRs are closed TUGC0 will perform a post-construction inspection of these panels, which will include verification of adequate separation between two pieces of SERVICAIR flex containing redundant cables. This inspection will be overviewed by the CPRT third-party.

Ravision: 1 Page 35 of 37 ,

RESULTS REPORT ISAP I.b.1 (Cont'd) 7.0 ONGOING ACTIVITIES (Cont'd)

TUGC0 also is in the process of developing and implementing a program to establish and maintain separation within electrical panels, as described in Section 5.10. The Electrical Review Team will review this program as it is being developed and implemented.

Upon the completion of these ongoing activities, a Supplemental Report will be issued; this supplement will provide the results of

j the activities described above.

8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE The program described in Section 5.10 will ensure that separation inside multi-train panels will be established and maintained.

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~

.(;. -RESULTS REPORT

- q,i - .

ISAP I.b.1 (Cont'd) ff Table 1 q" . '

Final' Separation Criteria for SERVICAIR flex to SERVICAIR flex inside the Control Boards and Vertic.al Ventilation Panels Tefzel.or Analyzed Non-Analyzed Non-Tafzel Non-Tefzel 4

Class IE Non-Class 1E Class IE Non-Class IE

-Tefsel or Class.1E 0" 0" 1" 1" LAnalyzed Non-Tefsel .Non-Class 1E 0" X 0" X y Class 1E 1" 0" i" - 1"

\h'  ?[Non-analy' zed Non-Tefsel.

Non-Class 1E 1" X 1" X X -- No Separation Required (Circuits are not redundant)

O

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h-RESULTS REPC'!T E ISAP I.b.1 (Cont'd) '

E Attachment I h Chronolo.;y of Major Activities Related to Action Plan I.b.1 E

July-September 1984 The NRC-TRT conducted onsite inspections, including a review of the Unit I control room

[

i control boards. _

October 1984 The initial version of Action Plan I.b.1 was issued.

[r e

November 1984 -

January 1985 TUGC0 performed a post-construction inspection of the Unit I control boards and

[

,p vertical ventilation panels. "

E ,

I January 1985 A draft of the circuit evaluation was [_

prepared.

3 g

h February-April 1985 An inspection of the Unit I control boards j and vertical ventilation panels was pr.rormed g

![ by *be CPRT third-party inspectors. E F

r--

March 1985 Short circuit and heat transfer tests of -

SERVICAIR flex were performed. I f h

! July 1905 DCA 21446 to Drawing 2323-El-1702-02, " Cable "-

and Raceway Separation. Typical Details," was issued. This DCA contained new criteria for -7 SERVICAIR flex in the control boards and [

vertical ventilation panels.

{

July 1985 Revision 1 of the circuit evaluation was y 1

issued.

, October 1985 TUGC0 performed a reinspection of the Unit I h 2

control boards and vertical ventilation f s

panels using the final separation criteria. g March 1986 Revision 0 cf the computer analysis of h I SERVICAIX flex was issued. 7 I h

[- January, May, and The CPRT Electrical Review Team examined Unit 5 L June 1986 1 and common area multi-train panels to -

1 determine where SERVICAIR flex had been used. 5 a

5

[-

(Future) TUGC0 will perform a final inspection of the [r Unit I conctol boards and vertical

{

ventilation panels using the final separation l criteria. This inspection will be overviewed by the CPRT third-party.

f

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E- -

COMANCHE PEAK RESPONSE TEAM g

RESULTS REPORT ISAP: I.b.2

Title:

Fle:tible Conduit to Cable Separation d REVISION 1 1

A f L Iss r sif o '

te Leader MYA _ . --

l l$ $b yviewTe Date ' #

Ca o. h Johnf. Beck,ChairmanCPRT-SRT e t4 /a Date

~ ~

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ISAP I.b.2 ]

Flexible Conduit to Cable Separation i i

-3

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7 Page J-42) ]

j r

"The TRT determined that the installation of certain safety- or g' nonsafety-related cables inside control room panels, which were in direct contact with safety-related flexible conduits associated (

vith the other redundant trains (see Table 1), was inconsistent with engineering-drawings and regulatory requirements... Because acceptability of the flexible conduit as a barrier vau not i established by analysis, as required by Section 5.6.2 of IEEE -'

Standard 384, the cables must be separated from the conduits inside 3 the panels by a minimum distance of 6 inches, as required by 3 e

Section 5.6.2 of IEEE Standard 384." ;q L

A 2.0 ACTION IDENTIFIED BY NRC.(NUREG-0797, Supplement No. 7 Item 6(b), g Page J-44) q

-si "TUEC shall accomplish the following actions prior to fuel load: $

Either correct each of the violations of separation criteria 3 concerning separate cables and cabler within flexible conduits i found in contact with each other inside main control room panels j (Table 1) or demonstrate by analysis the adequacy of the flexible ]

conduit as a barrier. TUEC shall also reinspect all remaining g panels in the control room and other areas of the plant containing g separate cables and cables within flexible conduit and shall take 4 the same corrective actions as those outlined in Table 1.

This analysis shall be accomplished in accordance with Section 3 5.6.2 of IEEE Standard 384-1974. In the event that the 3 acceptability of the conduit as a barrier cannot be d demonstrated, TUEC shall separate c.iles and cables within i flexible conduits by a minimum distance of 6 inches, as g required by Section 5.6.2 of IEEE Standard 384. Furthermore, g

TUEC shall correct all appropriate drawings and documents to y indicate the revised minimum separation." 9

3.0 BACKGROUND

E

l The cases of cables being in direct contact with the SERVICAIR flexible metallic conduit identified by the NRC under this action 7 plan are contrary to the project cable separation requirements j l, delineated on Drawing 2323-El-1702-02, Cable and Raceway '

l Separation Typical Details"; a one-inch separation should have been provided. h 9

4 1

i E

s

, , i MI M- -

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Y < e,~* e_.-

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' 'S ; RESULTS REPORT ,

."'):

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ISAP I.b.2 (Cont'd) r

}( .3.0. BACKGROUND (Cont'd)

' ' ' ~

LThe' main concern expressed by the NRC-TRT team'is that the '

SERVICAIR flexible metallic conduit

• used in'the control room panels has not been shown by analysis to qualify as a barrier **.

m , Both'IEEE 384-1974,."IEEE Trial-Use Standard Criteria for

Separation ~of Class IE Equipment and Circuits," and IEEE 420-1973,

, "IEEE Trial-Use Guide for Class-1E Control Switchboards for Nuclear Power Generating Stations," recognize metallic conduit as an acceptable barrier in '11eu of a minimum six-inch separation between redundant *** cables. Since SERVICAIR flex is a metallic conduit, it was judged by the Project to be an acceptable barrier in accordance with the Standards, and no specific testing and/or analyses was considered necessary.

In the construction of-nuclear power plants, it is necessary to ensure that isolated failures of individual safety systems do not cause consequential damage to and possible failure of redundant -

~*

safety systems.. In the area of electrical cabling, this assurance historically has been provided by specifying and enforcing

.( )' '

requirements on the minimum allowable physical separation of lk / redundant,, safety-class cables or by requiring the use of physical barriers to protect redundant cable trains. The specified separation must be mai.cained throughout the length of each cable.

IEEE 384-1974,'"IEEE Trial-Use Standard Criteria for Separation of

. Class IE Equipment and Circuits," IEEE 420-1973, "IEEE Trial-Use Guide for Class IE Control Switchboards for.N uclear Power Generating Stations," and Regulatory Guide 1.75, Revision 1,

'n " Physical Independence of Electric Systems", which are generally accepted as the documents governing electrical separation requirements and which are applicable to the CPSES (Comanche Peak

• The flexible conduit used for separation inside the control room panels is SERVICAIR flexible metallic conduit (referred to in this report as SERVICAIR flex or flex).

• • - As defined in IEEE 384-1974, a barrier is "a device or structure interposed between Class 1E equipment or circuits and a potential source'of damage to limit damage to Clr.ss IE systems to an acceptable level."

• • • All separation requirements in this report are for redundant cables. The word " redundant" as used herein means that the cables

. requiring separation belong to different trains, i.e., Class IE L train'A, Class 1E train B, or non-Class IE train C.

I

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' /- ISAP I.b.2

', (Cont'd)

~

i

3.0 BACKGROUND

(Cont'd)

' Steam Electric Station) Project, indicate that within electrical 1 panels and cabinets, " metallic conduit" is an acceptable separation barrier in lieu of physical separation. Therefore, rigid metallic

< conduit has been recognized by the nuclear industry as an

acceptable barrier inside electrical panels.

However -there are situations wh'ere maintaining sufficient physical separation is difficult or impossitie and for which rigid conduit is an unsuitable alternative. Hand switch modules in the CPSES control boards'are an example. By design, these modules have redundant cables in -close proximity to each other. Additionally, it is required to have slack in the cables attached to these devices to accommodate routine maintenance and adjustment of the controls. As a result, rigid metallic conduit cannot be used to

' solve the separation problems associated with these devices.

This same situation has arisen elsewhere in the nuclear industry and has been successfully resolved by the installation of SERVICAIR  !

flexible metallic conduit as a barrier. After obtaining IEEE i

/}/

Ax,-

~~

'323-1974 and IEEE 344-1975 environmental and seismic qualification  :

data for the SERVICAIR flex and after discussions with the supplier of the control boards (Reliance Electric Company), TUGC0 issued design change documents at Comanche Peak specifying the use of j

.. SERVICAIR flex as a barrier.

When the Project criteria were modified in November 1979 to specify the use of SERVICAIR flex, its use was limited to the main control boards. 'The use of SERVICAIR flex was expanded in October 1980 to

, incitle all panels supplied by Reliance Electric Company (procured under Purchase Order CP-0605 to Specification 2323-MS-605, " Nuclear Safety Related Control Boards"), which include the control room

' control boards and vertical ventilation panels. In November 1980, a Design Change Authorization (DCA) was issued to the Electrical Erection Specification 2323-ES-100 that listed SERVICAIR flex as metallic conduit, thereby allowing its use as a separation barrier in all electrical panels. For the reasons stated previously TUGC0 undertook no specific effort to qualify this material as a barrier.

The above facts notwithstanding, the NRC-TRT expressed a concern that SERVICAIR flex used in the CPSES control boards had not been qualified as a barrier through appropriate analysis and/or testing.

This action plan was designed to address the TRT's concern by demonstrating the adequacy of SERVICAIR flex as a barrier.

J

- - - - _ . - _ _ - , - -, ._...-_----_i

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'N RESULTS REPORT s_ )-' .

ISAP I.b.2 g; j (Cont'd) 3.0 . BACKGROUND.(Cont'd)

- Many of the activities described in this report are the same as or

~

similar.to.the activities described in the Results Report for Action Plan I.b.1, " Flexible Conduit to Flexible Conduit Separation." Nonetheless, the descriptions of these activities are

- repeated'herein for the reader's convenience.

4.0 CPRT ACTION PLAN

- 4.1- Scope and Methodology

-The objectives of this action plan were 1) to determine, by testing and analyses, the minimum acceptable separation distance between a cable enclosed within SERVICAIR flex and a redundant, exposed cable, i.e. a cable not in conduit, and 2) to reinspect all panels which contain redundant cables that could violate the final separation criteria

• for SERVICAIR

-flex to an exposed cable.

s 7-The'following tasks were' implemented to achieve these objectives:

Circuit evaluation and thermal analyses to demonstrate the adequacy of SERVICAIR flex as a barrier f

Testing to demonstrate the adequacy of SERVICAIR flex as a barrier Inspections of cables in the control room control boards and vertical ventilation panels for adequate ,

separation Procedure / Drawing revisions to incorporate the final separation criteria Examination of panels other than the control boards and vertical ventilation panels for the use of SERVICAIR flex I

• The final separation criteria (see Table 2) are the separation criteria developed as a result of this action plan. See

. DCA 21,446, Revision 1, to Drawing 2323-El-1702-02, " Cable and l j'~ Raceway Separation Typical Details" and Section 5.4.

.~~

4 4

~~ rm. -em--u.. ---.n->.,,,w,- - , , - , - , n,-,,,-,,,,mm, m. mm-gw,,---rr,w,,.- - - - , - .-, ----w-. .g--mm e n , u n.pc44r w,,

. .= _ . . . . .-

s , p. -

Revision: 1 Page 5 of 39

' I r-k - ' RESULTS REPORT L Y

'",[ .

9- ISAP I.b.2 4

(Cont'd).

4.01'CPRT ' ACTION PLAN (Cont'd)

~ ~

1 The' majority (over ninety percent) of the SERVICAIR flex is located in the : control room control boards and vertical

~

ventilation panels. Therefore, the analyses, testing, and

. inspections described above were based on the circuits and

configurations present in these panels. The remainirg Unit 1 and common area panels with two or more trains were examined

~

by the Electrical Reviev Team to identify the location of all

'SERVICAIR flex.

-4.1.1? Analyses 4.1.1.1 Circuit Evaluation An evaluation of circuits in the control boards and vertical ventilation panels was

, performed to determine the maximum current

. available for the control circuits. This  ;

ff,q information was used to help establish the

.! \ test conditions for the testing described

{'M below. 'In addition, this circuit evaluation was used to determine those circuits which contain multiple series protective devices and those circuits for which the maximum faulted current is insufficient to result in heat damage to the subject circuits themselves or adjacent cables. For these circuits, less stringent criteria for separation from other redundant circuits may be used. This is allowed per Paragraph 5.6.2 of IEEE 384-1974. The circuit evaluation specifically addressed the modular wiring to j hand switches where the required cable slack l creates difficulties in maintaining fixed.

spa,tial separation. Other circuits that are in close proximity to the hand switch module wiring were also included in the evaluation.

No specific circuit evaluation was planned for circuits contained in panels other than the control boards and vertical ventilation panels. For those cases where SERVICAIR flex is used in panels outside of those evaluated, the acceptability of SERVICAIR flex as a barrier requires further evaluation on a s,,,

case-by-case basis.

i-e y y+ --'-Wr-v, 1r- w- 19gw+w* 3 * - m p% .-9 yw-wmwe- g r ywm.--y+4-.y -.y------g-vn.r yv pys-*ig-,w-.i w- - -

-w gy-y--y-w.e- ,e- y,m,yw--pi.rs1 yr y y,y- --y  ; w- , . -- - - - - - -y-=em-r----l----

7r - ,

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.Page 6 of 39

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A RESULTS REPORT '

y p .

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ISAP I.b.2 (Cont'd)

+

o

~4.0-'CPRT ACTION PLAN (Cont'd)

Js ,

4.1.1.2 Thermal' Analyses m -

Thermal analyses, supported by the results of tests described in Section 4.1.2, were performed to determine the adequscy of SERVICAIR flex as a barrier. These analyses were based on the heat transfer characteristics of the cable and SERVICAIR flex and apply to this action plan, " Flexible Conduit to Cable Separation," as well as Action Plan I.b.1, " Flexible Conduit to Flexible Conduit Separation."

4.1.2 Test Program A two-part test program was conducted to determine the adequacy of the SERVICAIR flex as a barrier.

. ~

7'~'y The.first part of the test program was designed to L\s_, determine the-ability of SERVICAIR flex to carry a short circuit current without inflicting damage to

. cables contained in adjacent or touching SERVICAIR flex. In this test, two flex conduits were placed perpendicular to one another, touching at one point.

One lead from the current source was attached to one L SERVICAIR flex; the other lead to the other SERVICAIR flex. Test currents representative of the maximum possible fault currents from the control boards' and vertical ventilation panels' power supplies were applied during the tests. The test current flowed along one flex, across the point of contact, and then along the second flex (both flex conduits were isolated from ground). A cable was inserted in one of the flex conduits to serve as a " target" cable to enable monitoring of any damage incurred by cables contained in SERVICAIR flex due to the current in the flex.

The second part of the test program was designed to determine the ability of the SERVICAIR flex to act as an effective thermal barrier between a cable (within SERVICAIR flex) experiencing an overload condition and a redundant cable either exposed and one inch away or contained within an adjacent SERVICAIR flex. For this test a source cable was placed inside a one-inch

( ) SERVICAIR flex and subjected to several different j

h L4 l

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'RESULTS REPORT

.\ ja -

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[ , ISAP I.b.2 l (Cont'd) l

~~

-4.0 CPRT~ ACTION PLAN.(Cont'd)

~

. currents. A target cable was placed inside a S/8-inch SERVICAIR flex which was in contact with the one-inch

'SERVICAIR flex; a second exposed target cable was

, placed one inch above the one-inch flex.. Surface temperatures of the two pieces of flex and the exposed

. . target cable were monitored throughout the test, as ,

)

.well as the temperatures of the faulted conductors. .;i The test procedures were written and tests conducted i I

'; such that the test-results are applicable to the

~

control room control boards and vertical ventilation panels. The procedures for the test program were

. prepared by the Third-Party Adviser, in conjunction

_ with Gibbs & Hill, and approved by the Electrical

. Review Team Leader prior to implementation of the test program.

[ 4.1.3. Invastigations/ Inspections b' 4.1.3.1 Preliminary Investigations Concurrent with the above testing and c , analysis program, an inspection of the Unit I control boards and vertical ventilation panels was performed to determine the extent to which SERVICAIR flex was used as a barrier.

Separation guidelines based on preliminary, conservative separation distances were provided by Gibbs & Hill for review and approval by the Electrical Review Team Leader. Third-party inspectors inspected the control boards and vertical ventilation

~

panels using these guidelines to determine the extent of potential modifications required for compliance with the final separation criteria. In addition, this investigation provided input as to the types of cable insulation used in the control boards and vertical ventilation panels. This information, in turn, was used to determine  ;

the scope of the testing and to identify additional circuits that should be included

( in the circuit evaluation described above.

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. n RESULTS REPORT 3_,

ISAP I.b.2

~

(Cont'd)

.t 4.0 I CPRT ACTION PLAN ~(Cont'd)

These inspections involved all aspects of cable separation, including the issues addressed in Action Plan I.b.1, " Flexible Conduit to Flexible Conduit Separation," and Action Plan I b.4, " Missing Barriers."

The intent was to compare the CPRT third-party inspection findings against the final separation criteria. Those third-party findings that did not meet the final separation criteria were to be reported on Nocconformance Reports (NCRs).

4.1.3.2 -TUGC0 Inspections Prior to issuing NCRs for the findings identified by the CPRT third-party, TUGC0 3 -K. validated the findings, using the final

- (" )

separation criteria. For those findings which clearly violated the final separation o criteria, NCRs were issued. Another group of findings were acceptable when compared to the final separation criteria, since some of the attributes of the final separation criteria were less stringent than those used by the CPRT third-party. For other findings where the minimum separation distance was reduced by the final criteria, it was difficult to determine from the third-party reports if the less stringent, final criteria were met, since the actual separation distances had not been recorded.

To resolve this issue, the Electrical Review Team Leader initiated, through the TUGC0 Coordinator, an inspection of all third-party findings that did not clearly violate the

, final separation criteria.

Since the final sepatation criteria had changed to be more restrictive than the previous Project criteria, it was decided that a reinspection of the panels for those separation attributes that were revised to be F (. more restrictive be performed concurrently with the above validation of the CPRT

eL Revision: 1 Page 9 of 39 dp3 Y 'RESULTS REPORT l, -

,. ISAP I.b.2-(Cont'd) b.;

4.0 ' CPRT ACTION PLAN (Cont'd)

, , third-party findings. This inspection would provide the inspection of record for the control boards and vertical ventilation '

panels.-

4.1.3.3 Third-party overview f In_ addition to the above TUGC0 inspection, the;e will be a post-construction inspection performed by TUGC0 after all rework resulting J

from outstanding Nonconformance Reports for Action Plans I.b.2 and I.b.4 has been

_ completed. CPRT third-party p0rsonnel will overview this final inspection.

4.1.4 Procedure / Drawing Revisions Based on the results of the above analyses and testing.

-"(g-) TUGCO revised Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details" to reflect the final separation criteria. This drawing provides the separation criteria used by the Project.

The applicable QC inspection procedures were also revised to reflect the proper documents that specify the final separation criteria.

These above document changes were reviewed by the Electrical Review Team Leader, as discussed in Section 5.6.

4.1.5 Examination of Other Panels for SERVICAIR Flex A 100% examination of all panels in Unit I and common areas containing two or more trains was performed by the CPRT Electrical Review Team to determine where SERVICAIR flex was used outside the control room control boards and vertical ventilation panels. Since this action plan addresses the use of SERVICAIR flex in the control boards and vertical ventilation panels l O l

. ~ . . _ _ _ _ , _ , , _ _ . . , _ _ . - . _ . . . _ . . _ _ . , . . , . _ _ . _ . _ _ _ _ _ _ _ . . _ _ . _ . _ _ _ _ _ _ _ . _ _ . _

Revision: 1 Page 10 of 39

~

RESULTS REPORT ISAP I.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) ,

a only, the acceptability of SERVICAIR flex as a barrier in other panels requires further evaluation on a case-by-case basis by TUGCO. The CFRT third-party

' overviewed this evaluation for those cases where flex was found in panels other than the control boards and g vertical ventilation panels. W 4.1.6 Use of Results For Unit I and common areas, all deviations from the final separation criteria were noted. They were identified and dispositioned on Nonconformance Reports, and rework will be performed as required. For Unit 2, dl installation procedures and QC inspection procedures g have been or are being revised to ensure that personnel are aware of the required separation criteria. This, in turn, vill result in panel configurations that meet the specified requirements.

4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective work scope.

4.2.1 TUCCO Comanche Peak Project 4.2.1.1 Revised QC inspection procedures and will revise craft procedure to include new criteria resulting from tests and analyses.

Will retrain craft and inspection personnel to the new criteria.

~

4.2.1.2 Revised Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details", and

, other related documents, to reflect the final separation criteria.

4.2.1.3 Performed reinspections for the Unit 1 control room control boards and vertical ventilation panels for those final separation attributes which have been revised to be mora restrictive as a result of this action plan.

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- - - = -

( yp j -

Revision: 1-s n Page 11 of 39

) .+

a, ,N,3: .RESULTS REPORT

., S ,

ISAP I.b.2

-(Cont'd)

'4.0 'CPRT ACTION PLAN'(Cont'd)

_ '4.2.1.4 Will. process NCRs that were generated in r

connection with this action plan.

4.2.1.5 Personnel =

Mr. W. I. Vogelsang TUGCO Coordinator

.l 4.2.2 Electrical Review Team 4.2.2.1 Reviewed the analyses, circuit evaluation.

test results and revised QC inspection

, procedures. Will review revised craft procedure.

~

4.2.2.2 Completed 100% examination of all panels with two or more trains to identify cases where SERVICAIR flex is used outside the control '

room control boards.and vertical ventilation

_[ panels.

b=

4.2.2.3 Reviewed the inspection reports and will  :

review the NCRs generated as a result of this action plan.

4.2.2.4 Reviewed and approved the test procedures and test report.

4.2.2.5 Reviewed changes to Drawing 2323-El-1702-02, ,

" Cable and Raceway Separation Typical  !

Details", and other related documents, which reflect the final separation criteria.

4.2.2.6 Reviewed documentation of training of TUGC0 l Project inspectors to final separation criteria.

4.2.2.7 Will overview the TUGC0 post-construction inspection of the Unit I control room control boards and vertical ventilation panels.

4.2.2.8 Determined root cause, generic implications and safety significance, as required.

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Ravision: 1 Page 12 of 39 RESULTS REPORT d

, ISAP.I.b.2

. (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.9 Personnel (prior to October 18, 1985)

Mr. M. B. Jones, Jr. Review Team Leader Mr._E. P. Stroupe Issue Coordinator

. '4.2.2.10 Personnel (starting October 18, 1985)

Mr. J. J. Mallanda Review Team Leader Mr. R. J. Bizzak Issue Coordinator Mr. M. B. Jones, Jr. Third-Party Adviser Mr. E. P. Stroupe Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team

/%,

~!' ,) 4.2.3.1 Inspected Unit I control room control boards and vertical ventilation panels which have SERVICAIR flex for compliance to separation guidelines (see Section 4.2.5.4).

4.2.3.2 Will perform overview inspection (see Section 4.2.2.7) as determined by the Electrical Review Team. '

4.2.3.2 Personnel Mr. J. L. Hansel Review Team Leader 4.2.4 Third-Party Adviser 4.2.4.1 Prepared test procedures.

4.2.4.2 Supervised the tests.

I 4.2.4.3 Issued a report of the test results.  ;

4.2.4.4 Reviewed the circuit evaluation, as required. l

)

4.2.4.5 Personnel l Mr. L. D. Bates Third-Party Adviser 1

p Ravision: 1 Page 13 of 39

RESULTS REPORT ISAP I,b.2 (Cont'd) 2 .

~ 4.0 CPRT ACTION PLAN (Cont'd) 4.2.5 Gibb's'& Hill 4.2.5.1 Performed circuit evaluation and thermal analyses.

4.2.5.2 Assisted in preparation of the test procedures.

4.2.5.3 Reviewed and approved the test report.

4.2.5.4 Prepared separation guidelines for CPRT third-party inspectors.

4.2.5.5 Prepared final Project separation criteria.

4.2.5.6 Assisted in the QC inspections, as required.

f-] ' 4.2.5.7 Assisted in the processing of NCRs that were

(,,/ generated in connection with this action plan.

4.2.5.8 ' Personnel Mr. S. P. Martinovich Principal Electrical Engineer 4.3 Qualification of Personnel Where inspections required the use of certified inspectors, qualification at the appropriate level was to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants." CPRT third-party inspectors were certified to the requirements of the third-party employer's Quality Assurance program, and

.specifically trained to the CPRT Program Plan.

Where tests required the use of certified test personnel, qualification at the appropriate level to the requirements of ANSI N45.2.6 and Regulatory Guide 1.59 was not met. These i requirements were not part of the CPRT Program Plan at the '

time of testing. However, the qualifications of the individual supervising the tests were considered by the Review Team Leader to be more than sufficient to render the tests valid.

Third-party participants in the implementation of this action plan met the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.

PO ,

q

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l Revision: 1 Pags 14 of 39

-Q- . RESULTS REPORT -

L- .

i ISAP I.b.2-

'~

l (Cont'd) l l

-4.0CPRT ACTION PLAN (Cont'd) '

l Other participants were qualified to the requirements of the CPSES Quality Assurance Program or co the specific

-requirements of the CPRT Program Plan. CPRT activities

. performed by other than third-party personnel were governed by

~

'the applicable principles of Section III.K, " Assurance of CPRT

' Program; Quality", of the CPRT Program Plan.

4.4 Procedures The following CPRT procedures were develeped in support of e this Action Plan:

-4.4.1 Procedure I.b.1-001, " Cable /SERVICAIR Heat Transfer '

,. Test".

4.4.2 Procedure I.b.1-002, "SERVICAIR Short Circuit Test" 4.4.3 Instruction QI-004, "CPRT Action Item I.b.1 - Flexible 1 /). Conduit to Flexible Conduit Separation; CPRT Action

\> Item I.b.2 Flexible Conduit to Cable Separation".

4.5 Acceptance criteria

. 4.5.1 The acceptance criterion was that the SERVICAIR flex be shown by testing and/or analyses to be an acceptable barrier as provided by IEEE-384 (1974), IEEE-420 (1973) and Regulatory Guide 1.75, Revision 1, January, 1975.

L 4.5.2 The acceptance criterion for cable to SERVICAIR flex i separation is that the cable and flexible conduit not touch each other and that the separation provided meets the requirements stipulated in Drawing 2323-El-1702-02,

" Cable and Raceway Separation Typical Details" (see Section 4.2.1.2).

4.6 Decision Criteria If the tests and analyses results did not qualify SERVICAIR 2 flex as a barrier, qualified barriers were to be installed or 6" separation provided and the applicable documents revised to indicate the revised minimum separation for SERVICAIR flex.

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Revision: 1 Page 15 of 39

/N RESULTS REPORT ,

a t

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(Cont'd)

'5 . 0 DISCUSSION OF RESULTS _

.A chronology of the major activities discussed in this Results

Report is provided in Attachment-1.

