ML20209G730
| ML20209G730 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/27/1987 |
| From: | Wooldridge R WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#287-3282 OL, NUDOCS 8705010049 | |
| Download: ML20209G730 (115) | |
Text
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WORSHAM, FORSYTHE, S AMPELS 8c WOOLDIFIDGE THIRTT YWO MUNDRCD.2000 BRYAN TOWER O E N"A WOOtoR,Co E DALLAS. Texas 75201 *^f*
01: *"
ER C R'"a RONALD M. MANSON TELEPMON E (2:4)979 3 COO
~87 APR 29 P1 :44 Or COUNSEL J. DAN eOMANNAN JOS. tRION WORSMAM TR AVIS E. VAN D ER POOL EARL A. FORSYTH E JUDaTM M. JOHNSON N'CHAmoL.AoAMS Office 0; : . -t u.
oe<.o c. LON E" ^" DOCXETir6 >. '.E nvy'f'C " ' ' " " * ' ' ' * * ' "
JOMN W. MCREYNOLOS BR A NCW
TMOM AS F. LILLAR D ROBERT K. WISE TIMOTNT A Mac et ROSE RT M. FsLLMORE
- eo STEPHEN SovD MARn R. WASE M CHRtSTOPMER R, MILTEN8ERGER ROBERT R. OLIVER
,CMA** " **
O "'jR O E April 27,1987 NANCYE L. SETMUREM
. CECELIA J. BRUNER JOE A. DAVIS ERIC M. PETERSON WALTER W. WMITE 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 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 - D[,
Dear Administrative Judges:
TU Electric has this date delivered to the Nuclear Regulatory Commission the following SRT approved Results Reports:
I.a.2 Inspection Reports on Butt-Splices, Revision 1 III.a.5 Preoperational Test Review and Approval of Results, Revision i VI.a Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall, Revision 1
'Ihese reports should be placed in sequence behind the tabs "Electricai" for I.a.2, " Testing" for III.r. 5, and " Mechanical" for VI.a in the results reports binders previously transmitted. Also enclosed is a revised Table of Contents reflecting the issuance of these reports. As with all previous Results Reports issued to date, this material is r:ot being offered into evidence at this time and is provided for information only.
Respe ully submitted,
%50 h070427 0500 Ro ert A. Wooldrid RAW /kiw Enclosures bh cc: Service List
E
&9 Log # TXX-6425 CPRT-885
. 2 File # 10068 r =
nlELECTRIC April 27, 1987 William G. Counsil Esecutne %cr Preuknt U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 CPRT RESULTS REPORTS Gentlemen:
We transmit herewith the following SRT Results Reports:
I.a.2 Inspection Reports on Butt-Splices, Revision 1 III.a.5 Preoperational Test Review and Approval of Results, Revision 1 VI.a Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall, Revision 1 These reports should be placed in sequence behind the tabs " Electrical" for I.a.2,
" Testing" for III.a.5 and " Mechanical" for VI.a in the results reports binders previously transmitted. Also, 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 t Dallas office. Anyone wishing to inspect these files should contact Ms. Susan Palmer (214/979-8242).
We shall issue further Results Reports on a periodic basis as they are approved by the CPRT Senior Review Team.
l Very truly yours, k ). C . &
W. G. Counsil i
i By: b # z.). b e S n W. Beck Vice President, Nuclear Engineering TLS/mlh Enclosures l
l anas owe sema i.a si caus. reus nxi
TABLE OF CONTENTS O COLLECTIVE SIGNIFICANCE REPORT
- Later -
COLLECTIVE EVALUATION REPORTS
- Later -
RESULTS REPORTS Electrical I.a.1 Heat-Shrinkable Cable Insulation Sleeves -
Revision 1 I.a.2 Inspection Reports on Butt-Splices, Revision 1 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
- Re/ision 1 I.b.2 Flexible Conduit to Cable Separation - Revision 1 I.b.3 Conduit to Cable Tray Separation - Revision 1 I.b.4 Barrier Removal ~- Revision 1 Civil / Structural l II.b Concrete Compression Strength - Revision 1
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II.c Maintenance of Air Gap Between Concrete Structures
{ - Revision 1 l
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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.a.5 Preoperational Test Review and Approval of Results, Revision 1 III.b Conduct of the CILRT - Revision 0 III.d Preoperational Testing - Revision 1 Mechanical V.a Inspection for Certain Types of Skewed Welds in NF Supports - Revision 1 V.c Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings - Revision 1 V.d Plug Welds - Revision 1 V.e Installation of Main Steam Pipes - Revision 1 VI.a Gap between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall, Revision 1 l
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{} 0A/0C I.d.2 Guidelines for Administration of QC Inspector Test
- Revision 1 I.d.3 Craft Personnel Training - Revision 1 VII.a.3 Document Control - Revision 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.1 Onsite Fabrication - Revision 1 VII.b.2 Valve Disassembly - Revision 1 DSAPs O - Later - -
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O COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.a.2
Title:
Inspection Reports on Butt-Splices REVISION 1 iO n
~Isstie Coordinator
.3AVs7 Dice '
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. Y $ hb v!r eview I Leade"r 3l37/17 Dafe /
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Jol& W. Be:k, Chairman CPRT-SRT
+Mr Date O
Ravision: 1 Pags 1 of 34 RESULTS REPORT
( ,) ISAP I.a.2 Inspection Reports on Butt-Splices
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7, Page J-29)
"...the TRT reviewed the QC Inspection Reports for 12 butt-splices and found the following:
Nine of these splices were documented on the inspection form designated in paragraph 3.3 of the procedure for post-installation inspections instead of on the correct form designated for witnessing-type inspections. It should be noted that all splices were required to be witnessed by QC personnel per paragraph 3.1.d of the procedure [QI-QP-11.3-28
, Revision 21. " Class 1E Cable Terminations"].
Six of the nine incorrect forms contained handwritten notes by the inspector indicating that he had witnessed the splice; however, no reference was added to indicate that the installation of the heat-shrinkable sleeves was required to be witnessed.
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The remaining three of the nine incorrect forms did not indicate that the splices had been witnessed.
For three splices which were documented on the correct forms, a
the forms all contained an "N/A" (not applicable) handwritten by the inspector on the line indicating that the installation of the heat-shrinkable sleeve was witnessed."
2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7. Item 6.(d)(2) and (3), page J-31)
"TUEC shall accomplish the following actions prior to fuel load:
... ensure that ...(2)* all QC inspections requiring witnessing for splices have been performed and properly documented, and (3) all butt splices are properly identified on the appropriate design 4
drawings and are physically identified within the appropriate panels."
Item (1) regarding installations requiring heat-shrinkable insulation sleeves was addressed by Results Report I.a.1,
" Heat-Shrinkable Cable Insulation Sleeves."
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Rsvision: 1 Page 2 of 34 i
RESULTS REPORT 4 i -
ISAP I.a.2 (Cont'd)
3.0 BACKGROUND
The following information should be considered in addressing the i
issue identified by the NRC:
From late 1982 through mid 1983, while incorporating certain
' " human factors" modifications and while completing various other rework on control panels, some conductors were found to 4
be too short to be properly terminated at designated termination points. In lieu of repulling cables or redesigning cabinet internals, either of which would have involved significant disassembly and rework, the CPSES Project i elected to add extensions to the subject conductors by using butt-splices. The type of butt-splice used by the CPSES i
Project for splicing in panels was the AMP Pre-Insulated Environmentally Sealed (PIES) splice.
i
- IEEE 383-1974, "IEEE Standard for Type Test of Class 1E Electric Cables, Field Splices, and Connections for Nuclear Power Generating Stations " recognizes that qualified field splicing is acceptable, and provides criteria for the O qualification of such splices. As discussed in ISAP I.a.3,
" Butt Splice Qualification," the AMP FIES splices have been qualified for use in electrical panels at CPSES.
Section 8.1.5.2.4 of the FSAR originally committed to the j.
provisions of Draft Standard IEEE 420-1973, "IEEE Trial-Use i
Guide for Class 1E Control Switchboards for Nuclear Power ,
Generating Stations," which states that splices are not allowed within control switchboards (including panels).
Regulatory Guide 1.75, Rev. 1, " Physical Independence of
! Electric Systems," states that splices in raceways should be prohibited.
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, - In July, 1983, TUGC0 contacted the NRC staff to discuss the l potential need to revise the FSAR to cover these splices.
FSAR Amendment 44 was issued in October, 1983, to encompass the use of these splices in control panels. The TRT
!. investigation occurred in July, 1984 - subsequent to the
! submittal of this amendment, but prior to the NRC response.
Upon inspection of documentation associated with twelve of the control panel splices, the TRT noted the concerns listed in Section 1.0.
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Rsvision: 1 Paga 3 of 34 sy RESULTS REPORT
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ISAP I.a.2 (Cont'd)
3.0 BACKGROUND
(Cont'd)
- In September, 1984, the NRC Staff approved the FSAR amendment with the provisions that: (1) the installation procedures provide for verification of the operability of those circuits for which splices are being used; (2) the wire splices used are qualified for anticipated service conditions; and (3) the splices are staggered within the panel so they are not adjacent to each other in the same wire bundle and pressing against one another.*
4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objectives of the action plan were to assure that known butt-splices are properly identiffed on the appropriate design drawings, are physically and prorarly installed where required, and that required inspections have been performed
(N and properly documented.
The scope of this plan included the investigation of all Class 1E essential and associated cables that were known to be spliced with AMP PIES splices. This action plan was divided into three sequential phases.
4.1.1 Phase I Phase I consisted of a review of the in-process, post-installation and final Inspection Reports (irs) for the twelve cables reviewed by the TRT and twelve (12) additional cables selected by TUGCO. The purpose of this review was to determine if required documentation for splice witnessing existed and was acceptable. This review substantiated the NRC concerns, and Phase II was initiated.
4.1.2 Phase II Phase II consisted of the following items:
Items (1) and (2), and the procedure changes for item (3) are discussed in the Results Report for ISAP I.a.3. The reinspections
() for item (3) are discussed in this report.
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Ravision: 1 Page 4 of 34
_ (- - RESULTS REPORT l ISAP I.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Review of all drawings and design change documents for Class 1E essential and associated cables in the control room and cable spreading room panels of Unit 1 to identify those panels that included cables that had been authorized to be spliced.*
Inspection of these panels to determine whether the drawings correctly reflected the as-built condition, and whether the AMP PIES splices met the FSAR and installation requirements, and the NRC requirements listed in Section 2.0. If the drawing did not reflect the as-built condition of the cable, !
the drawing was revised to show the actual '
hardware configuration. A review of the associated CPSES Project irs for the spliced cables was also performed to determine j- whether the splices had been inspected and f,
' had been found acceptable per Quality
. Inspection Procedure QI-QP-11.3-28.
Removal of any AMP PIES splices that were considered unsatisfactory after evaluating the above inspection results. These removed splices were pullout-tested to determine the acceptability of the splices for their intended service conditions. The test was conducted in accordance with U.L. Standard 486C, Section 13. " Pullout Tests." Prior to this destructive test, the splices were radiographed to determine the actual depth of conductor insertion into the wire barrel of the splices. (The design of the splices normally precludes determining this depth visually after installation.)
To be reasonably sure that no undocumented AMP PIES splices existed in Class 1E essential and associated circuits in the control room and cable spreading room panels O
As discussed in Section 5.0, this scope was later expanded to include panels outside these two rooms.
Rsvision: 1 Pags 5 of 34 RESULTS REPORT
-' ISAP I.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) of Unit 1, the population of Class 1E panels for which drawings and design change documents did not indicate the presence of any AMP PIES splices was inspected to confirm that no splices were present. These inspections were accomplished without
- separating all cable bundles or dismantling equipment.
Phase II also accomplished part of Action Plan I.a.3,
" Butt-Splice Qualification," by inspecting for known splices located adjacent to and pressing against one another in the same wire bundle (i.e., inspection for
" stagger" of splices).
If one or more AMP PIES splices were found not to be properly installed (e.g., not fully inserted, crimped with the wrong tool, wires curled back, or incorrect size splice used), Phase III was to be initiated by C~)s TUGCO. (This occurred.)
4.1.3 Phase III Phase III consisted of the identification and inspection of all essential circuits where AMP PIES splices may have been used for terminations of
, equipment (e.g., pigtails on solenoids or electrical devices) or splicing of cables in Units 1, 2 and Common areas that were not inspected during Phase II.
Nonconformance Reports (NCRs) were issued by the CPSES Project to identify and initiate inspections of these cables. Phase III was overviewed by CPRT third-party personnel.
4.2 Participants Roles and Responsibilities l The organizations and personnel that participated in this effort are described below with their respective work scope.
4.2.1 CPSES Project 4.2.1.1 Reviewed drawings and design change documents.
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Revision: 1 Page 6 of 34 gx RESULTS REPORT I \
ISAP I.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.2 Assisted the Review Team Leader in identifying cables to be inspected for AMP PIES splices.
4.2.1.3 Processed NCRs that were generated due to this action plan.
4.2.1.4 Assisted the Review Team Leader in the pullout test program preparation and execution.
4.2.1.5 Prepared pullout test procedure.
4.2.1.6 Performed Phase III activities.
4.2.1.7 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator 4.2.2 Electrical Review ream 4.2.2.1 Reviewed and approved the third-party reinspection procedure.
4.2.2.2 Reviewed third-party Inspection Reports and CPSES Project NCRs.
4.2.2.3 Reviewed and approved the pullout test procedure.
4.2.2.4 Reviewed and evaluated the pullout test results. Approved the test report.
Determined any ongoing corrective actions based on the test report results.
4.2.2.5 overviewed the CPSES Project inspection effort described in 4.1.3 (Phase III).