5.1 Summary The first objective of this. action plan was to determine through testing and analyses the minimum acceptable separation

, distance between cables of redundant trains, when only one of

-the cables-is enclosed within SERVICAIR flex. Since SERVICAIR flex was used'mainly in the control room control boards and vertical ventilation panels, the program described below was based on the circuits in those panels.

The first step was a circuit evaluation to determine the

~

-maximum credible overload or short circuit current that should I be used in the subsequent testing. In addition, various l circuits were evaluated to determine if they could be shown  !

.not to cause damage to adjacent cables either because they

.( '

-were incapable of carrying high. currents or because they contained multiple protective devices in series.

An investigation of the cables in the control boards and vertical ventilation panels was then undertaken using preliminary, conservative separation guidelines. This i investigation provided an assessment of the extent to which SERVICAIR flex was used as a barrier. Furthermore, the investigation provided data on the type of cable insulation used, i.e., Tefsel* versus non-Tefzel. Internal wiring by Reliance Electric is all Tefsel-insulated; field wiring to the terminal blocks in the back of the panels is mostly non-Tefscl. The field investigation provided preliminary confirmation that the majority of the areas where separation could be 'a problem involved only Tefzel cable. Therefore, the l testing that was performed during the same time frame as these investigations was limited to Tefzel cables. Those circuits that most commonly used non-Tefzel cables were assessed relative to the circuit evaluation that had already been performed and additional evaluations were performed to justify less stringent minimum separation distances for these additional circuits.

O

• Tefzel is DuPont's registered trademark for fluoropolymers used for, among other things, conductor insulation and cable jacketing.

l s

Revision: 1 Page 16 of 39 l

=c l a: .

RESULTS REPORT a .

ISAP I.b.2 l

.x (Cont'd) 1

, 5.0 DISCUSSION OF. RESULTS (Cont'd)

A two-part test program was conducted to determine the

-adequacy of SERVICAIR flex as a barrier for Tefzel cables.

The first test was designed to determine the ability of SERVICAIR flex to carry a short circuit current without inflicting damage to cables contained in adjacent or touching SERVICAIR flex, even if the short circuit current passed from the SERVICAIR flex.containing the faulted circuit to the SERVICAIR flex in contact with it. The second test was designed to determine the ability of SERVICAIR flux to act as an effective thermal barrier between an overloaded circuit

~

contained in the SERVICAIR flex and either a redundant cable contained in SERVICAIR flex touching the first piece of flex or an exposed cable one inch away. The case of an exposed cable one inch from a flex containing a faulted circuit was

' performed in support of this action plan.

Subsequent to the testing program, parametric computer

>~x . analyses were performed to determine the effectiveness of i ) SERVICAIR flex as a thermal barrier for a range of configurations. Parameters such as current level, flex size, flex length, and flex orientation were examined to determine the effectEthat these parameters would have on the maximum flex surface temperature.

The second objective of this action plan was to reinspect all electrical panels which contain redundant cables in SERVICAIR flex that could violate the final separation criteria. The CPRT third-party identified nonconforming conditions involving separation of SERVICAIR flex to exposed cables in the control boards and vertical ventilation panels based on the preliminary, conservative separation guidelines developed by Gibbs & Hill. When the final separation criteria were developed. TUGC0 QC inspectors performed a validation of the CPRT third-party findings and a reinspection of these panels to the final separation criteria.

For panels other than the control boards and vertical ventilation panels, the CPRT Electrical F.eview Team performed an examination of all multi-train electrical panels to determine where else SERVICAIR flex were used. Since the testing and analyses that were performed to show that SERVICAIR flex is a barrier were based on the circuits present in the control boards and vertical ventilation panels, the use of SERVICAIR flex in other panels would require further k evaluation on a case-by-case basis to demonstrate the acceptability of SERVICAIR flex as a barrier.

Revision: 1 Page 17 of 39 -

RESULTS REPORT -

O_ .

ISAP I.b.2 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd) 5.2 Testing A two-part test program was undertaken to determine the adequacy of SERVICAIR flex as a barrier when Tefzel cables contained therein are subjected to electrically-initiated a failures.

~

The first part of the test program was Gesigned to determine the adequacy of the SERVICAIR flex to provide a path for short circuit current without causing damage to cables in an adjacent or touching flex. The circuit in the test set-up consisted of two pieces of flex in contact with each other, ,

crossing at approximately 90 degrees. A target 2 Tefzel-insulated cable was inserted in one of the two pieces of flex. One lead from the current source was attached to one ,g SERVICAIR flex; the other lead was attached to the other j SERVICAIR flex. The flex conduits were isolated from ground, E" which resulted in the current passing from one flex to the e other at the point of contact. The circuit breaker test set used to supply current for these tests was preset to deliver a 2000 amperes DC current when applied to a single piece of 3

j flex. Using this machine setting, current was applied to the }k test circuit three times with a 30-ampere fuse in the circuit ,

and three times without a fuse. The most severe cases were j those run without a fuse. During the first such case without g a fuse, the circuit breaker test set was preset to trip 4 automatically. For the last two cases without a fuse, the current was manually interrupted shortly after two seconds, which is much longer than the time normally required for a fuse or circuit breaker to open. The tcst current for the case of automatic machine interruption was 1560 amperes; the  ;

maximum test current for the cases involving manual 4 interruption was 1102 amperes. It should be noted that j although the test equipment was set to deliver 2000 amperes g through a single piece of flex, the current in the test passed y from one flex to the other (both ungrounded) and the

• additional resistance due to the contact point between the two pieces of flex reduced the current. Nonetheless, the test j currents were representative of the maximum fault currents i

( .

that can be postulated to occur in the control boards and i vertical ventilation panels.  !

$ J 1

-E

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.I y . Revision:

~#

Paga 18 of 39. I

~ v

N b RESULTS REPORT

'I '

ISAP I.b.2 .

(Cent'd) x i

-n . . >

.5.0 ' DISCUSSION OF.RESULTS (Conc'd)

The only cases that resulted in any damage during these tests were those where the test currents were applied to the two pieces of. flex without a fuse in the test circuit and without automatic machine interruption. The outer bronze braids covering the steel bodies of the flex conduits became welded ys .together at the contact point. Nonetheless, there was no damage to the steel body of either SERVICAIR flex. The cable inside the san 11er.5/8-inch flex was not damaged. This was -

U' verified by post-test visual examination of the cable jacket

• for signs of Tefsel melting. In addition, megger testing of the cable did not indicate any damage to the cable.

.As a result of these tests it was concluded that SERVICAIR

,  ; flex could carry currents representative of the maximum fault currents expected at the control boards and vertical ventilation panels without imposing damage to Tefzel cables in

~

an adjacent touching flex even if the fault current were to

.- flow through both of the touching flex conduits.

[M .Since the cable inside the current carrying flex was not damaged, an exposed cable or.e inch away from the flex would likewise not be damaged.

P The second part of the test program investigated the heat transfer characteristics of SERVICAIR flex. The test setup s

included a soarce cable inside a one-inch SERVICAIR flex. A target cable was placed inside a 5/8-inch SERVICAIR flex in

contact with the one-inch flex. An exposed target cable was e

placed one inch above the one-inch flex. As current was applied to a circuit enclosed within the one-inch diameter

SERVICAIR flex, the temperatures of the copper conductors and i the outside surfaces of the two pieces of flex were monitored, as well as the air temperature one-quarter inch above the flex and the temperature of the exposed conductor one inch above the flex. Current levels were varied from fifteen to forty amperes per energized conductor (four conductors were

_ energized to represent the worst case of concurrent faulting of two circuits within the same flex feeding a single piece of i equipment). The upper-bound current of forty amperes was selected since the circuits involved are protected by circuit protection devices (i.e., fuses or circuit breakers) rated at 30 amperes or less; fuses are used exclusively for protection

above 20 amperes. Per UL Standard 198B, a current of 135 j percent of the fuse rating will open the circuit within one

' i hour. Therefore, the maximum substained current for these i circuits in the control boards is less than 40.5 amperes.

~

I l

Ravision! 1 Paga 19 of 39

", 1

'^s RESULTS REPORT l- .

ISAP I.b.2 (Cont'd) r 5.0 DISCUSSION,0F RESULTS (Cont'd)

-1 The results of this testing showed that the Tefzel insulation melted only during the forty ampere case, during which the-energized conductors reached a maximum temperature of 350*C.

Even then, the maximum surface temperature of the flex

~

containing the overloaded circuits was only 149'C. The maximum measured temperature of the cable one inch from the flex containing the overloaded circuits was 65'C. As .

discussed in Section 5.3.1, these temperatures were shown to

- < be acceptable.

.5.3 Analyses

.5.3.1 Thermal (Post-Test)' Analyses for Tefsel Cables Subsequent to the completion of'the heat transfer tests, computer analyses were performed in which several of the test parameters were varied, such as current level, flex size, flex length, and flex

!,- ) - orientation. This parametric study was performed to

- 'N /

determine the maximum flex surface temperature due to a faulted circuit within the flex and also to provide quantitative answers to the following questions:

If the protection device malfunctioned, would a current higher than 40 amperes give a

s. higher transient flex surface temperature prior to insulation melting than was experienced in the 40 ampere test case?

Since the melting of the Tefzel insulation during the test significantly reduced the temperature of the copper conductors, and hence the temperature cf the SERVICAIR flex, would the flex temperature be higher at the current level corresponding to the point just prior to gross melting of the insulation?

How do the results apply to the other sizes of SERVICAIR flex used at Comanche Peak (i.e., 5/8-inch-diameter flex and 2-inch-diameter flex)?

/

(>

41

'y y M 4- '

Revision: 1

. Page 20 of 39 il [, RESULTS REPORT- ,

v -

ISAP I.b.2 (Cont'd)

, s

[;h

'5.0 -DISCUSSION OF RESULTS (Cont'd)

~ '

'How does the orientation of the flex affect the results? The testing was done for a horizontal piece of flax. A vertical flex

- would have a lower convective film

. coefficient, and, therefore, could have a higher surface temperature. ,

3

- ' What effect does the length of SERVICAIR flex have on the maximum temperature?

s The initial' step in the computer analyses was to dcvelop a model and analyze it at the same current levels used in the testing program. The time history

. temperatures from the computer analyses and the tests were compared and refinements were made to the computer model until the computer results were validated by the test results. The computer n:odel for a one-inch flex

/N was then used to analyze six different current levels

) ranging from thirty-two and one-half amperes to sixty amperes. The steady-state flex temperatures were found

.for those current levels which result in conductor temperatures lower than that at which gross melting of the Tefzel insulation occurs, i.e. 350*C*. For those

, current' levels which resulted in the temperature of the energized conductors excauding 350*C, the analyses were terminated when the conductors reached 350'C. The tests demonstrated that at this temperature the 1 insulation experienced gross melting. The results of these analyses provided answers to the first two questions. The maximum flex surface temperature occurs '

between 30 and 40 amperes, at the current level that results in a steady-state conductor temperature of 350*C. This is the temperature at which gross melting of the Tefsel insulation occurs.

b Analyses were then performed for a vertical, 5/8-inch flex, which is the worst case by virtue of the smallest

!~ convective surface area and smallest natural convective p film coefficient. In addition, no axial heat flow was

, modelled, which corresponds to an infinite length of flex. The results of this analysis gave a maximum flex surface temperature of 211*C at 29 amperes.

• Although the manufacturer's stated melting point of Tefzel

{ insulation is 270*C, a conductor temperature higher than 270*C is

required to raise the outer surface of the cable jacket to 270*C.

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Rsvision: 1 Page. 21 of 39 ,

,; , RESULTS REPORT

~.- .

O , ISAP 1.b.2 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd)

~

In lieu of data regarding the temperature of a cable one inch away from an adjacent SERVICAIR flex, the unfaulted, exposed cable was assumed to be at the same temperature as the surface of the flex containing the faulted circuits. This is a conservative' approach.

The. flex temperature of 211*C is less than the melting point of Tafzel insulation (270*C). Nonetheless.

~

further study was performed to ensure that the cable

.would not be degraded due to the elevated temperature.

The manufacturer provides data that Tefzel has a qualified life of 1500-2000 hours at 205'C. This allows approximately two months for the operator to detect and correct'the malfunction resulting in the overloaded circuit before the Tefzel qualified life is expended. The following points also provide assurance that a faulted circuit in SERVICAIR flex will not 7-'g. result in damage to's cable one inch away:

g

'V '

1) The temperature of 211*C is for the surface

' of the flex containing the faulted circuits.

The temperature of a cable one inch from the flex with the faulted circuits would be lower.

2) These analyses assume that the overload current will not be interrupted by protective

, devices. In reality, the majority of the

+ instrumentation and control circuits in the control boards and vertical ventilation panels contain protective devices rated at 20 I

amperes or less. The 20-ampere protective devices would open the circuit at a current of 29 amperes within one hour. Protective devices rated below 20 amperes would open the circuit at a current of 29 amperes even faster. The remaining instrumentation and control circuits are protected by fuses rated at 30 amperes. An evaluation of these circuits has shown either that components in the circuit other than the protective devices, such as the switchgear trip and close coils, would interrupt a 30-ampere

+

O current within one hour or that the circuit current would be limited to low current levels by che resistors in series with the light circuits.

as ,

[ (f [

s Rsvision: 1 Page 22 of 39 RESULTS REPORT

~ISAP I.b.2 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd)

3) The tests and analyses assumed that four conductors carried the faulted current, i.e.

two complete circuits are assumed to malfunction simultaneously. If a single circuit were to fail, the current level required to raise the flex temperature over 205'C is above 40 amperes. At this current

. level, fuses, which are the only 30-ampere

. protective devices used, would open the circuit within one hour.

The conclusion drcwn from the testing and analyses is that, for the control and instrumentation circuits in the control boards and vertical ventilation panels,

_ SERVICAIR flex containing a faulted, Tefzel insulated cable will not cause damage to a Tefsel cable one inch away. Therefore, it was concluded that SERVICAIR flex meets the IEEE 384-1974 definition of a barrier when

,/~'}. both cables are Tefzel-insulated.

-.A ,/

The reverse situation of a faulted, exposed cable one

-inch from a SERVICAIR flex containing a redundant cable was inferred from the testing performed. The test results show that the temperature increase above ambient temperature for a conductor one inch above the flex ranged from 28 to 38 percent of ESv temperature increase above ambient for the SERVICAIR flex. This

- indicates that heat is being rapidly dissipated by the convective currents in the air.

For the untested case of an exposed, overloaded cable one inch below a SERVICAIR flex, the cable could reach a temperature as high as the melting temperature of Tefzel (350*C) versus the SERVICAIR flex temperature of 149'C from the tests. Using the highest test ratio of the temperature increase of the conductor above the flex to the temperature increase of the flex itself, a flex one inch away from an overloaded cable would be approximately 148'C. Since the exposed cable would have a higher temperature than the SERVICAIR flex in the test, the air flow would be more turbulent and increased air mixing would occur. Therefore, the use of the temperature ratio from the test data is conse rvative. Since this conservatively-calculated, O flex temperature is of the same magnitude as the flex

o-Revision: 1  ;

Paga 23 of 39 l RESULTS REPORT 7_ ! ISAP I.b.2 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd) test temperature, the case of the faulted circuits in the flex, i.e..'the case tested and analyzed, will envelope the reverse case of exposed, faulted conductors below SERVICAIR flex.

5.3.2 Circuit Evaluation for Non-Tefzel Cables Concurrent with the testing program, an evaluation of the control board and vertical ventilation panel circuits was performed by Gibbs & Hill. This evaluation addressed the modular wiring to hand switches as well as other circuits in close proximity to the hand switch wiring. The objective of this evaluation was to determine the maximum current available to the circuits. This information was used to help establish the test conditions for the testing  !

discussed above. Also, from this evaluation, it was determined that six categories of non-Tefzel cables

, g . were adequately protected by multiple protective  ;

T'~'/ devices in series or that the maximum faulted current i was insufficient to result in heat damage to the I subject cables or adjacent cables. These six l categories are: )

i l

1) Annunciator lampbox cables, .

l

2) Safety System Inoperable Indication (SSII) i lampbox and field input logic cables, l

3) Power cords from receptacle strips on control wireways to devices such as instrument recorders,

4) Sound-powered telephone cables,

5) Coaxial video CRT cables, and

6) Fire detection cables.

An evaluation of tt.e annunciator (category 1), SSII (category 2), and the power cords from receptacle strips (category 3) demonstrated that a single failure of protective devices in these circuits would not result in sufficient energy to comprouise the integrity

O of adjacent safety-related wiring or devices. The

N> circuit evaluation determined that the sound-powered d

4

_,______--___...-------I

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[ < s Revision: I f- Page 24 of 39 1

, "Ne .RESULTS REPORT

_a

• ISAP I.b.2

-(Cont'd)

• s ,

'5.0' DISCUSSION OF RESULTS (Cont'd)

(category 4) and coaxial CRT.(category 5) circuits, which operate at voice and video signal levels,

respectively, pose no inherent hazards. Fire detection (category 6) cables comprise 24V dc, ungrounded

. supervised circuits having a 13.1K-ohn series resistor in the loop that limits the maximum fault current to very small values. Ground detection is also provided for the control room fire detectors. Therefore, the

. separation criteria for Tefsel-insulated cables can be used for these six categories of cables.

This circuit evaluation did not include the 120-volt AC lighting and convenience receptacle wiring. This

wiring is considered to be " power" wiring. The separation criteria for the lighting and convenience receptacle wiring were revised to reflect the fact that it is to be considered more stringently than control Wc\ and instrumentation wiring. Thus, the criteria state I ' that SERVICAIR flex is not to be used as a barrier for 4

d the 120-volt AC lighting and convenience receptacle wiring. Additional evaluation on a caae-by-case basis would be required to demonstrate the acceptability of SERVICAIR flex as a barrier for these cables.

5.4 Final Separation Criteria

~

The final separation criteria within electrical panels for redundant control and instrumentation cables, one of which is enclosed in SERVICAIR flex, are given in Detail 61F of DCA 21446, Revision 1, to Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details." The final separation criteria allow an exposed cable to be one inch from a redundant cable in SERVICAIR flex when each cable is either Tefsel or is a circuit in one of the six categories of non-Tefsel cables discussed in Section 5.3.2. Furthermore, an exposed cable can be one inch from a redundant cable in flex when one of the cables is a non-Tefzel Class IE cable, provided that the other cable is a non-Class IE cable which is either Tefsel-insulated or non-Tefsel but power-limited (cables discussed in Section 5.3.2). This is a logical extension of the interpretation of the separation criteria,

- which is only to protect Class IE circuits. For all other cables, which were neither tested nor analyzed due to their limited use, a minimum six-inch separation is required, i.e.,

Os the separation given in IEEE 384-1974 (Paragraph 5.6.2) for redundant, exposed cables in electrical panels. These criteria are summarized in Table 2 of this report.

r; Rsvision: 1 Page 25 of 39 RESULTS REPORT ISAP I.b.2 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd) 5.5 Investigations / Inspections / Examinations The second objective of this action plan was to reinspect all panels which contain redundant cables that could violate the

-final separation criteria for SERVICAIR flex to exposed cable.

This program involved three distinct activities:

1) Preliminary third-party investigations of the control boards and vertical ventilation panels using preliminary, conservative separation guidelines,

2) Reinspection of the control boards and vertical ventilation panels by TUGC0 to the final separation criteria, and

3) A third-party examination of multi-train panels to identify all other uses of SERVICAIR flex, n

( ) 5.5.1 Preliminary Investigations Prior to the completion of th3 testing and analyses described above, a CPRT third-party inspection of the Unit I control boards and vertical ventilation panels was performed. Since the majority of SERVICAIR flex is located in the control room control boards and vertical ventilation panels, the third-party QC inspections were limited to these panels. This inspection provided aa assessment of the extent to which SERVICAIR flex was used as a barrier. In addition. this investigation was used to deteraine which additional circuits should be included in the circuit evaluation.

It should be noted that conservative separation guidelines, specified by Gibbs & Hill and approved by the Electrical Review Team Leader, were used in this investigation. As such, they were more restrictive than the final separation criteria. Using these more restrictive guidelines' ensured that all deviations to the final separation criteria that might exist would be discovered. This was intended to minimize the need for any subsequent inspections.

Based on these more restrictive inspection guidelines,

[]/

A_ s the third-party inspectors identified 42 instances of SERVICAIR flex-to-exposed cable separation findings.

Revision: 1 9 Page 26 of 39 -

RESULTS REPORT ISAP I.b.2 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd) 5.5.2 TUGC0 Inspections trior to issuing NCRs for the findings identified by h the CPRT third-party. TUGC0 validated the findings, H using the final separation criteria. For those findings which clearly violated the final separation criteria, NCRs were issued. Another group of findings were acceptable when compared to the final separation criteria, since some of the attributes of the final separation criteria were less stringent than those used g

• by the CPRT third-party. For other findings where the aj minimum separation distance was reduced by the final criteria, it was difficult to determine from the -

third-party reports if the less stringent, final L

, criteria were met, since the actual separation ,

distances had not been recorded, g r

To resolve this issue, the Electrical Review Team Leader initiated, through the TUGC0 Coordinator, an _

inspection of all third-party findings that did not .g clearly violate the final separation criteria. =

A Since the final separation criteria had changed to be 4 more restrictive than the original separation 5 criteria *, it was decided that a reinspection of the panels be performed concurrently with the above f i validation of the CPRT third-party findings. Only -

those separation attributes that were revised to be more restrictive were inspected. For example, the final criteria require a six-inch separation between a -

cable and flex for cases involving certain non-analyzed, non-Tefzel cables; the original criteria required a one-inch separation. This inspection E -

provided the inspection of record for the control d boards and vertical ventilation panels.

h d

• The original separation criteria are defined as the criteria in existence prior to this action plan, i. e., Detail 61 of Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details",

O Revision 2, not including any outstanding Design Change Authorizations (DCAs).

-a

i i L

3 x Revision: 1 E Page 27 of 39 -

1 RESULTS REPORT i

2 O -

. ISAP I.b.2

~

g (Cont'd)i

% s 5.0 DISCUSSION OF RESULTS (Cont'd) 5 The TUGC0 QC inspection identified eight additional '

s f violations of SERVICAIR flex to exposed cable, F

The original 42 findings identified by the CPRT third-party inspectors were compared to the final f '

p separation criteria. Of the 42 findings, 19 of the i finding: vere acceptable per the final criteria.

[ Therefore, a total of 23 third-party findings plus +

M eight noted by the TUGC0 inspec: ors (total of 31

% findings) were identified in the Unit I control boards  ;

I and vertical ventilation pancis. Twenty two of the -

1 31 findings were violations to the original criteria.

h The remaining nine violations were violations of the f final criteria only. The Elt-trical Review Team has .

L reviewed the findinge from both the third-party ,

g inspectioti and the TUGC0 inspectie: and concurs with ,

t F

these conclusions. A summary of{t.iese find 1ags is '-

given below: ,

W

[ Acceptable s 19 T Violations of original 22 h h and final criteria c =

% Violations of final 9 L criteria only h

p Total CPRT third-party and 50 g TUGC0 findings -

e TUGC0 is currently performing rework in the control room control boards and vertical ventilation panels to ~;l

= resolve the outstanding Nonconformance Reports issued  ; j E as a result of deviations related to this action plan  :

l h-and Action Plan I.b.4. When this work is complete, a l post-construction inspection will be performed by TUCCO , -j j QC inspectors and overviewed by CPRT third-party personnel. -]-

N 5.5.3 Third-Party Examination of Additional Multi-Train -[

Panels "

The Electrical Review Team requested that TUCCO identify all other panels outside the control room

)

@- control boards and vertical ventilation panels that

} contain SERVICAIR flex. TUGC0 examined panels af g  :

E I

4 Revision: 1 m Page 28 of 34 O

1 RESULTS REPORT ISAP I.b.2 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd) purchased to Specification MS-605, which bounds the panels authorized to contain flex per DCA-8830 to Electrical Erection Specification 2323-ES-100. TUGC0 provided a list of six additional panels that contain SERVICAIR flex. (It was subsequently determined that .

DCA-9086 to the same specification defines SERVICAIR flex as an acceptable ma.tallic barrier and does not limit its use to any particular type of panel.)

}

Subsequent to this response, the action plan was _

revised to require the CPRT E'ectrical Review Team to a examine all Unit I and common area electrical panels f with two or more trains to identify any additional uses of SERVICAIR flex. Psnels other than multi-train panels were not examined since a panel that contains ,,

only one train does not require electrical separation; j therefore, SERVICAID flex would not have been used as a j barrier. -

The first step of this examination process was to k generate a list of electrical panels with two or more q trains. To determine this, all Unit I and common -

electrical panel connection drawings and one-line 3 diagram were reviewed by the CPRT third-party. This 5 review showed that there are no more than 115 7 electrical panels with multiple trains, including the 5 thirteen control room control boards and vertical y3 ventilation panels. During subsequent investigations it was determined that some of these panels contained j cables exempt from separation requirements, some panels a had been removed, some panels were not multi-train i panels, etc. The number of multiple train panels ~'

requiring cable separation was ultimately reduced from -

115 to 88. The CPRT Electrical Review Team examined the panels and found three that contained SERVICAIR flex in addition to the six identified by TUGCO. g ni For all instances where SERVICAIR f?.ex was used outside "

the control room control boards and vertical g; ventilation panels, Nonconformance Reports were HFq written. Since the analyses and testing performed for 3 SERVICAIR flex are applicable only to the control room @

control boaras and vertical ventilation panels, the 9 acceptability of SERVICAIR flex as a barrier elsewhere 3 3

requires further evaluation by TUGC0 on a case-by-case g basis.

3 a ,

w

, Revision: 1 Page 29 of 39 RESULTS REPORT

, ISAP I.b.2 L

(Cont'd)

=

. 5.0 DISCUSSICN OF RESULTS (Cont'd) t For those cases where SERVICAIR flex was used as a barrier outside the control boards and vertical

[ ventilation panels, three cases were identified where i the minimum separation distance between an exposed g cable and SERVICAIR flex had been violated.

s

[

The CPRT Electrical Review Team reviewed and concurred with the disposition of the NCRs issued for SERVICAIR

( flex in panels other than the control boards and

vertical ventilation panels.

E

{ 5.5.4 NRC-TRT Findings The cables listed in Table 1 of NUREG-0797, Supplement 4 7 (also Table 1 of this report) were found to be in

[ contact with other (train) safety-related conduits by

[ KRC-TRT during their inspection. These findings were i

reviewed against the TLGC0 post-construction inspection

,. and third-party inspection. The table in the NUREG does a

not list what items these cables are touching, se it is not possible now to correlate these findings with subsequent post-TRT inspection reports. An attempt was made to locate what evidence exists to show that none of these cables still violate separation criteria.

Post-construction inspection records and Inspection

} Reports dated within the time frame of post-TRT inspection were checked. Also the third-party

! inspection reports were reviewed. In these document

packages a total of 13 of the 21 cables have separation i findings written against them.

8 g As stated above, it cannot be determined if these i findings are identical to the TRT's; however, the fact y that findings were made shows that TUGC0 QC and the i CPRT third-party inspected these cables and found g separation violations. As for the remaining eight g cables, construction activities in the control boards p conducted after the TRT inspection, such as

installation of unistrut supports for seismic purposes, are likely to have involved the rerouting of cables and g possibly eliminated these eight cases.

L N

E k

e

c Rsvision: 1 1 Page. 30 of 39 x ;)

RESULTS REPORT ISAP I.b.2 (Cont'd) 5.0 DISCUSSION OF RESULTS-(Cont'd)

LFinally, it-should be noted that two 100% inspections since the TRT inspection have been performed. These provide assurance that the NRC's separation findings have either been explicitly addressed and corrected or no longer exist due to physical changes in the control F boards. In addition TUGC0 will perform a i post-construction inspection of these panels after all rework has been completed.

, , 5.6 Procedure / Drawing Revisions

.The primary document detailing separation requirements between redundant electrical cables used by the Project is Drawing

" 2323-El-1702-02, " Cable and Raceway Separation Typical Details." In particular, Detail 61 provides the separation

. criteria for control and instrumentation circuits within electrical panels.