4.2.2.6 Determined root cause and generic implications, and evaluated safety significance.
4.2.2.7 Personnel (prior to October 18, 1985)
Mr. M. B. Jones, Jr. Review Team Leader 1
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Rsvision: 1 Page 7 of 34
,, RESULTS REPORT (s
ISAP I.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Mr. E. P. Stroupe Issue Coordinator 4.2.2.8 Personnel (starting October 18, 1985)
Mr. J. J. Mallanda Review Team Leader Mr. J. R. Pearson 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 Prepared the inspection procedure.
4.2.3.2 Inspected the AMP PIES splices for compliance with acceptance criteria.
) 4.2.3.3 Reviewed CPSES Project inspection documentation to determine whether evidence of splice witnessing existed.*
4.2.3.4 Performed the overview inspection (see Section 4.2.2.5) as determined by the Electrical Review Team Leader.
4.2.3.5 Personnel Mr. J. L. Hansel Review Team Leader -
QA/QC 4.2.4 Third-Party Adviser 4.2.4.1 Reviewed pullout test procedure.
l 4.2.4.2 Supervised pullout test.
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4.2.4.3 Personnel Mr. L. D. Bates Electrical
(- Engineering Adviser l
l In some Cases this review was performed by the Electrical Review Team.
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Revision: 12 Pags 8 of 34 g] RESULTS REPORT V
ISAP 1.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 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 in accordance with 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 1.58 was not met. These requirements were not part of the CPRT Program Plan at the time of testing. However, the qualifications of the individuals 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.
Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific, requirements of the CPRT Program Plan. CPRT activ1 ties performed by other than third-party personnel are governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality," of the CPRT Program Plan.
4.4 Procedures 4.4.1 Instruction QI-002, "CPRT Action Item I.a.2, Inspection of Butt-Splices and CPRT Action Item I.a.3, Butt-Splice Qualifications."
4.4.2 Test Procedure I.a.2/I.a.3-001, " Butt-Splice Pullout Test Procedure."
4.4.3 Test Procedure I.a.2-002, " Butt-Splice Special Test."
(See Section 5.2.6.)
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Rsvision: 1 Page 9 of 34 i 3' I j- '
RESULTS REPORT
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ISAP I.a.2 (Cont'd) 4 4.0 CPRTACTIONPLAN(Cont'df 4.5 Acceptance Criteria
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4.5.1 The acceptance criteria for the butt-splice reinspection are listed in Instruction No. QI-002, Revision 4.
4.5.2 The acceptance criterion for drawings is that each reflect the as-built configuration of butt-splices in Class lE essential and associated cables.
4.5.3 The requirements for the pullout tests are specified in i
Test Procedure I.a.2/I.a.3-001 and Test Procedure
,I I.a.2-002.
j 4.5.4 The acceptance criterion for the review of an inspection report (IR) is that the IR indicates that the splice was witnessed. If this indication was not present, and the associated splice had not been removed because of other findings, then an NCR was issued.
'# 4.6 Decision Criteria In Phaas II, failure of one or more AMP PIES splices to meet the acceptance criteria of 4.5.1, 4.5.2, or 4.5.4 will initiate Phase III. (This occurred.)
l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The Phase I review of CPSES Project irs substantiated the TRT Staff fir aings that splice witnessing had not always been documented. As a rest.'t, Phase II was initiated, which included the reinspection
, i and ds . ament review of AMP PIES splices in Class lE essential and associe'.ed circuits in panels located in the control room and cable spreading room of Unit 1. Many deviations from the acceptance
'e criteria of Sections 4.5.1, 4.5.2, and 4.5.4 were discovered. As a a
' result, two further investigations were initiated. First, Phase II was expanded to include the reinspection and document review of known , splices in electrical panels in other areas of Unit 1.
.Second,' Phase III was initiated by the CPSES Project to identify and reinspect any essential cables in areas not covered by Phase II for which AMP PIES splices might have been used. Phase III included Units 1, 2 and Common.
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J i Rsvisio'n: 1 1
n,. Pago 10 of 34 e e t' RESULTS REPORT
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k_3,) ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Sections 5.1 through 5.3 provide a discussion of the results from the implementation of Phases I, II and III, respectively. Use of the results from these activities is discussed in Section 5.4.
Other CPRT activities related to this ISAP are discussed in Section 5.5. Analyses of the findings, including safety significance, adverse trend, root cause and generic implications, as well as recommended corrective actions are presented in subsequent sections.
5.1 Phase I
- Phase I consisted of a review of the documentation for the twelve cables reviewed by the TRT and for an additional twelve '
r cables selected by TUGCC. As the TRT had found, the' r documentation failed do meet the requirements for splice witnessing. As'a result, Phase II was implemented. The scope of Phase II included iny AMP PIES splices reviewed in Phase I. ,'
Section 5.2 incl 6 des a detailed discussion of the findings ~
from Phase II'at.d the corrective actions taken.
5.2 Phase II - '
5.2.1 Design Document Review The CPSES Project reviewed drawings and design change documents for Class lE essential and associated cables in the control foom and cable spreading room panelv of Unit 1 and identified those panels where design /
documentation indicated that AMP PIES splices (1) were and (2) were not installed. These lists were then used for the third-party reinspections described below.
5.2.2 Reinspection of AMP PIES Splices Reinspection Methodology The initial reinspections included, with ore exception involving nine splices *, all Class IE essential and
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- The splices in two HVAC' pant'1s were inaccessible for this inspection. Later three splices in these panels were judged '
accessible and were reinspected. One other eglice has been -
g replaced subsequently due to inadequate inspection documentation.
-g) The CPSES Project has been requested by the Electrical Review Team to reinspect the remaining splices in these pancis.
1 Revision: 1 Pegs 11 of 34
,_ RESULTS REPORT
- s/ ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) associated cables that had been identified by the design document review as authorized to be spliced.
Cable bundles were disassembled to the extent necessary to identify and reinspect any splices in these cables.
During this identification and reinspection activity, the panels were also reinspected for unauthorized splices. This aspect of the reinspection was limited
' to those conductors that were initially visible or made visible by the cable bundle disassembly described above. However, for those panels that were considered highly likely to contain additional unauthorized splicing, the cable bundles were disassembled to allow any other unauthorized splices to be identified and reinspected. As a result of the above activities, 577 AMP: PIES splices were identified and reinspected.
Because of many construction deviations identified during thetw veinspections, the scope of Phase II was f- g expanded to include the reinspection and document
() review of other known AMP PIES splices in panels in Unit I and Common. (This scope otherwise would have been included in Phase III.) As a result of this expansion, which included Motor Control Centers (MCCs) and local Heating Ventilating and Air Conditioning (HVAC) panels, 31 more AMP PIES splices were identified i
' and reinspected, thus bringing the total number reinspected to 608.
The reinspections of each AMP PIES splice consisted of 1
a check of each of the following attributes:
that the correct splice for the associated conductor size had been installed; that the splice was properly crimped, including use of the proper tool (evidenced by a " dot code");
that no conductor strands showed outside the wire barrel of the splice; that the conductors at each end of the splice were the same color and size as each other; that the splice was identified on the Os associated CTSES Project drawing; and i
Rsvision: .1 Pags 12 of 34 RESULTS REPORT O ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) that the splice had not been heat-shrunk.*
Following completion of the reinspection of the splices, the conductors were verified to be satisfactorily rebundled. Rebundling was considered satisfactory when the following three criteria were met:
that splices in the same bundle were staggered or spaced so that they were not adjacent to and touching one another**;
that the cables for redundant trains met separation requirements ***; and that the bend radius requirement for the 4
conductors was met ***.
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(% The results of the reinspections were evaluated, and
(,,) those splices judged unacceptable were removed. All but three of the removed splices were pullout-tested **** to determine the actual effect of the noted deviation (s) on splice integrity. The results of these reinspections are discussed below and the findings are summarized in Appendix A. Where the discussion below indicates that certain splices were removed and included in the pullout test, the safety significance of the respective findings was assessed by that test (see Section 5.2.4).
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' The AMP PIES splice is designed to allow for heat-shrinking of the splice insulation in order to achieve an environmental seal.
However, for mild environments such as these control panels, heat-shrinking is not necessary. CPSES Project design documents usually instructed craft not to heat-shrink the splices.
The verification of this criterion completed the commitment made in the Results Report for ISAP I.a.3.
These attributes are out-of-scope with respect to the AMP PIES splices, but are fundamental to proper rebundling.
The three exceptions are discussed in the appropriate sections O- below.
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Rsvision: 1 Page 13 of 34 RESULTS REPORT ISAP I.a.2
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(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Contd)
Correct Splice Installed Eight splices were found where the wrong size splice had been installed for the conductor size involved.
All eight were splices intended for #12-14 AWG conductors, but were installed on #16 AWG conductors.
All eight splices had been authorized by CPSES Project engineering on the same Design Change Authorization (DCA 17,762). This DCA actually specified the wrong splice. These are considered to be design deviations.
All eight splices were removed and included in the pullout test.
Proper Crimping Sixteen (16) splices were noted as having improper l
crimps, including crimps on the wire stop (rather than the wire barrel), twisted crimps, and off-center crimps. Fourteen (14) of these were removed and
( included in the pullout test. The remaining two were omitted from this test erroneously due to an ambiguous aspect of the inspection procedure. Both of these splices were noted as having crimps that " appeared twisted." NCRs were written, resulting in both splices
- being replaced. The Electrical Review Team has evaluated these two splices separately and considers 4
that they were adequate to perform their intended
, safety function. These 16 cases are considered to be construction deviations.
Three splices were noted as having it.aulation damage caused during crimping. For two of these, protection of the underlying wire barrel and conductors was still provided. For the remaining splice, the damage resulted in the wire barrel being exposed. This splica was noted as being installed within a large wire bundle such that it was protected by the surrounding conductors. Consequently, the splice could still have performed its intended safety function. As this was the only such deviation, and essentially all of the known splices have been reinspected, there is no adverse trend. All three of the splices with insulation damage were removed and included in the i pullout test. These are considered to be construction i
deviations.
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Rsvision: 1 Page 14 of 34
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V RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Twenty-four (24) more splices were noted during reinspection as unsatisfactory because the dot code left by the crimping tool was incorrect (thus indicating that the wrong tool had been used). These splices were all removed and included in the pullout test. Two other splices that had been noted by third-party inspectors as improperly crimped due to the crimps being twisted were also noted by the Electrical Review Team as evidencing the wrong dot code. These two had been included in the pullout test because of the twisted crimps. These 26 cases are considered to be construction deviations.
Thirty-four (34) splices were noted as indeterminate for this attribute because the dot code could not be discerned due to the splice having been heat-shrunk.
(AMP's literature indicates that the dot code will disappear when the splice is heat-shrunk.) For 28 of these, the CPSES Project irs indicated that a QC
\s inspector had witnessed the correct tool being used.
These were not considered to be deviations. For five of these, the CPSES Project irs indicated that the wrong tool had been used. These five were removed and included in the pullout test. These are considered to be construction deviations. One was indeterminate because witness documentation was not found. Though this one was later removed, it was not included in the pullout test. Based on the results from pullout testing of other similar specimens, for which pullout forces ranged from 50 to 126 pounds, the Electrical Review Team considers that this splice would have been able to perform its intended safety function. This is-considered to be a construction deviation.
No Strands Outside Barrel This QI step was apparently intended to check for strands showing outside the insulating barrel of the splice. No such deviations were noted. However, three cases were noted where the inspector was able to discern that strands had not been inserted into the wire barrel of the splice. These were removed and included in the pullout test. During review of the radiographs of the other pullout specimens,10 more m'-- --
-m,.,,, , g+-+-g- - -+ --m-r--- r---i-ve---,i-c--= gg --, ,e,- ,w-, .i-ywm w-- - -
Ravision: .1-Pags 15 of 34 4
RESULTS REPORT ISAP I.a.2 (Cont'd)-
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) cases were noted where strands had not been inserted into the wire barrel of the splices. This condition i
can not always be detected by visual inspection, either because the opaque quality of the splice insulation prevents the inspector from noting that a strand is curled back or cut off, or because the insulation of
, the conductor is flush with the end of the splice wire '
barrel. The implications of this potential shortcoming in the reinspection process are discussed in Section 5.2.6. These 13 cases are considered to be l construction deviations.
4 4
Matching Conductor Size and Color
- Four cases were found where the inspector could not determine whether the correct size of extending-4 conductor had been spliced onto the field conductor.
As these four were a subset of the eight splices that O were the wrong size for the given size of field cable (see first attribute above), they were removed and included in the pullout test. Examination during pullout testing indicated that the correct extending
, conductor size had been used, thus these are not considered to be deviations.
' Six cases were found where the color of the extending E
conductor did net precisely match the color of the field conductor. In each case, it appeared that the extending conductor was from a different cable type, and thus differed in chromatic content. Though this condition had no direct functional impact (all were terminated correctly), all six splices were removed and
- included in the pullout test. These are considered to be construction deviations.
Splice Shown on Drawing There were 109 cases where the splice was not shown on CPSES Project drawings. Sixteen (16) of these were cases where the corresponding conductor had been spared, and thus these were not considered to be valid iO i !
4
Rsvision: 1
. Pags 16 of 34 7-s RESULTS REPORT l\- '/ ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS.(Cont'd) deviations.* Another 16 of these were found never to have been authorized by engineering and thus constituted construction deviations. (Splicing is prohibited without engineering approval.) The remaining 77 cases involved splicing that had been authorized by DCA, but where CPSES Project drawings had never been revised to reflect the splicing. These were considered to be design deviations. In 70 of these cases, the DCA had actually been revised later to delete the authorization for the splices. These splices were removed and subject to pullout testing only in cases where other findings were noted that impacted the quality of the splices.