'O

(,,/ As a result of the testing and analyses performed during this action plan, a new detail - Detail 61F - was added to the drawing via DCA 21446, which specifies the minimum separation for redundant cables, when one cable is enclosed in SERVICAIR flex.

The applicable QC inspection procedures (QI-QP-11.3-28 and 1 QI-QP-11.3-40) were revised to reference this drawing for  ;

separation requirements.

In addition, DCA-8830, which originally revised the Electrical Erection Specification but now'also applies to Drawing 2323-El-1702-02, was revised to allow flex in " Reliance Control Board and Vertical Ventilation Panels (MS 605)."

These document changes involving the use of SERVICAIR flex as a barrier were reviewed by the Electrical Review Team Leader.

In addition to reviewing these documents, the Electrical Review Team reviewed the sections of Electrical Erection Specification ES-100 relating to internal wiring separation, as well as the applicable portions of the Brown & Root Construction Procedure 35-1195-EEI-8, " Class 1E and Non-Class IE Cable Terminations."

Suggestions for enhancement of these documents were

() transmitted to TUGCO. The Project responded to the comments and the Electrical Review Team concurs with the proposed actions to revise these documents to resolve the comments.

i

e i Revision: 1

-? Page 31 of 39 a . . . ,

[N RESULTS REPORT Lb -

ISAP I.b.2 (Cont'd)

j

-5.0 DISCUSSION OF RESULTS (Cont'd)

,. - 5.7 Review of Training -

1-The Electrical Review Team also reviewed the current program for training of construction and QC personnel. Craft instructors were interviewed to determine the extent and depth of the instruction given craft personnel in the area of electrical separation inside panels. The program is comprehensive and includes classroom training on procedures, J,

examinations, and " hands-on" experience. The Electrical

~

, Review Team noted that separation criteria are shown on

Drawing 2323-El-1702-02, " Cable and Raceway Separatica Typical Details." in addition to the Electrical Erection Specification

'2323-ES-100. Since the instructors were not receiving controlled copies of changes to the drawing, they were not w ~

aware of the.chatges made to the separation criteria for ,

SERVICAIR flex. . This has since been remedied by having the instructors receive controlled copies of all changes to this V5 drawing. Therefore, whenever the drawing is revised or a

.Q.

design change is made to the drawing, the instructors will

' automatically receive these documents.

The Electrical' Review Team reviewed the QC Lesson Plan  !

' developed for QC Procedure QI-QP-11.3-28. The Lesson Plan presents the subject of separation inside panels adequately and refers the inspector to Drawing 2323-El-1702-02 for details.

Due to the changes that are currently being incorporated into the procedures, drawing, etc., further training will be required.

5.8 Categorization of Findings  !

5.8.1 Control Boards and Vertical Ventilation Panels l The CPRT third-party inspectors and TUGC0 QC inspectors, during their inspections of the control boards and vertical ventilation panels, identified 31  ;

violations of the final separation criteria for two

. redundant cables, one cable of which is enclosed in SERVICAIR flex.

Of the 31 violations, 22 were deviations of the criteria in existence when the cables were installed.

O' The remaining nine deviations were violations of the final criteria developed as a result of this action plan, but were not deviations of the original criteria.

e -e-v- w..,t---e,.---,%--p -,, ,,-.-,--,.-,-,.s.,w ,.,--.,w.,,wm.,,,,wr-.--..w,w.,,..w-,,w%,--,,-,,,.-.,----a,.. . pa-me,-,-,, e-evew.,,,,,,nr.,,,--~3--,.,re sp e w. -

ji (

- vb ' Revision: 1 Page 32 of 39

^

RESULTS REPORT

(> ISAP 1.b.2 (Cont'd) 5.0 5. DISCUSSION OF RESULTS (Cont'd) 5.8.2' Panels Other Than The Control Boards and Vertical '

s

-Ventilation Panels

. For panels other than the control boards and vertical ventilation panels, the CPRT Electrical Review Team examined all multi-train. panels to determine where SERVICAIR flex had been used as a barrier. During this exacination of multi-train panels, a total of nine panels were.found to contain a total of 16 pieces of

~

SERVICAIR flex. Since the existence of these pieces of flex is in violation of the final criteria, .

Nonconformance Reports were issued.

In addition.to these nine panels, SERVICAIR flex was found in a Reliance-supplied panel, CPI-ECPRLV-17, by third-party QC inspectors performing inspections for Action Plans I.a.2 and I.a.3. During the process of resolving a separation violation, this flex was removed

./' - prior to the Electrical Review Team's examination of

}? - multi-train panels. Therefore, the examination of l multi-train panels performed for this action plan did l not identify any flex in Panel CPI-ECPRLV-17.

.These cases of SERVICAIR flex in panels other than the

+

control boards and vertical ventilation panels are addressed in Action Plan I.b.1. It should be noted, however, that violations of the original separation criteria for exposed cables and SERVICAIR flex were noted in three of the nine panels.

5.8.3 Observations During the implementation of this action plan, several observations were noted. These observations are discussed in the Results Report for Action Plan I.b.1.

5.9 Safety Significance Evaluation The CPRT third-party inspection and TUGC0 inspection of the

. Unit I control room control boards and vertical ventilation panels resulted in 31 violations of the final separation criteria for exposed cables and SERVICAIR flex. Three additional findings of exposed cables and SERVICAIR flex were

~

identified in panels other than the control boards and vertical ventilation panels. Of the 34 total findings, nine y are not deviations since the installation did not violate the criteria in existence at the time of installation.

Y a,

~

UD?I .

af Ravision: 1 Page 33 of 39

[ p RESULTS REPORT 3 .

ISAP I.b.2

.(Cont'd)

. : .L: .

- 5.0 DISCUS'SION OF RESULTS (Cont'd)  ;

'The determination of whether or not these deviations are safety-significant would require an extensive program of testing'and analyses of the various different types of cable  ;

, insulation and. circuit functions involved. Rather than '

perform this type of safety significance evaluation,' the '

deviations have been. categorized as " unclassified deviations".

As such the deviations will be corrected, a root cause evaluation will be performed, and generic implications will be investigated.-

.5.'10 Root Cause/ Generic Implications  :

-These deviations represent violations of cable-to-flex.

separation only. Other similar violations, such as cable-to-cable separation violations and cable-to-wireway separation violations,'were also found. These deviations are addressed in Action Plan-I.b.4.- Because the deviations identified in this action plan are similar to those addressed in Action Plan

'f(

s ,j- -

I.b.4, the root cause analysis and generic implications evaluation for all separation deviations will be reported in .

the Results Report for Action Plan I.b.4. The root cause i analysis and generic implications evaluation for Action Plan I.b.4 are currently being conducted.

5.11 Corrective Action The corrective actions required for the unclassified deviations noted above are for TUGC0 to issue and close out

~

Nonconformance Reports for the deviations. The Electrical Review Team will review the disposition of these NCRs as part of the NCR review performed for Action Plan I.b.4.

The disposition and third-party review of the NCRs issued for those cases where SERVICAIR flex was used outside the control room control boards and vertical ventilation panels have been addressed by the Results Report for Action Plan I.b.1.

The details of the corrective actions associated with the root cause and generic implications of the deviations noted in this action plan are addressed in the Results Report for I.b.4. A general description of the proposed corrective actions is provided in the Results Report for Action Plan I b.1.

VO

, , . _ . . ._,_..~. - . ___.___ _ _ .._.. _.._-,._.._, . . _ . . . . _ _ _ ._ - m. .._m - - ... _ .-. - . - -.

c., . _ . . _ _ . . _ . _ .-__ _.

n-s Revision: 1

. Page 34 of 39 m.

RESULTS REPORT j )5 .

? \ ISAP I.b.2 .

(Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd) 5.12 Additional Findings ~

All additional findings including cable-to-cable and cable-to-wireway separation nonconformances noted during the implementation of this action plan will be addressed in the Results Report for' Action' Plan I.b.4.

5.13 Unit 2 Multi-T.ain Panels The inspections and examinations performed under this action plan involved Unit 1 and common area multi-train panels.

~

However, the corrective action discussed in the Results Report for Action Plan I.b.1 will also apply to Unit 2. This corrective action will ensure that the use of SERVICAIR flex ,

meets the final' separation criteria developed as a result of i this action plan.

6.0 CONCLUSION

S J{j" -

The actions identified by the NRC in Section 2.0 of this report can be separated into the following three items:

1)-Reinspect all panels which contain SERVICAIR flex and exposed cables,

2) Demonstrate by analysis the acceptability of SERVICAIR flex as a barrier or provide the necessary separation, and

3) Revise the engineering drawings and related documents to reflect the final separation criteria.

To satisfy Item 1, the Unit I control boards and vertical ventilation panels were reinspected. In addition, all Unit 1 and common aren multi-train panels that require separation of

' cables were examined to determine if they contain SERVICAIR flex.

Since the criteria have been revised to authorize the use of flex only in.the control boards and vertical ventilation panels, Nonconformance Reports were issued whenever SERVICAIR flex was used in panels other than the control boards and vertical ventilation panels. For Unit 2, the TUGC0 program described in the Results Report for Action Plan I.b.1 will ensure that field installations meet the final separation criteria for SERVICAIR flex.

. i

Rsvision

1 4 g*7 , Page 35 of 39 e

-(~N .. RESULTS REPORT u -

ISAP.I.b.2 (Cont'd) h

6.0 CONCLUSION

S (Cont'd) ,

l The findings noted by the NRC-TRT are deviations from the original,

, as well as final, separation criteria. The aforementioned inspections, in conjunction with the completion of ongoing .

, activities, will ensure that all deviations to the final separation criteria for exposed cables to SERVICAIR flex have been identified and corrected. '

~ To' satisfy Item 2, analyses and testing were performed to demonstrate that SERVICAIR flex in combination with a cae-inch gap from~an exposed cable is an acceptable barrier.for the majority of the circuits in the control room control boards and vertical ventilation panels. For the remaining circuits, a six-inch separation is specified, which is.the same separation required for two exposed cables.

JTo satisfy Item 3, the final separation criteria are being incorporated into the appropriate project documents.

3 ,v

/ f- These actions, in conjunction with the completion of ongoing

',- activities, will ensure that all concerns regarding separation of redundant cables, one of which is enclosed in SERVICAIR flex, are

-resolved.

+

. 7.0 ONGOING ACTIVITIES The NCRs issued for the control room control boards and vertical ventilation panels as a result of deviations related to this action l

- plan as well as Action Plan I b.4 have not yet been completely resolved. After the NCRs are closed, TUGCO will perform a

- post-construction inspection of these panels, which will include verification of adequate separation between exposed cables and l SERVICAIR flex. This inspection will be overviewed by the CPRT i I

third-party.-

Upon the completion of these ongoing activities, a Supplemental Report will be issued; this supplement will provide the results of the activities described above.

8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE The corrective action described in the Results Report for Action

!( -

Plan I.b.1 will ensure that separation inside multi-train panels will be established and maintained.

4

->---*-wgy-ev,we.we,-,-y y y-,---e,-- - w- -----y, - - . - ---vy--- ,- -,, w y ,,- ------- ,,m,--, -----y __.--,v-w-,y--------r- v

J. -

Ravision: 1 Page 36 of 39 RESULTS REPORT s_- -

ISAP 1.b.2 (Cont'd)

Table 1*

' Safety or Nonsafety-Related Cables in Contact with Other Safety-Related Conduits in Control Room Panels

1. Control Panel CP1-EC-PRCB-02: Containment Spray System

Cable No. Train Related Instrument EG139373 B (green) Undetermined E0139010 A (orange) Undetermined

2. Control Panel CPL-EC-FRCB-07: Reactor Control System Cable No. Train Related Instruer.nt

, EG139383** B (green) Reactor manual trip switch E0139311 A (orange) Undetermined (y)

'~,

E0139310 A (orange) Undetermined EG139348 B (green) Undetermined

3. Control Panel CP1-EC-PRCB-06: Chemical & Volume Control System  ;

1 Cable No.- Train Related Instrument EG139335 B (green) LCV-112C E0139301 A (orange) Undetermined E0139305 A (orange) LCV-112B NK139605 Nonsafety CSALB-6AB 1 (in bundle) j

4. Control Panel CPI-EC-PRCB-09: Auxiliary Feedwater Control System Cable No. Train Related Instrument E0139753 A (orange) FK-2453A E0139754 A (orange) FK-2453B EG139756 B (green) FK-2454A EG139288 B (green) FK-2454B EG145780 B (green) FK-2454A

• From NUREG-0797, Supplement 7, Table 1, Pages J-39-40. ,

l

• • The correct number is EG139352.

l l

0 :p Revision: 1 ,

Pags 37 of 39

~

j/ 'g , RESULTS REPORT ISAP I b 2

'(Cont'd)

Table 1

.(Cont'd)

Cable.No. - Train- Related Instrument EG145781' ' B (green) FK-2460A A0138622 A (orange HS-2452G-H Assoc.)

NK139647 Nonsafety HS-2383

5. . Control Panel CPI-EC-PRCB-08: Feedwater Control

-Cable No. Train Related Instrument

-EG140309 - B (green) PK-23I4

-EG139757 . B (green) PK-2328 NK13957 Nonsafety HS-211A l(~

x o

k

+

9 I

y Rsvision: 1 Page 38 of 39

[ r'

. RESULTS REPORT A 'L' -

1 SAP 1.b.2

.. (Cont'd)

Table 2 i Final Separation Criteria for SERVICAIR flex to cable inside the Control. Boards and Vertical. Ventilation Panels Tefzel or Analyzed Non-Analyzed Non-Tefzel Non-Tefzel

. I Class IE Non-Class 1E Class 1E Non-Class IE Tefsel or ' Class-1E 1" 1" 6" 6" Analyzed _

Non-Tefzal Non-Class IE 1" X 1" X

- ('~'l LNon-analyzed kf Non-Tefzel-Non-Class 1E 6" X 6" X i

t. X - No Separation Required (Circuits are not redundant) l l

- -- , --w+- -,-,aw---n~-a w\--mw---wwww----------ww.,~m,---m----w-------r--r---------e a e v- r,r-,-m--- v- ,-- ---w--r- ,-,

4

~ '

Revision: 1 Page 39'of 39

[. L <

-RESULTS REPORT

,[ 's./L i ISAP I.b.2 '

(Cont'd)

Attachment 1 *

-Chronology of. Major Activities Related to Action Plan I.b.2

- July-September 1984- The NRC-TRT conducted onsite inspections, including a review of the Unit I control room control boards.

October 1984l The initial version of Action Plan I.b.2 was issued.

November 1984 -

.TUGC0 performed a post-construction January 1985 inspection of the Unit 1 control boards and T ' vertical ventilation panels. '

January'1985, A draftlof the circuit evaluation was prepared.

- February-April 1985 An inspection of the Unit I control boards

)-~g; and vertical ventilttion panels was performed i j by the CPRT third-party inspectors. l March 1985- Short circuit and heat transfer tests of SERVICAIR flex were performed.

l July 1985 DCA 21446 to Drawing 2323-El-1702-02, " Cable i and Raceway Separation Typical Details," was l issued. This DCA contained new criteria for SERVICAIR flex in the control boards and 1 vertical ventilation panels.

July.1985 Revision 1 of the circuit evaluation was issued.

October 1985 TUGC0 performed a reinspection of the Unit I control boards and vertical ventilation l panels using the final separation criteria. ,

March 1986 Revision 0 of the computer analysis of SERVICAIR flex was issued. ,

i January, May, and The CPRT Electrical Review Team examined Unit  ;

June 1986 1 and common area nulti-train panels to  !

determine where SERVICAIR flex had been used. '

(Future)

O' TUGC0 will perform a final inspection of the Unit I control boards and vertical l

ventilation panels using the final separation l criteria. This inspecticn will be overviewed l by the CPRT third-party.  !

- - . - _ - _ - - - _ = -- :

)

COMANCHE PEAK RESPONSE TEAM' RESULTS REPORT ISAP: V.a

Title:

Inspection for Certain Types of Skewed Welds in NF Supports REVISION 1 t

4 D ,2bl Issue Coordinator e in +/5 '

Date /

' I KeviediTeam Leider' V

]l/ ~

Date nin/rs Y' ^^$- fpf2,1fSG

.76hn W. Beck, Chairman CPRT-SRT Date O

l v

+---w w 4 --- --. ,,.w--.__ ypy, ...pr--m---w_-...-- ----,v----- ----.r-----my,- ,-y .- ,_ _ - - -- , . - - - - -%,+---- -,w.-,- -- - - _ , -

gca +

Revision: I g ~

Page 1 of 57 4., . ,

T

). RESULTS REPORT

_ y-ISAP V.a Inspection for Certain Types of Skewed Welds in NF Supports

'1,0 . DESCRIPTION OF ISSUE IDENTIFIED BY NRC-The'NRC Staff's position on this-issue along with their evaluation is presented in Supplements 10 and 13 to the Safety Evaluation Report ~(SSER 10'and SSER 13) for the CPSES (References 9.1 and ,

9.2). The following excerpts from pages N-327 and N-328 of SSER-10

describe this technical issue:

"( Y "The TRT investigated inspection procedures of Brown & Root (B&R) for welds in pipe supports designed to ASME III Code, i Subsection NF. The TRT found that no fillet weld inspection criteria existed for certain types.of skewed welds. By definition, skewed welds are those welds joining (1) two non-perpendicular or non-colinear structural members, or (2) two members with curved surfaces or curved cross sections, such as a pipe stanchion (a section of pipe used as a structural member) welded to another pipe stanchion or to a curved pipe pad. Notice that for type-2, the effect of 1(T curvature at the weld connection induces skewed

\_sI considerations, even though the two joining members are

' physically perpendicular. The B&R weld inspection procedures CP-QAP-12.1 and QI-QAP-11.1-28 for NF supports have addressed type (1) skewed welds; however, the TRT found that 1 QI-QAP-11.1-28 did not include veld inspection criteria for )

type-2 skewed welds. Although the TRT was told by Brown & i Root personnel that procedure QI-QAP-11.1-26 for piping weld l inspection was used, since such weld connections were similar )

i in configuration to a pressure boundary stanchion attachment l

. weld, no evidence documenting the use of this inspection  ;

procedure was provided to the TRT. According to records reviewed by the TRT, these welds were actually categorized as "all other welds" rather than " skewed welds" on the required QC checklist. Instead of using fillet weld gauges for l measuring the size of nonskewed welds, welders were supposed to use a straight edge and a steel scale'for measurement of a type-2 skewed weld, as described in QI-QAP-11.1-28. In addition, due to the variable profile along its curved weld connection, the weld size should have been measured at several different locations. The lack of inspection criteria and lack of verification of proper inspection procedures being conducted for type-2 skewed welds are a violation of ASME Code for NF supports committed to by TUEC in FSAR Section 5.2.1 and a violation of Criterion KVII in Appendix B of 10CFR50.

l l

f.

l 1

p Revision: 1 Page 2 of.57

>D-

~

RESULTS REPORT Q ):

ISAP V.a-(Cont'd)

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (Cont'd)

- .The TRT reviewed weld inspection procedures, weld data cards, and visually inspected several type-(2) skewed welds in randomly sampled NF supports where pipa stanchions were used.

Although the small~ sample of welds inspected by.the TRT are acceptable, due to deficiencies in inspection records and the apparent lack of inspection criteria, the TRT is not certain whether other type (2) skewed welds were inspected properly.

.This is a generic issue involving many NF supports in various safety-related systems. The lack of documented inspections and criteria for type (2) skewed welds in NF supports represents a safety concern regarding the possible existence of under-sized welds in supports which are required to resist

.various design loads."

2.0 ACTION-IDENTIFIED BY NRC p The NRC (Reference.9.1) identified that the following action should

(): be taken on this issue:

"Accordingly,.TUEC shall (1)" Revise Brown & Root weld inspection procedures CP-QAP-21.1 [ sic]* and QI-QAP-11.1-28 to properly address type (2) skewed welds of stanchion to stanchion and stanchion to pipe pad; and (2) provide evidence to verify that previous inspections of these types of skewed welds were performed to the appropriate procedures."

3.0 BACKGROUND

SSER-10 focuses the issue on the inspection methodology and determination of weld size for type-2 skewed welds only. The procedures used for the measurement of type-2 skewed welds, the measurement techniques and methods for documenting the results of these measurements have changed during the construction of the CPSES. The history of these changes and their significance are discussed in Section 5.1 of this report. A summary of those aspects most pertinent to the formulation of this action plan is provided below within this section.

• NRC letter incorrectly cited CP-QAP-12.1 as CP-QAP-21.1.

~

lWl p- Revision: 1 Page 3 of 57

) RESULTS' REPORT ISAP V.a  !

(Cont'd) l

3.0 BACKGROUND

(Cont'd) -

3.1~. Inspection of Type-2 Skewed Fillet Welds l On September 3, 1982, Revision 12 of inspection procedure QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports" was issued. This established inspection methodology which addressed measurement of type-2 skewed fillet welds. Inspection procedures in place prior to this time did not include specific instructions for

, measurements of these welds.

On March 18, 1983,~ Revision 5 of inspection procedure CP-QAP-12.1, "ASME Section III Installation Verification and N-5 Certification", was issued. A program iras initiated to reinspect all accessible NF welds using a checklist created in the revision. The documentation for the reinspection was not

. specific to individual welds, instead it covered all the welds for the support. The CP-QAP-12.1 checklist had two entries for the welds; one for skewed welds, another for all other pd ' welds. On the CPSES project, type-2 skewed welds were termed

" stanchion welds"; therefore, supports with stanchion welds and no'other skewed welds had no entry or "N/A" under the checklist item for skewed welds. Although the project intended that the reinspection program would ensure proper measurement of all the type-2 skewed fillet welds, the records in themselves cannot provide conclusive evidence of this. The source of the ambiguity was in the terminology used in inspection procedures and documentation for skewed welds.

Given the me:. hods of measurement for type-2 skewed fillet welds prior to September 3, 1982 and the nature of the N5 reinspection documentation, review of the documentation by itself could not be used to verify the size of the welds initially inspected prior to September 3, 1982.

Initial inspectione performed after September 3, 1982 were controlled by the procedures which included updated inspection methods. Additionally, documentation of inspections underwent significant upgrade. The documentation of skewed fillet welds which are also pressure boundary welds is weld specific using Weld Data Cards. On December 15, 1982, weld mapping was instituted for non-pressure boundary fillet velds thereby providing weld specific documentation.

k' I

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.. n -, -- - . - , , . - - - - - ~

T' '

. Revision: 1

{ PaFe 4 of 57 yy RESULTS REPORT

[d'?

ISAP V.a (Cont'd) 3.'O BACKGROUND _(Cont'd)

In addition to the procedures discussed above, inspection procedure QI-QAP-11.1-26. "ASME Pipe Fabrication and Installation. Inspections" was used directly or by reference to I

define inspection methods for type-2 skewed fillet welds, and

-is reviewed in Section 5.2 herein.

3.2 Inspection of Full or Partial Penetration Reinforcement

~The inspection attribute which is the technical focus of this

'ISAP is the geometric and dimensional characteristics of the

' fillet veld in locations where simple fillet gauge measurement is not possible. In general, a similar inspection attribute does not exist for full or partial penetration welds.

However, if full or partial penetration welds call for reinforcement, the inspection of the dimensional aspects of

. -the reinforcement is similar to a fillet weld inspection.

gs Such reinforcement is not commonly used for skewed welds but 4,,) .

where they_are used, the action plan has included them.

4.0 CPRT ACTION PLAN

'The' objective of this action plan was to provide reasonable

assurance that-the as-built type-2 skewed welds on NF pipe supports

' meet the dimensions specified by the design requirements.

A review of inspection procedures and documentation methods indicated a need for a program to assess the documentation methods and verify on a random sampling basis, that type-2 skewed welds meet the design requirements. Some of the post-September 1982 records do provide sufficient documentation to attest to the adequacy of the dimensions of individual type-2 skewed welds.

However, due to the time phased implementation of the procedure

revisions described in Section 3.1, sample reinspection of the entire population of type-2 skewed welds was considered to be more effective than a document review combined with sample reinspection of the part of the population that has ambiguous inspection records, o

, _ _ _ _ _ , . . _ _ _. ~ - - . - .

Revision: 1 Page 5 of 57 RESULTS REPORT

.(x_-{-

ISAP V.a (Cont'd) 4.0 ,.CPRT ACTION. PLAN (Cont'd)

^

4.1-' Scope and Methodology 4.1.1 The chronology of measurement techniques and documentation methods used for the inspection of type-2 skewed welds was prepared (Reference 9.3). This

. chronology was used in the evaluation of the results of the sample reinspections, and to identify the-4 procedures used for' type-2 skewed weld inspections that have'not been superseded by subsequent inspections.

4.1.2' Inspection procedures;QI-QAP-11.1-26, QI-QAP-11.1-28 and CP-QAP-12.1 were reviewed to determine if the method of inspection that was included for type-2 skewed weld inspections was adequate to address the unique aspects of skewed weld dimensional configurations. Procedure QI-QAP-11.1-28 was revised (Revision 30) to directly include the measurement

'7s '

techniques for type-2 skewed welds and to eliminate the

( J . need for referencing other procedures for this measurement; the other procedures did not require

- revision.

4.1.3 .To assess the adequacy of inspection procedure implementation and to verify that design size requirements were met, a random sample of type-2 skewed welds was selected. This random sanple excluded the pressure boundary welds, which are not at issue. These samples wera selected from Unit 1 Unit 2 and common for. reinspection and review of inspection documentation. The samples were reinspected to inspection procedures which include specific '

measurement criteria for type-2 skewed welds. A sampling evaluation was appropriate since the objective was to determine if the procedural inadequacy related to the measurement of type-2 skewed welds actually resulted in the existence of undersized welds.

The sample plan was designed in accordance with Appendix D of the CPRT Program Plan, using a sample size of 60, with a detection number of zero (i.e., the critical region was one or more deficiency found in the sample). In this case a deficiency was defined as a weld in which the ASME Code allowable stress levels

() were exceeded.

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- -~ - . _ - ,

A1 Revision:

1 Page 6 of 57 t

RESULTS REPORT L(s.. l' -

IGAP V.a

, (Cont'd) 4.0' CPRT ACTION PLAN (Cont'd)

The action plan.also included provisions for sample .

expansion in accordance with Appendix D.if a l deficiency had been found, the evaluation of trends of deviations, and the assessment of root cause and 4 generic implications as required by Appendix E of the CPRT Program Plan.

- 4.2 Participants Roles and Respcasibilities '

The organizations and personnel that participated in this

-e ffort are' listed below with their respective scopes of work.

4.2.1 Comanche Peak Project Engineering 4.2.1.1 Scope '

Prepared inspection chronology g __) -

Reviewed procedures Revised procedures Assisted in evaluation of inspection results 4.2.1.2 Personnel

, Mr. C. Moehlman Project Mechanical O Engineer 4.2.2 Third-Party Overview 4.2.2.1 Scope Assessed procedural adequacy Verified sample selection i.

Reviewed reinspection instructions Reinspected welds (QA/QC Review Team) t

-(-

(

4

Revision: 1

,. Page 7 of 57

,[ RESULTS REPORT ISAP V.a M (Cont'd) 4.0~ CPRT ACTION PLAN-(Cont'd) ,

Evaluated weld reinspection results 1 Evaluated safety significance of i deviations Evaluated trends in the results of the measurements and documents reviewed Prepared Results Report 4.2.2.2 Personnel Mr. H. A. Levin TERA - CPRT Mechanical Review Team Leader Dr. J. R. Honekamp 46RA - CPRT TRT Technical

/~T. Manager

$.).

Mr. J. C. Miller TERA - CPRT TRT Issues Manager Mr. C. Spinks QA/QC Review Team (ERC) -

Inspection Supervisor Dr. F. A. Webster Jack Benjamin &

Associates (JBA), - CPRT Statistics Advisor Mr.'R. L. Shipp TERA - Senior Materials and Welding Engineer Mr. R. Sanan TERA - Senior Structural Engineer Issue Coordinator O

. - - --,e-- -, - , -.-,. ,.-.r. n-, me,-,- - ,-- ,- - ,y - -.,- -.-,r,-, .g - , - - . , . - - - -

a

' Revision: 1 Page 8 of 57 (y-)).; RESULTS REPORT

. ISAP V.a (Cont'd) ,

4.0 CPRT ACTION PLAN (Cont'd)-

4.3 -Personnel Qualification Requirement

Third-party participants in the implementation of this Action l Plan. net the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing

. procedures.1 Third-party inspectors were certified to the requirements of the third-party employer's Quality Assurance Program, and trained to ERC procedure QI-006 (Reference 9.8).

Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT. Program Plan.. Activities performed

- by other than third-party personnel were governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 ' Procedures

(')

\J.

ERC developed procedure QI-006 for the reinspection of skewed welds. This procedure was used by the QA/QC Review Team in

. this ISAP.

4.5 Standards / Acceptance Criteria The criteria for evaluating the acceptability of any weld determined to be less than specified size are the same as those defined in the ASNE Boiler and Pressure Vessel Code

. Section III, 4.6 Decision Criteria The results and conclusions of the physical reinspection of randomly selected type-2 skewed welds provided the basis for any modifications required to meet the design requirements.

No modifications were found necessary to meet design requirements.

8 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The implementation of this action plan involved: the development of a chronology of the procedures, inspection techniques and documentation methods used for the measurement of structural type-2

'()-

skewed welds; the review of scribe line and profile inspection techniques; and, a reinspection of type-2 skewed welds. The results of these investigations are summarized in the following

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Revision: 1 Page 9 of 57 v) RSSULTS REPORT ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) sections of this report. Additional sections are included to discuss safety significance, trend analysis, out of scope findings, and address the direct concern of the NRC related to the root cause and generic implications of this issue.

5.1 Chronology of the Inspection of Type-2 Skewed Welds A chronology of the procedures, inspection techniques and documentation methods used for the measurement of the type-2 skewed welds was prepared by the Project (Reference 9.3) and reviewed by the third-party. The results of this review are described in this section.

Figure 1 shows the geometry of a typical type-2 skewed weld that results when two curved support members are joined using a fillet veld. As indicated in Figure 1, the size of the fillet weld leg on one side of the weld can be measured with a 75 fillet veld gauge or a straight edge ruler since the reference ,

~~(,,/ . point for this measurement is a flat surface. However, this technique is difficult to use when measuring the size of the

, other leg since the reference point is a curved surface. For this measurement, two techniques were provided in CPSES procedures. The first, referred to as the scribe line  ;

technique, utilizes a reference mark placed on the support member prior to welding as shown in Figure 1. The second, I referred to as the profile technique, utilizes a contour gauge  ;

as shown in Figure 2. Only the profile technique can be used l for reinspections of completed welds if the scribe lines were not placed prior to welding. In addition, where scribe lines were used for the original inspection they are generally not visible during reinspection if the support has been painted.

The inspection techniques used and the methods of documenting the inspections of type-2 skewed welds changed with time and involved the following procedures:

QI-QAP-11.1-26: which addressed the fabrication, installation and inspection of ASME pipe and attachments welded to the pipe.

QI-QAP-11.1-28: which addressed the fabrication, installation and inspection of ASME pipe supports

except for attachments welded to the pipe.

Revision: 1 Page 10 of 57 s ) RESULTS REPORT

-- ISAP V.a (Cont'd)

- 5.0 IMPLDfENTATION OF ACTION PLAN AND DISCUSSION OP RESULTS (Cont'd)

CP-QAP-12.1: which addressed the final verification of ASME. pipe supports prior to certification (preparation of the ASME N-5 form).

Table 1 provides a chronology of the key events related to the measurement of type-2 skewed welds. As indicated in Table 1, specific criteria for the measurement of' skewed fillet welds

. _ were provided for the first time in September 1982 by L*

-Revisions 12 and 13 of QI-QAP-11.1-28. The scribe line

-technique was the only inspection method included in the

,- procedure at that time.

Three months later (December 15, 1982) the type-2 skewed weld incpection methodology was moved from the pipe support  !

procedure (QI-QAP-11.1-28, Revision 16) to the piping procedure (QI-QAP-11.1-26, Revision 9) on the basis that most l

- of the type-2 skewed welds were attachment welds to the pipe

-p

'd and thus fell within the scope of the piping procedure.

The pipe support procedure referred to the piping procedure for all welds which attached support members to the pipe but said nothing about the type-2 skewed welds that were not pipe attachment (pressure boundary) welds. This question was

. addressed by a Brown & Root instruction to inspectors QCWI-1 (Reference 9.4) which stated that skewed fillet welds attaching pipe stanchions to pipe saddles (i.e., welds that were not attachments to the pipe itself) were to be inspected in accordance with the skewed weld inspection instructions in QI-QAP-11.1-26 for piping attachment welds. While this instruction provided clear direction for the inspection of the type-2 skewed welds of concern to the TRT, this instruction was not reincorporated in the pipe support procedure until about two years later (January 25, 1985).

The third-party reviewed training records associated with QCWI-1 and discussed its use with QC personnel who worked in  ;

the ASME inspection group at the time it was issued (Reference 1 9.5). Training records indicate that 21 inspectors were  ;

indoctrinated with respect to QCWI-1 the day after it was

, issued. However, based on discussions with QC personnel it  ;

appears that no further training specific to QCWI-1 was performed on the basis that QCWI-1 was not a procedure and )

that the information contained in QCWI-1 was intended to be

-h included in the training associated with the piping and suppert procedures themselves. Since QCWI-1 was only one sentence in length, such training is considered adequate.

'- )

Revision: 1 m

Page- 11 of 57 i,-

3 j. :

lRESULTS REPORT ISAP V.a (Cont'd) 2 5.0 : IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

In early 1983 a reinspection of all accessible structural welds on ASME supports was initiated to implement a commitment to NRC Region IV for a reinspection of type-1 skewed welds and to: resolve ~a concern related to excessive grinding of welds.

This reinspection was conducted as part of a broader inspection and document review related to ASME N-5 certification. N-5 is the data report signed and furnish =d by the NA stamp certificate holder for the fabrication and installation of the piping. As a result, weld reinspections were conducted and documented under procedure CP-QAP-12.1 which referenced the pipe support procedure (QI-QAP-11.1-28) for the inspection of skewed welds. The method of documentation of this reinspection was a check list which contained two entries (skewed welds and all other welds) to include all the welds-on the support. At that time the term

" skewed weld" was used by the Project to describe what is referred to by the TRT as a type-1 skewed weld and the ters

. (~T . " stanchion. weld" was used to describe the type-2 skewed weld.

In this 1983 reinspection the " skewed weld" checklist entry

- was intended to document the reinspection of type-1 skewed welds in compliance with the commitment to NRC Region IV.

In August 1983, the piping procedure (QI-QAP-11.1-26) was revised (Ravision 13) to add the profile technique for measurement of type-2 skewed welds. From this point on the piping procedure included both the scribe line and profile techniques for measurement of type-2 skewed welds.

In January 1985, the scribe line measurement technique was re-incorporated in the pipe support procedure (QI-QAP-11.1-28' , Revision 29). Three months later the profile technique was added to this procedure under Revision 30.

The method of documenting the results of type-2 skewed weld measurements depended on the measurement technique used and the procedure under which the inspection / reinspection was performed. For example, since December 1982 the pipe support procedure (QI-QAP-11.1-28, Revision 16) provided documentation of weld size measurements on an individual weld basis.

However, the reinspections performed in 1983 under CP-QAP-12.1 utilized a checklist with two entries (skewed welds and all other welds) to cover all the structural welds on a support.

O 4

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M Revision: 1 Page 12 of 57-

~,-

f;,

, L RESULTS-REPORT s...e :

ISAP V.a (Cont'd)-

~

] '5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Six different methods of documenting the results of type-2 -

skewed weld inspections were permitted by procedure at various times.- These methods were:

1. . HIR -

Hanger Inspsetion Report

2. CSC --

Component Support Checklist

3. NWDC -

Multiple Weld Data Card

4. WICL' -

Weld Inspection Checklist

5. CSF&SWIR --

Component Support Fillet and Skewed Weld Inspection Report

6. COT -

Construction Operation Traveler

(~% All but one of these methods were encountered in the records

\ml - for the 60 supports selected for reinspection under this action plan. However, the most common record was the CSC checklist used for the reinspection performed under CP-QAP-12.1.

5.2 Procedure Review As discussed.in Section 5.1, two techniques for the measurement of type-2 skewed welds were provided in the Brown

& Root procedures. ,The third-party has reviewed both ,

techniques and concluded that they are adequate to address the l unique dimensional aspects of the type-2 skewed weld configuration. However, for a two year period (December 15,  !

i 1982 to January 25, 1985) the pipe support inspection  ;

procedure (QI-QAP-11.1-28) did not include either technique except by reference to the piping inspection procedure '

I (QI-QAP-11.1-26). This discrepancy, which is the original concern identified by the TRT, was documented on DIR-E-1061 and submitted to the QA/QC Program Adequacy review team for classification under that program.

l The Project's intent that the inspection techniques for skewed welds in the piping procedure be used for inspection of skewed  ;

welds on pipe supports was clearly indicated by the Brown & 1 Root memo (QCWI-1) issued in February, 1983 (Reference 9.4). i n()~ However, training records specific to this instruction were not maintained. In addition, work sheets or other records l

documenting the inspection of type-2 skewed welds using the i I

.e-- , , , _ . . _ - , . , _ _ - , . , , , _.-,,,_m _,_m , . . . - - - - . . . ~ , . - . . . , - , , . , _ . _ -

Revision: 1

-' Page 13 of 57 ku

[( -

.RESULTS REPORT

.v

'S .ISAP V.a (Cont'd).

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

. techniques referenced in the piping inspection procedure were not required to be maintained for the reinspections performed under QI-QAP-12.1. Thus, for these reinspections, the inspection records do not indicate the inspection technique used.

A review of.the~ history of the applicable procedures indicated that at the start of the reinspection under CP-QAP-12.1

_(Revision 5 issued March 18, 1983) the piping inspection procedure (QI-QAP-11.1-26 Revision 10) contained only the scribe line inspection technique which is not applicable for reinspections. .The profile technique was added in Revision 13 of QI-QAP-11.1-26.(issued August 4,~1983). This revision of

, .QI-QAP-11.1-26 corresponds in time to Revision 8 of QI-QAP-12.1. The results of the document review performed under this action plan (Section 5.3) indicate that most of the

'reinspections were performed to revisions later than Revision 8 and when the profile technique was available. A summary of yf A_,v) the revision number and effective dates for procedure CP-QAP-12.1 and corresponding revisions of procedures

~QI-QAP-11.1-28 and QI-QAP-11.1-26 is provided as Table 2.

In-response to the concern raised by the TRT,.the Project revised the pipe support inspection procedure (QI-QAP-11.1-28) to include both techniques for inspection of type-2 skewed welds thus eliminating the need to refer to the piping procedure for this inspection. In addition, the Project identified and corrected an error in the scribe line measurement technique in both QI-QAP-11.1-26 and p QI-QAP-11.1-28. This error involved the omission of a factor that is necessary to correct the measured leg size (dimension C in-Figure 1) for the skewed angle in order to determine the skewed weld leg size (dimension S** in Figure 1). This error did not affect the reinspections performed under this action plan or the conclusions drawn from these data since these measurements were made using the profile technique.

~

The Project also concluded that revision of QI-QAP-12.1 to incorporate skewed weld inspection criteria was not required, since the weld reinspections under this procedure were complete. Future inspections or reinspections of skewed welds would be performed under QI-QAP-11.1-28. The third-party has reviewed the actions taken by the Project to revise the

. '()

b inspection procedures related to type-2 skewed welds and concurs that the changes made are adequate.

4 O

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b l

Revision: 1 Page 14 of 57 l

-1 1/ 'y RESULIS REPORT '

\m /i

- l 1

+ '

ISAP V.a. '

(Cont'd) l l

l I

. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION.0F RESULTS (Cont'd)

The' third-party also evaluated the potential impact of the error in the scribe line technique and the Project's corrective action as defined in TDDR No. PS-86-1973. The impact of the error on the weld stress level is directly proportional'to the reduccion in the effective throat size of the weld. The effective throat size (ETS) is the minimum

, -distance from the root of the weld to its face.and it is calculated from the weld size (dimensions S* and S** in Figure.1).

1

-The~ reduction.in ETS due to the error depends on the relative diameters of the two support members being welded and the angle at which these members intersect. If the diameter of the smaller member is less than or equal to 1/3 the no correction to the ETS

. diameter-of

.is. the larger required because membe{ defines the weld size as equal the Code to dimension "C" in Figure 1. Where the diameter ratio is f.

s greater than 1/3, the maximum reduction in ETS at a single point along the weld due to the error is 17%. While this could result in regions of some welde that do not meet the

- ASME weld size inspection criteria, the reduction in ETS for the weld as a whole is much less.

The results of the third-party evaluation (Reference 9.18) indicate that for 90' or "T" joints the reduction in ETS for the weld as a whole ranges from 0 to 6% depending on the relative diameters of the members. For oblique or "Y" joints the reduction in ETS for the weld as a whole ranges from 0 to 12% depending on the diameter ratio and the angle at which the two members intersect. Thus, while the error may have led to some weld regions which are undersize and require evaluation on a case-by-case basis, the increase in weld atzer levels is expected to be small (0 to 12% depending on the joint d+ sign).

l L The supports affected by the error are those with type-2 skewed welds that were measured by the scribe line technique and were excluded from the population sampled for reinspection under this action plan. The type-2 skewed welds excluded from the population sampled were those which attach to the pressure l-boundary and those that were accepted by QC after the sample was drawn in September 1985. Supports included in the 1

Code in this case refers to AWS D1.1. It is recognized that the (J controlling code for pipe support is ASME. However, the ASME code does not address skewed fillet weld joints for pipe supports. As a l result the standard industry practice is to utilize the definitions in AWS D1.1 for skewed fillet weld joint details. The supports however are designed, constructed and inspected in accordance with the ASME code requirements.

w k

Revision: 1

}- Page 15 of 57 RESULTS REPORT ISAT V.a g (Cont'd) e E

E 5.0 IMPLEMENTATIOh 0F ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) q population sampled for reinspection are not of concern since p undersize weld regions caused by this error would be detected p by the profile measurement technique used for the p reinspection. The third-party has reviewed the recommended 2 corrective action for TDDR No. PS-86-1973 and provided comments to the Project (Reference 9.18). The Project is developing a corrective action plan which will be overviewed E by the third-party in accordance with Appendix H of the CPRT e Program Plan.

! 5.3 Reinspection and Records Review of the Sample of Type-2 Skewed E Welds E 5.3.1 Population Determination and Sample Selection a

The population of supports with type-2 skewed welds was g

5 established as described in Reference 9.6. The basis was a list of all large bore pipe supports f

4 obtained from the Hanger Information Tracking System (HITS). All the d'.. wings listed on the HITS printout were reviewed to identify the supports that contained

[ one or more type-2 skewad welds. The accuracy of the HITS data base was verified by the third-party

[ (Reference 9.7). A total of three hundred fifty-nine (359) supports containing type-2 skewed welds were identified and a random sample of supports was selected g in accordance with Appendix D of the CPRT Program Plan.

E

The initial sample selection process was performed g without any screening. As a result nine (9) supports fabricated by Nuclear Power Services, Inc. (NPSI) and B one (1) support fabricated by ITT-Grinnell (ITT) were h

E inadver :ently included in the sample for reincpection (NPSI and ITT are pipe support fabrication firms).

y Since these supports were fabricated and inspected under the NPSI/ITT QA programs using NPSI/ITT i procedures and persennel they were removed from the j sample and additional supports were drawn at andom

? from the population of 359 total supports until 60

$ supports fabricated by Brown & Root were obtained. The y total number of supports fabricated by NPSI and ITT a that contain type-2 skewed welds is 32, or about 9% of 1 the total population of 359.

i

=

E I

E

( ._ . . , . . . . ,

3-

=

5 Revision: 1 ?

Page 16 of 57 i A

RESULTS REPORT ISAP V.a $

(Cont'd) 4 4

4 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) j The screening criteria used in establishing the final i sample were:

3

1) Exclude supports not fabricated by Brown & h Root.

2) Exclude supports where the type-2 skewed weld E was not complete (not yet fabricated). 4 1

3) Exclude supports where the type-2 skewed weld i had not been final inspected / accepted by 7 Brown & Root QC at the time the sample of sixty (60) supports was selected for reinspection uncer this action plan.

4) Exclude supports where there were no s structural type-2 skewed welds. ]

O 5) Exclude supports where more than 50% of the i 8

length of the type-2 skewed welds were inaccessible for e.aasurement using the {

profile technique.

3 2

1 As described in Section 1.0, the TRT concern related to j the procedures used by Brown & Root QC for the j inspection of type-2 skewed welds. Thus, the first 2 three screening criteria were intended to focus the f

sample on supports inspected by Brown & Root QC. The j fourth criterion deleted those welds which have a skewed B configuration but, because of their angle being greater a than 135' (see Figure 2), are not considered in the $,

support design analysis as a structural weld and thus are not required to be measured.

]

3 The last criterion was for the determination of accessibility. An accessibility criterion was f necessary to avoid biasing the sample with a number of -:

supports in which only a small portion of the weld was 4 measured. Inaccessible welds were those where j permanent plant equipment blocked the use of the A contour gage at the skewed weld. The need to remove j

insulation or erect scaffolding was not considered a 3 basis for a weld being inaccessible. The skewed welds in approximately 23% of the supports selected at random [

were determined to be inaccessible.

~

I

~'

a

J Revision: 1 Page 17 of 57 J

^

O RESULTS REPORT ,

1 ISAP V.a 5 (Cont'd) j

$ ~

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) il 5.3.2 Results of Reinspections '

The sample of sixty (60) Brown & Root supports $

g contained one hundred-two (102) type-2 skewed welds u with a total length of 2475 inches. Each type-2 skewed  ?

weld in the sample was reinspected by the QA/QC Review $

Team, a third-party organization, using ERC procedure [

QI-006 (Reference 9.8). This procedure utilized the A profile technique as described in Figure 2. The acceptance criteria applied for the weld size -;

measurement were as specified in ASME Section III subsection ND-4427 (W82). This cection of the ASME code allows welds to be undersized by up to 1/16-inch ,

for 2-inches or 10% of the length of the weld, 3 whichever is less. -i Y

Twelve (12) of the sixty (60) supports were found to j contain undersize weld regions that were in excess of y the ASME criteria. The total length of the undersize q regions was 79-1/2 inches or 3.2% of the total weld s4 length. Table 3 lists the supports found by the $

third-party inspectors to hav6 undersized welds and the e resultant NCRs issued by Brown & Root QC to document j these non-conforming conditions. As discussed in j Section 5.3.4, evaluation of these undersize welds by both the Project and the third-party concluded that in gc all cases the undersize welds were well within ASME 'I allowable stress levels. The results of these 3 inspection have been submitted to the QA/QC Review Team 3 for trending of construction deviations in their  ;

Quality of Construction program TReference 9.17). (

5.3.3 Results of Records Reviews T 9

The records of the original inspections for the sample h of 60 Brown & Root supports were reviewed to determine  :

which procedures were used to inspect the type-2 skewed j welds and if there were relationships which correlated g

~

with the undersize welds observed in the reinspections j performed under this action plan. The results of this =

review are listed in Table 4 and summarized in this section. -

~

. b J

a l

?p .n 3 -

k p

geesessvve- - - - . - - - - , - - - . - - - - - - - - - - - -

f$

Revision: 1  :

Page 18 of 57

' h

v

( RESULTS REPORT ISAP V.a (Cont'd) 5.0 ' IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

' All the supports in the sample have inspection records

~

corresponding.to procedures QI-QAP-11.1-28 or CP-QAP-12.1. The most common record (67%) was the

. Quality Control Component Support Checklist from '

CP-QAP-12.1. This is the checklist that contains two entries, skewed welds and other welds, to document the

-inspection of all welds on the support. This record does not indicate which measurement technique was used to inspect the type-2 skewed welds.

, Fourteen-(14) supports had a record documenting a QC inspection at fit up of the type-2 skewed weld. Since a fit up inspection was not required for these welds prict to (January 25, 1985) unless the scribe line technique was used to measure the size of the skewed weld, it is considered probable that these skewed weld were inspected using the scribe line technique.

(I A review of the relationship between the undersize welds found in the reinspection under this action plan

-and the Brown & Root inspectors who performed the original inspections indicated no correlation. The twelve supports with undersize welds were inspected by thirteen Brown & Root inspectors with several supports being inspected by more than one inspector. Eleven of these inspectors each had inspected only one of the supports found to contain undersize welds. The remaining two inspectors each had inspected two of the supports found to contain undersize welds.

A correlation is apparent if the sample is examined m the basis of those supports for which the records indicate that the scribe line technique was probably used. This group of 14 supports contained no undersize welds compared to a 4.1% occurrence for the remaining 46 supports in the sample or the 3.2% average rate for the sample as a whole.

A correlation can also be seen if the sample in i.

examined on the basis of whether the supports were inspected before or after the profile measurement technique was added to the piping inspection procedure (QI-QAP-11.1-26, Revision 13) on August 4, 1983. Table 4 indicates that of the 60 supports in the sample, 14

'~ were inspected before August 4, 1983, 43 supports were inspected after August 4, 1983 and 3 were inspected se - , ~ ~t a e w,. e-=w-r.,,,,--e-= ,we., ---,---,y

, >~e,..,--, ,-v-*= , w , . ,c --, - - -- - - - -<w--r---ee- --:,----v y w w-- , , ,rwv- n

s Y

• Revision: 1 Page- 19 of 57 W

1 RESULTS REPORT v )~

ISAP V.a

- (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN'AND DISCUSSION OF RESULTS (Cont'd) both before and after August 4, 1983. . Ignoring the 3 supports that were inspected both before and after

- August 4, 1983, the percentage of undersize welds for the. supports inspected before August 4, 1983 was 3.3%

campared to 1.4% for those inspected after August 4, 1983 when the profile technique was available. If the 14 supports that were probably inspected by the scribe line technique are eliminated from this comparison, the

trend persists, although not as strong (i.e., the

. percentage of undersize welds for supports inspected

- before August 4, 1983 becomes 3.3% compared to 2.1% for those inepected after August 4, 1983).

These correlations between the probable use of the scribe line technique or the introduction of the profile technique and a reduction in the rate of

. undersize welds support the TUGC0 contention that Brown

? f'%g. & Root QC inspectors were aware of the inspection

'\_/' methodology in the piping inspection procedure (QI-QAP-11.1-26) and the intent that this methodology

'should be used for measurement of type-2 skewed welds

that were not attachment welds to the pipe.

5.3.4 Safety Significance Each of the NCRs listed in Table 3 was evaluated by the Project pipe support engineering organization to determine the effect of the undersize condition. The Project calculations were also reviewed by the third-party (Reference 9.9) to determine if the observed deviations were safety-significant in i accordance with the CERT Program criteria. The results of both the Project and the third-party reviews i concluded that all the undersize welds were well within

' the ASME allowable stress levels and thus the deviations were not safety-significant. The NCRs were dispositioned appropriately, use-as-is.

In the course of this review the third-party issued two (2) Discrepancy / Issue Resolution Reports (DIRs:

D-0130, D-0133) to document discrepancies in the Project calculations related to the evaluation of the NCR conditions. These DIRs were classified as

,( ) observations' iince the' conclusion reached by the Project based on these calculations were correct, the errors were not programmatic in nature and the errors, if undetectid, would have had no effect.

=w-- w w m - -,-,,w, -m--e --y-+- ,v.-w -r - w-.-, .-w m3-- r---rv- -,,----sw.,--w--. .-m ,. -, w- -----. y --

y- - ,- -, --

.W

- .~-

Revision: 1 l

Page 20 of 57 l c H RESULTS REPORT ej -

U .S ,

ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

-5.3.5; Trend Analysis While none of the undersize welds was found to be safety-significant, the occurrence of undersize welds on twelve (12) supports in a sample of sixty (60) supports required evaluation in accordance with Append 2x E of the CPRT Program Plan to determine if these constituted an adverse trend. A trend is defined by the Program Plan as adverse if it is determined that i the identified pattern or commonality is likely to have  :

resulted in the occurrence of an undetected deficiency in the. affected area, population or stratum.

Figure 3 shows the distribution of the weld size measurements for the one hundred-two (102) type-2

- skewed welds in the sample of sixty (60) Brown & Root supports that were reinspected. In accordance with the f4 );

.q(_j inspection procedure, each weld was measured at 2 to 3 inch intervals along.its length. The data in Figure 3 were obtained by averaging the individual measurements

' for each leg of each weld, dividing by the design size of the fillet weld leg and selecting the leg that was the smallest fraction of the design size for that weld.

As can be seen from Figure 3 the aver 2ge size of the one hundred-two (102) type-2 skewed welds in the sample was 30% larger than required by the design.

Figure 3 also shows that about 10% of the welds were smaller than required by the design by amounts up to 25%. Since it was already known that none of these undersize welds exceeded the ASME allowable stress limits there was reason to believe that the design weld sizes contained significant margin. Therefore a statistical evaluation (Reference 9.10) of the margin in the as-measured weld sizes was performed to assess

. the probability of type-2 skewed welds in the population exceeding the ASME allowable stress levels.

Using the average measured size for each weld, the J-- maximum stress was recalculated for each of the one hundred-two (102) welds in the sample (References 9.11 m.

'~"

. and 9.15). The resulting stress levels were compared to each of the applicable ASME stress limits. Figure 4 shows the distribution of the limiting type-2 skewed r

y - - - --, - - - - ,-,,-= - ,-4 e, e-ww -y-w- ----,E-4 +-rw,, , . - - - - - - . . - - , . - - - - . - - - ,. - - - - - - , . . - - --.--w.-

, w

--j;"

. , Revision: 1 Page 21.of 57 l

It)Y:

S,] RESULTS REPORT l 1

ISAP V.a  !

a, a: (Cont'd) l l

5.0j. IMPLEMENTATION OF ACTION PLAN AND DISCUSSION'0F RESULTS (Cont'd) weld for each support.in the. sample as a percent of the controlling ASME limit for that weld. The most limiting weld stress in the' sample of sixty (60) supports was at 82.7% of the ASME' allowable stress.

The average limiting weld stress in the sample was 37.8% of the ASME allowable stress.

To assess;the likelihood of a type-2 skewed weld

~

exceeding the ASME allowable stress levels, the fraction of the populatioa above the ASME limits was calculated (Reference 9.10) at'the 50% confidence level and at'the 95% confidence level using a one-sided tolerance limit approach. - For this calculation a normal distribution was assumed. This assumption was tested and accepted at the 5% level of significance

- using the Chi-square and Wilks-W tests.  !

, 2 The results of these analyses-indicate that the best

" ~

estimate (50% confidence) of the fraction of the

- population above the ASME limits is 0.001. The 95%

confidence estimate of the fraction above the ASME ,

limits is 0.006. .

7 These statistical inferences are derived from the measurements and analyses of the 60 Brown & Root supports in the sample and hence represent the population from which they were drawn. Since screening

+

criteria were used in selecting the sample, it is necessary to consider the engineering significance of these criteria to determine the extent to which these inferences apply to the part of the population that was excluded from the sampling. The first four criteria

, excluded supports that were fabricated by NPSI,

. supports that were either not complete or not inspected and accepted, and supports for which the type-2 skewed

. welds were not required to be measured (see Section

5.3.1). The NPSI supports were fabricated and

inspected under a different program and hence have been analyzed as a separate group, not as part of this population (see Section 5.4). The supports that were

~

not complete or were not final inspected and accepted

~

' 38' at the time of the reinspection under this action plan f' are subject to inspection under the revised procedures

}( F which include specific instructions for type-2 skewed welds. Thus, these supports may not be representative

. of the work performed under the earlier procedures and t

d v ,-r- y- --no w, v< ,,,,-,-,-,y,---c.-,r, ,w ,, , rw-- - - reyrew .-w-w-w-ww.e,--,-,------_----ev---ew-r-r-----m- . r--= r-. - = = ---3 -----n- w--- w-- ------+s=- w e'r---sw*-. = - -Y

u; -

l

'. +%

i Revision: 1

+

Page 22 of 57  ;

g( f RESULTS REPORT ISAP V.a l (Cont'd)

. 5.0.. IMPLEMENTATION.0F ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

'have_not been included in this population. Supports with skewed welds that were not required to be measured were not included since they have no significance from

,,3 - either a structural or inspection view point. These four criteria resulted in the exclusion of 43.2% of the

" supports drawn at random from the total population of 359.