There were 149 cases where the CPSES Project drawings indicated that conductors were spliced but where third-party reinspections found no splices. NCRs were written to initiate the correction of the drawings.
(*wg These are considered to be design deviations.
4 Q Splice Not Heat-Shrunk As discussed above, 34 cases were found where the splice had been heat-shrunk. Design documentation was reviewed for these cases. For 29 there was no requirement prohibiting heat-shrinking at the time of installation. As there is no technical reason to avoid heat-shrinking, these are not considered to be deviations. For the remaining five, the DCAs in effect l
instructed that the splices should not be heat shrunk.
Because of this prohibition, these are considered to be construction deviations. All five were removed and included in the pullout test.
Seven of those splices that had been heat-shrunk were noted as having insulation damage. It appears that these splices were overheated causing a slight split in the sleeve of the splice at a point of crimping-induced I
stress. In all seven cases the wire barrel and I
l As discussed in the Results Report for ISAP I.a.4, " Agreement Between Drawings and Field Terminations," spare conductors are not
[~'h required to be shown on drawings per CPSES Project procedures.
V
Rsvision: 1 Pags 17 of 34
_s RESULTS REPORT
\j N
ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) conductors were still protected. The damage would not have affected the intended safety function of the splices. Nevertheless, all seven splices were removed and included in the pullout test. These are considered to be construction deviations.
Proper Rebundling and Stagger In many cases, the reinspections also found that the splices had not originally been staggered in the wire bundles. These were not considered to be deviations, because no such requirement was in place at the time that the splices had been installed. (The requirement was added following the receipt of the NRC comment to FSAR Amendment 44.) During the rebundling process that followed the reinspections, CPSES Project personnel ensured that the splices were staggered. This activity was verified by third-party inspectors. In one case, which involved one cable with six spliced conductors, gj there was insufficient slack in the conductors to achieve the required staggering. The CPSES Project issued an NCR to document this finding, and dispositioned the NCR by directing craft to install insulating material between the conductors.
Other Observations Over the course of the reinspections, third-party inspectors noted that a significant portion of the splice population had a condition described as
" improper insertion depth and/or overstripped insulation." The indeterminacy of the condition is due to the inability to determine insertion depth of the conductors into the wire barrel by post-installation visual inspection. Therefore, when there is a gap noted between the conductor insulation and the wire barrel, it is not known whether the conductor was underinserted, the insulation was overstripped, or both. None of the conditions involved the conductors being exposed beyond the insulating barrel of the splice. The implications of this potential shortcoming in the reinspection process are discussed in Section 5.2.6.
s_J
Rsvision: 1 i Paga 18 of 34
_s RESULTS REPORT
)
ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
During the reinspection effort, other findings that were unrelated to splicing (e.g., cable separation violations) were identified. These findings were tracked as out-of-scope observations and, as noted in Section 5.4, were forwarded to the appropriate RTLs for consideration.
5.2.3 Documentation Review A review of CPSES Project irs was conducted for the AMP PIES splices that had been identified by reinspection.
This review involved a check of the irs to verify that 1
the PIES splice installations had been witnessed by QC during installation. In addition, a check was performed of irs for cables that had been authorized to be spliced, but where no splice had been found.
This review found that adequate evidence of QC witnessing did not exist for 101 of the splices
() discussed above. This review also found sev<aral other unsatisfactory conditions. Appendix B summarizes the documentation review findings and the corrective actions taken.
, Of particular concern was a finding where splice witnessing was indicated on eight irs for certain conductors that had not actually been spliced. As a result of this finding, in addition to all of the construction deviations noted during reinspection, CPSES Project QA initiated Corrective Action Report CAR-050 to explore further the work of four electrical QC inspectors whose work came into question. This investigation found that one of these inspectors had completed inspection documents for items that he had not actually inspected. This inspector was immediately relieved of all inspection duties, and his historical work was thoroughly rechecked by the CPSES Project.
The work of the remaining three inspectors was found to be acceptable.
One other notable finding from the documentation review was that the irs indicated that an incorrect crimp tool
Ravision: 1 Pags 19 of 34
,_ RESULTS REPORT (s_/ )
ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) had been used for 19 of the splices.* All 19 of these splices were removed and included in the pullout test.
5.2.4 Pullout Test Program-A test program was initiated that provided the basis for an evaluation of the acceptability of AMP PIES splices with construction deviations.
Samples for the test program were obtained by removing 48 AMP PIES splices (and a portion of the attached conductors) with deviations potentially affecting splice integrity and 32 others that either had no identified deviations or had deviations not expected to affect the integrity of the splices.**
Each splice was first radiographed so that the depth of insertion of wire strands into the wire barrel could be fm determined. Continuity checks were performed prior to
'-~) application of pullout forces on the splices. Splices on #12 AWG conductors were exposed to gradually increasing pullout forces up to 35 pounds, and then maintained at that level for 60 seconds. If they survived this stage, they were then destructively tested by increasing the pullout force until the splice failed. Splices on #16 AWG were subjected to the same test except that the stopping point was 15 pounds.
Of the eighty removed splices subjected to the pullout tests, three (2-#12 AWG, and 1-#16 AWG) failed to meet the U.L. Standard 486C pullout force requirements. The details of these three is as follows:
One (#12 AWG) had an improper (twisted) crimp-and failed at 15 pounds.
14 of these also showed physical signs of an incorrect tool and 5 were indeterminate due to the splices having been heat-shrunk.
In addition, 12 prepared test samples were made using the correct wire size / connector / cool combination and varying insertion depths of the conductor into the wire barrel of the splice. These were used for comparisons with the radiographed samples removed from the C3 field.
Revision: 1 Page 20 of 34 m RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
One (#16 AWG) had the wrong size splice for the conductor size and had been crimped by.
the wrong tool. This splice reached the required 15 pounds, but did not maintain that force for the full 60 seconds.
One (#12 AWG) had two (out of seven) strands not inserted into the wire barrel. These strands were curled back between the wire barrel and the conductor insulation which also prevented adequate insertion of the remaining five strands into the barrel. This splice failed at 25 pounds.
One other splice was improperly tested. It was on a
- 16 AWG conductor, but was taken past 15 pounds without stopping. It failed at 27 pounds. Those performing the test presumed that it would likely have passed at
( 15 pounds for 60 seconds if properly tested. This was
',\ another case of the wrong size splice and the wrong a
crimping tool having been used.
Each of the 80 tested splices was found to have acceptable electrical continuity prior to the pullout tests. Although the pullout force did not meet the minimum U.L. test requirements in three cases, it was noted that in all cases cable bundles are securely fastened together with cable bundle ties at regular intervals, and thus the tension exerted on the splices themselves was expected to be minimal. Stone and Webster Engineering Corporation (SWEC) performed an analysis demonstrating that, under assumptions of proper cable bundle support intervals per FSAR commitments, the maximum pullout force that would be exerted on one of these splices under a design basis seismic event would be 5 pounds for 10 seconds. This became the acceptance criterion for further evaluations of AMP PIES splices. The third-party adviser who administered the pullout test considers that the three splices that failed to meet the UL limits would have passed at a 5 pound load for 10 seconds.
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Revision: 1 Pag 2 21 of 34 RESULTS REPORT i
V ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.5 Inspection of Panels Where Splices Were Not Shown on a
Drawings Fifty-five (55) panels were identified where the design document review did not indicate the presence of splices. These panels were reinspected by third-party inspectors to determine whether it was reasonable to conclude that splices do not exist in these panels. In 10 panels, cable bundles were broken apart entirely for reinspection; in one panel, the cable bundles were partially separated during inspection; one panel contained no cable bundles; and one panel contained no Class 1E cables. For the remaining 42 panels, the reinspections were accomplished without separating all cable bundles or dismantling equipment.
One AMP PIES splice was found during these reinspections. However, further review revealed that 4
this splice had been authorized by the CPSES Project subsequent to the design document review discussed in Section 5.2.1. Based on these results the Electrical Review Team concludes that few, if any, unauthorized splices of.jst in these panels.
5.2.6 Assessment of Findings As noted in Section 5.2.2, there were two conditions that raised concerns about the ability to judge splice quality by post-installation inspection. The first was the inability to detect missing or curled-back strands, as evidenced by 10 such cases noted by radiographic inspection that had not been detected by field inspection. For the 12 tested splices that had one out of seven strands missing or curled back, the destructive pullout forces ranged from 50 to 116 pounds. For the one splice that had two out of seven strands curled back, the destructive pullout force was 25 pounds. This condition had been detected during reinspection. This splice was also noted as having the remaining five strands underinserted by approximately 1/8 inch (half of the wire barrel length). Because all cases where one strand wes missing had acceptable pullout forces, and the definitive worst case was detected during reinspection, the post-installation inspection process is considered to be an acceptable
( screen for splice quality.
t 3
Ravision: 1 Pags 22 of 34 RESULTS REPORT
)
ISAP I.a.2 (Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The second concern was'due to the inability to judge insertion depth of conductor strands into the wire barrel of the splice. Eighteen (18) splices that had been noted during reinspection as being overstripped and/or underinserted were included in the pullout testing. If the insulation strip length were closely controlled, then adequate insertion depth could be
- . determined by examining the distance from the conductor i
insulation to the wire barrel. Radiographic
{_
examination suggested that this close control did not exist (i.e., strip length varied significantly), and that there were some cases where conductor strands were indeed underinserted. Only two of the 80 splices radiographed were underinserted by as much as-1/8 inch.
These were the two #12 AWG splices discussed in Section i
5.2.4 that failed to meet the UL Standard requirement of 35 pounds for 60 seconds. However, it is noted that both of-these splices had other deviations affecting the quality of the splices. For the remaining 16
, splices included in the pullout test that had been noted during reinspection as overstripped and/or-
) underinserted, the pullout forces ranged from 58 to 125 pounds. For the three of these for which potential underinsertion was the only noted concern that could impact upon pullout force, the tested pullout forces j
were 114, 115 and 125 pounds. These data suggested d
that insertion depths of the remaining AMP PIES splice installations were likely to be acceptable.
In addition to the above concerns about the efficacy of the post-construction inspection process, the design document review had failed in identifying all splices i
at CPSES (evidenced by splices found during reinspection that had not been authorized on design i
documents). Therefore, the Electrical Review Team
- recommended a reinspection to identify any remaining i
undetected splices, and the replacement of all splices installed prior to the time that adequate procedures J
and training were in place.* However, the CPSES 1
Refer to Section 5.7 for a discussion of procedures and training.
O
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i' ___. _ . _ . _ . _ _ _ , _ _ , _ _ _ _ _ _ .,_ _ . - _ ,, _ . _ _ ,, - ._ _.. ,
Rsvision: 1 Pagt 23 of 34 f-~s RESULTS REPORT
- f ') l ISAP 1.a.2 l (Cont'd) 1 l
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Project proposed an alternative approach, which consisted of: (1) an analysis of the maximum pullout force that could be expected at CPSES; (2) an analysis of electrical performance characteristics of the splices; (3) parametric testing of a random sample of those splices remaining in the field that had passed the Phase 11 reinspections; and (4) an assessment of the need for further reinspections based on the results of steps 1-3. The Electrical Review Team accepted this approach and overviewed its implementation. The results of these activities (discursed below) demonstrated that there is reasonable assurance that the AMP PIES splice installations in electrical panels i
at CPSES are capable of performing their intended safety function.
As discussed in Section 5.2.4, SWEC performed a seismic analysis that demonstrated that the maximum pullout force that the splices would encounter under worst-case
-) design basis seismic activity at CPSES is 5 lbs. for 10 seconds.* The minimum failure point encountered during the pullout testing was 15 lbs. for the visually-rejected splices and 84 lbs for the visually-accepted splices. Though the three splices that failed pullout testing per the U.L. Standard were not specifically maintained at 5 lbs. for a full 10 seconds, the Electrical Review Team considers that those three splices would have passed such a test.
Analysis and testing of electrical characteristics showed that the splices would be capable of carrying rated current under either of the following conditions:
(1) uncrimped and with all strands underinserted by
' 1/8 inch (significantly worse than any deviation encountered); (2) crimped but with 2 of 7 strands not inserted (1 similar deviation encountered and none worse). Furthermore, the spliced field cables are all for instrumentation and control circuits. The actual i
current levels of these circuits will be significantly lower than the rated current of the cables.
i This assumes maximum spacing between wire bundle supports of 15" i ) horizontally and 24" vertically. The CPSES Project has committed l
to a walkdown of electrical panels to confirm this spacing. Any t
deviating conditions will be corrected.
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Page 24 of 34 r~}
~J RESULTS REP' ORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
To determine the adequacy of the splices that had passed visual reinspection, parametric testing of the pullout force was performed on a random sample of 50 of these splices. The samples for this testing were obtained by removing 50 of the splices still installed in the field. This testing revealed an average pullout force of 128 lbs. and a standard deviation of 14 lbs.
(thus, the average was more than 8 standard deviations above the maximum expected force at CPSES). The minimum force at which any of the 50 splices failed was 84 lbs. Prior to being pulled to destruction, each specimen was tested at 5 pounds for 10 seconds, 10 pounds for 10 seconds, and 35 pounds for 60 seconds.
All 50 splices passed at each of these levels.
Acceptable electrical continuity was verified before and after each level. This testing was overviewed by third-party personnel. Though the destructive pullout forces of the sample did not conform closely to that of
/
a normal distribution, the strengths of all of the (s- tested splices were so many times greater than the maximum
- expected force at CPSES that the probability of a deficient splice existing in the balance of the population must be negligibly small.
Phase II reinspections were extensive and detailed.