As discussed in Section 5.3.1 the accessibility criterion was applied to avoid biasing the results by including a number of supports in which less than half of the skewed weld length was available for measurement at this time. However, good access for inspection was available during the original inspection of these supports at the time the skewed welds were made. Thus -

it is reasonable to extend the results of statistical evaluation of the supports reinspected under this

/T action plan to include the inaccessible portion of the QsJ population. On this basis, the population size to be considered (accessible plus inaccessible) is estimated to be 204 supports. Using this population size the best estimate is that there are no supports that exceed the ASME limits. The 95% confidence estimate is that the number of supports exceeding the ASME allowable stress limits is one or less.

While this analysis clearly indicates that it is unlikely that any of the Brown & Root supports with type-2 skewed welds exceeding the ASME stress limits, an additional analysis (Reference 9.10) was performed to assess the likelihood of a type-2 skewed weld exceeding the allowable stress level by a significant j amount (i.e., yield). For this evaluation the ASME Level B stress values for the limiting type-2 skewed weld in each support were compared to the yield stress.

At the 95% confidence level the fraction of the population above yield was negligibly small (10-8),

Based on these evaluations it was concluded that the observed undersize type-2 skewed walds do not constitute an adverse trend.

v 4

d

.-,-,..-m-_ .. - _,,,_,n.wm___... ,_.-,y_,.m. w._,..,_,_m._,.___.,_,,_,..-.m._._m,.-____,o_..,

t -

Revision: 1 Page 23 of 57

.w.

i

-v 11 RESULTS REPORT ISAP V.a

, (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.4Sout of Scope Findings

.As discussed in~Section 5.3.1 prefabricated NPSI and ITT supports were inadvertently included in the sample for j reinspection. A total of nine (9) NPSI supports containing thirteen (13) type-2 skewed welds were reinspected. One of

- these NPSI supports (see Table 3) was found to contain an undersize weld. fThis non-conforming condition was evaluated by both the Project pipe support engineering group and the

third-party and found to be well within ASME allowable. stress levels. Thus, the deviation was not safety-significant and no corrective action was required.

. To evaluate the significance of this out of scope finding, a margin analysis, similar to that prepared for the Brown & Root supports was performed (Reference 9.10). Figure'5 shows the distribution of the average weld size for the smaller of the je'i two (2) fillet weld legs. As can be seen from Figure 5, the ,

LL_J: mean of the distribution is 134% of the design size and, on the basis of the average weld size, none of the welds were

'* less than the design size. The one weld that did not meet the weld size inspection criteria was undersize by 1/16 inch for a length of 3-1/2 inches.

Figure 6 shows the distribution of the limiting type-2 skewed weld in the NPSI supports reinspected as a percent of the controlling ASME limit for these welds. These results were obtained in the same manner as described in Section 5.3.2 for the Brown & Root supports (Reference 9.13). The most limiting ,

type-2 skewed weld was at 70.3% of the controlling ASME l allowable stress. The average of the type-2 skewed welds in the NPSI supports-reinspected was 26.5% of the controlling ASME allowable stress.

To assess the likelihood of a type-2 skewed weld on a NPSI support exceeding ASME allowable stress levels a statistical evaluation (Reference 9.10) of the results shown in Figure 6 was performed. Because of the small size of the population of NPSI supports with type-2 skewed welds a different approach was used for this evaluation than was used for the evaluation of the Brown ~&' Root supports. The evaluation of the NPSI supports involved the decennination 6f thdt" fraction.of the total type-2 skewed welds in the. complete NPSfisupport

() population'that may exceed the most limiting stress condition (i.e., greater than 70.3%) found for the type-2 skewed welds on the nine (9) NPSI supports that were reinspected. Based on

• ~_y- - ~ 3=_ j

• E.

, Revision: 1 Page 24 of 57 RESULTS REPORT IL) ...

ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) t this evaluation it is expected at the 50% confidence level that 92% of the type-2 skewed welds in NPSI supports will be

, s at or below 70.3% of the controlling ASME limit. At the 95%

s

_ confidence level, 76% of the NPSI type-2 skewed welds will be at or below 70.3% of the controlling ASME limit.

Since only one (1) of the thirteen (13) NPSI type-2 skewed

- welds reinspected was undersize, that weld was still well

. within the ASME allowable stress limits, and the NPSI type-2 skewed welds have considerable margin for minor weld size deviations, no further investigation of this out-of-scope

- finding was considered necessary.

5.5 Evaluation of Hypothesized Root Cause and Generic Implications The investigations performed under this action plan did not

, identify any deficiencies or adverse trends thus an evaluation

'of root cause and generic implications is not requir ed by th e is'%)-

Os_ CPRT Program Plan. However, the TRT (References 9.1 and 9.2) considered the root cause and generic implications aspects of this issue to be important since the question of adequate

- measurement techniques for skewed welds had been addressed by a previous (1982) Project corrective action. The TRT investigation concluded (Reference 9.1) that the 1982 corrective action appropriately addressed measurement of all skewed welds on non-ASME supports and type-1 skewed welds on ASME supports. However, the TRT did not find evidence in the

- inspection procedures or records that type-2 skewed welds on ASME supports had been correctly measured thus suggesting potential generic implications related to the effective completic . of other Project corrective actions at that time.

The investigations performed under this action plan indicate that the 1982 corrective action did include measurement of the type-2 skewed welds on ASME supports using appropriate i 1

techniques. This conclusion is based on:

Brown & Root memo QCWI-1 which clearly indicates that type-2 skewed welds on ASME supports were intended to be measured using the techniques provided in the piping inspection procedure (QI-QAP-11.1-26).

The results of the inspections and records reviews

~ ( )'- which indicate that 23% of the supports in the sample were probably inspected using the scribe line measurement technique contained in procedure

, QI-QAP-11.1-26.

< ,, . - , - - - - - ~ - - - - - -,v. ,--~~e.- -,-e----w--------w--,-w-,,--, . - , - , , , - , - , + , - ------,,--,m--,we- -------.,-w-----,n,n-ans.,o,--, --w en - ---

-r-

m .

g; Revision: 1 Page 25 of 57 R:

7 3;J - RESULTS REPORT J ,

ISAP V.a

. (Cont'd) b 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The results of the inspections and records reviews

.which indicate that adding the profile measurement technique'to procedure QI-QAP-11.1-26 reduced the rate of occurrence of undersize welds in the sample of supports reinspected.

Thus,'while the procedures and inspection records for the 1982 corrective action do not provide objective evidence that type-2 skewed welds on ASME supports were measured using the

, . techniques in procedure QI-QAP-11.1-26, the results of this action plan support the position that these techniques were

'e .used. Investigation of the possibility that other Project

~ corrective accions may not have been complete is included in

_ISAP VII.a.2, "Nonconformance and Corrective Actions System."

The existence of a group of welds that did not meet the weld size-inspection' criteria indicates that the 1982 corrective

.' action was not fully effective. However, as discussed in x- . Section 5.3.5 the average size of the type-2 skewed welds was larger than required by design and the extent of the weld undersize regions was small and not significant when compared to the large. margins provided in the design of these welds.

Thus further investigation of the population of type-2 skewed welds is not necessary. The results of this ISAP investigation have been submitted for Collective Evaluation to address the impact of all instances where CPRT investigations "

. have found that Project corrective actions were not fully effective (Reference 9.14). In addition, DIR-E-1061 has been submitted to the QA/QC Review Team for evaluation and classification under the QA/QC Program Adequacy program.

6.0 CONCLUSION

S The investigations performed under this action plan confirmed that the procedures of record (CP-QAP-12.1 and QI-QAP-11.1-28) for the inspection of Brown & Root pipe supports did not contain inspection criteria for type-2 skewed welds. However, acceptance criteria for type-2 skewed welds were contained in the piping inspection procedure (QI-QAP-11.1-26). This procedure also provided two

-measurement techniques for type-2 skawed welds during the period I when mos+. type-2 skewed welds were inspected.

G e

Rsvision: 1 Page 26 of 57 f,[,jQ RESULTS REPORT

^

ISAP V.a (Cont'd)

6.0 CONCLUSION

S (Cont'd)

Project correspondence indicates that it was intended that the

< inspection criteria and techniques in the piping procedure be used for inspection of type-2 skewed welds on pipe supports. In addition, trends observed in the results of the reinspections performed under this action plan support the position that the inspection criteria and techniques in the piping inspection fprocedure were usr,d for the inspection of type-2 skewed welds on pipe supports. The pipe support inspection procedure (QI-QAP-11.1-28) has been revised (Revision 30) to contain acceptance' criteria and techniques for the measurement of type-2 skewed welds thus eliminating the need to refer to the piping inspection procedure for this inspection.

The reinspection performed under this action plan provided

-reasonable asaurance that the type-2 skewed welds on Brown & Root pipe supports are within the ASME allowable stress levels.

Although twelve (12) suppcets were found to contain undersize welds, none of these weldt

. '-(~ ) aeded ASME stress limits. An evaluation of margin based .a che measured weld size indicates that

~

p it is not likely that any of the type-2 skewed welds in the plant exceed ASME limits.

A type-2 skewed weld on a vendor (NPSI) fabricated pipe support was found to be undersize. This undersize weld was also within the

.ASME strese limit. An evaluation of the margin in type-2 skewed welds fabricated by NPSI indicated that these supports have considerable margin for minor weld size deviations hence no further investigation was necessary, i

7.0 ONGOING ACTIVITIES

~~

The third-party will overview the corrective action for TDDR No.

PS-86-1973-in accordance with the requirements of Appendix H of the CPRT Progr.sm Plan.

l 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE 4 'w Brown & Root procedure QI-QAP-11.1-28 has been revised (Revision

30) to include acceptance criteria and measurement techniques for the inspection of type-2 skewed welds. Therefore, it is no longer necessary to refer to the piping inspection procedure

.O (QI-QAP-11.1-26) for this information. This should preclude future occurrence of this problem.

I

l

, Ravision: 1 l Page 27 of 57 l l

RESULTS REPORT

, ISAP V.a  !

-(Cont'd) )

i

9.0 REFERENCES

l 9.1 NUREG-0797,-Supplement No. 10. " Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric

' Station, Units.1'and 2", Concern / Allegation Number AQW-73, 7 LApril 1985.

9.2 NUREG-0797, Supplement No. 13, " Safety Evaluation Report '

Related to the Operations of Comanche Peak. Steam Electric Station, Units 1 and 2", Appendix B, page 2, May 1986.

9.3 TUGC0 Memo #CPP-18,148 from C. K. Moehlman to Doug Witt, "TRT Issue V.a and V.e Skewed Wald Inspection, Main Steam I.ine Installation", April 8, 1985. y 9.4 Brown E. Root Memo.fQCWI-1 from W. T. Sims, " Skewed Welds on

' Stanchions (NF)", February 21, 1983.

.9.5 TERA meno from J. Honekamp and R. Sanan to V.a File, " Summary p

d of h ecing with J. T. Blixt, Brow & Root Quality Engineering Supervisor", CPRT #477, June 5, 1986.

9.6 -.TUGC0 Memo #56078 from C. Moehlern revising CPPA #46,663,

-June 10, 1986.

9.7 ERC h ao #QA/QC-RT-200." Population Items List: Large Bcre Pipe Supports, Rigid", July 3, 1985.

9.8' ERC Procedure QI-006.

9.9 TERA h ao from R. Sanan to V.a File documenting the review by Rich Rotblatt of NCRs, June 19, 1986.

9.10 CPRT Calculation #JBA243-010 " Margins on the Maximum Stressed Skewed Welds", Revision 1, September 3, 1986.

9.11 TUGC0 b eo #CPPA-48,771 from J. J. Ryan to Claude Moehlman,

" Skewed Wald Study", February 3, 1986.

9.12 TERA b oo from R. Sanan to V.a File, July 2, 1986.

9.13 TUGC0 Memo #CPPA 49,046 from J. Ryan to Claude Moelhaan "CPSES Skewed Weld Study", February 5, 1986.

J-9.14 TERA Memo from J. Miller to J. Hansel regarding Collective Evaluation, September 5, 1986.

s t

,w,- ---, .w..,..,,.,,,_..,_..---,-,--.-,,, ~~- y vm-m-,ww-,m,--.--,,,,-wwr,---w,w--.,

Revision: 1

, Page 28 of 57 RESULTS REPORT (s_-)

ISAP V.a-(Cont'd)

9.0 REFERENCES

9.15-Memo from R. Sanan to V.a File September 11, 1986 documenting

' the review of References 9.11 and 9.13.

$f 9.16 QAP/DAP-Document Interface Transmittal Form # S-1055, September 18, 1986.

9.17 TERA Memo from J. R. Honekamp to J. Hansel, Trending Information on Undersize Type-2 Skewed Welds, September 17, 1986.

9.18 TERA Memo #ISAP L-003 from J. Honekamp to M. Chamberlain

" Comments.on the Proposed Corrective Action Plan for the Error in the Scribe Line Measurement Technique", October 9, 1986.

h s_ ' <

e I

i (1) ,

4 e

Revision: 1 Page 29"of 57 p.

'd RESULTS REPORT ISAP V.a (Cont'd)

Figure 1 Measurement of Typical Type-2 Skewed Weld Using the Scribe Line Technique

• To mooswo this .eid log size

! ST N ""***'**'d"

5#

d l

f - /

l TYPE-2 SMEWED An 'l b

'0 f  %

PPE pat >

/#MSJ [Dc I \ N s

'J..

1. # To moosure this weltf leg size establish scribe mark "A" 3 in.

from intersection of ports of fitup on ottochment. At final inspection, moosure '9" dimension

" and 34stract '9" from "A" to get "C"(A4 C). Scribe mark r,oy have to be shortened or lengthe esd to asit field conditions (if this is necessory, the QCl will erwetote the MWDC ocrordi ly to reflect te scribe merk Bur:ot . Locate scrit>

marks et 6 in, or 450 oround the PPE ,, //

' #M///

1

. e O

Revision: 1 Page 30 of 57 RESULTS REPORT ISAP V.a (Cont'd) -

Figure 2 .

Measurement of Typical Type-2 Skewed Weld Using the Profile Technique TYPE-2 SEED ELD C r C

\

i %s V fd,i

/ s 2.Tll".:l e- g.gy,,.;N .g= '.i:: m.a'"e%%  %-~

pe::::::lllll"2"3:2f. C'.hT TRAPSFER TE WELD PRWLE FROM TE CONTOUR GAUGE TO A WORK SEET g% ,

WING APROTRACTOR F GREATER TNAN 135,EASUE ANGLE 9 WELD SIZE I EASUREENT 5 NOT PEQUIED

\

l i

FOR EACH LOCATION FEQUIRING WELD SGE E ASUPEENT ESTASLISH TANENT N LIPE5 ON T4 WELD PROFLES TRA14 N FERRED TO TPE WORK SEET AND EASURE WELD SIZE '5"

\ N Ii\

i!

+

Revision: 1 Page 31 o'f 57 f'y,

- (,/ l RESULTS REPORT ISAP V.a (Cont'd)

Figure 3 Distribution of the Measured Size of Type-2 Skewed Welds in Sample Reinspection of Brown & Root Supports 100 -

angAN = 135,3 p/

(

.3 g

I 40 <

p

<a .

~

, 20 - '

b '

40 8'O 150 th0 153 id0 l$0 250 2hD AVERAG SIZE OF SIAALLER LEC  ;

(Pelt CENT OF MSIGN SIZE) 1 O

4

._ - _- .- - . - . . . . - - - - - - - - --- ----~ - - - -- ~ ~ - -- ~ ~ ' ~ " ~ ~ ~~~-

R2 vision: 1 Page 32 of 57 b RESULTS REPORT ISAP V.a (Cont'd)

Figure 4 Distribution of Margin to Controlling ASME Limit For Type-2 Skewed Welds in Brown & Root Supports ISO <

t

.C 00<

E ste37J E 33 E

g .

I

• E 40-g l

20-l

~

\

0 l'O 2'O 3'O $0 5'O $0 IO 8O $0 Ido PERCENT OF CONTROLl.ING ASE LIMIT FOR LIMITING TYPE-2 WELD ON SUPPORT

. O e

e 9

w - -

,-,-_,.,.,.-.,.,-._...,,,,,..,nn,,__,-._._,,,,,,_,,n, n--,___ _-n___,,,,. .n._,rs- ,,, l

Revision: 1 Page 33 of 57

( ..

kJ RESULTS REPORT ISAP V.a

.(Cont'd) v Figure 5 Distribution of the Measured Size of Type-2 Skewed Welds In the Sample of IEPSI Supports Reinspected l

l l

19-O - '"'

s -

6 e m.

E E

EN .0 K

20-40 50 $0 150 150 150 150 150 200 AVERA2 SIZE OF SMALLER LEC MR GNT OF DE54GH SIZE) t O

O

- - - , , - . . --n, ,. n. .n-, -------,---ern,,_n w_n-,~,,. .- - . - - . _ , , , , , - - - - - - - . . ,

n,--. .-n~--r,-,,-ww,.-,,,-,-,--n,._,.n,.n,-

Revision: , 1 Page 34 of 57 f

.RESULTS REPORT ISAP Y.a (Cont'd) -

Figure 6 Distribution of Margin to Controlling ASME Limit for Type-2 Skewad Welds in the Sample of NPSI Supports a

e

-9 ..

2. ..

.h4 ga .

a "- .

20 1 .

~

N k 0 l0 IO N N IO 8'O $0 150 PER NT OF CONTROLLING A$8E LlWT FOR LlWTING TYPE-2 WELD ON StPPORT i

O 6

e,-,--,--~--,, --,n--- r,,,.--- w-- n o- o w m m, n- w

~ .. . - - _ _ _ - _

a

< 4 Rsvision: 1 Page 35 of 57 l

f^N l

.3 _): RESULTS REPORT I ISAP V.a l

~(Cont'd) '

l

, . Tabla 1 l LKey Events Related to the Measurement of l Type-2 Skewed Welds l

l August'1982 l NRC Region-IV questions the measurement methodology and acceptance criteria for inspection of type-1 skewed welds. Brown & Root QC

' questions.the methodology and acceptance criteria for the measurement of type-2 skewed welds (stanchion welds) because of their similarity to

. type-1 skewed welds.. '

l l

' September 1982 1

- Inspection methodology and acceptance criteria for measurement of both '

- type-1 and type-2 skewed welds are added to the pipe support procedure 1 (QI-QAP-11.1-28 Revision 12 and Revision 13). At this time (9/1982)  ;

the only measurement technique specific to type-2 skewed welds included j

_()

v

- in the procedure was the scribe line method. '

. December 15, 1982

. The measurement methodology and acceptance criteria for type-2 skewed welds were moved from the pipe support procedure (QI-QAP-11.1-28, Revision 16) to the piping procedure (QI-QAP-11.1-26. Revision 9).

. February 21, 1983 Brown & Root instruction QCWI-1 was issued to inform inspectors to use the inspection methodology and acceptance criteria in the piping procedure (QI-QAP-11.1-26) when measuring type-2 skewed welds on pipe supports which are not attachment welds to the piping.

4 February / March 1983 4

Revisions 4 and 5 of procedure CP-QAP-12.1 were issued to initiate reinspection of all accessible structural welds on ASME supports. These reinspections were documented in accordance with the checklist in

' . CP-QAP-12.1 which contained two entries (skewed welds and all other welds) to cover measurement of all the structural welds on the support.

Auause 4, 1983

+ -

The profile technique for measuring the size of type-2 skewed welds was added to the piping procedure (QI-QAP-11.1-26, Revision 13). Inspection records indicate that most (72%) of the supports with type-2 skewed weld,s w p g ,ted after this date.

,. Rf

'~

f?!

Revision: 1 Page 36 of 57 g RESULTS REPORT ISAP V.a (Cont'd)

Table 1 (Cont'd)

January 25, 1985 The scribe iine technique for measurement of type-2 skewed welds was re-incorporated in the support procedure (QI-QAP-11.1-28, Revision 29).

April 25, 1985 The profile technique for measurement of type-2 skewed welds was added to the support procedure (QI-QAP-11.1-28, Revision 30). From this point on both piping and support inspection procedures contained both the scribe line and profile techniques for measurement of type-2 skewed welds.

O f

l

(

4 O

. - - - i

m 1

L

^

Rsvision: 1 Page 37 of 57

)L RESULTS REPORT ISAP V.a C (Cont'd)

Table 2 4.

Summary of Procedures CP-QAP-12.1, l QI-QAP-11.1-28, and QI-QAP-11.1

4 CP-QAP-12.1 Rev. No. and Corresponding Revision Corresponding Revision

Effective Dates of QI-QAP-11.1-28 of QI-QAP-11.1-26 Did Not Exist Rev. 0 (09/08/80) Rev. 0 (01/03/80)

Rev. 1 (09/11/80) Rev. 1 (02/06/80)

Rev. 2 (09/15/80) Rev. 2 (06/26/80)

- Rev. 3 (10/03/80) Rev. 3 (07/22/80)

,n

=KJ Rev. 4 (12/08/80) Rev. 4 (08/28/80)

Rev. 5 (01/17/81) Rev. 5 (04/29/81)

Rev. 6 (02/18/81) Rev. 6 (01/15/82 thru 02/21/82)

Rev. 7 (05/28/81)

Rev. 8 (01/15/82 thru 02/21/82)

Rev. 0 (02/22/82 Rev. 8 (02/22/82 Rev. 6 (02/22/82 thru 03/09/82) thru 03/09/82) thru 03/09/82)

Rev. 1 (03/10/82 Rev. 8 (03/10/82 One Day) Rev. 6 (03/10/82 thru 05/10/82) thru 03/11/82)

Rev. 9 (03/11/82 Rev. 7 (03/12/82 th:u (05/10/82) thru 04/14/82)

Rev. 8 (04/15/82 thru 05/10/82)

O i

1

m ,. . _9 , .

[ Ravlsion: I ft.- ,

Page' 38 of 57

( j- 'RESULTS REPORT ISAP V.a l(Cont'd)

Table 2 -

~(Cont'd)

L i~ CP-QAP-12.1

,Rev. No. and- Corresponding Revision Corresponding Revision

! Effective Dates' .of QI-QAP-11.1 of QI-QAP-11.1-26

,Rev.-2l(05/11/82 Rev. 9 (05/11/82 Rev 8 (05/11/82 fthru 05/10/82) thru 05/19/82) thru 05/19/82)

Rev. 3 (05/20/82 Rev. 9 .(05/20/82 Rev. 8 (05/02/82

.thru 02/01/83 thru 06/11/82) thru 12/15/82)

Rev. 10 (06/12/82 Rev. 9 (12/16/82

. thru 07/20/82) thru 02/01/83)

) Rev. 11 (07/21/82 thru 09/02/82)

Rev. 12 (09/03/82 thru 09/20/82)

Rev. 13 (09/21/82 #

thru 09/28/82)

Rev. 14 (09/29/82 thru 10/28/82)

Rev. 15 (10/29/82 thru 12/14/82)

Rev. 16 (12/15/83 thru (02/01/83)

Rev. 4 (02/02/83 Rev. 17 (02/02/83 Rev. 10 (02/02/83

, thru 03/17/83) thru 03/17/83) thru 03/17/83) 1

.Rev. 5 (03/18/83 Rev. 18 (03/18/83 Rev. 11 (03/18/83 thru 04/11/83) thru 04/11/83 thru 04/11/83) )

w --

k,(N{g "k('

a>

Ravision: 1 Page 39 of 57-Lb

['Y RESULTS REPORT-

', ISAP V.a n

(Cont'd) -

K Table.2

(Cont'd)

'CP-QAP-12.1 Rev..No.'and Corresponding Revision , Corresponding Revision Effective Dates of QI-QAP-11.1-28 of QI-QAP-11.1-26

^ Rev.- 6 (04/12/83 Rev. 19 (04/12/83 Rev. 12 (04/12/83 thru 06/28/83) thru 05/15/83) thru 06/28/86)

Rev. 20.(05/16/83 chru 06/28/83)

.Rev.,71 (06/29/83 Rev. 21 (06/29/83 Rev. 12 (06/29/83 thru 08/02/83) thru 08/02/83) thru 08/02/82)

C

'%)

Rev. 8 "(08/03/83 Rev. 21 (08/03/83 Rev. 12 (08/03/83 thru 08/18/83)' One Day Only) One Day Only)

Rev. 22 (08/04/83 Rev. 13 (08/04/83 thru 08/18/83) thru 08/18/83)

Rev. 9 (08/19/83 Rev. 22 (08/19/8'3 Rev. 13 (08/19/83 thru 12/27/83) thru 10/23/83) thru 09/12/83) l Rev. 23 (10/24/83 Rev. 14 (09/13/83 thru 12/27/83) thru 12/27/83)

Rev. 10 (12/28/83 Rev. 23 (12/28/83 Rev. 14 (12/28/83 thru 06/10/84) thru 04/17/84 thru 04/17/84)

Rev. 24 (04/18/84 Rev. 15 (04/18/84 thru 06/10/84) thru 06/10/84)

O ,

e

Rsvision: I g- Page 40.of 57

?(~'i -

RESULTS REPORT

. ; j.

ISAP V.a

'(Cont'd)  !

p Table 2

'(Cont'd)

.~ . CP-QAP-12.1 Rev. No..and ' Corresponding Revision Corresponding Revision Effective Dates ' of QI-QAP-11.1-28 of QI-QAP-11.1-26 Rev. 11 (06/11/84 Rev. 25 (06/11/84 Rev. 16 (06/11/84 thru 10/14/84) thru 10/14/84) thru 10/14/84)

Rev. 12 (10/15/84 Rev. 26 (10/15/84 Rev. 17 (10/15/84 thru 05/19/85) thru 11/14/84) thru 05/19/85)

Rev. 27 (11/15/84

,-ss thru 12/05/84)

Rev. 28 (12/06/84 thru 01/24/85)

Rev. 29 (01/25/85 thru 04/14/85) l Rev. 30 (04/15/85 thru 05/19/85)

Rev. 13 (05/20/85 Rev. 30 (05/20/85 Rev. 17 (05/20/85 thru 08/16/85) thru 06/29/85) thru 08/16/85)

Rev. 31 (06/30/85 i thru 08/16/85)

L l

Rev. 14 (08/17/85 Rev. 32 (08/17/85 Rev. 17 (08/17/85 l thru 11/19/85) thru 08/28/85) thru 11/19/85) {

Rev. 33 (08/29/85 Rev. 18 (11/20/85 thru 11/19/a5) --

, , (Completion of third-party q }_ review) e

,e.mmw-,wew---w *=1mr--wwww**-**"w="*h"*---

m.

t Revision: 1

< Page' 41 of 57 RESULTS REPORT .

v ISAP V.a (Cont'd)'

Table 2 (Cont'd)

CP-QAP-12.1.