Essentially all of the AMP PIES splices in Class IE essential and associated circuits in control panels of Unit I have been identified. Of those reinspected, approximately 10% were replaced because of visual defects. The seismic analysis and original pull testing demonstrated that even these would have performed their intended safety function. Therefore, further activities, involving equipment disassembly, for the purpose of identifying some minimal number of unknown splices, would be very unlikely to lead to the discovery of a construction deficiency and are not recommended.
5.3 Phase III Because of the numerous conditions found curing Phase II that did not meet the acceptance criteria, Phase III was initiated.
Phase III consisted of the identification and inspection of all essential circuits where AMP PIES splices may have been
[ used for equipment termination or cable splicing in Units 1, 2 and Common areas that were not reinspected during Phase II.
Revision: 1 4
Pago 25 of 34' -
i -
RESULTS REPORT ISAP I.a.2
.(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Phase III was performed by the CPSES Project. CPRT third-party overviewed any reinspections where AMP PIES
- splices were actually used.
i Two of these cables were found to be terminated to vendor l pigtails using AMP PIES splices (two splices per two-conductor
, cable). In both cases the vendor wiring was #18 AWG, and the splice was one designed and specified by CPSES Project design documents for use only on #12 and #14 AWG wire. These splices were cut out and replaced with the proper connector per CPSES a
Project procedures. Upon examination of one of the removed
' splices by the Electrical Review Team, the. vendor wire was able to be pulled out of the splice with minimal effort.
Based on this observation of the mechanical integrity of these-splices, these findings have been classified as safety-significant deviations constituting a construction deficiency.
The CPSES Project activities for Phase III also included the
( reinspection of several cables that had terminations covered by heat-shrinkable insulation sleeves. One finding from this activity (sleeve overlapping fiberglass braid) was reported in the Results Report for ISAP 1.a.1. An additional finding pertaining to these sleeves was noted for Cable EG109955A, where there was lack of proper adhesive flow and one sleeve was overlapping the braided cable insulation. The CPSES Project has issued NCR E-86-100865 to document this finding.
The Electrical Review Team considers that the corrective actions described in the Results Report for ISAP I.a.1 are sufficient to encompass any concerns raised by this finding.
5.4 Use of Results The CPSES Project has generated NCRs (or equivalent) to i'
document all unsatisfactory conditions requiring corrective action. The Electrical Review Team has reviewed these i
documents and provided comments to the CPSES Project for resolution. In some cases documentation findings did not require NCRs because the corresponding splice was replaced due to hardware findings (thus resulting in the documentation j being superseded). Discrepant conditions noted after removal of splices from the field (e.g., from examination of radiographs) were not specifically appended to the NCRs because those splices were no longer installed.
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i 4
-. - .- ~ , - , , . .. _ , . _ .-4-, .-. w.,_. ,_,,, ,,w w_.m,,c. - evy~_ _,.m__-y,_, ym,,. .y..y.-,,,,m,.y,-v~._
. . . . = .. _. ~ . - - _ . - . - _. - - . _ - _ -
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Ravisions. 1 Pags 26 of 34 i
RESULTS REPORT i ISAP.I.a.2 i
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
All deviations and out-of-scope findings were forwarded to the i
appropriate RTLs for consideration in the various ISAPs, DSAPs and collective evaluations as considered appropriate by the 4
Electrical Review Team.
5.5 Related CPRT Activities In addition to the Phase III findings presented above, a i
related finding was forwarded from ISAP I.a.1, " Heat
! Shrinkable Cable Insulation Sleeves." Cable AG130695 was
- found to be terminated using AMP PIES splices, one of which had split insulation. NCR E-85-100265S was issued to document this finding and was dispositioned by instructing craft to j install new AMP PIES splices. However, the field cable was i
- 12 AWG and the vendor cable was #18 AWG. Therefore, this was
- an incorrect application of the subject splices, and contrary to CPSES Project design documents. The hardware aspects of s
this finding are essentially identical to those described
- I above under Phase III. However, the disposition of the NCR, which directed craft to again install AMP PIES splices instead of the proper connector for the application represents a design deviation, which has been forwarded to the Design a
Adequacy Program for further evaluation, a
j 5.6 Safety Sianificance Evaluacion i-(
For the Phase I and II findings, the testing and analysis i performed by the CPSES Project and'SWEC has demonstrated that i the AMP PIES splices would have performed their intended functions. Therefore, the individual findings are not considered to be safety-significant.
However, 10CFR50 Appendix B, Criterion V, " Instructions, Procedures and Drawings," requires activities affecting i quality to be prescribed by documented instructions.
l procedures or drawings, and to be accomplished in accordance l
with same. This requirement was not met in the following two l areas:
1 Craft and QC procedures contained no detailed instructions on the proper selection, installation, and inspection requirements for AMP PIES splices. This is j
considered to be a QA/QC Program Deviation.
l r
RGvision: 1 Peg 2 27 of 34 ps RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Witnessing of all splices was required by CPSES Project procedures. (Witnessing is appropriate because of the noted inability to determine such characteristics as insertion depth by post-installation inspection.)
However, a substantial percentage (15-20%) of the splices identified by this ISAP appear not to have been witnessed. Thus the witness program was not accomplished in accordance with prescribed instructions. This is considered to be a QA/QC Program Deviation.
Because of the type and number of construction deviations encountered, and the extensive testing and analysis that was required to determine the acceptability of the remaining hardware installations, the Electrical Review Team considers that the above two deviations constitute a QA/QC program deficiency as defined in Appendix E to the CPRT Program Plan.
As noted in Section 5.3, the Phase III findings have been
( classified as a construction deficiency.
5.7 Root Cause Analysis The Electrical Review Team has assessed the root cause and/or contributing causes for the QA/QC Program Deficiency and the construction deficiency discussed above.
Prior to the time of the TRT investigation, the craft Construction Procedure EEI-8, " Class 1E and Non-Class 1E Terminations," did not contain specific instructions regarding the selection, installation or inspection of AMP PIES splices.
This procedure did indicate that manufacturers' instructions were to be used for installation of connectors, but no specific instructions with respect to selection of splice type or size, the correct tool to use, or accept / reject criteria for installation were included. It is noted that CPSES Project Drawing 2323-El-1701 contains the typical details for splice installations, including a chart defining the correct choice of a splice for a given set of wire sizes.
l However, this drawing was not referenced in the craft procedure. The uncertainty over actual insertion depths
- required extensive testing and analysis in order to determine i
the adequacy of existing splice installations. This procedure did not include adequate controls over conductor strip lengths. In fact, craft were allowed to strip conductor q $nsulation with pocket knives, i
Ravision: 1 Page 28 of 34 O RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Prior to the time of the TRT investigation, the QC Inspection Procedure QI-QP-11.3-28 " Class IE. Terminations," did not contain specific instructions regarding the selection, installation or inspection of AMP PIES splices. This procedure did contain some genera 1' statements about using manufacturers' instructions, but no specific instructions in the area of splicing. Again, there was no reference to Drawing 2323-El-1701.
Specific training in the selection, installation, and inspection of these splices was not researched. As there were no specific requirements in the procedures and training was based on the content of the procedures, little insight could have been gained by such research.
Because the construction deficiency was a result of the wrong size splices being chosen, and because the two procedures referenced above did not include proper references to or C,/g contain the necessary information regarding the selection of splice size, the Electrical Review Team has concluded the following:
The primary root cause was inadequate craft installation procedures.
A principal contributing cause was inadequate QC '
inspection procedures.
The QA/QC program deficiency was a result of the failure to comply with 10CFR50, Appendix B, and the resultant effort required to assess the adequacy of the hardware installations.
The components of this deficiency include: (1) failure to maintain a proper witness program for splices as required by CPSES Project procedures; (2) failure to maintain accurate configuration control with respect to identifying splices on design documents; and (3) failure to install the splices properly. The causes of each aspect of this deficiency are discussed below.
QC Inspection Procedure QI-QP-11.3-28 required QC witness of all splices. However, approximately 15-20% of the splices identified by this ISAP appear not to have been witnessed.
Some were documented on post-installation inspection forms without indicating that witnessing had occurred, while for
() others the documentation does not suggest that the QC
Rsvision: 1 Pega 29 of 34
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RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) inspector was aware that splices were installed. It was noted that craft Construction Procedure EEI-8 contained no hold points for QC witness. Based on this evidence, the Electrical Review Team concludes the following:
The primary cause of this aspect of the deficiency was inadequate QC supervision, allowing such a widespread breakdown in the witness program.
A contributing cause was inadequate craft procedures 3 due to the lack of hold points for QC witness.
For the failure to maintain proper configuration control, the apparent root cause was a breakdown in the interface between engineering and construction personnel. The prevalent occurrences of unauthorized splices, splice authorization being deleted from DCAs after splices had been installed, and drawings indicating many splices where no such splices were installed, indicate that feedback and verification as to the i
(s specific conductors being spliced were either extremely inaccurate or "else nonexistent.
l The causes of the repeated failure to install the splices correctly were:
The primary cause was inadequate craft procedures as discussed above (and the resultant lack of adequate training).
1 A contributing cause was inadequate QC procedures as e
discussed above (and the resultant lack of adequate training). -
5.8 Generic Implications Evaluation
' The implication of the Phase III construct 1on deficiency and associated primary and contributing causes is that other cases may exist in associated Class 1E circuits where AMP PIES
' splices were used to terminate to vendor wiring that is not the correct size for the splices. Implications beyond the
- hardware scope of this ISAP will be considered in the
, collective evaluation process.
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M Revision: 1 Pass 30 of 34 RESULTS REPORT !
ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) f The primary and contributing causes of the QA/QC program 3
deficiency do not have any generic implications within the
- population of AMP PIES splices because the ISAP essentially was formulated with built-in corrective actions (i.e., 100%
reinspection of known AMP PIES splices). Specifically:
l ,
The craft procedure was inadequate in that it did not include hold points for QC witnesslof splices, or j instructions for the proper selection or installation i
of the splices. As discussed'in the Results Report for ISAP I.a.3, this procedure has been revised and appropriate training has been accomplished. The 4
reinspection, testing and analyses performed for this ISAP have demonstrated that remaining installations are acceptable. No further implications exist for the
- population of AMP PIES splices.
The QC procedure was inadequate in that it did not l
t include instructions for the proper inspection of the splices. As discussed in the Results Report for ISAP 3
^
I.a.3, this procedure has been revised and appropriate training has been accomplished. Further, though this procedure had required QC witnessing of all butt j
splices, a full witness program did not exist. The 4
reinspection, testing and analyses performed for this I
ISAP have demonstrated that remaining installations are acceptable. No further' implications exist for the population of AMP PIES splices.
I
{- -
There was a lack of configuration control due to an j
apparent breakdown in the interface between engineering
}
and construction. . Drawings have been or are being revised as appropriate to reflect the as-built configuration of known AMP PIES splices in the field in l Class 1E essential and associated cables. No further j implications exist for the population of AMP PIES splices.
h The various causes of the deficiencies discussed in Section
- 5.7 will be assessed in the collective evaluation process for
[ any further implications outside the scope of hardware covered j by this ISAP.
I i
R: vision: 1 i Paga 31 of 34 l l
f'~x RESULTS REPORT l
U) -
ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.9 Corrective Action Recommendation The Phase I and II findings have been or are being corrected as indicated in Appendixes A and B. The concern about splices (both known and unknown) still remaining in the field have been adequately addressed by the program discussed in Section 5.2.6.
As discussed above, safety-significant deficiencit were identified in Phase III. The Electrical Review Team has recommended that all associated Class IE pigtails terminated with AMP PIES splices be reinspected by the CPSES Project for correct application of hardware.
6.0 CONCLUSION
S The following major findings were identified during the course of implementing the Phase I and II activities of this ISAP:
O kls -
Some splices were installed without authorization on design documents. Also, some design documents were revised by deleting splices, even though the corresponding conductors had actually been spliced. These findings were the apparent result of a breakdown in the interface between construction and engineering.
There were eight conductors spliced with the wrong size splice. All eight cases were caused by a single DCA, in which engineering had specified the wrong splice.
- There were no specific instructions regarding the installation or inspection of AMP PIES splices in the applicable CPSES Project procedures at the time that the splices were installed. Consequently, there were many inadequate splice installations that were not detected by QC inspection.
Documentation of splice witnessing by QC did not exist for 15-20% of the splice population. This substantiated the TRT finding regarding splice witness documentation.
- Some cable inspections were documented by QC as including splice witnessing when actually no splices existed in those cables. CPSES Project QA took prompt action to correct this situation and investigate the magnitude of the problem. No O evidence of a further programmatic breakdown was found.
Ravision: 1 Paga 32 of 34 i.
{- RESULTS REPORT ISAP I.a.2 (Cont'd) 6.0 -CONCLUSIONS (Cont'd) .
Despite the various breakdowns in engineering, craft, and QC that
' occurred, the testing and analysis discussed in this report demonstrated that the splices reviewed in Phases I and II would have been.able to perform their intended function. All known AMP PIES splices have been or will be reinspected. Corrective action has been initiated for each of the findings. Drawings have been updated to show all known splices. Inspections have been performed to verify that splices are now staggered.
In Phase III, the Electrical Review Team found instances where AMP
[ PIES splices had been used for terminating field cables to vendor 1
pigtails. These splices were not the correct connectors for these i
terminations due to the size of the vendor wiring. Corrective action has been recommended to and concurred with by the CPSES Project. With the completion of this corrective action, all known AMP PIES splices in Class IE essential and associated circuits in Units-1, 2 and Common that were installed prior to the middle of i 1985 will have been reinspected and findings noted and corrected as appropriate.
j 7.0 ONGOING ACTIVITIES i
The CPSES Project will implement the recommended corrective actions discussed in Section 5.9. Thiro party personnel will overview this I
process, and will ensure that crements to NCRs are incorporated, and that reinspections of previausly-inaccessible splices discussed
- in Section 5.2 are performed. Ihe results of these activities will be presented in a Supplementary Report.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE The corrective actions taken as a result of the findings presented j herein together with the completion of ongoing activities will
{ ensure that existing installations are adequate. Current l procedures provide adequate instructions for the installation and i
inspection of AMP PIES splices. Training accomplished to date j together with ongoing periodic training will ensure that craft and j
QC personnel are adequately aware of the installation and
- inspection requirements. No other actions are necessary.
i 1
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m R vicion: 1 Pega 33 of 34 i
RESULTS REPORT
\--
ISAP I.a.2 (Cont'd)
Appendix'A Summary of Phase II Reinspection Findings NO. OF ITEM DESCRIPTION OF ITEM FINDINGS RESOLUTION
- l 1 Splice Not Shown on Drawing 109 Drawing Updated 2 Drawing Shows Splice - No 149 Drawing Updated o Splice Found 3 Splice Heat Shrunk - Crimp Tool 34 Reviewed IR for Tool #
Indeterminate by Reinspection 4 Splice Insulation Split from 7 Replaced Defective Splice Heat Shrinking 5 Incorrect Color Extending Replaced Splice
!O. Conductor Spliced On 6
6 Improper Crimp 16 Replaced Defective Splice 7 Crimping Damaged Insulation 3 Replaced Defective Splice 8 Incorrect Tool Used 26 Replaced Defective Splice (Wrong Dot Code) 9 Strand (s) Outside Wire Barrel 13 Replaced Defective Splice 10 Wrong Size Splice 8 Replaced Incorrect Splice 11 Stagger Unsat After Rebundling 6 Inserted Insulating Mat-l-
l erial Between Conductors Total 377 The noted resolution was the usual one. However, in some cases, circumstances dictated a different, but equally adequate, resolution (e.g., conductor is now spared, so the defective splice was removed rather than replaced by a new splice).
l
R2 vision: 1 Pago 34 of 34
~~
RESULTS REPORT N- '
ISAP I.a.2 (Cont'd)
Appendix B Summary of Phase II Document Review Findings NO. OF ITEM DESCRIPTION OF ITEM FINDINGS RESOLUTION
- 1 Splice Not Documented as 101 Reinspected Splice Witnessed 2 IR Indicates Splices as Witnessed 8 CAR on QC Inspectors But No Splice Exists 3 IR Indicates Splicing of Conductors 1 CAR on QC Inspectors But Conductors Don't Exist 4 Incorrect Drawing Referenced 1 Reinspected Splice (s) 5 Incorrect Drawing Rev. Ref'd 3 Reinspected Splice (s) 6 No Drawing Referenced 22 Reinspected Splice (s) 7 Incorrect Cable ID Referenced 1 IR Superseded 8 Incorrect Cable End Referenced 1 IR Superseded 9 Incorrect Tool for Splice 19 Removed Splice Referenced 10 IR Altered w/o Initials & Date 4 Corrected per Procedures 11 IR States Conductor Scrapped, 1 IR Corrected Relugged and Retermed But Conductor Found Spliced -
IR Altered after Level II Review 12 Two Cri=p Tools Noted on IR 3 Reinspected Splice (s)
Total 165 The noted resolution was the usual one. However, in some cases, circumstances dictated a different, but equally adequate,
( resolution (e.g., the documentation finding was rendered moot due to corrective action taken because of a hardware finding).
O COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: III.a.5
Title:
Preoperational Test Review and Approval of Results REVISION 1 l
l O i k, -
3 24-97 sue Coordinator Date w b. c. 3 c.4-97 iew Team Leader Date
& G. k JohW W. Beck, Chairman CPRT-SRT 2h <.h r Da t'e
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R2 vision: 1 Paga 1 of 22 RESULTS REPORT v
ISAP III.a.5 Preoperational Test Review and Approval of Results
1.0 DESCRIPTION
OF ISSUE In a Memorandum dated December 21, 1984, the Atomic Safety and Licensing Board (ASLB) described the issue as follows:
Testimony indicates that system performance did not meet the acceptance criteria, both because of obvious calculational errors and because the acceptance criteria were exceeded.
, 2.0 ACTION IDENTIFIED BY THE ASLB The information required by the ASLB is as follows:
k'e need to know how this occurred and to be assured concerning the frequency of similar errors in startup test results.
- p
3.0 BACKGROUND
V The ASLB conducted a companion hearing to the CPSES Operating License proceedings during mid-1984. The subject of the hearing was the alleged harassment, intimidation, and threatening of QA/QC inspectors. The portion of this hearing related to testing activities was conducted in camera, and is the subject of a protective order issued by the ASLB. The ASLB's Memorandum resulted from TU Electric's presentation of an approved preoperational test data package, 1-CP-PT-02-02, "118 VAC RPS Inverters," as evidence in this companion ASLB hearing. The approved test data package for these inverters contained recorded test data that did not meet the stated acceptance criteria.
l The function of the inverter system is to assure an uninterruptable AC power supply to the reactor protection system instrumentation.
This function is accomplished by having the inverters supplied from an AC and a DC power source, and transferring upon loss of one source to the other without interrupting the output. The results of the first preoperational test of this system were reviewed and approved by the Joint. Test Group (JTG) in January 1983. During subsequent operation of the system, ferroresonant transformers, a i
major component of the system, exhibited in-service failures.
I
, ASLBP No. 79-430-06 OL, Memorandum (Standards Applicable to Pending
.A Motions)
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Rsvision: 1 Pags 2 of 22 4.
RESULTS REPORT ISAP III.a.5 (Cont'd) i
3.0 BACKGROUND
(Cont'd)
Investigation of the failures led to the filing of a notification to the NRC pursuant to the requirements of 10CFR50.55(e). The transformers were repaired and reinstalled. The retest requirement specified for the system was total reperformance of the original preoperational test procedure. During preparations for performing the retest, the responsible System Test Engineer, who had not performed the original test, identified the unacceptable data in the original test data package. Subsequently, the original test data package was presented as evidence in the companion ASLB hearing in order to impeach testimony given by an individual. A 4
chronology of events related to this issue is presented in Attachment 1.
l The preoperational test program is conducted in accordance with written administrative and test procedures. The administrative procedures are reviewed by the Lead Startup Engineer and Manager, Operations Quality Assurance, and approved by the Manager, Startup.
l The test procedures are reviewed and approved by the JTG, an j organization whose membership reflects the major CPSES design, testing, and operating organizations. The administrative procedures establish the methods for preparation, format, review, approval and performance of test procedures, for documentation and
] I resolution of test exceptions, and for review and approval of test
, results. Test procedures are prepared and performed by the Startup i organization. Startup also prepares the test data package containing all the information relevant to the test results for
/
3
' subsequent JTG review and apptoval. A System Test Engineer (STE) from the Startup organization performs each of these activities (preparation, performance, and documentation) for the systems to I which he is assigned. During the course of testing, one STE may perform all activities for a system or several STEs may be involved in a test. The STEs may be assigned both preoperational and
' acceptance tests. Preoperational tests are tests of safety-related systems and components as distinct'from acceptance tests, which are the same type of tests performed on non-safety-related systems and
)
components.
s,
- .i While the NRC-TRT was at CPSES, they reviewed fifteen of the j
[ twenty-two preoperational test data packages associated with hot I
functional testing and, also, the preoperational test data package for the containment leak rate test. These reviews were documented in an NRC letter of September 18, 1984 that subsequently formed the l I
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_ ~ . -.; - . . _ . - _ . __
Rsvision: 1 Pags 3 of 22 RESULTS REPORT ISAP III.a.5 4
(Cont'd)
- 4
3.0 BACKGROUND
(Cont'd) basis, in part, of the CPSES Safety Evaluation Report, Supplement No. l 7, dated January 1985. The NRC-TRT requestedradditional .
information'related to preoperational test data packages; this was '
the basis for the test program related' action plans. Shortly after receipt of the NRC letter dated September,16', 1984,'the Joint Test Group initiated a reevaluation of the preep'erational tast data 1-packages it had previously approved., Ihis reevaluat:fon effort was ,< l performed in accordance with Startup Administrative Procedure CP-SAP-11. " Review, Approval and Retention of Test Re.sults,"
I
! augmented by additional criteria approved by the JTG'. The ~
additional criteria were specifically related to the NRC-TRT's request for additional information. A Test Deficiency Report (TDR) was issued in accordance with CP-SAP-16. " Test Deficiency and" ? I_
j Nonconformance Reporting," to document the conduct of each ^
reevaluation and, if necessary, to documert corrective actions and s ,4 ratesting. The scope of the reevaluation progret consisted of$the three preoperational hot functional test data packages in whi W the NRC-TRT expressed a specific concern; tha+seven hot functional test
. data packages not reviewed by the NRC-TRT; and a sample of the 139
}
other preoperational test data packages that had been approved by
- the JTG as of September 17, 1984. (The JTG continued to review and j ~ approve test data packages subsequent to that date.) This sample
- . consisted of twenty preoperational cast data packages considered by l j the JTG to be the most safety-significant. The JTG completed its reevaluation in April 1985. One reevaluation criterien, as stated in the original Startup Administrative Procedure CP-SAP-11, was to verify that the stated acceptance criteria had been met in each
- preoperational test data package reviewed. The JTG's review did j not identify any additional acceptance criteria that had not been met.
4.0 CPRT ACTION PLAN !
.g (
The objective of this Action Plan was two-fold: a) to identify the f actora that contributed to the approve.1 of test data that did ctoc meet speciffgations; and b) to provide reasonable assurance thee were no siri]ar errors made in the review of other preoperational testtresulUr.' '
- t, 4.1 Scope hnd Methodology , ' .
The scope of the evaluation included the examination of the circumstances that led to the approval of test rasults that
, did not meet specifications, and the remaining test data packages to determine if similar errors had occurred.
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Revision: 1 y Page' 4 of 22-RESULTS REPORT ISAP III.a.5 ;
(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) '
4.1.1 1-CP-PT-02-02, "118 VAC RPS Inverters
[
The original test data package was reviewed to determine the reason (s) for approval of test results l that did not meet the stated acceptance criteria.
4.1.2 Preoperational Test Data Packages Test data from the preoperational test data packages !
were exa,sined to determine if there were any other instances where test data did not meet the stated acceptance criteria via a random sampling program as discussed in Section 4.4. ,
6 4.2 Participants Roles and Responsibilities The CPRT Testing Program Review Team Leader, Mr. J. E.
4 Rushwick, was responsible for the review and evaluation described in Sections 4.1.1 and 4.1.2. The Startup Special
- Projects Supervisor, Mr. G. M. McGrath, provided assistance l by documenting the population of acceptance criteria (reviewed j by the RTL for completeness) and by providing technical l information as requested.
l 4.3 Qualifications of Personnel The CPRT Testing Programs Review Team Leader met the
). qualifications as described by the CPRT Program Plan. The Review Team Leader (RTL) was responsible for ensuring that l other personnel providing assistance in the conduct of the Action Plan were appropriately qualified.
- 4.4 Sampling Program
- i The RTL elected to evaluate conformance to acceptance criteria i
in the preoperational test data packages approved by the JTG by means of a random sampling program conducted in accordance I
with Appendix D. "CPRT Sampling Policy, Applications and Guidelines," to the Program Plan. The purpose of the random 1 sampling program was to determine if there was a programmatic i
problem associated with the process of review and approval of l preoperational test data packages.
!O
Revision: 1 Page 5 of 22
T (J t RESULTS REPORT ISAP III.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The JTG had approved 206 preoperational test data packages.
Subsequent to the identification of problems with the original 1CP-PT-02-02, unrelated to this issue, the JTG voided the test data package and removed it from the archive records center.
The total population of acceptance criteria associated with the 205 remaining preoperational test data packages was 3,391.
Recognizing that one example of approved test data exceeding the acceptance criteria had already been identified, the minimum sample size necessary to test for programmatic implications was ninety-five items per Appendix D to the Program Plan.
4.5 Acceptance Criteria For each randomly selected acceptance criteria, the results of testing or retesting meet the stated acceptance criteria and have been approved by the JTG, or if the criteria had not been met, the JTG had approved the required retest on a Test
[J) Deficiency Report.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The following presents the results of the RTL's review conducted in order to addrera the concerns of the ASLB as expressed in Section 2.0.
5.1 Requirements of Startup Administrative Procedures The requirements with respect to acceptance criteria are specified in Startup Administrative Procedures (SAP), which are, in some cases, augumented by additional guidance
- presented in Startup Interoffice Memoranda (SIM).
CP-SAP-2, "Startup Program Organization and Responsibilities," delegates responsibility for preparation of test procedures to the assigned STE.
The STE assigned to perform the test, who may be someone other than the procedure preparer, also prepares the test data package. The test data package contains the test procedure with the recorded data and any related information identified during the conduct of the test. These activities are to be performed according to the SAPS. The JTG is assigned final
\s review and approval responsibility for test procedures and test data packages.
Revision: 1 3
Pags 6 of 22
/"'N RESULTS REPORT n,
I ISAP III.a.5 (Cont'd) 6 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
CP-SAP-7, " Format and Content of Test Instructions / Procedures," requires the STE' preparing a
- test procedure to state acceptance criteria "against which the success or failure of the test results may be judged," and establishes the minimum level of detail at which acceptance criteria must be stated. Examples of j
i the latter are provided in SIM-82106 (
Subject:
Acceptance Criteria Clarifications, dated 11/19/82).