Rev. No. and Corresponding Revision Corresponding Revision Effective Dates .of QI-QAP-11.1-28 of QI-QAP-11.1-26 Rev. 15 (11/20/85 _Rev. 34 (11/20/85

• thru 02/17/86) --

(Completion of third-party review)

Rev. 16-(02/18/86 thru 04/03/86) 0; Rev. 17 (04/04/86 (Completion of third-party review)

-O

^

Rzvision: 1 Page 42 of 57

=i ,

RESULTS' REPORT ISAP V.a (Cont'd)

Table 3

( Summary of Supports with Undersize Welds No. Random # NCR Support Number 1 7 M-17291 CT-2-005-403-S22K 2 8 XI-6/85-0183 CC-X-022-001-F43A >

3 24 XI-10/85-0186 CT-1-049-415-C92A 4- 43 XI-3/85-0180 MS-1-004-009-C62K 5 92 XI-4/85-0181 MS-1-002-008-C72K 6 129 XI-5/85-0182 BR-X-001-720-A53A 7 132 XI-7/85-0184 CC-1-087-004-A33A y_ .8 151 XI-8/85-0185 CT-1-042-401-C82A

~9 184 . XI-11/85-0187 CT-1-033-414-C92A 10 -186 XI-12/85-0202 CC-1-019-003-A33R 11 221 XI-859 CC-1-065-002-S33R 12 204 XI-21/85-0203 CC-1-173-012-S53A NPSI Support XI-2 SI-1-181-005-C41R Nv O

- g- , , - - - , y.., .,,,,,,,-,,---n---n-e-,-,----+,- - - - - , - - - - - --,-,..---,-,,-------,,,----,a -

,~ < , - . _ .

,-c

, (y - a , ..

N. l .

' Revt. ion: 1, Page .? 43 of 57 RESULTS REFGtT ISAP V a (Cont'd)

Table 4 1 QC Document Package Review for Skewed Welds i

s i '

Hingtr/ Support No. Unit Skewed B&R Inspect B4A Rev. Inspector . Checklist Comments-No. Weld Inspection Date . Procedure No. Type I Description No. *

. SI-2-071-405-S32K 2 1/4" Fillet Skewed Welds 12-14-84 QI-QAP-11.1-28 28 Rey QC-HIR I TS 6"x6"x3/8" MWDC to 3/4" Saddle

! CC-1-202-001-S53A 1 6"x6" x 1/2" TS Skewed Welds 11-16-83 CP-QAP-12.1 9 F. Coleman QC-CSC to MnOC 3/8" saddle 5/16" Fillet CT-2-00%-403-S22K 2 6"x6" x 3/8" TS Skewed Welds 9-14-84 QI-QAP-11.1-28 25 Clem Mathews .QC-HIR Note 1 to 1/2" saddle WICL 5/16" Fillet 6-23-82 QI-QAP-11.1-26 8 W.T. Jim MWC i

CC-X-022-001-F43A Common 10" Sch 80 Skewed Welds 04-13-83 QI-QAP-11.1-28 19 R. A11strom QC-CSC Note 1 Pipe to 3/4" MWDC l T saddle 1/2" fillet i

n Note 1: NCR condittori'in reinspection under ISAP V.a i Note 2: Fitup holdpoint for skewed weld checked on MWDC a

i

t s

V- (../

Revir, ion: . J1 Page L 44' of. 57 - H

,j RESULTS REFWT 4

-ISAP V.a (Cont'd) ,

. Table 4

.(Cont'd)

Hanger / Support No. Unit Skewed B6R inspect B6R Rev. Inspector Checklist Comments No. Weld Inspection .Date Procedure . No. Type Description No.

4 a

AF-2-101-431-S33A 1 3"Sch. 80 Skewed Welds 04-19-84 QI-QAP-11.1-28 ' 24 R.E. Ondracek QC-HIR Note 2' l to 1/2" saddle

5/16" groove + WICL l 1/8" x 1/4" Misc

, fillet ,

i l

i CC-2-158-408-A43K 2 6"x6"x1/2" TS Skewed Welds 11-17-83 CP-QAP-12.1 9 S. Sanders QC-CSC to WDC -

3/4" saddle 1/4" fillet i CC-1-009-016-A43A 1 8" Sch. 40 Skewed Welds 01-24-84 CP-QAP-12.1 10 S.. Sanders QC-CSC to 1/2" saddle WDC

1/4" groove +

1/2" fillet i

RH-1-001-010-C41K 1 6"x6"x1/2" TS Skewed Welds 08-26-83 CP-QAP-12.1 9 M. Ivey QC-CSC i to 1/2" saddle WDC

! 1/4" fillet i

-. . - +  :,r 7 ry _

.j

^

(f,,)

.( '..

V- 'G1 g .. . .

' Revision:' ~ 1: .

Pageje5of57.-- .j RESULTS REPORT ISAP V.s (Cont'd)

Table 4 (Oont'd)

Hanger / Support No. Unit Skewed B6A Inspect B&R Rev. Inspector Checklist Comments No. Weld Inspection Date Procedure No. Type Description No.

RC-1-146-003-C81K 1 2" Sch. 160 Skewed Welds 03-15-84 CP-QAP-12.1 10 W.C. QC-CSC to 1/2" saddle IM)C 1/4" fillet 09-08-83 CP-QAP-12.1 9 Anthony QC-CSC Linzy MIA)C CT-1-049-415-C92A 1 6" x 4" x 1/2"TS Skewed Welds 06/14/83 CP-QAP-12.1 6 J. Stanford QC-CSC Note 1 3 to 1/2" Saddle MIA)C 7/16" fillet

~

CC-2-116-006-F43A 2 12" Sch 40 Skewed Welds 4-20-83 CP-QAP-12.1 6 F. Evans QC-CSC' to 14" Sch 80 MIOC pipe stanchion QI-QAP-11.1-28 19 PWDC 5/6 fillet 12" SCH 40 to 6" SCH 40 1/4" fillet AF-2-006-412-S33A 2 6" Sch 80 Skewed Welds 02-29-84 QI-QAP-11.1-28 23 A. Linzy QC-HIR Note 2 to 1/2" plate C.S.

3/8" grove +

• Fillet 3/8" fillet and ,

skewed weld I.R.

)WDC a

.?

r ,\ ,

'.~ . ,)- s

~

. Revision': 'in Page ~ 46 of 57 l 2

RESULTS REFW T

,ISAP V.a (Cont'd)

Table 4 (Cont'd)

Hr.nger/ Support No. Unit Skewed B6R Inspect B&R Rev. Inspector Checklist Cossents No. Weld Inspection Date Procedure No. Type Description No.

RH-2-064-406-S22R 2 3"x3" x 1/4" TS Skewed Welds 08-31-84 QI-QAP-11.1-28 25 R. Duncan QC-HIR to Ma)C 1/2" saddle 3/16" Fillet RC-1-135-004-C51K 1 8"x8" x 1/2" TS Skewed Welds 02-14-83 CP-QAP-12.1 4 M. Kaplan- QC-CSC to and MEC 1/2" saddle W. Onadwick MbOC 5/16" fillet 08-16-83 8 C3-2-597-403-C42A 2 1/4" groove + Skewed Welds 03-27-85 QI-QAP-11.1-28 29 A. Linzy MdDC Note 2 3/16x1/4" fillet saddle to trunnion 4

CT-1-013-421-C82R 1 6" Sch 40 Skewed Welds 06-18-83 CP-QAP-12.1 6 J.Hassey QC-CSC to MEC 3/4" saddle 1/4" fillet

-3;7-W ; q;

i. )~ _

Revistan: 1' Page c 47 of 57 RESULTS REMRT ISAP V.a (Cont'd)

Table 4

.(Cont'd) 1 i'

Hanger / Support No. Unit Skewed BMt Inspect B&R Rev. . Inspector Checklist Comments No. Weld Inspection Date Procedure No. Type Description No.

MS-1-004-009-C62K 1 16" Sch 60 Skewed Welds 08-23-83 CP-QAP-12.1 9 R. Dalgle QC-CSC Note 1 pipe to Miec 1-1/2" T saddle 5/8" fillet 07-11-83 QI-QAP-11.1-28 21 J.R. Parker MWDC BR-X-106-059-S43A Common 4" Sch Skewed Welds 08-13-83 CP-QAP-12.1 8 J. Massey QC-CSC ,

80 to 3/8" ss MlSC pl. 3/16" fillet WICL 4" Sch 80 to QI-QAP-11.1-28 22 MWDC 6" 9 Sch 120 Stanchion 1/4" fillet AF-2-004-405-S33A 2 4"x6"x3/8" TS Skewed Welds 02-16-84 QI-QAP-11.1-28 23 Vaughn Frost WICL Note 2 to 1/2" T 160C saddle 3/8" -

groove + 3/16" x 3/8" fillet

.n- ..

.7y , ;

p ( ,.

~ -

. Revision:

~

' 1.

Page -48 of 57  ?..,

' ^

RESULTS REPORT -

ISAP V.a (Cont'd)

Table 4 (Cont'd)

Hanger / Support No. Unit Skewed BMt Inspect B&R Rev. Inspector. Checklist Comuments No. Weld Inspection Date Procedure No. Type Description No.

CT-2-039-404-C42A 2 3" Sch 80 Skewed Welds 05-19-85 QI-QAP-11.1-28 30 - C. Saengerhausen QC-HIR to 3/8" MlOC Saddle 1/4" fillet CC-1-035-018-A33A 1 5" Sch 40 Skewed Welds 10-21-83 CP-QAP-12.1 9 Eugene Ray QC-CSC to 3/8" MOC saddle 5/16" fillet DO-1-038-003-S63K 1 24" Sch 100 Skewed Welds 07-13-83 CP-QAP-12.1 7 M.C. Welch QC-CSC to 1/2" Saddle MlOC 1/4" fillet CT-2-038-404-C52A 2 4" x 2"x 1/4" TS Skewed Welds 03-22-84 QI-QAP-11.1-28 23 Jackie Barrett WICL to 1/2" saddle QC-HIR 1/4" fillet MlOC

=

3-(" N N) ,

'.d ~ '

Revision 1;

. Pqp 49 of 57 >

~

. arman asper ISAP V.a (Cont'd)

Table 4

-(Cont'd) '

Hanger / Support No. Unit Skewed B&R . Inspect B&R Rev. Inspector Checklist Comments No. Weld Inspection Date- Procedure - No. Type Description No.

MS-1-03-005-C72K 1 18" Sch 80 Skewed Welds 07-10-83 CP-qAP-12.1 7 A.R. Bagley QC-CSC to 1" saddle NGC 3/8" fillet SI-2-038-409-S22A 2 1/4" groove + Skewed Welds 08-23-84 QI-QAP-11.1-28 25 C. Swindell QC-HIR Note 2 1/4" fillet. EfDC TS 4"x4"x1/2" to saddle RH-2-016-401-S22K 2 5/16 groove + Skewed Welds 12/20/84 QI-QAP-11.1-28 28 M. Osterday QC-HIR Note 2 3/16 x 5/16 mfDC fillet 4"9 Trunnion to 3/4" saddle.

AF-1-002-033-Y33K 1 4*x4"x1/2" TS Skewed Welds 09-07-83 CP-QAP-12.1 9 F. L. Harper QC-CSC l to 3/4" ElDC l saddle 5/16" fillet 3

-.3

^

. ., Revision: .1 Page E 50 of 57

- EESULTS BEP ST ISAP V.a (Cont'd)

Table 4 (Cont'd)

Hanger / Support No. Unit Skewed 36R Inspect B&R Rev. Inspector Checklist Comments No. Weld Inspection Date Procedure Ilo. Type Description Ilo.

SW-2-035-703-JO3R 2 8"a8"x3/8" TS to Skewed Welds 06-29-83 CP-QAP-12.1 7 J. Staus QC-HIR 24" Sch 20 saddle Q1-QAP-11.1-28 21 feeC-3/16" fillet CC-I-079-006-A43A em 18" Sch 40 #==d Welds 09-26-83 CP-QAP-12.1 9 S. Duncan QC-CSC to 3/4" ledDC saddle 3/8" fillet MS-1-002-008-C72K 1 16" Sch 60 pipe Skewed Welds 02-10-84 CP-QAP-12.1 10 R. Daigle QC-CSC Note 1 to 1-1/4" T leeC saddle 1/2" fillet ,

CT-1-053-404-C62A 1 3" Sch 80 Skewed Welds 07-05-83 CP-QAP-12.1 7 M. Saldi QC-CSC to o ledDC 4" Sch 60 saddle 1/4" fillet

5 ( )

V v Revision: _1

..Page 51'of 57' 3

. EESULTS MPIRT

'o ISAP Y.a (Cont'd) -

Table 4 (Cont'd) -

Manger / Support No. Unit Shewed 36K Inspect B&R Rev. Inspector Checklist Comments No. Weld Inspection Date Procedure No. Type Descriptica No.

SI-1-037-005-S32A 1 6" Sch 80 Skawed Welds 10-03-83 CP-QAP-12.1 9 F. Coleman QC-CSC to 3/4" T ISOC saddle 1/2" fillet DD-1-012-033-Y33A 1 4" Sch 80 Skewed Welds 9-15-83 CP-QAP-12.1 9 Vaughn Prost QC-CSC Note 2 to IGEC 3/8" saddle 1/4" fillet b

CS-1-597-006-C42A 1 3" Sch 160 Skewed Welds 11-21-83 CP-QAP-12.1 9 D. Sanford QC-CSC to A" Sch 160 INDC saddle 1/4" fillet VA-I-05-716-A73K c-n 8" Sch 40 Skewed Welds 06-07-83 CP-QAP-12.1 6 P. Atkins QC-CSC ,

to IGEC 5/8" saddle 1/4" fillet

.W: , n Sr;

. Revision: '1 .

s Page -52 of 57 <

. MTt M ISAP V.a (Cont'd) i

! Table 4 3

(Cont'd) 9 i'

Manger / Support No. Unit Skewed 36R Inspect 36R Rev. Inspector Checklist Cosments j No. 11: 1 4 Inspection Date Procedure llo. Type

! Descriptica No.

i AF-2-084-401-S33A 2 6" Sch amS Skewed lields 6-8-85 QI-q4P-11.1-28 30 CG CS Fillet Note 2 I to 1/2" Saddle and skewed j 7/8" groove and wcld Insp

( 7/16" x 7/8" Report

} fillet ISfDC ,,

4 i

I l BR-X-001-720-A53A Connon 3" Sch 160 Skewed W ids 7-25-83 CP-qAP-12.1 7 Misich QC-CSC Note 1 i to feeC 1/2" T saddle j 3/8" fillet 1

J CC-1-087-004-A33A 1 8"x8"x5/8" TS Skewed lields 5-17-84 QI-q&P-11.1-28 24 C. D.na8herty QC-IIIR Note 1 to saddle 78mC j 3/8" groove + -

3 3/8" fillet 4

CC-1-135-008-C41K 1 6"x6"x5/8" TS Skewed nields 10-5-83 CP-q&P-12.1 9 R. Sontand QC-CSC j to 3/4" saddle P8mc 1

1/4" fillet 1

)

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Reviatens . '1-Page 53 of__57.

MSUL15 MfWT ISAP T.a (Cont'd)

Table 4 (Cont'd) -

(

Ranger / Support No. 13 nit Shmued . BER Inspect B&R Bew. Inspector ' Checklist Comments No. Wald Inspection Bote Procedure No. Type Description No.

CC-1-235-006-C53R 1 2" Sch 80 Skewed Welds 06-08-83 CP-q&P-12.1 6 Nouard Niggins qc-CSC to 3/8" ISSC saddle 1/4" fillet AF-2-009-413-S33A 2 4"Sch 160 to 3/4" Skaued Welds 7-11-e'. QI-q&P-11.1-28 25 T. Coleman QC-HIR , Note 2 saddle 5/16" '

leac groove + 3/16mS/16" fillet CT-1-039-423-C42A 1 3" Sch 80 Skewed Welds 9-28-83 CP-qAP-12.1 9 J. Nessey . QC-CSC to 1/2" plate DeBC 1/4" fillet ,

CT-1-054-431-C42A 1 3" Sch 80 Skewed Welds 9-9-83 CP-Q&P-12.1 9 J.M. Rodgers QC-CSC to 5" Sch ledDC 120 saddle 1/4" fillet

n 1; G E s J .

Revision: 1 Page' 54 of 57 EESULTS RErtBT ISAP Y.a (Cont'd)

Table 4 (Cont'd)

I Hanger / Support No. Unit Skewed 36R Inapect 56R Rev. Inspector Checklist Comments No. nield Inspection Date Procedure No. Type Description No.

CT-1-042-401-C82A 1 6"x6"x1/2" TS to Skewed nields 12-8-83 CF-QAP-12.1 9 J. Lloyd QC-CSC Note 1 4 1/2" saddle leeC

, 7/16" fillet db CT-2-127-403-C72A 2 6" Sch 40 Skewed lields 6-7-85 Q1-Q&P-11.1-28 30 R. Boykin CSF & Note 2

! to 1/2" saddle skewed j 1/4" groove + weld IR 1/8"x1/4" fillet feeC 1

l CT-1-127-403-C72A 1 6" Sch 80 Skewed nields 7-10-83 CP-Q&P-12.1 7 A.R. Bagley QC-CSC

] to 1/2" saddle ledDC 5/16" fillet 1

i MS-1-002-012-C72S 1 10"x6"z1/2" TS Skewed Welds 10-24-83 CF-QAF-12.1 9 Phil Brown QC-CSC

] To 1/2" saddle leiDC 1/4" Fillet

, w.

w _

Revisten:.. ' Page, 55 of 57

- RESULTS Mp4ET ISdP V.a (Cont'd)

Table 4 (Cont'd)

Hanser/ Support No. Unit Skewed BER Inspect BAR Rev. Inspector CheckItst Comments No. Wald Inspectica Date Procedure No. Type Description No.

CC-1-065-003-S33R 1 6" Sch 80 Skewed Welds 12-06-83 CP-qAP-12.1 9 F. Colemme qc-CSC (Stanchion) IGSC to 3/4" plate 3/8" fillet Im-1-012-724-A33A 1 3" pipe Skaued Welds 09-09-83 CP-qeP-12.1 9 Scott Duncan qc-CSC to 5'1 Sch 120 MWDC

• saddle 3/16" fillet i

MS-1-003-009-C72K 1 3/4" fillet for Skewed Welds 12-02-83 CP-q&P-12.1 9 M. Cannon QC-CSC i 10" Sch 140 #GdDC l to 20" Sch 80 J. Massey I

j CT-1-033-414-C92A 1 4"m4"x1/2" IS Skewed Welds 7-2-83 CP-q&P-12.1 7 J. Lloyd QC-CSC Note 1 i to 1/2" saddle temC 5/16" fillet t .

i (X:-1-019-003-A33R 1 16" Sch 40 to Skewed Welds 08-30-83 CP-qAP-12.1 9 Brian Coffin QC-CSC Note 1

! 3/4" saddle ledDC l 3/8" fillet 1

1

- ~

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,f Revistem: l' ,

Page 56 of 57 .

~

. RESIR.TS MMET ISAP Y.a (Cont'd) i

Table 4 i (Cont'd) i i

f Banger / Support No. Unit Sksued BER t Inayect B6R Rev. Inspector Checklist Comments l No. Wald Inspectica Date Procedere llo. Type Descriptica Ito.

l l

CC-2-028-414-S33It 2 8" Sch 40 to 3/4" Skewed Walds 10-24-84 qI-q&P-11.1-28 26 C. Swindell WICL Ilote 2 i

saddle 5/16" groove and 5/16"x qc-HIR

3/16" fillet

! 14" Sch 40 to 193DC f 3/4" saddle 7/16" groove +

7/16x1/4" fillet 1

i

, CC-1-109-005-A43A 1 8" Sch 40 Skewed Welds 12-01-83 CP-q&P-12.1 9. A.C. hamn QC-CSC 3 to 1/2" saddle ISBC 3/8" fillet .

(I:-1-173-012-S53A 1 4" Sch 80 to Skewed Welds 7-22-83 CP-qAP-12.1 7 M. Kaplan V-4 C - Note 1 1/2" saddle M.C. Welch ISBC 1/2" fillet l,

I-MS-2-416-405-S43R 2 6"x6"x3/8" TS Skewed Welds 6-25-85 QI-q&P-11.1-28 % R. L@in CSF and IEote 2 to 3/4" Skewed j saddle 3/8" groove weld 1.R.

+ 3/8" fillet ISEC i

l i

I. 9

Bevistem: 1 Page 57 of 57

. unosn m ISAP Y.a (Cont'd)

Table 4 i (Cont'd)

Ranger / Support No. Unit Showed R&R Inspect R&R Rev. Inspector. Checklist Comments No. Wald Inspection Date Procedure No. Type Description No.

CC-1-065-002-S3R 1 3/4" plate Skewed Welds 12-15-83 CP-qAP-12.1 9 F. Coleman QC-CSC Note 1 to 3/4" plate 78EC 5/16" fillet E-2-068-405-S33R 2 8" Sch 40 Skewed Welds 3-28-85 QI-qAP-11.1-28 29 C. Mathews WICL Note 2 to 1/2" saddle Groove and ISEC 5/32"x5/16" fillet AF-1-006-013-S33A 1 6" Sch 80 Skewed Welds 11-11-83 CP-qAP-12.1 9 K. Crider QC-CSC to 1/2" saddle 38dDC 3/4" fillet E 028-411-533K 2 3/4" saddle to Skaued Welds 01-21-85 QI-qAP-11.1-28 28 K. Mass 18dDC Note 2 TS 1/2"z8"z8" 5/16" fillet 02-07-85 29 K. Mass QC-HIR w ISOC

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- -s COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP VII.a.7

Title:

Housekeeping and System Cleanliness REVISION 1

, ~(

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ll*20 * $h Issue Coordinator Date L 0 (Lub ReWew team Leader ahohs Date' /

G4-.U.??e John W. Beck, Chairman CPRT-SRT u/zi/n.

Date

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m 4

-4.. -

Revision: 1

-c. Pags 1 of 36 A RESULTS REPORT U ,

ISAP VII.a.7 Housekeeping and Systes Cleanliness

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC 1.1 US NRC-TRT Letter January 8, 1985, Issue 9, Housekeeping and Systes Cleanliness "The TRT inspections at CPSES indicated that the facility was well-maintained. However, two issues were identified that indicate housekeeping and system cleanliness deficiencies. ,

A. The TRT reviewed the August 6, 1984, draft of flush procedure FP-55-08. The purpose of this procedure was to verify the cleanliness of Unit I reactor coolant loops, including the reactor vessel, by means of handwiping, visual inspection, and swipe testing.

Tests to determine surface chloride and fluoride contamination were performed by TUEC systems test engineers and Westinghouse representatives. The TRT notes, however, that FP-55-08 required only two swipe tests of the reactor vessel--one on the side and one on O the sotto - rhis ti ited nu ser of swi e9 tests ear net provide adequate assurance that the vessel had been properly cleaned.

B. In rooms 67, 72, and 74 of the Unit 2 Safeguards Building, the TRT ob?arved that not all snubbers were wrapped with protective covering when welding was being done in close proximity to them. This practice was a violation of Brown & Root procedure CP-CPM-14.1, which required protection of installed equipment during

welding. This condition was immediately corrected when the TRT reported it to TUEC QA management, and an

, inspection was performed by TUEC to correct similar

[ conditions in other areas as well."

1.2 NUREG-0797, Supplement 11 (SSER 11), May 1985 Housekeeping Issues (Catesory 5C)

"Two allegations were investigated by the QA/QC Group. The allegation relating to inadequate cleanliness controls during the early stages of construction (AQ-54) was substantiated.

L TUEC's QA surveillance inspections reported a substantial number of cleanliness procedure violations, which were subsequently corrected. The other allegation, concerning a supervisor's instructions to disregard some reactor vessel cleanliness control requirements (AQ-65), could not be i

O substantiated.

l

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Revision: 1

g; Pega 2 of 36

,A RESULTS REPORT r A.) ' ..

ISAP VII.a.7 (Cont'd) ,

11.0 DESCRIPTION

OF ISSUE (Cont'd) j The TRT assessed the current housekeeping system of cleanliness and equipment protection, performed a walkdown surveillance of Units 1 and 2, and reviewed cleanliness control procedures, and found that the overall program for detection and correction of housekeeping deficiencies appeared to be satisfactory.

During the QA/QC Group's assessment, two items were identified that require TUEC's action. The first pertains to the number of swipe tests required by draft procedure FP-55-08 to assure that the reactor vessel had been adequately cleaned. The second pertained to an observation that not all pipe support snubbers were protected from ongoing construction activity."

(Paragraph 3.2.7, QA/QC Category 5C, Page 0-13) 2.0 ACTION IDENTIFIED BY NRC

- Evaluate the TRT findings and consider the implications of

(^}

s-- these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT.

- Address the root cause of each finding and its generic implications...

<p - Address the collective significance of these deficiencies...

Propose an action plan...that will ensure that such problems do not occur in the future."

3.0 BACKGROUND

Previous NRC-TRT reports have requested specific actions to be

taken for deficiencies related to housekeeping and system cleanliness. Specifically, an NRC-TRT letter dated September 18, 1984, addressed NCR closeout for construction debris in the air gap of seismic Category I structures. Action Plan II.c was prepared to resolve that item. An NRC-TRT letter dated November 29, 1984, addressed the possibility of construction debris in the RV shield wall annulus. Action Plan VI.a was prepared to resolve that ites.

In addition, NRC-TRT letter, November 29, 1984 Item V.b alleged the possibility of debris in anchor bolt holes, but only requested

a v Revision: 1

g. -

Pags 3 of 36  ;

l

/-' RESULTS REPORT Af .

ISAP VII.a.7 (Cont'd)

'3.0' BACKGROUND (Cont'd) verification of anchor bolt length and replacement or justification if-required. As a-result of the NRC-TRT Items, a " critical spaces program" was initiated-through ISAP VI.a to assess the impact of construction debris.

t An additional discussion of previously identified problems and concerns is presented in Appendix 1.

JA preliminary review of the circumstances related to Reactor Coolant System (RCS) flush and cleanliness verification was

. performed to identify background data related to the issue raised in the NRC-TRT letter dated January 8, 1985, Item 9A [See Section i 1.1.Al. This background is summarized as follows:

- Visual inspection of all four (4) loops, steam generators, i reactor coolant pumps, and the reactor vessel and internals was conducted by Startup personnel prior to turnover to Startup. Startup accepted custody on February 18, 1982.

'r -

RCS loops were handwiped on several occasions between January,  ;

1982 and July, 1982 following ECCS flushes.

The RCS was cleaned, visually inspected, and tested for chloride residue preparatory to cold hydrostatic test. During cold hydro, water samples were taken and analyzed to assure water chemistry specifications were maintained (July 5, 1982 through August 7, 1982).

The RCS was cleaned and visually inspected again, preparatory to Hot Functional Test (HFT) (October 1982 through January 1983). During HTT, water samples were taken and analyzed to assure water chemistry specifications were maintained (February through May 1983).

- The RCS was periodically filled and drained during testing of other fluid systems.

4

- Cleaning was performed in accordance with Flush Plan FP 55-08 prior to turnover to Operations. Although the flush plan only required chloride residue swipes et two (2) locations, eight (8) swipes were actually taken by test lab technicisns. The RCS was turned over to Operations in October, 1984 following

< final QA acceptance of system cleanliness.

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~

RESULTS REPORT

'_ 'y ,

ISAP VII.a.7 )

(Cont'd) '

l

'3.0' BACKGROUND (Cont'd)  ;

A preliminary review of protection of components frr.m adjacent welding activities (NRC-TRT letter, January.8, 1985, Item 9B) was i not performed, since the NRC-TRT evaluation, as documented in SSER 11,-Allegation AQ-54, page 0-159, concluded that " Based on its review of records of QC surveillances for January and February, 1979 and inspection reports for 1981 and 1982 the TRT finds some merit in the allegation relating to inadequate cleanliness controls during the early stages of construction. The TRT concludes that the cleanliness controls implemented since 1981 indicate that management recognized the cleanliness problem and implemented procedures to correct it."

4.0 CPRT ACTION PLAN -

4.1 Scope and Methodology This Issue-Specific Action Plan assessed the adequacy of the j( ) housekeeping and system cleanliness program at CPSES.

The following tasks were implemented to achieve this objective:

Reviewed TUGC0 and Brown & Root procedures for establishment of housekeeping and cleanliness measures (including surveillance requirements).

Evaluated implementation of FP 55-08 for Reactor Vessel cleanliness.

Reviewed and evaluated implementation of TUGC0 and Brown & Root Surveillance program by observation of performance of surveillances and review of records.