CP-SAP-11. " Review, Approval and Retention of Test Results," specifically requires that during the review of test results, the STE shall verify tLat the stated acceptance criteria have been met. SIM-63019 (
Subject:
Preoperational/ Acceptance Test Data Package Checklist, dated 2/14/83) suggested the details of a review to be performed by an STE prior to submitting a test dati package to the JTG.
i The responsibility for preparing a test procedure and its test data package for subsequent JTG review rests with an.STE.
, This responsibility specifically includes ensuring accurate statement of the acceptance criteria during procedure 4
preparation and verifying that the results of the test meet the stated acceptance criteria prior to submitting the test i data package for JTG review and approval. The JTG's responsibilities specifically include confirming the STE's 4 .
evaluation and providing final approval of the test data 1 package.
i The RTL concluded that the instructions provided in the SAPS and SIMs are sufficiently clear with regard to the responsibilities of the individuals or groups involved in preparing, reviewing, and approving test procedures and test i data packages. Supplementary guidance on methods of implementation of these responsibilities (SIMs above) was l provided after the 1CP-PT-02-02 test was performed. This type l of evolution in test program direction is normal in the
( initial stages of such programs.
i 5.2 Approval of ICP-PT-02-02 The RTL reviewed the circumstances surrounding approval of preoperational test data package 1CP-PT-02-02. This test procedure was authored by one individual, performed by another j
\
Revision: 1 Paga 7 of 22 RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) individual, and the recorded data and calculations were reviewed by a third individual. The RTL specifically examined the following:
the style in which test procedures were written by each of the individuals involved; the manner in which they performed tests; their work load; and the JTG's activities during this period.
5.2.1 Author of ICP-PT-02-02
. Test Procedure 1CP-PT-02-02
(')
( ,j The acceptance criteria were stated in Section 2.0 of the test procedure as required by CP-SAP-7. Acceptance criteria were stated for measureable parameters and equipment functionality and were applicable to the four inverters tested by this procedure.
Excerpts from pertinent sections of the test procedure and a replica of a data sheet are provided herewith as Attachment 2. The information enclosed in brackets is explanatory information added by the RTL. The handwritten entries represent actual data recorded from the test.
The acceptance criteria were stated as shown on Attachment 2. The numbers enclosed in parentheses after each acceptance criterion are the procedure step numbers where conformance with the acceptance criteria would be expected to be observed. This practice is performed in most test procedures as suggested by i
The acceptance criterion that was exceeded was the nominal value of output voltage of 118 VAC ! 4 percent,
' that is, acceptance criterion 2.3 on Attachment 2. All four inverters tested in the preoperational test exceeded this output voltage specification. One N
inverter exceeded the nominal output voltage of 118 VAC by 6.44 percent, two by 5.34 percent, and one by 4.15 percent.
l l
l
Revision: 1 Paga 8 of 22 RESULTS REPORT (JD .
ISAP Ill.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The instructions in the test procedure are clear. The data sheet is not, however, because of the ambiguous voltage regulation statement marked (A]. It is not readily apparent what information was intended to be recorded at this location. As stated in the acceptance criteria, each of the first four (7.1.7, 7.1.11, 7.1.17, and 7.1.32) output voltages should be within
!4% of 118. If the author intended that the percentage deviation from 118 volts be recorded, he should have provided space for four entries.
Similarly, with respect to the data developed from an analysis of the recordings, the voltage regulation entry (marked (B]) also appears to be ambiguous. The recordings are very high speed recordings of alternating current and voltage waveforms and are used [
to verify that inverter output is uninterrupted when
/N the input source is changed.
> b Other Test Procedure Writing Work The author of ICP-PT-02-02 wrote two other test procedures. One test procedure was an acceptance test that involved functional verification of non-safety-related 480 volt switchgear and motor control centers (MCC). This test procedure was clearly written and the acceptance criteria were met.
The second test procedure was a preoperational test of two inverters performing the same uninterruptable power i
supply function for the balance of plant (BOP) i instrumentation. The acceptance criteria were written i
in a similar manner as follows:
I Steady State Voltage regulation of each inverter shall be within 2.% of nominal 118VAC over the load range 0% to 100% (85 amps) and over the range of possible battery input voltages of 105 VDC to 140 VDC.
(7.1.2.2, 7.1.2.17, 7.2.6, 7.2.10, 7.2.14, 7.2.19, 7.2.22, 7.2.25, 7.2.28)
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Revision: 1 Page 9 of 22 l
) RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The output frequency of each inverter shall not exceed 1 0.5 Hz of nominal frequency (60 Hz) over the load range of 0% to 100%.
(7.2.5, 7.2.11, 7.2.13, 7.2.18, 7.2.21, 7.2.24, 7.2.27)
The data sheets for this test were structured differently than for ICP-PT-02-02. In this case, the author chose to have output voltages for the various loads recorded on one data sheet, output frequency recorded and verified within the body of the procedure, and waveform analysis verified on another separate data sheet. The final instructions in the procedure were:
a) Analyze analog recordings 02-01-01 through 02-01-06 and record data as shown on Data Sh~eet 3.
Data Sheet 3 indicated that the waveforms were to be continuous or interrupted for less than 1/4 cycle.
b) Verify 1 2% voltage regulation of IVIEC1 by analyzing Data Sheet 7.
Data Sheet 7 contained only output voltages recorded during various load combinations and numbered to correspond to the acceptance criteria statements.
Each of the acceptance criteria in this procedure was met.
System Testing Work The author of ICP-PT-02-02 was not responsible for the performance of any tests as System Test Engineer.
RTL Evaluation i
The test procedure for the BOP inverters was the first of this author's test procedures submitted for JTG review. Approximately one month later, the acceptance test procedure for the MCCs was submitted. And finally, two months after the submittal of the first
(\-#) test procedure, the test procedure for ICP-PT-02-02 was submitted for JTG review. The first test procedure l
Ravision: 1 Page 10 of 22 (G) 'RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
'(BOP inverters) was written in a style that minimized the likelihood of making errors in data entry or interpretation of results. When ICP-PT-02-02 was submitted two months later, the author exhibited a general change in his overall organization of a test procedure.
The RTL reviewed the comments prepared by the JTG during its review of the subject test procedure. There were no comments by the JTG reviewers related to what information was actually sought on the data sheet for the voltage regulation entry.
The RTL concluded that the test procedure for ICP-PT-02-02 was misleading as written, and that the JTG review of the test procedure was initially flawed in that it did not identify the procedure as being
(N misleading, and require that it be changed.
\s-5.2.2 System Test Engineer for 1CP-PT-02-02 Performance of ICP-PT-02-02 The STE perfo- 2d the test in an orderly manner in two days.
The data recorded are shown on Attachment 2 for one of the four inverters tested in ICP-PT-02-02. Acceptable output voltages recorded in 7.1.7, 7.1.11, 7.1.17, and 7.1.32 would be between 122.7 and 113.3 volts.
l The basis of the numbers recorded in the spaces for voltage regulation is not be readily apparent. It appears that the STE performed a graphical determination of the ratio of output voltages to arrive at the numbers recorded.
Two of the numbers recorded at the location marked B on 1
the data sheet may be duplicated by calculating voltage regulation as the difference in output voltage at each load divided by full load output voltage, multiplied by 100. However, on the remaining three data sheets, no voltage regulation entries could be duplicated in this manner.
Ravision: 1 Pega 11 of 22
() RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
When the nominal value of operating voltage is l
specified, in this case 118 VAC, the output voltages must be within 4% of 118 VAC. The nominal value of operating voltage for these inverters is specified in the purchase specifications, the specification section of the vendor's operating manual, and in the title of the test procedure.
Test Procedure Writing Work The STE wrote six test procedures. Four tests were of inverter equipment similar to that tested in ICP-PT-02-02, and two were battery load tests. Voltage regulation was a pertinent parameter in each of these tests. One of the tests authored by this individual was of the same type of equipment tested in ICP-PT-02-02 used in a non-safety-related application
(T s_ ,/
as an uninterruptable power supply for a plant computer. This acceptance test had acceptance criteria written in the same manner as follows:
The steady state voltage regulation shall be
! 5% from 2/3 load (41 amps) to full load (63 amps). (7.56)
The STE wrote his test procedures in a style that was different from ICP-PT-02-02 in that no data sheets were used. Steps in the body of the procedure required recording test data in spaces provided at that specific step location. The acceptable range of the parameters being measured was also placed at the specific step.
For example, step 7.56 for the test mentioned above stated:
Verify output voltage recorded in Steps 7.6, 7.15, 7.32, and 7.37 to be within 118 VAC 2 5 percent (112.1 to 123.9).
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Revision: 1 Page 12 of 22
{ RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Each of this STE's test procedures was written in this style; that is, the voltage :egulation statements were l either the same or very similar to that described above.
Other System Testing Work The STE performed two of the inverter procedures that he authored. There were no problems identified with these test data packages. He also performed 1CP-PT-02-12. " Bus Voltage and Load Survey." f0his STE observed that acceptance criteria were not met by the data obtained during testing. A Test Deficiency Report was processed by this STE in accordance with the SAPS.
The NRC-TRT identified a concern with this test regarding inadequate specification of retests by the JTG. The NRC-TRT concern is the subject of ISAP O' III.a.1, " Hot Functional Testing (HFT)," and is addressed in that Results Report.
RTL Evaluation Two weeks prior to this STE's performance of ICP-PT-02-02, he submitted the two battery tests and one of the inverter test procedures for JTG review.
Within two weeks after performing ICP-PT-02-02, he submitted two more inverter test procedures for JTG review. The final inverter test procedure was submitted five months later. Review of the JTG comments indicated that these test procedures were not substantially changed as a result of the JTG review, and that the procedures, as drafted and implemented, were basically as described above.
The RTL concluded that there is no acceptable explanation for not recognizing that the acceptance criteria of ICP-PT-02-02 were not met. The STE who ,
performed the test had written six test procedures in which voltage regulation was a parameter of interest.
O U
d
Revision: 1 Page 13'of 22
( RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Four of the tests were for inverters of the same or similar design. These tests were written in a format that minimized the likelihood of recording or approving unacceptable test data. He had also performed the bus voltage and load survey test, and had observed that the acceptance criteria were not met. He had processed the proper documentation to document this deficiency. Yet, in the ICP-PT-02-02 procedure, the output voltage data recorded do not meet the acceptance criteria, and voltage regulation entries appear to have been either graphically determined from the recordings or miscalculated.
5.2.3 Data Reviewer for ICP-PT-02-02 1CP-PT-02-02 Review O The data sheets for each of the four inverters were signed by the data reviewer, indicating the recorded results were satisfactory, when, in fact, they were not.
Test Procedure Writing Work This STE authored two acceptance tests and one preoperational test. The two acceptance tests were: a) 138KV Startup Transformer XSTI Protective Relaying Performance; and b) Unit Auxiliary Transformer & 6.9KV Common & Normal Switchgear. The preoperational test was the Power Transformer Load Test.
System Testing Work This STE performed the Power Transformer Load test and the Unit Auxiliary Transformer & 6.9KV Common & Normal Switchgear test, each of which he had authored. He also performed the preoperational test and retest for the 345KV Startup Transformer and 6.9KV Class IE Switchgear.
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()
/"'N RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The acceptance criteria in these procedures were all met.
RTL Evaluation This STE authored and directed most of the safety and non-safety-related high voltage, high capacity electrical equipment tests performed on site. He was likely to have been mislead by the test procedure as described above, perhaps because he lacked familiarity with the low voltage, low capacity equipment tested in ICP-PT-02-02.
5.2.4 STE Work Load The author of ICP-PT-02-02 wrote three test procedures and did not perform any tests. The STE who performed O ICP-PT-02-02, wrote six test procedures, four on very similar equipment, and two battery load tests. He also performed four tests. The STE who evaluated the ICP-PT-02-02 data wrote three test procedures and performed five tests. The calendar time for these activities was approximately from September 1982 through the completion of hot functional testing in June 1983. The RTL does not consider these efforts an undue burden.
5.2.5 JTG Activities Original Review and Approval Activities The JTG began holding routine meetings to approve test procedures in April 1982. The meetings were conducted approximately weekly and test procedure approval continued through 1984. Test data packages were first j introduced as an agenda item in January 1983.
' ICP-PT-02-02 was one of the first test data packages reviewed an'd approved by the JTG. The JTG had ICP-PT-02-02 in its possession for forty-five days.
The average time for JTG review and approval of acceptance and preoperational test data packages was approximately twenty-two days. The average for test l O, procedure review and approval was approximately 72 days. Test data package approval continued through March 1985.
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-[d RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
RTL Evaluation The JTG was performing the test procedure and test data package review and approval process in an orderly manner, allowing sufficient time for a review.
The RTL reviewed the Test Deficiency Reports (TDR) issued to document the results of the JTG reevaluation effort described in the background section of this report. The RTL concurred with the JTG's disposition of each TDR. The number of acceptance criteria contained in the above population that had been reverified as being met is approximately 580.
5.2.6 Identification of Unacceptable Test Results The STE assigned to reperform the ICP-PT-02-02 test F} procedure on the inverters subsequent to the
(_/ installation of the repaired transformers identified the unacceptable output voltage data. This was done during his review of the original test data package in preparation for the retest. He issued a Test Deficiency Report in accordance with the SAPS.
This STE had performed one inverter test approximately 12 months prior to the retest, and was familiar with the equipment.
RTL Evaluation Detection of the error in this subsequent review demonstrates that the problem was detectable even though the style in which the procedure was written tended to obscure it.
5.2.7 RTL Evaluation of Root Cause As discussed in Section 5.3 below, the untimely detection of test data failing to meet stated acceptance criteria was, in this instance, of minor significance from a safety point-of-view. Nonetheless, since attainment of the fundamental objective of a l
g-'g preoperational test program, which is to provide
( ) assurance that a facility can be operated in a manner that will not endanger the health and safety of L.
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}
ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the public, is so closely tied to the level of scrutiny test data receive in terms of acceptability, it is important to determine the root cause of the subject-incident'. It is clear that the JTG's performance was less-than-adequate in exercising its responsibility to assure that acceptance criteria were satisfied. It is also clear that the STEs charged with the 4
responsibility of reviewing test data prior co submittal of same to the JTG acted with less-than-4 adequate diligence. The RTL's review of the level of performance of STEs and the JTG over a broad range of additional acceptance criteria as discussed below indicates, however, that a similar failure to provide adequate test data scrutiny is unlikely to have occurred elsewhere and that the subject case is not typical of the performance of the JTG and STEs on the CPSES Test Program.
x
' A review of all the preoperational testing work of the STEs involved indicates that it was performed in a satisfactory manner. The results of the random sampling program described below indicate that there is !
no programmatic weakness in the JTG revie" and approval process. A review of the administrative procedures and supplementary instructions indicates that they provide adequate guidance to the personnel involved.
The root cause of the failure to identify unacceptable test data was that the process, as implemented, permitted the acceptance criterion and implementing instructions to be stated in the procedure in a sufficiently ambiguous manner that reviewers did not anticipate the misinterpretation adopted by the
{
performer and that recorded data outside the limits of acceptability were not readily apparent. That is, had the ICP-PT-02-02 test procedure been written in a format similar to the majority of procedures developed at CPSES, with the range of acceptable inverter output voltage specified, the process, as implemented, would have insured detection and resolution of the unacceptable test data.
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[~'T RESULTS REPORT
\s l' {
ISAP III.a.5 {
1 (Cont'd) '
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3 Engineering Evaluation of the Test Data At the request of the Startup organization, TU Engineering performed an evaluation of the inverter output voltage data.
TU Engineering found that the inverter's performance was acceptable based on the original test, and would not have posed any significant safety concern for the equipment powered by the inverters even if the failure to meet the stated acceptance criteria had not been detected.
5.4 Results of the Acceptance Criteria Sampling Program A sample of ninety-five acceptance criteria randomly selected from the preoperational test data packages approved by the JTG was evaluated. The evaluation showed that each of these items met the following criterion:
The results of testing or retesting meet the stated
.( acceptance criteria and have been approved by the JTG, or if not, the JTG had approved the required retest on a Test Deficiency Report.
i The results of the sampling program indicate that similar errors, if any, would be random in occurrence.
6.0 CONCLUSION
S The RTL concluded that there is reasonable assurance that the acceptance criteria in the preoperational test data packages have, i
in fact, been reviewed and approved according to the Startup Administrative Procedures, that the requirements in the Startup Administrative Procedure are adequate to accomplish the review and approval process, and that the acceptance criteria in the Unit 1 preoperational test data packages have been met.
This conclusion is based upon a review of the Startup Administrative Procedures, events surrounding the review and approval of ICP-PT-02-02, RTL concurrence with the JTG reevaluation
' effort, and the demonstration through the random sampling program that there was no programmatic problem associated with the process of review and approval of test results.
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RESULTS REPORT
.)
ISAP III.a.5 (Cont'd) ,
7.0 ONGOING ACTIVITIES There are no ongoing activities related to this issue.
8.0 ACTION TO PRECLUDE OCCURRENCE'IN THE FUTURE The JTG recognized the need to bolster the review process of test data packages. Two new groups were formulated in February 1983.
The first group was internal to the Startup organization and it provided an independent review of test data packages prior to submittal to the JTG. In addition, the JT" formed a dedicated working group to assist it in the performance of its review responsibilities and to provide approval recommendations to the JTG. Subsequently, these groups were additionally chartered to review test procedures prior to implementation.
The RTL believes that suf ficient measures have been established to preclude occurrence in the future.
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[U RESULTS REPORT ISAP III.a.5 (Cont'd)
Attachment 1 Chronology of Events Related to ICP-PT-02-02 April 1982 -
The JTG convenes and begins formal approval of test procedures.
September 1982 -
The test procedure for ICP-PT-02-02 is submitted to the JTG for review and comment.
October 1982 -
JTG approves the ICP-PT-02-02 test procedure.
November 1982 -
The test for ICP-PT-02-02 is conducted.
The test data package for ICP-PT-02-02 is prepared and sent to the JTG for review and approval.
January 1983 -
The JTG approves the test data package for ICP-PT-02-02.
June 1984 -
The STE assigned to perform the 1CP-PT-02-02 retest identifies the unacceptable test data and files a Test Deficiency Report.
August 1984 -
The test data package for the reperformance of ICP-PT-02-02 is submitted to the JTG for review and was approved.
September 1984 -
The original ICP-PT-02-02 is presented as evidence to the ASLB.
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\,,) RESULTS REPORT ISAP III.a.5 (Cont'd)
Attachment 2 Excerpts From ICP-PT-02-02*
1.0 TEST OBJECTIVE The objective of this test is to verify the ability of the 118 VAC uninterruptible A-C power system to provide a continuous source of power to the Reactor Protection System.
2.0 ACCEPTANCE CRITERIA 2.1 The inverter shall transfer to the DC Input Source upon loss of the normal AC input voltage without interruption. (7.1.16) 2.2 The steady state running frequency shall be 60 Hz 2 0.5 Hz from 2/3 load (41 lamps) to full load (63 amps). (7.1.7, 7.1.11, 7.1.17, 7.1.32) 2.3 The steady state voltage regulation shall be t 4% from 2/3 load (41 amps) to full load (63 amps). (7.1.7, 7.1.11, O 7.1.17, and 7.1.32) 7.0 PROCEDURE 7.1.7 Record output voltage and frequency on Data Sheet 1. [ Interchange steps Name/Date loaded inverter to 2/3]
7.1.11 Record output voltage and frequency on Da.a Sheet 1. [ Interchange steps Name/Date loaded inverter to full load]
7.1.14 Stop the recorder after allowing it to run for approximately 10 seconds. Name/Date Identify the recording as 02-02-2.
Note A copy of this recording 02-02-2 is to be attached to this test as base line data, Information in brackets "[ ]" added by RTL for clarity of (s} illustration.
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( RESULTS REPORT ISAP III.a.5 (Cont'd)
Attachment 2 (Cont'd) 7.0 PROCEDURE (Cont'd) 7.1.15 Observe loss of AC input alarm on I-ALB-10B, 1.16. Name/Date 7.1.16 Verify that inverter is now being being powered by the battery input Name/Date by observing the DC input current
, meter.
7.1.17 Record output voltage and frequency on Data Sheet 1. [ Previous steps Name/Date simulated a loss of AC input while a recording was made of the transfer from the AC source to the DC source]
7.1.31 Stop the recorder after allowing it Os to run for approximately 10 seconds. Name/Date Identify the recording as 02-02-3.
Note A copy of this recording 02-02-3 is to be attached to this test as base line data.
7.1.32 Record output voltage and frequency on Data Sheet 1 [ previous steps Name/Date i
simulate a loss of DC input while a recording is made of the transfer from the DC source to the AC source]
7.1.36 Analyze recordings 02-02-2 and 02-02-3 and fill in required data Name/Date on Data Sheet 1 O
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O RESULTS REPORT U
ISAP III.a.5 (Cont'd) .
Attachment 2 (Cont'd)
Data sheet 1 i
FARAGRAFE NAME/DATI 7.1.7 Output Voltage [2/3 Load] /)W.3VAC --
NAME/DATE 7.1.11 Output Voltage (Full Load] //J. 8 VAC +
NAME/DATE 7.1.17 Output Voltage (DC Source] /88.YYAC MAME/DATE 7.1.32 Output Voltage (AC Source) /2 YAC NAME/DATE 7.1.7 Output Frequency (60 t .5 CPS) (d.dJ 3 NAME/DATE 7.1.11 Output Frequency (60 t .5 CPS) f9. 93 Es NAME/DATE 7.1.17 Output Frequency (60 2 .5 CPS) (0 02 Es i
NAME/DATE 7.1.32 Output Frequency (60 2 .5 CPS) 6d.7 Es NAME/DATE Voltage Regulation (2 41) (A] O. 73 g &
t NAME/DATE Recording 02-02-2 7.1.36 Voltage Regulation (141) (B] O.Y g NAME/DATE 7.1.36 Vaveform is Continuous M NAME/DATE Recording 02-02-3 7.1.36 Voltage Regulation (243) (3} O. Y g M NAME/DATE 7.1.36 Vavefors is Continuous N NAME/DATE Remarks:
Recorded By: & Date Reviewed By: Dates
~ ^
O COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: VI.a
Title:
Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall REVISION 1 l
iO
' m 3l18 81 hsue Co rdinator Date i Rdvlew Team Leader 0 \ _s/nk7 Dath '
l g- 4) . / e L 3/zfl8 7 Johyd. Beck, Chat'cmanCPRT-SRT Date i
O 1
Pavicion: 1 Pega 1 of 52 RESULTS REPORT ISAP VI.a Gap Between Reactor Pressure Vessel Reflective ;
Insulation (RPVRI) and the Biological Shield Wall
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC Issue VI.a was identified in SSER 8 (Reference 9.1, page K-180) as follows:
"The TRT investigated an allegation that the Unit I reactor pressure vessel outer wall was touching the concrete biological shield wall. A TRT review of existing documentation and discussions with TUEC personnel indicated that this allegation was not factual. However, a significant ccustruction deficiency report, submitted pursuant to 10CFR50.55(e), on August 25, 1983, documented that enacceptable cooling occurred in the annulus between the RPVRI and the shield wall during hot functional testing, apparently because of the existence of an inadequately sized annulus gap and possibly hecause the presence of construction debris in the annulus. TUEC corrected the situation by modifications to allow increased air flow for proper heat dissipation and by removal of the construction debris. TUEC representatives indicated that testing to verify the adequacy of the cooling flow will take place when additional hot functional testing is conducted. Information gathered by the TRT during the investigation indicated that a design change in the RPVRI support ring (i.e., locating the ring outside rather than inside the insulation) resulted in a limited clearance between the RPVRI and the shield wall. The TRT review of the 50.55(e) report revealed that TUEC failed to: (1) address the fundamental issue of the design change impact on annulus cooling flow, and (2) determine whether Unit 2 was similarly affected."
2.0 ACTION IDENTIFIED BY NRC The actions to be taken regarding Issue VI.a were identified in SSER 8 (Reference 9.1, pages K-180 and K-181) as follows:
"Accordingly, TUEC shall:
(1) Review their procedures for approval of design changes to non-nuclear safety-related equipment, such as the RPVRI, and make revisions as necessary to assure that such design changes do not adversely affect safety-related systems.
Revision: 1 Pags 2 of 52 RESULTS REPORT ISAP.VI.a (Cont'd) 2.0 ACTION IDENTIFIED BY NRC (Cont'd)
, (2) Review procedures for reporting significant design and construction deficiencies, pursuant to 10CFR50.55(e),
e i
and make changes as necessary to assure that complete evaluations are conducted.
(3) Provide an analysis which verifies that the cooling
- flow in the annulus between the RPVRI and the shield wall of Unit 2 is adequate for the as-built condition.
(4) Finally, verify during future Unit I hot functional testing that completed mo,difications to the RPVRI support ring now allow adequate cooling air flow.
- The TRT noted that control of debris in critical spaces between components and/or structures was identified as an i
issue, both in the investigation of this allegation and the civil / structural area item II.c (Maintenance of Air Gap Between Concrete Structures), contained in Darrell G.
Eisenhut's September 18, 1984, letter to TUEC. Accordingly, O TUEC shall also:
(1) Identify areas in the plant having critical spacing
, between components and/or structures that are necessary i
for proper functioning of safety-related components,
' systems or structures in which unwanted debris may collect and be undetected or be difficult to remove; (2) Prior to fuel load, inspect the areas and spaces identified and remove debris; and, (3) Subsequent to fuel load, institute a program to minimize the collection of debris in critical spaces i
and periodically inspect these spaces and remove any debris which may be present."
3.0 BACKGROUND
During the hot functional testing of cooling flow in the annulus between the reactor pressure vessel reflective insulation and biological shield wall performed during early 1983 for Unit 1, an inability to meet the test procedure criteria was noted (i.e.,
measured temperatures were too high) and documented on test deficiency reports TDR-908 and 1221. A review of the test data led 1
i
Rsvision: 1 Pags 3 of 52 RESULTS REPORT ISAP VI.a !
(Cont'd)
3.0 BACKGROUND
(Cont'd) to a remote visual inspection of the area around the reactor vessel to determine the cause of the observed high temperatures and high heat load input to the neutron detector cooling system. The visual inspection revealed that the reactor pressure vessel reflective insulation support ring extended into the annulus area (air flow space) between the concrete biological shield wall and the reflective insulation. The flow path was further restricted by debris resting on the support ring and due to an apparent eccentricity between the support ring and biological shield wall, which resulted in an uneven space. The Unit 1 support ring was modified to increase air flow and to improve air flow distribution.
This was accomplished by providing holes in the support ring. All construction debris was also removed from the reactor cavity area.
In addition, the neutron detector cooling system was modified to compensate for the higher heat load.
A visual inspection of the Unit 2 annulus was performed during this time frame to determine if a similar condition existed. This inspection revealed a similar flow constraint; i.e., RPVRI support ring extended into the annulus with debris resting on top of this ring (the above-mentioned eccentricity between the support ring and shield wall did not exist for Unit 2). Therefore, the annulus was first cleared of dahris prior to testing and evaluation of the Unit 2 cooling system. The tests indicated that although additional heat removal capacity was required there was no need to modify the insulation support channel as had been done in Unit 1. As with Unit 1, this was accomplished by modifying the neutron detector cooling system.