Reviewed the preliminary results of ISAPs II.c and VI.a for adverse trends related to housekeeping and system cleanliness.

The specific methodology is described below.

4.1.1 Housekeeping and System Cleanliness procedures were reviewed to determine if the requirements of 10CFR50 Appendix B and the FSAR are included. Procedural

=-

controls for site and plant surveillance were also reviewed.

se Rsvision: 1 Paga 5 of 36 ve -

y sg RESULTS REPORT L. f ' '

ISAP VII.a.7 (Cont'd) l

.4.0 CPRT ACTION. PLAN (Cont'd) 4.1.2 The TUGC0 flush procedures for verifying cleanliness of the Reactor Coolant Loops, including FP 55-08, as referenced in Item 9A of the NRC-TRT letter dated January 8, 1985, were reviewed to determine the adequacy of swipe testing performed in accordance with the Westinghouse guidelines. Also, the adequacy of the flushing and associated swipe. testing performed on the

< reactor coolant system was verified. Other Review Team Leaders participated in discussions with TUGC0 and Westinghouse to aid in the determination of the adequacy of the swipe testing performed on the Reactor Coolant System, as well as the procedural requirement for two (2) swipe tests of the Reactor Vessel.

4.1.3 Plant areas (warehouses, laydown areas and in-place storage areas), both Unit I and Unit 2, were reviewed for evidence of housekeeping and system cleanliness

. . problems in conjunction with the TUGC0 surveillance

,(~] group. The results of these reviews were used to

%/ determine the effectiveness of the current Housekeeping and System Cleanliness Program. The reviews checked the following:

1 Access control to plant areas,

- - Any evidence of damage or deterioration to materials and equipment, and 0

Equipment protection from environmental and work induced conditions.

4.1.4 A review of TUGC0 documentation was conducted to establish the effectiveness of the current TUGC0

, Housekeeping and System Cleanliness Program. The j following documents were reviewed for related housekeeping and system cleanliness concerns:

- TUGC0 and Brown & Root audit reports, surveillance reports, inspection reports, NCRs, CARS, NRC reports and system cleanliness packages.

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Rsvision: 1 f #, ' - Page 6 of 36 REFULTS REPORT ISAP VII.a.7 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

, 4 .1". 5 The preliminary results of the following action plans were reviewed for housekeeping and system cleanliness

_ deviations

~

Action Plan II.c, Maintenance of Air Gap Between Concrete Structures - relates to construction debris in the air gap.

Action Plan VI.a. Cap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall - relates to construction debris in the gap between the RPVRI and the shield wall.

4.1.6 A detailed analysis was conducted on the data from the reviews in paragraphs 4.1.1 through 4.1.5. Data were analysed to determine if the current Housekeeping and iq System Cleanliness Program meets the requirements of g 10CFR50, Appendix B and the FSAR.

4.2 Participants Roles and Responsibilities 4.2.1 TUGCO, CPSES Project 4.2.1.1 TUGC0 assisted in identifying and locating applicable information and documentation to support the Review Team activities.

4.2.1.2 Personnel Mr. D. W. Snow TUGC0 QC Coordinator 4.2.2 CPRT-QA/QC Review Team 4.2.2.1 Scope All activities not identified in 4.2.1 above were the responsibility of the QA/QC Review Team.

O

Revision: 1

_y Prgs 7 of 36 73 RESULTS REPORT

~

a 5 ISAP VII.a.7 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2' Personnel (Prior to March 1, 1986)

Mr. J. L. Hansel QA/QC Review Team Leader Mr. S. L. Crawford Issue Coordinator 4.2.2.3 Personnel.(Starting March 1, 1986)

Mr. J. L. Hansel QA/QC Review Tesa Leader Mr. G. W. Ross Issue Coordinator 4.3 Qualifications of Personnel All personnel associated with analysis and evaluation of findings were qualified in accordance with the requirements of CPRT Program Plan.

- (' }

tio inspections were required during the L*plementation of this Action Plan; therefore inspection personnel certified in accordance with ANSI N45.2.6 were not required.

4.4 Procedures Matrices and data sheets were developed as an integral part of the evaluation. No formal procedures were required since no reinspections were performed.

4.5 Standards / Acceptance Criteria Housekeeping and System Cleanliness activities shall be in compliance with 10CFR50, Appendix B, and the associated commitments of CPSES/FSAR. Minimum acceptance criteria abstracted from these documents and from Westinghouse specifications are 4.5.1 Materials and equipment shall be protected from damage or deterioration during storage.

4.5.2 Implementation of procedure requirements shall be verified through surveillances or audits.

O

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Revision: 1 i g, Page 8 of 36 ,

Da s . RESULTS REPORT f i ISAP VII.a.7

, (Cont'd) 24.0 CPRT' ACTION PLAN (Cont'd)'

4.5.3 'Specisi environmental protection such as inert gas, humidity controlled or temperature controlled storage areas shall be provided for materials And equipment, when required.

4.5.4 Access control to plant and storage areas shall be maintained.

4.5.5 The number of swipe tests performed shall be sufficient to insure that the surfaces have been adequately cleaned and meet the chloride and fluoride

. limits of acceptance.

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The CPSES program for housekeeping and system cleanliness is based upon-10CFR50, Appendix B and the FSAR. Requirements from these documents are presented in Appendix 2.

{v .

Implementation of tha. specific tasks described in Section 4.1 is discussed in the following sections. Section 5.1 addresses Section 4.1.1; Section 5.2 addresses Sections 4.1.3 and 4.1.4; Sections 5.3 and 5.4 address Section 4.1.2; and Section 5.7 addresses Section 4.1.5.

5.1 Procedure Review 9

The procedures which describe the current CPSES program for housekeeping and system cleanliness controls and surveillance are shown in Appendix 3. These include B&R construction procedures and B&R and TUGC0 Construction and Startup/ Turnover (CST) quality procedures.

The B&R construction procedures define measures for .

housekeeping and cleanliness control which satisfy the program '

basis requirements shown in Appendix 2.

The B&R and TUGC0 CST quality procedures listed in Appendix 3 adequately address all of the elemente of an effective surveillance program with three minor exceptions. The TUGC0 and B&R quality procedures that define measures for surveillance or monitoring of site activities were reviewed to determine their adequacy in addressing the following elements

( ), of an effective housekeeping / storage surveillance program:

s - , --nn-,,a.,.__,__,,m,__ .v.--_,,- . - , , - - - , - ~ , - - - - , - - . , .

Ravision: 1

.; Paga 9 of 36

~

^c i RESULTS REPORT <

v: .

ISAP VII.a.7 (Cont'd)

~

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Applicable to all safety-related permanent plant equipment, Surveillance schedule required and minimum frequency defined.

- All storage areas defined.

- All work areas defined, Surveillance attributes / checklists defined.

' Verification of corrective action required for closure.

' Report distribution to appropriate organisations/ management for evaluation and trending defined, Retention of records as QA Records,

}

Applicable supplemental procedures referenced.

This listing of surveillance program elements was derived from 10CFR50 Appendix B, and the CPSES FSAR Section 17.

. Figure 1 is a matrix that depicts compliance of these procedures with the surveillance program elements listed.

The following are the minor procedural inadequacies:

Brown & Root CP-QAP-14.1, Revision 6, provides for Storage Surveillance of twenty-five (25) areas identified by Attachment I to the QAP. Surveillances are being performed for twenty-nine (29) areas. The areas not shown on Attachment 1 include: Area 26 - Safeguard Building EL 773', Area 27 - Safeguard Building EL 880',

Area 28 - Laydown Area East Reactor Building No. 2 Area 29 - Weld Qualification Training Center (WQTC)

Storage Area.

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Pags 10 of 36

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fN RESULTS REPORT Q- ,

ISAP'VII.a.7 4 -

(Cont'd) 5.0 -IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

CP-QAP-14.1, Revision 6, paragraph 3.1.b, states that

"...a copy of unsat SSR (Site Surveillance Reports]'

shall be given to the Assistant. Project Manager for resolution...".- A minimum distribution that would assure that surveillance reports are appropriately evaluated and trended should be defined in this procedure.

g TUGC0 DQP-SG-1, Revision 0, requires that surveillance checklists be prepared based upon the requirements of specifications, procedures, etc.. This appears to be

' adequate for surveillances other than housekeeping; however, since housekeeping requirements are stated in numerous procedures, it is appropriate to define surveillance attributes / criteria in DQP-SG-1 to preclude omissions.

As an alternate, a new site housekeeping procedure, consolidating all housekeeping requirements, could be developed.

5.2 Discussion of implementation of Plant Surveillances Brown & Root Two hundred six (206) B&R Site Surveillance Reports (SSRs) issued between January, 1985 and October, 1985 were reviewed.

Surveillances were conducted for twenty-nine (29) areas instead of the twenty-five (25) areas identified by CP-QAP-14.1, Attachment 1. These twenty-nine (29) areas included all applicable areas at the time of this site review.

The physical areas have changed somewhat from those shown on Attachment I due to site construction. The content and resolution of the 1985 B&R SSRs reviewed indicates that the surveillance program is being effectively implemented. Of the two hundred six (206) SSRs reviewed, eleven (11) identified unsatisfactory conditions which were subsequently corrected

.and the SSRs closed.

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-Revision: 1 ,

Lc Page 11 of 36

/i:

^

RESULTS REPORT  !

'D ^

ISAP VII.a.7

,. (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) y TUCCO A new-group of construction surveillance personnel was created at the direction of the site QC Manager in late 1985. This group performed surveillances of construction activities. A separate QA group performed surveillances on startup. In July, 1986, the surveillance program became the responsibility of the QA Manager and was implemented by the Surveillance Supervisor. Under his direqtion were a Construction Surveillance Lead and a Startup/ Turnover Surveillance Lead.

Each of these individuals supervised a group of surveillance specialists which performed the actual surveillances. In

-September, 1986, the responsibility for startup surveillances was transferred to TUGCO Operations QA.

The QA/QC Review Team observed the performance of seventeen (17) surveillances by TUGCO, nine (9) of which identified

_ housekeeping deficiencies. These deficiencies were reported

.( on irs and later verified to have been corrected. Discrepant items were identified, corrective action was verified and signed off by QC as satisfactory.

At the time of this review, the surveillance program was being implemented through CP-QP-19.0 Revision 4. Twenty-seven (27) surveillance reports from October,1985 to February,1986 involving housekeeping and system cleanliness were reviewed to

determine program adequacy. The Construction Surveillance j -

ggroup performed twenty (20) housekeeping surveillances and the l Startup Turnover Surveillance group performed seven (7) '

! surveillances involving system cleanliness verification.

Eleven (11) surveillances identified deficiencies which were

. documented on Surveillance Deficiency Reports (SDRs). Four (4) responses to the SDRs listed corrective action and actions to preclude recurrence. The remaining seven (7) SDRs listed corrective actions but did not address actions to preclude l recurrence; however, it was noted that the nature of the

! deficiencies was such that the corrective action alone was sufficient.  ;

From the review of surveillances performed since the

! implementation of CP-QP-19.0 Revision 4, it appears that the L controls for the housekeeping program are being utilized as l- outlined in the procedures. The content and resolution of l

surveillance reports reviewed indicates that the surveillance I

program is being effectively implemented.

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Revision: 1 Page 12 of 36 RESULTS REPORT ISAP VII.a.7 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Current implementation of housekeeping, cleanliness and l surveillance activities.is considered adequate to meet the l

- procedural requirements and appears to be effective in identifying and obtaining resolution of unsatisfactory conditions.

5.3 Discussion of Reactor-Vessel Cleanliness

.In the 3RC-TRT letter dated January 8, 1985, the TRT noted that TUGC0 flush procedure FF-55-08 required only two swipe tests for chloride'and fluoride surface contamination. The letter further stated that "This limited number of swipe tests may not provids adequate assurance thit the vessel had been properly cleaned.". The following is an evaluation of the adequacy of the swipe testing performed on the reactor vessel.

Westinghouse Cleaning Guidelines W During the course of evaluating the adequacy of the swipe bl. -testing performed, the QA/QC Review Team noted ambiguities in

-the Westinghouse (W) cleaning guidelines which could affect the acceptability of swipe test results. As the following discussion will show, these ambiguities concern the chloride surface contamination limits to be applied to the inside surfaces of piping systems, vessels, tanks and components.

-The chloride acceptance limit is defined with regard to surface condition (insula::ed/uninsulated) in one (W) document; and with regard to operating temperature (heated / unheated) in anotbre (W) document. The (W) documents do not distinguish between inside and outside surfaces with regard to chloride

-surface contamination limits. In response to a request for clarification, (W) ~

has indicated that inside surfaces should be considered as unheated (uninsulated). This clarification provides the guidance necessary for TUGC0 to define the chloride surface contamination acceptance limits clearly in procedures.

Westinghouse guidelines for cleaning and flushing are included in the following specifications and procedures:

Process Specification PS 292722, " Cleaning and Packaging Requirements of Equipment for use in the

- Nuclear Steam Supply System",

t_

i Process Specification PS 597760, " Cleanliness Requirements During Storage, Construction, Erection, and Startup Activiti,es",

- - - - _ - - .e .-- - - -- - - . - - _ _ . _ . , . - - - - . - ,--._m-, , - . , , - - . - - - , - - - , -

y , , , - , - - - - . ,

4'  ?,-4 Revision: 1 Page 13 of 36 RESULTS REPORT a(-- .

ISAP VII.a.7.

(Cont'd) p.

l5.0 . IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Process Specification PS 84351 NL, " Determination of Surface Chloride and Fluoride Contamination on

. Stainless Steel",

Procedure TBX/TCI-SU-2.1.10. " Reactor Coolant System Post Hot Functional Inspection, Cleaning, and Testing",

Chemistry Criteris & Specifications Manual, Section 1,

" Water Chemistry Specifications".

Cleanliness classification and associated chloride and *

. fluoride limits for Reactor Coolant System (RCS) components, abstracted-from these documents, are presented in Table 1.

Table 1 Cleanliness Classification

/(~5 Inside Outside 3ssl: Reactor Vessel C D RC Piping B B Steam Generators C D Pressurizer B D RV Internals C C Chloride and Fluoride Limits - ag/de s Chloride Fluoride Class B - Insulated /

heated

( )> 150* F) 0.0015 0.0015 Non-insulated /

unheated

( ( 150*F) 0.015 0.0015 Class C - 0.05 0.010 Class D - -

None Specified -

, PS 292722 provides that Class A and B surfaces "shall not exceed the limits for chloride and fluoride contamination as

. ( ))' specified in Westinghouse Process Specification 84351 NL", and Class C components "shall meet the same cleanliness

-4 Revision: -I c3 Page 14 of 36 fN RESULTS REPORT

() ,

1 SAP VII.a.7

-(Cont'd).

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) requirementsasspecifiedinClass'BexcegttheC1andF1 2

limits shall be .05 mg/dm and .010 mg/dm respectively when tested per PS 84351 NL."

PS 84351 NL states that "The higher chloride limit on non-insulated surfaces is permitted due to the decreased 2"

potential for chloride cracking on non-heated surfaces. Since temperature has little effect on fluoride cracking, the fluoride limit is identical for both insulated and non-insulated surfaces.".

The (W) Water Chemistry Specifications, Revision 2, March, 1977, Table 1-8, " Stainless Steel Surface Contamination" reinforces tha't the chloride surface contamination limits are based on. operating temperature conditions. Although the Water Chemistry Specifications (WCS) are not referenced by PS 292722, the WCS, Paragraph 1.1. Scope states: "These specifications are considered mandatory to insure component

'()

j.

integrity'and efficient plant operation." In addition Table 1-8 of the WCS references PS 84351 NL as the required specification for the determination of chloride and fluoride surface contamination of stainless steel materials. Table 1-8 prevides exactly the same chloride and fluoride contamination limits as PS 84351 NL except that the different chloride limits are referenced to " heated" (2>150*F)and"non- i heated" surfaces instead of insulated and non-insulated surfaces.

Neither (W) PS 292722 or PS 84351 NL clearly defines whether the surface contamination limits for interior surfaces should be based on operating temperature conditions or on insulated /uninsulated conditions.

When this lack of definition and inconsistency of the (W) specifications was identified to TUGCO by the QA/QC Review Team, the QA/QC Review Team was advised that the decision to consider interior surfaces of piping systems, vessels, tanks and components, including the reactor vessel, as "non-insulated" instead of heated surfaces was a joint decision between TUGC0 and (W) CPSES site personnel. Although the PS 84531 NL discussion of chloride limits in the context of insulated surfaces is appropriate for the exterior surfaces of piping, tanks, vessels and components, it is not clear whether interior surface chloride limits should be based on Os surface condition (i.e., non-insulated) or on operating

. temperature (as implied by the (W) Water Chemistry

. Specifications). The reactor vessel operating temperature will exceed 500*F.

l Revision: 1

} Page 15 of 36

? -< RESULTS REPORT k.. ..

ISAP VII.a.7 (Cont'd) 5.0. IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

~~ ~ '

~

'Since neither PS 292722 nor PS 84351 NL clearly stated requirements for interior surfaces, an inquiry to Westinghouse Water Reactors Division for clarification of the specification requirements was submitted. The (W) response. WPT-7996, dated August 19, 1985-discussed chloride and fluoride limits by referring to chloride solubilities, reactor coolant system surface-to-volume ratio and chloride cracking test results.

The following points were made in the (W) response:

Since chlorides are extremely soluble in water solutions, the residence time of any surface chloride would be very short as solution is added to the reactor coolant system and would be removed from the surfaces

, prior to any heating. Therefore, for purposes of

-interpreting Process Specification 84351NL - Revision 3, the inside of RCS piping should be considered a

- "Non-Rested" surface.

l ["N . -

The halogen concentration limits for inside surfaces are imposed to prevent contamination of the fluid added to the reactor system. The chloride and fluoride concentration limits imposed on this fluid are 0.15 ppm (150 ppb).

Based upon estimated surface area and volume, the maximum permissible chloride surface contamination for Class C cleanliness of 0.05 mg/dm a would yield a concentration of 3.9 ppb.

Thus if the entire reactor coolant piping was contaminated to the maximum permissible surface chloride of 0.05 mg/da2 , it would still not pose a corrosion cracking issue.

(; - Based on these considerations, the Class B cleanliness l classification for reactor coolant piping and fittings l in Westinghouse Process Specification 292722 Revision 9 is being modified to a Class C cleanliness classification.

The interior surface of the reactor vessel is specified as Class C by (W) in PS 292722.

i O. .

-,e- - - , - , , ~ - . - , .

.n ,n_..n,a , , , , , , . , _ . . . . _ , . , - , - - - , , , , . , . . , . . - - . - - _ - . - . . - . - . . , , , , , , , - - , . , . - - - - , - - - - , ,

S ,

Revision: 1 Page -16 of 36

.m- RESULTS REPORT ISAP VII.a.7 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The (y). specifications do not identify a specific number of swipe tests or locations; but state "....The amount of sampling for a given system or component must be sufficient to insure that'the surfaces have been adequately cleaned and meet the chloride and fluoride limits of acceptance. .. .". It should be noted that swipe testing is not the pole means of verifying acceptable chloride and fluoride cleanliness.

During system filling and flushing, water samples are taken and analyzed to assure water chemistry specification limits are met. The results of analyses of the water samples to date have confirmed acceptable concentrations of chlorides and fluorides.

TUGC0 System Cleanliness Plan (FP 55-08)

Flush Plan FP 55-08 was approved August 6, 1984, to verify:

" Level B cleanliness of the guide tubes for bottom mounted reactor instruments by flushing."

~

" Level B cleanliness of the reactor coolant loops by handwiping, visual inspection and swipes for chemical analysis."

Although the (y) specification, PS 292722, does not requite RV cleanliness to Class B requirements, FP 55-08 does by including the reactor vessel as part of the reactor coolant loops. Paragraph 4.3.1 provides for handwiping, visual

~ inspection and swipe tests to be taken and ana.iyzed by test lab personnel "per their procedure". FP 55-08 does require, as stated by the NRC-TRT letter dated January 8,1985, and by SSER fil, Allegation AQ-54, two (2) swipes, one on the side of the RV and one on the bottom.

Flush Plan FP 55-08 does not define the acceptance limits for chloride and fluoride surface contaaination. Nor does it reference the applicable procedures and specifications.

The procedures used by the Test Laboratory for surface chloride and fluoride determination are:

QI-QP-11.1-65 (Surface Chlorides)  !

QI-QP-11.1-66 (Surface Fluorides)

O

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_.-.~,..,.c ---.._ ,-

i

~

Revision: I j Pags 17 of 36

j. l

.-N '

RESULTS REPORT

( )- ~

~

ISAP VII.a.7. i

~

(Cont'd)  !

.5.0 IMPLDfENTATION 0F ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

. QI-QP-11.1-65 does not reference (W) PS 84351 NL but does

' include the. acceptance limits for Class A, B and C as identified by (W) PS 292722 and PS 84351 NL. QI-QP-11.1-65 also includes the system and component cleanliness classifications of PS 292722 Table III.

Reactor Vessel Cleanliness Swipe Test Results Although FP 55-08 required only two (2) swipe tests of the Reactor Vessel, eight (8) swipe tests were actually taken to verify Class B cleanliness of the vessel.

The results of the eight (8) Reactor Vessel swipe tests, evaluated to Class B non-insulated acceptance limits, were:

Location Date Cl Limit Actual F Limit Actual

'Rx containment ** 08/27/84 .015 .0013 .0015 .0001 Vessel Botton RV Botton 08/28/84 .015 .0018 .0015 .0000 RV Botton 08'/28/84 .015 .0013 .0015 .0001 RV 8' 08/28/84 .015 .0007 .0015 .0000 RV 25' 08/28/84 .015 .0006 .0015 .0000 RV 25' 08/28/84 .015 .0002 .0015 .0000

. RV Rim 08/28/84 .015 .0057 .0015 .0004 RY SG #1 Cold 08/28/84 .015 .0013 .0015 .0000

• • Discussions with Test Lab personnel indicate that the

" Reactor Containment Vessel" is actually the Reactor Vessel. QI-QP-11.1-65 and QI-QP-11.1-66 Data Sheets 3 note the " sample was taken prior to final cleaning of the containment vessel."

J The results on all samples were well below the limits specified for Class C, the classification defined by (W) specification PS 292722 for the interior surfaces of the reactor vessel. However, the flush plan required cleanliness level B but did not define the limits as " Insulated"

. (heated, > 150*F) nor "Non-insulated" (unheated, <,150*F) .

The results on all samples were within the limits for Class B, non-insulated;(but for insulated heated, two 2)150*F) samples uceed the chloride limit surfaces.

y B >

U Revision: 1

.,. Page 18 of 36 y} -

RESULTS REPORT 4

Q ,

ISAP VII.a.7 (Cont'd)

-5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

' Summary - Reactor Vessel Cleanliness Westinghouse. specifications PS 292722 and PS 84351 NL do not clearly establish which chloride contamination limits are acceptable for' Class A and B cleanliness of interior surfaces of heated vessels, components and piping.

The (W) . specifications state .that the sampling for surface contaminatio'n must be sufficient to insure that the surfaces are adequately cleaned. According to TUGC0 Startup personnel, the intent of.the two (2) swipes required by FP-55-08 was to be a minimum number, with one swipe (minimum) on a vertical surface' and one swipe (minimum) on a horizontal surface. The actual number and specific location of swipe tests was left to  !

the discretion of the chemist performing the swipes.

- Accordingly, Test Lab personnel took swipe tests at eight (8) locations in the reactor vessel as showa above. The QA/QC Review Tesa considers these eight (8) swipe tests plus water chemistry samples to be adequate to demonstrate acceptable cleanliness of the Reactor Vessel.

The results of the August, 1984 swipe tests for the Reactor

, Vessel were acceptable for Class C cleanliness for interior

surfaces required by (W) specification PS 292722.

5.4 Other Flush Plan and Swipe Test Results

~

Due to the questions raised on the applicable chloride limits for the reactor vessel, an additional selection of flush plans and swipe test results was reviewed. This selection included the results of fourteen (14) swipe tests of the reactor internals and twenty-four (24) swipe tests of reactor coolant piping and steam generator primary sides performed in accordance with FP 55-08; and the results of swipe tests performed in accordance with six (6) other flush plans / travelers.

The review revealed that Flush Plans / Travelers do not define cleanliness classifications consistent with (W) specification PS 292722 and do not clearly state the applicable acceptance limits for chloride and fluoride surface contamination. As a result, Test Lab personnel establish the acceptance limits against which the test results are evaluated. The acceptance

()

• limits established and the resulting evaluations are not consistent relative to insulated (heated) versus non-insulated (unheated) surfaces. Additional details of this review are presented in Appendix 4.

4

. , , _ , - . .-----,,.4 .- , - , , - - - . . . - - - . . . , - - - . . - - . -

. i Revision: 1 4

Pags 19 of 36

g"4 . RESULTS REPORT V ,

ISAP VII.a.7-(Cont'd)

. 5,0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

A review of the laboratory test reports for the swipe tests performed in accordance with flush plan FP.55-08 revealed that 35% of the tests did not meet the wiped area requirement of 8

20dm as specified,in (W) specification 84351 NL, flush plan FP_55-08 Attachment I and QI-QP-11.1-65.

• The " cleanness" inspection for flush plan FP 55-08 is documented on IR 84-1001 which does not reference the flush

. plan, (W) specifications or STA-612. " Cleanness Control".

Therefore, the acceptance criteria utilized can only be inferred. - Item 3 of the IR states " Verify an acceptable

, chemistry report for flourides [ sic] & chlorides has been received for the following areas. . . .". This step is signed off as SAT even though some swipe test areas do not meet the 20dm2 requirement. Per TUGC0 Startup personnel, the Item 3 statement was intended to only verify that a report showing results accepted by the laboratory was received. No verification of the acceptability of the test was intended.

In summary, Flush Plans and Travelers do not adequately define cleanliness requirements for the Reactor Coolant System in accordance with Westinghouse guidelines or CST procedure CP-SAP-24. They do not reference the Westinghouse specification nor the applicable TUGC0 analytical procedures.

t TUGC0 Startup procedures XCP-ME-4 and CP-SAP-24, which define l flush plan and system cleanliness requirements, do not address l swipe testing.

According to TUGC0 Startup personnel, the B&R QC laboratory

has full responsibility for swipe testing. The statement of acceptability on the test report by Test Lab personnel is accepted without question. The TUGC0 analytical procedures do l not clearly define acceptance criteria for interior surfaces,

l. since they reflect the (W) specifications. This results in an inconsistent evaluation of the swipe test samples for acceptability.

Swipe test sampling requirements are not consistently met. QC review of stripe test laboratory reports is unsatisfactory.

Inspection Reports do not identify acceptance criteria nor reference procedures containing them.

4 e

c -

r,-m---- +- ,,er,, emwn---,-r,,.a ,,,,.,,m-,-,_,-n,-.,,.. ~-,,-,,~-._,n_,n--,.-------,r,,_.c,, , - - . . , , , - _ - . _ _ _ - - - - - , - - - - - - - - - - , - , -

,~

'i Revision: 1 ng Page 20 of 36 f'] RESULTS REPORT U '

ISAP VII.a.7'

, (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

.5.5 Summary of Results-Procedures-The B&R-construction procedures establish requirements for housekeeping and cleanliness _that are considered adequate to satisfy the program basis requirements of 10CFR50 Appendix B

.and the'FSAR, if effectively implemented. Since January, 1985 the B&R quality procedures adequately address all of the

. elements of an effective surveillance program with the exception of repor't distribution to appropriate

< organisations/ management for evaluation and trending and definition of all areas subject to surveillance.

.The TUGC0 quality procedure currently in effect, DQP-SG-1, adequately addresses all of the elements of an effective surveillance program, with the minor exception of not defining

_ housekeeping surveillance attributes / criteria.

'i Refer to Figure 1 for a synopsis of current procedures versus the elements of an effective surveillance program.

Plant Surveillances Implementation of current TUGC0 and B&R procedural requirements is considered adequate and appears to be effective in identifying and obtaining resolution of unsatisfactory conditions. -

l Reactor Vessel Cleanliness i

The intent of flush plan FP 55-08 was to require a minimum of one (1) swipe on a vertical surface and one (1) swipe on a horizontal surface. The actual number and location of swipe tests was left to the discretion of Test Lab personnel.

Although two (2) swipe tests of the Reactor Vessel as required by FP 55-08 may not have been ".... sufficient to insure that L

the surfaces may have been adequately cleaned and meet the chloride and fluoride limits of acceptance...." (Westinghouse specification PS 8351 NL), the actual number of swipes taken and analyzed, eight (8), is considered sufficient to verify the cleanliness of the Reactor Vessel.

sO:

Revision: I as Page 21 of 36 RESULTS REPORT M(~T ..

ISAP VII.a.7 (Cont'd) 5.0' IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The results of the August, 1984 swipe tests for the Reactor

-Vessel were acceptable for Class C cleanliness for interior surfaces as required by (W) specification PS 292722.

Flush Plan and Swipe Test Results

The cleanliness classes and criteria described by Westinghouse specifications, B&R procedures, TUGC0 Startup procedures and TUGCO,0perations procedures, while similar, are not defined to a common basis or in the same terms. This allows for potentially incompatible or at least inconsistent requirements and acceptance criteria from phase to phase (e.g., ,

Construction, Startup/ Turnover, Operations).

The Flush Plans / Travelers reviewed do not adequately define cleanliness requirements and acceptance' criteria in the text

~. ' or through reference to applicable specifications or procedures. The cleanliness classifications used are not

() always consistent with the Westinghouse specification.

-TUGC0 Startup procedures XCP-ME-4 and CP-SAP-24, which define flush plan and system cleanliness requirements, do not address swipe testing.

Due to inadequate definition of requirements, swipe test I samples are not consistently evaluated to the applickble l acceptance criteria. The minimum wipe area required by i procedure is not always set. QC review of test reports has failed to identify this lack of compliance with procedures.

In spite of the above, all of the sixty (60) swipe test results reviewed met the minimum chloride and fluoride surface I

contamination limits intended by Westinghouse. The inconsistencies noted in the cleanliness classifications defined in flush plans / travelers and in the evaluation of swipe test results have resulted in the application of more stringent limits than intended by Westinghouse.

i. The inadequacies identified in the TUGC0 flush plans and the Startup procedures which govern them have been discussed with TUGC0 personnel. Revisions to these procedures are currently being made to address the inadequate areas.

(

1 a

n ,- ,

Revision: I g Page 22 of 36 s

7-- mn RESULTS REPORT

.\

l ~

ISAP VII.a.7 )

(Cont'd) )

5.0 . IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.6 Compliance with 10CFR50, Appendix B and FSAR Commitments The current CPSES program for housekeeping activities, including surveillance, complies with 10CFR50, Appendix B and the associated commitments of the CPSES FSAR shown in Appendix 2.

The B&R construction procedures establish requirements for storage, housekeeping and system cleanliness which satisfy the

, program basis requirements. However, the B&R and TUGC0 procedures for surveillance of housekeeping and storage to assure implementation of the established requirements contain minor inadequacies as described in Section 5.1. There were no deviations noted during the. implementation of this action plan which were associated with specific hardware items. Therefore no Construction Deviation Repgrts (DRs) were issued. No QA/QC Program Deviation Reports (FDRs) were issued relative to the housekeeping and surveillance program. However, the current N CPSES program for system cleanliness fails to comply with

("b 10CFR50, Appendix B and FSAR causitments. TUGC0 flush plans / travelers and the procedures which govern them do not adequately define appropriate acceptance criteria.

Accordingly, a QA/QC Program Deviation Report, QA/QC-RT-49, was' written to document this deviation. TUGC0 is currently taking action to review and revise the affected procedures.

5.7 Trend Analysis There were no QA/QC Program Deviation Reports (PDRs) or

j. Construction Deviation Reports (DRs) issued as a result of the review of current housekeeping / surveillance activities. The one PDR written rels.tive to the system cleanliness program does not constitute a trend. The program deviation described

! in this PDR is not the result of multiple deviations that would constitute a trend. Therefore, a trend analysis

. relative to the current program is not required.

A review of the results of Action Plan II.c, " Maintenance of Air Gap Between Concrete Structures", did not identify any problems attributable to housekeeping / surveillance practices.

Action Plan II.c concluded that the presence of construction debris in seismic gaps was the result of inadequate construction and inspection procedures for concrete pours.

Action Plan II.c further states that the determination of a

() more refined root cause will be made by the QOC (QA/QC)

Collective Evaluation group. One such potential root cause is 1 the failure of the engineering specifications to identify the critical nature of the seismic gaps.

<.4;,

a Revision: 1

, , e v.

Page 23 of 36

, RESULTS REPORT

~f ISAP VII.a.7 (Cent'd)  ;

~5.0l IMPLEMENTATION OF LCIION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The' inspection of critical spaces required by Action Plan VI.a. " Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall", identified a significant amount of construction debris in these areas.

Action Plan VI.a was unable to attribute the debris which had accumulated in critical spaces to any one particular phase of plant construction or to any one organization. As a result, _

the Action Plan, VII.a.7, Issue Coordinator was requested to evaluate the historical housekeeping surveillance program.

This evaluation shows some evidence of housekeeping and surveillance inadequacies, particularly prior to 1981. '

However, the problems identified could not be related to the accumulation of construction debris in critical spaces.

The Deviation Repo-ts and out-of-scope observations generated under ISAP-VII.c. were reviewed to identify instances of damage to permanent plant equipment which could be attributable to poor housekeeping / protection of equipment. No instances were

- /"' -

identified.

5.8 Root Cause and Generic Implications Analysis In accordance with the CPRT Program Plan, root cause and

, generic implications evaluations are not required since no deficiencies or adverse trends were identified. However, since the inadequacies found in the TUGC0 procedures governing system cleanliness and flush plans could have implications in other areas, a description of these inadequacies has been transmitted to the QA/QC Review Team Collective Evaluation Group for information and action as appropriate. The QA/QC Review Team concluded that housekeeping practices and housekeeping surveillance activities were not a contributing factor to the accumulation of debris in the seismic gaps and

, critical spaces which was found through Action Plan II.c and VI.a.

l.

5.9 Recommended Corrective Action B&R procedure CP-QAP-14.1 should be revised to define a minimum distribution for surveillance reports and to define

( all current areas subject to surveillance.

TUGC0 procedure DQP-SG-1 should be revised to define the attributes / criteria to be used for housekeeping surveillance.

I h

l *t

, F -Revision: 1

.,' . Paga 24 of 36 j; RESULTS REPORT

% /:; _

ISAP VII.a.7 fy .(Cont'd)

, 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

TUGC0 procedures governing system cleanliness and flush plans should be revised to provide cleanliness classifications consistent with Westinghouse requirements and to clearly define chloride and fluoride surface contamination limits.

This action is currently _in process. The proposed changes c have been reviewed'by the QA/QC Review Team and are considered to be adequate to resolve this deviation.

6.0 CONCLUSION

S 6.1 Plant Housekeeping and System Cleanliness B&R construction procedures which define housekeeping and 4 . cleanliness re'quirements were adequate to meet FSAR commitments.

Current housekeeping practices and procedures are considered

, satisfactory and comply with the program basis defined in Appendix 1. This conclusion reflects the results of the

'f ) - - observations of TUGC0 surveillances of Unit 1 and 2 areas and facilities (warehouses, lay-down areas, in-place storage,

etc.) which verified the following:

j -

Satisfactory access control as appropriate, Absence of evidence of damage to or deterioration of plant materials and equipmente Satisfactory protection of eq.tipment from harmful environmental and work Induced conditions.

6.2 Plant and Storage Surveillance l Current plant and storage surveillance procedures comply with l- the program basis defined in Appendix 1 with only minor

!. inadequacies. "

The current program is being adequately implemented and is effective in identifying and obtaining resolution of unsatisfactory conditionr.

6.3 Reactor Vessel Cleanliness The actual number of swipes taken, eight (8), was adequate to

'\ verify cleanliness.

,y- .,v _ -. . _ __ _em_.y . _ , . _ . , , , ,_.__,.__-.m, ,_.,,,.mm,_,,,,_ . _ , , , _ , . _ . ,_c . ._ ,_,,, , .__,.-,. ..,_,. ,, , _ _ , - _ - . . . , _ _ _ _ _ , , .

Revision: 1 Page 25 of 36

< ~

RESULTS REPORT

'I '

ISAP VII.a.7 (Cont'd)

6.0 CONCLUSION

S (Cont'd)

RV cleanliness under FP 55-08 was maintained to Class B although (W) Specification 292722 only required the less stringent Class C'for the internal surfaces.

FP 55-08 is a one-time-only-use procedure for Unit 1; new fps

.. are required to be prepared for any_ subsequent flushes per procedure XCP-ME-4.

Westinghouse specifications and TUGC0 procedures do not clearly define chloride and fluoride surface contamination limits for interior surfaces relative to the heated / insulated issue.-

6.4 Flush Plans and Swipe Test Results Flush plans / travelers do not consistently define cleanliness classifications in accordance with We'stinghouse specification PS 292722 and do not identify the acceptance limits for tT chloride and fluoride surface contamination.

V Thereviewofsixty(60)swdpetestresultsfromeight(8) flush plans indicates that Westinghouse chloride and fluoride surface contamination limits are being met. As stated in Westinghouse letter WPT-7996, these limits are imposed to

, prevent contamination of the fluid added to the reactor system and are well below those which would pose a corrosion cracking issue.

-7.0 ONGOING ACTIVITIES The following activities, related to the evaluations performed under this ISAP, remain open or to be accomplished:

Westinghouse (W) specification 292722, Revision 9 is to be revised per (W) letter WPT-7996, August 9, 1985, but no schedule for the revision and no commitment to revise (W) specification 84351 NL Revision 3 for clarification of interior surface chloride and fluoride limits have been identified.

However, (W) has provided sufficient guidance through correspondence, etc. to permit TUGC0 to define clearly in procedures, cleanliness requirements which are consistent

] ) with (W) requirements.

_ .1 Rsvision: 1

• , Page 26 of 36

,'"y '

RESULTS REPORT _

A/ '

ISAP VII.a.7 (Cont'd)

~

8,0 ACTION TO PRECLUDE RECURRENCE IN THE FUTURE The TUGCO action, currently in process, to review and revise procedures affecting system cleanliness activities will be adequate to preclude recurrence of swipe test problems.

id .

D

, O 1

6

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Revision: 1

.. Page 27 of 36 e's -

-RESULTS REPORT

%) ' .

ISAP VII.a.7 (Cont'd)

Figure 1 ISAP Vll. a. 7 Results Report CPSES PROCEDURES B&R TUGCO-SURVEILLANCE PROGRAM ELEMENTS CST CP- CP-QAP QAP DQP-14.1 11.1 SG 1 Applicable to all Perm. Plant Equipment + e +  ;

Schedule Required / Frequency Defined + e +

All 5torage Areas Defined A C 1 AllWorkAreas Defined A C 1 Attributes / Checklists Defined + e D

-O Verification of Corrective Action Defined + e +

i Appropriate Report Distribution Defined B e +

Report Retention as a QA Record + e +

Supplemental Procedures Referenced + +

NOTES :

A. - Attachment 1 shows 25 areas, surveillances are performed of 29 areas.

B. - Unsatisfactory reports to Ass't. Proj. Manager- No other distribution defined, r C. - Inspector to " routinely observe general workmanship" and document unsatisfactory l conditions per CP -QAP- 14.1

[- D. - Checklists are required to be prepared based upon procedures and specifications.

l- 1. - Not applicable. TUGCO surveillance program is an overview of B & R activities.

l l

l Legend:

( .

+  : Adequately Addressed Letter : Inadequately Addressed

. e : Not Addressed 1

.m Ravision: 1

,, Page 28 of 36 j l

,.7-3_

RESULTS REPORT i

--< r g- l ISAP VII.a.7 l (Cont'd) '

Appendix 1 i

Discussion of Previously Identified Problems and Concerns USNRC TRT Items The following allegations were evaluated by the USNRC TRT and reported in Safety Evaluation Report, NUREG-0797, Supplements Nos. 9, 10, and 11:

AP-6: Crowbar dropped in neutron detector well. The TRT

- found that a crowbar was apparently dropped in 1980 or 1981 and was not removed until November, 1983 by flushing. Although the TRT noted that the accumulation of debris in the reactor cavity was a non-compliance with procedure CP-QP-19.5, the TRT concluded that there was no safety significance and no TUGC0 action was required.

AW-65: Debris in Transfer Tube. Coincident with an evaluation of incomplete welds, which was expressed by

/~T Allegation AW-65, the TRT observed miscellaneous

\l debris in the transfer tube expansion joint, including  !

a shop rag and a toothbrush-type stainless steel brush. The TRT found no safety significance to the alleged weld discrepancy, but provided no conclusions or required actions for the construction debris.

AP-10: A steam pipe fell off a truck, but did not know if damage occurred [ sic). The TRT review concurred with a prior Region IV (RIV) investigation that the specific case had no safety significance, since the pipe in question was part of a "non-Q" (non-safety related) system. However, the TRT did note a number of previously identified deviations and violations, which, although not related to piping, did indicate a generic problem with the protection of safety-related mechanical equipment.

INPO "CPSES Design and Construction Self-Initiated Evaluation Report", October 13, 1982, finding CC.2-1, identified a deficiency in the storage and maintenance of pipe support details in outside laydown areas.

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'92 . RESULTS REPORT Y. ..

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(Cont'd)

Appendix 1 (Cont'd)

'USNRC tdt Items (Cont'd)

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- IR 50-446/83-12, April 8, 1983,-NRC CAT inspection identified violations of 10CFR50

. Appendix B, Criterion XIII and XVI related to improper storage control of safety related equipment in outside laydown areas and lack

,. -of timely resolution of TUEC audit findings b related to maintenance instructions identified during 1979, 1981 and 1982 TUEC audits.  ;

a IR 50-445 & 446/79-04, February 27, 1979 and associated notices of violation 445/7904 and 446/7904 identified a violation of 10CFR50 Appendix B, Criterion V related to non-

, .. compliance with storage maintenance

~

requirements for safety-related equipment.

(}

- IR 50-445/83-24 and 50-446/83-15, August 24, 1983 and associated-notices of violation 445/8324-02 and 446/8315-02 identified a violation of 10CFR50 Appendix B, Criterion XIII related to failure to prevent deterioration of safety-related e- equipment in storage.

During the course of their investigation of AP-10, the TRT identified that randon QC surveillance over storage and control of materials in the fabrication shop area was not performed as required. The TRT observed that failure to perform these surveillances E was " contrary to the results to be achieved by TUEC corrective action in response to NOV 445/8324-02, 446/8315-02." "The TRT assessment of the currett requirements for the protection of mechanical equipment during storage and maintenance and installation formd that the requirements were adequate and appear to be implemented adequately for piping."

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ISAP VII.a.7 (Cont'd)

Appendix 1 (Cont'd)

Internal-Items In_ addition to the inspection and audit items noted by the TRT during evaluation of AP-10, the QA/QC Review Team observed that Brown & Root internal audit CP-17,' September 16-19, 1980, Audit Deficiency Report ADR CP-17.2, identified numerous supports with rusted threads. The audit team noted that the problem was generic and, although specific items had been reported on B&R NCR-2359 and Surveillance Report S-009, corrective action had not been implemented at the time of the audit. . NCR 2359 R1 was closed November 23, 1980, but S-009 was never closed out due to deletion of governing procedure CP-QAP-12.2 on August 25, 1980.

~

MAC Items In 1978, Management Analysis Company documented a concern with onsite storage practices:

.OI " Exterior storage practices should be reviewed. The protective coverings of many items are damaged; some reported on monthly surveillance reports have not been corrected.

Large temporary structures, such as those over the emergency diesel engines, require wind bracing to prevent further i damage. Because of soil chemistry, rain and humidity,.the l current practice of allowing large stainless steel piping to remain uncovered should be reviewed. Sensitized stainless is extremely sensitive to chloride, fluoride and sulphide contamination which with water as a couplant can cause

intergranular corrosion and premature failure."

TUGC0 responded to the'MAC Report internally by meno July 11, 1978:

!- "We had previously reviewed the storage practices and have no I

reason to believe that a problem exists. Various NRC inspectors have also inspected this activity. However, Westinghouse is reviewing this, and their metallurgist will

( report by July 15."

l' In summary, numerous concerns, observations, findings and l violations have been identified by various internal and external sources relating to housekeeping, cleanliness, storage and surveillance for the period 1978 to 1985. The corrective action commitments, and the actions taken to implement and verify them had 7 not been effective in precluding recurrence of identified deficiencies and violations. The items discussed in this appendix have been transmitted to the Issue Coordinator of Action Plan VII.a.2, Nonconformance and Corrective Action System, for information.

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RESULTS REPORT'

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ISAP VII.a.7 (Cont'd)  ;

Appendix 2 s ,

, Housekeeping and System Cleanliness Program Basis 10CFR50. Appendix B Criterion XIII s

"" Measures shall be established to control the handling, storage,

, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration. Uten necessary for particular products, special protective environments, such as inert gas atmosphere, specific moisture content levels, and temperature levels, shall be specified and provided."

FSAR,. Paragraph 17.1.13

'" Contractor procedures for the performance of cleaning, handling, storage, shipping, and preservation of materials and equipment to prevent damage or deterioration are reviewed by TUGC0 or the prime

) contractor.- The approved procedures become a part, either by inclusion or reference, of the purchase documents issued by these organizations. TUGC0 verifies that adequate provisions for procedures are included in purchase documents by ongoing review

-prior.to issuance, by surveillance, or by audits.

At the site, material and equipment are stored in accordance with approved procedures. TUGC0 requires that instructions or guidance for site handling, preservation, storage, and control are prepared i and approved prior to arrival of the equipment at the site. These procedures may require that special environmental facilities such

.as inert gas, humidity controlled, or temperative controlled storage areas be required at the site prior to the receipt of the

" equipment.

TUGC0 performs periodic surveillance and audits of contractors to assure that the specified and approved procedures are being L

properly implemented."

p FSAR, Paragraph 17.1.15 states in part:

" Conditions which render the quality of an item or activity unacceptable or indeterminate will be identified, resolved and closed out. Such conditions are documented on inspection reports, deficiency reports, or nonconformance reports in accordance with O procedures.

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' ,:, . RESULTS REPORT i i,

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-ISAP VII.a.7 (Cont'd) )

I

, ,, -Appendix 2 f,y . (Cont'd) '

I FSAR, Paragraph 17.1.15 (Cont'd)

Procedures require trending of deficiencies reported on inspection reports, deficiency reports, and nonconformance reports to identify

^

-trends adverse to_ quality. Trend reports are reviewed quarterly by appropriate levels of management to address areas requiring corrective action.

Nonconformance reports and trend reports are reviewed upon issuance

, 'by IVGC0 QA for significant conditions adverse to quality or  !

chronically repetitive deficiencies. If such conditions exist, procedures require additional action, as appropriate. This may include issuance of corrective action requests as discussed in

.Section 17.1.16, ' Corrective Action', or reports to the Nuclear Regulatory Commission."

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ISAP VII.a.7 )

(Cont'd) l Appendix 3 l l

Current' Housekeeping and System Cleanliness Procedures

Brown & Root Construction Procedures CP-CPM 6.9H: Rev. 0 02/06/80 " Cleanliness Control" (with DCN #1, 2, 3)

CP-CPM 8.1 Rev. 2 09/25/84 " Receipt, Storage, and Issuance of Itema" CP-CPM 10.2 Rev. 2 07/12/83 " Cleaning and Insulating  ;

, Stainless Steel Pipe and Equipment" (with DCN #1)

CP-CPM 14.'1 Rev. 2 04/05/84 " Guidelines for the Protection of Permanent Plant Equipment" CP-MCP-10 Rev. 9 07/02/85 " Storage and Storage

/) Maintenance of Mechanical and h/~ Electrical Equipment" MEI-8 Rev. 1. 07/07/81 "NSSS Cleanliness Control

, During Coolant Loop E

Installation" e

Brown & Root - Quality Procedures CP-QAP-14.1 Rev. 6 01/25/85 " Inspection of Storage and Maintenance of Parmanent Plant Equipment" i'

CP-QAP-11.1 Rev. 8 11/20/85 " Fabrication, Installation i j_ Inspection of ASME Component Supports, Class 1, 2 and 3" j TUGC0 Construction and Startup - Quality Procedures DQP-SG-1 Rev. 0 07/01/86 " Construction Startup/

l Turnover (CST) Surveillances" l'

DQP-SG-2 Rev. 0 07/01/86 " Training, Qualification and Certification of Surveillance h, Specialists"

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ISAP VII.a.7 (Cont'd)

Appendix 4 F

Review of Other Plush Plans and Swipe Test Results

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FP 55-08 Reactor-Internals and Reactor Coolant Piping Twenty-four (24) swipes of the Reactor Coolant Piping and Steam Generator primary-sides (5 in Loop #1, 8 in Loop #2, 6 in Loop #3, 5 in Loop #4) were taken under FP 55-08, all to Class B cleanliness acceptance limits (non-insulated surfaces).

All samples taken for chloride surface contamination under FP 55-08 in August, 1984 were analyzed against .015 mg/dm8 because the interior surfaces were regarded as "non-insulated" surfaces even though the operating temperature will exceed 550*F. Approximately 58% of the RC piping samples (14/24) did not meet the Class B surface chieride limits for heated surfaces. None of the Reactor Vessel or Reactor Internals samples exceeded the Class C surface chloride limits, but the Reactor Vessel and Internals were sampled and analyzed under QI-QP-11.1-65 to Class B non-insulated (unheated) acceptance criteria. Approximately 25% (2/8) of the RV c(]L samples and 57% (8/14) of the Reactor Internals samples did not meet Class B insulated (heated) surface chloride limits.

i FP 55-02 Pressurizer (RCRCPR)

PS 292722 requires the Pressurizer (inside) to be cleenliness Class B. FP 55-02, June 2, 1982 required the Pressurizer to be cleaned l and verified to cleanliness Level 1. Traveler ME-82-2365-5500, l

June 15, 1982 provided for verification to cleanliness class B.

The swipe test data sheets (QI-QP-11.1-65) taken for swipe J-161, l June 28, 1982 indicated that the results were originally analyzed 2

l to .0015 g C1/dm (insulated / heated) but were later changed to

.015 mg/dm (non-insulated) per a handwritten memo which states that the swipe tests are on interior surfaces and "Therefore common l_ sense dictates these surfaces shall be non-insulated." Two of the four swipe teste exceeded the Class B insulated chloride limits (but did not exceed the non-insulated 31mits).

FP 55-058 Pressurizer Relief Tank (RCATPR) l PS 292722 requires the Pressurizer Relief Tank interior to be

cleanliness Class C. FP 55-055, October 18, 1982 required the l Pressurizer Relief Tanks to be cleaned and verified to cleanliness Level 1. The swipe test data sheets (QI-QP-11.1-65) taken for swipe J-206, October 28, 1982 indicate a non-insulated surface,

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?/~'O RESULTS REPORT d ,

ISAP VII.a.7 (Cont'd)

Appendix 4 (Cont'd)

FP 55-05B Pressurizer Relief Tank (P.CATPR) (Cont'd) but provided the actual limits for an insulated surface (.0015 mg C1/dm8 ). One swipe exceeded the allowable value for insulated

= surfaces (.0032 mg/dm8 ). The relief tank was recleaned in the unacceptable area and was retested acceptably. The original test i would not have exceeded non-insulated surface limits.

FP 56-09 RecyEle Holdup Tank #1 (CSATRT)

PS 292722 requires the Boron Recycle Holdup Tank interior to be cleanliness Class C. .:MP 56-09 required the Recycle Holdup Tank to be verified to cleanliness Class B. The swipe test data sheets (QI-QP-11.1-65) taken for swipe J-642, dated March 27, 1984, indicate a non-insulated surface and the correct chloride limits 4 (.015 mg/da ) for a non-insulated surface. The CPSES FSAR, Table 2

9.3-8, shows the design temperature of the Boron Recycle Holdup Tanks to be 200*F. The swipe exceeded the allowable value for i

heated surfaces (.0020 mg/dm8 ) but was accepted because the

.non-insulated surface limit was not exceeded. It was noted that the Recycle Holdup Tanks are identified by FSAR Figure 9.3-11 (P&ID 2323-M1-0258) as component BRATRE instead of CSATRT noted by PS 292722. See also comments to FP 55-10 below.

FP 55-10 Recycle Holdup Tank #2 (BRATRH-02)

PS 292722 does not identify a tank with identification BRATRH; as a result, the swipe test data sheets (QI-QP-11.1-65) taken for swipe J-731, May 18, 1984 did not identify any acceptance limits and made the remark that the equipment was not listed in (W) specification PS 292722 Revision 9. As noted in the discussion of FP 56-09 above, it appears that the tanks BRATRH (FSAR and P&ID) and CSATRT (PS 292722) are the same. FP 55-10 required the Recycle Holdup Tank to be verified to cleanliness Class B. The swipe test results were within the limits provided for insulated (heated) surfaces even

_though acceptance limits were not identified on the data sheets.

Traveler ME-82-1699-4900 Cation Bed Domineralizer (CSDMCB)  ;

I PS 292722 required the Cation Bed Domineraliser interior to be cleanliness Class C. The traveler, dated July 17, 1982 required the domineraliser to be verified to Grade A cleanliness. The swipe l

n- test data sheets (QI-QP-11.1-65) taken for swipe J-181 (July 18, V 1982) indicate a non-insulated surface. The swipes exceeded the allowable value for heated surfaces (.0064 and .0030) but did not exceed the non-insulated surface limit.

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. RESULTS REPORT ISAP VII.a.7 (Cont'd)

Appendix 4 (Cont'd)

- Traveler ME-82-1754-4701 Resin Fill Tank (CSATRF)

PS 292722 requires the Resin Fill Tank interior to be cleanliness Class C. The traveler, October 4,.1982 required the Resin Fill Tank.to be verified to Grade A cleanliness. The swipe test data sheet (QI-QP-11.1-65) taken for swipe J-198, dated October 13, su 1982, does not indicate the type of service, but provides the chloride acceptance limits for heated (insulated) surfaces. This is not consistent with the actions taken for traveler ME-82-1699-4900 discussed above. The swipes met the acceptance

. requirements for insulated surface chloride contamination limits.

During a discussion of flush plans / travelers, TUGC0 Startup personnel stated that swipe test performance and acceptance was the responsibility the of B&R QC Laboratory and was governed by their procedures. Flush

- plans / travelers, whose content is governed by procedure XCP-ME-4, were not required to define or reference swipe test acceptance criteria. No J(-s) specific quality procedures were identified.

TUGC0 Startup procedure XCP-ME-4, Revision 8 " System Cleanliness

- Verification" - defines the requirements for the content of flush plans.

It does not address swipe tests, but does state that acceptance criteria for visual examination and/or flushing are specified in procedure CP-SAP-24.

CP-SAP-24, Revision 1 " System Cleanliness Requirements and Control" -

does not specify chloride and fluoride swipe test acceptance limits nor clearly reference (!) specifications. Attachment B, which dalineates the cleanliness classifications of various components / systems, does not specifically list the reactor vessel. As a result, the cicanliness classification of the reactor vessel is not defined in accordance with L the (!) specifications.

TUGC0 Operations procedure STA-612, Revision 0 " Cleanliness Control" -

defines cleanness classifications and requirements in Attachment 1.

l Swipe testing is not addressed. Additionally, STA-612 states that the i procedure "...is to be implemented as systems, components and equipment l come under custody of the CPSES operating staff.".

I

~ TUGC0 procedure QI-QP-11.1-65, Revision 4 " Determination of Surface Contamination of Fluorides and Chlorides on Stainless Steel" - defines swipe test sampling and analytical methods and acceptance criteria. The (3) specification PS 292722 is referenced and the acceptance criteria O. and cleanliness classifications from PS 292722 and PS 84351 NL are included.

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