Initial startup test procedure ISU-282A, " Containment and Feedwater Penetration Room Temperature Survey", was conducted during the late 1984, early 1985 Unit 1 plant heatup to satisfy certain deferred preoperational testing requirements. This included repetition of portions of the HFT related to the neutron detectors performed in 1983 which gave rise to the cooling adequacy question. Testing was performed to assess RCS pipe penetration concrete temperatures, containment average air temperature, steam generator and pressurizer compartment air temperatures, neutron detector well exhaust air temperatures, and reactor vessel support cooling air supply temperatures under hot standby conditions (nominal 557'F RCS temperature). The results of these tests were not available for the TRT at the time SSER #8 was released. These results are discussed in Section 5.0.
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RESULTS REPORT f\
\./ ISAP VI.a (Cont'd) 4.0 CPRT ACTION PLAN The objectives of this action plan were to:
Evaluate the adequacy of the testing and analyses performed to confirm that sufficient air flow is provided in the annulus between the RPVRI and the shield wall.
Provide additional assurance that design changes to non-nuclear safety (NNS) items have not adversely affected safety-related systems.
Identify areas in the plant that have critical spacing where debris could collect and be undetected or difficult to remove, confirm that these spaces are free of significant debris, and provide procedural controls to assure that they will remain-clear of debris.
These objectives were addressed through the four tasks described below. Two additional tasks related to these objectives, i.e.,
reviews of the process for reporting significant deficiencies
()s
( , pursuant to 10CFR Part 50.55(e) and of current and past housekeeping methods, are included in ISAPs VII.a.2, "Non-conformance and Corrective Action Systems", and VII.a.7,
" Housekeeping and System Cleanliness", respectively.
4.1 Scope and Methodology 4.1.1 Review of Annulus Cooling: At the time of the TRT investigation, the annulus between the reactor vessel insulation and the shield wall in both units had been cleaned, inspected and closed to prevent debris intrusion. In addition, the insulation support ring in Unit I had been modified to provide a more uniform air flow distribution and the cooling capacity of the Neutron Detector Cooling System for both units had been increased. The modified systems had been tested and the results were under evaluation by the Project.
These measures were all conducted as a direct result of the hot functional test program.
To confirm that adequate air cooling is provided in the reactor vessel to shield wall annulus following removal of debris and modifications, these tests and evaluations performed by the Project for both units were reviewed by the third-party.
Rsvision: 1 Page 5 of 52 RESULTS REPORT ISAP VI.a (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Evaluation of NNS Design Change Process: The purpose of this evaluation was to assess the adequacy of the process by which changes in the design of NNS items are reviewed to identify and resolve adverse interactions between the NNS items and safety-related items. This process consists of a combination of multi-discipline reviews of the NNS design changes, programs such as the Damage Study
- to address interactions that are not readily identified by review of the NNS design changes, and the use of criteria such as electrical separation that are included in the design of both the NNS and safety-related items to preclude adverse interactions.
Since portions of this process were being reviewed in other elements of the CPRT Program (i.e., ISAPs I.c,
" Electrical Conduit Supports" II.d " Seismic Design of Control Room Ceiling Elements", and the Design Adequacy Program) the evaluation performed under thi's action plan focused on the adequacy of the overall scope of
-g the NNS design change process and review of those areas g j not being addressed in other parts of the CPRT Program.
4.1.3 Review of Selected NNS Design Changes: Implementation of the NNS design change process was evaluated by reviewing design changes involving NNS items. Criteria for selecting the items to be reviewed were established based on a review of the history of the design change process, the applicable procedures and the scope of other CPRT activities which address portions of the NNS design change process.
4.1.4 Review, Inspection and Maintenance of Critical Spaces:
The concern for critical spaces where debris could collect, be undetected or difficult to remove, and affect the proper functioning of safety-related equipment was addressed through the identification and inspection of critical spaces under this action plan and a review of housekeeping methods (see ISAP VII.a.7,
" Housekeeping and System Cleanliness"). The results of the critical spaces review and reinspection were utilized to establish an ongoing Operations QC inspection program to assure that the identified critical spaces remain free of debris prior to and after fuel load.
The Damage Study Program was renamed Systems Interaction Program during the course of this Action Plan.
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Rsv,ision: ' d I Pags ,6 of 52 '..- ,
1 RESULTS REPORT
(N !
k-s ISAP VI.a '
(Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd)
ISAP VII.a.2, "Non-conformance and Corrective Action Systems", '
will evaluate the procedures for reporting significant design and construction deficiencies pursuant to 10CFR Part 50.155(e).
1 TheactionplancontainedprovisionsfortheevaluationInd/or modification of procedures o; equipment found to be defici'e nt in accordance with the requibements of Appendices E and H of the CPRT Program Plan. The extent to which it was necessary to implement these provisions is discussed in Section 5.0 of this Results Report.
4.2 Participants Roles and Pesponsibilities i
The organizations and persor.nal that participated in this effort are listed below with their respective scopes of work.
4.2.1 TUGC0 Nuclear Engineering (TNE) 4.2.1.1 Scope .
\ I, i Confirmed history of design change 's process ,
+ , '
Selected NNS design change package sample and~ conducted change package review i
Identified potential critical clearances Developed inspection plan for
- critical clearances 1 ,
4.2.1.2 Personnel Mr. C. Moehlman Mechanical Engineer (TUGC0 Issue Coordinator) 4.2.2 TUGC0 Operations 4.2.2.1 Scope Developed operations program for maintaining critical spaces D
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Page 7 of 52
! t j3, f RESULTS REPORT
,,i t
\ ' t ISAP VI.a I
(Cont'd) i-4.0 CPRT ACTION PLAN (Cont'd)
, 4.2.2.2 Personnel
! . ,' 1 n
Mr. R. A. Jones Manager Plant Operations
[,
4.f2.3 TUCCO Quality Assurance
. ') ' v.
'/
, 4.2.3.1 Scope Developed critical spaces inspection
<, i procedure l -
Inspected critical clearances t ,
4.2.3.2 Personnel
,(
, Mr. P. Halstead Quality Control c
' ), , < 4.2.4 Gibbs & Hill i i T, '
4.2.4.1 Scope
- y. b f, '
Analyzed Unit 2 cooling system i , performance
, 4
, ' '4.2.4.2 Personnel i Mr. E. Nicolaysen Mechanical Engineer j , 4.2.5 Third-Party Activities y ts . y , 4.2.5.1 Scope i
Reviewed cooling system calculations r ,
and test data Reviewed design change process Reviewed NNS design change package sample selection process 4
Reviewed Proj ect's re-review of selected NNS design change packages Reviewed developw nt of critical spaces list
Revision: 1 y #f Pago 8 of 52 ;
'3G l
RESULTS REPORT ,
- I s
f, ISAP FI.a
. N (Conu'd) l
.s t, 4.0 CPRT ACTION PLAN (Cont'd)
- Reviewed i:Irit ria and plan tot j
,j-critiedi spales,tinspection
- n }
3 -s Overviewed' critic'lspaces a i g
s c.tspection <
'! 3. f Reviewed 0;;erdtion#L prog'rsa for <
maintenance of critical spaces
.- i Revica?d modifications to procedures Reviewed design calculations (no new calculatf ore w '
" ere generated'in this 4 ISAP) I
>,+
, \
Prepared Results Report t
'" , t (
4.2.4.2 Pecsonnel j
) , Mr. H. A. Levin T'45tA Corporation - CPRT Kechanical Review Team Leader Dr. J. R. Honekainp TERA Corporation - TRT ,
, Technical Manager ?
' .! t .i
, s Mr. J. C. Miller TERA Corpetstion - TRT
', Issues M,anegte, t -
?:
Mr. P. L. Turi TERA Coperation - Issue
~
g ,~Coordiktato'r #
) ,.\
4.3 Perscanel Qualification Requirementf",
- (
7 +3 1hird-party participants in the inple.nentation of this Action Plan met the personnel qualificatic,r! and objectivity requirements of the CPRT Program Plan and its implementing procedures.
hnspectionsperformedaspartofthecriticalspaiesprogram were cbnducted by TUGC0 QC, with Sbiithwest Research Institute (SwRI) performing a third-party ovarview. TUGC0 QC personnel meeting. the appropriate requirement's.,of AEQ N45.2.6,
'" Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants", were trained to TUGC0
( . p r
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Rcvision: 1 Pags 9 of 52 RESULTS REPORT ISAP VI.a (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) procedure CP-QP-11.24 " Cleanliness of Critical Spaces". The SwRI third-party inspector was certified to the SwRI Quality Assurance Program. The SwRI inspector was also indoctrinated to TUGC0 procedure CP-QP-11.24 and the "SwRI Surveillance Plan for Verification of the Implementation of Inspection Procedure CP-QP-11.24 Cleanliness of Critical Spaces".
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 Construction QC conducted critical space inspections using TUGC0 procedure CP-QP-11.24, " Cleanliness of Critical Spaces",
which was developed as part of this Acticn Plan. A third-party overview of the critical space inspections was done by Southwest Research Institute. This overview was conducted using the SwRI surveillance procedure developed for this task (Reference 9.2).
4.5 Standards / Acceptance Criteria The acceptance criterion for the review of annulus cooling flow was the CPSES Technical Specification limit for exit air temperature. A revision to this temperature limit has been proposed in a change request submitcod to the NRC for their review (TUGC0 letter TXX-4418, April 30, 1985). The modified temperature limit for the reactor cavity is 150*F (Technical Specification Table 3.7-6) .
l The acceptance criterion for the critical spaces undergoing inspection required the space to be free of debris or obstructions that would have an impact on the functionality of the associated safety-related item.
The acceptance criteria for the safety-related/NNS interface l evaluations were determined by the specific safety-related/NNS In general, acceptance required i
interface being evaluated.
i that the NNS entity not adversely affect the ability of the safety-related entity to perform its function.
I l
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R; vision: 1 Paga 10 of 52 RESULTS REPORT ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS This section discusses the implementation of the tasks defined in Section 4.0 (related sections shown in parenthesis) and the associated results. The review of the reactor cavity annulus cooling flow (Section 4.1.1) is addressed in Section 5.1. A discussion is presented in Section 5.2 detailing the cooling problem identified by the Project during hot functional testing. Section 5.3 contains an evaluation of the CPSES non-nuclear safety design change process (Section 4.1.2). The review of selected h3S design changes (Section 4.1.3) is addressed in Section 5.4. Section 5.5 describes the Critical
. Spaces Program (Section 4.1.4). In addition to discussion of the completion of the tasks listed in Section 4.1, this section also includes a summary of Discrepancy / Issue -
Resolution Reports * (DIRs) (Section 5.6), an assessment of ~
safety significance (Section 5.7), ard an evaluation of root cause and generic implications in accordance with the requirements of the Program Plan (Section 5.8). A summary of the acronyms used in this section is presented in Table 1.
5.1 Adequacy of Cooling Flow in Reactor Cavity 5.1.1 Statement of Problem The HVAC system providing cooling to the reactor cavity was originally designed for a heat load capacity of nearly 300,000 BTU /hr (Reference 9.3). The cooling capacity provided prevents the occurrence of high temperatures in the cavity which could have a detrimental ef fect on both neutron detector equipment and shield wall / vessel support concrete. The maximum temperature for normal operations for the detectors is 135'F. However, equipment qualification testing has established that the detectors can withstand exposure to 200*F for five years (Reference 9.4).
During hot functional testing (HFT) performed in early 1983, temperatures higher than that allowed by Technical Specification limits were identified and recorded (as high as 314*F in the reactor vessel The Discrepancy / Issue Resolution Report (DIR) is a form used to track the status, classification and resolution of all open issues and of all discrepancies identified during the implementation of this Action Plan as well as the Design Adequacy Program (DAP).
I
Rsvision: 1 Paga 11 of 52 RESULTS REPORT t' ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS support and neutron detector well area - Reference 9.5). In investigating the deficiency, the Project determined that the cause involved two factors:
(1) HFT data showed that the heat load in the reactor cavity was approximately 600,000 BTU /hr (instead of the 300,000 BTU /hr design i
value).
(2) The RPVRI insulation support ring channel was found to intrude into the annular air space, which created a substantial flow restriction that was further compounded by the accumulation of construction debris on top of the channel.
It is believed that the second factor gave rise to the former in that cooling air was forced through seams at the base of the RPVRI because of the flow restriction (i.e., support ring and debris) (see Figures 1 and 2).
The air Troceeded up the space between the reactor vessel outer wall and RPVRI (not intended to be a flow path), acquiring a significant quantity of heat energy.
The combination of the flow of air up the vessel wall 4
(exhausting at the top of the cavity) and the reduced air flow in the intended flow path caused temperatures i
in excess of the Technical Specification limits. These high temperaturer also exceed the temperature above which deterioration of concrete could occur (150*F, Reference 9.6) and, if left uncorrected for a long period of time, could have led to degradation of concrete under the reactor vessel supports. The concrete reactor vessel supports are on the " List of l Quality Assured Items" (Table 17A-1 in FSAR Section i
17A). Because the supports perform a safety-related function, the potential deterioration of the underlying concrete has safety significance.
The Project corrected the Unit I situation by first removing the debris from the top of the support ring channel and then cutting holes in the support ring in order to increase air flow rates (see Section 5.2 for
- discussion of support ring). Modifications were made
' to the Neutron Detector Cooling System to accommodate a conservative heat load of 600,000 BTU /hr. In l addition, Westinghouse made modifications near the i reactor vessel flanges to reduce the air flow between I
y___ _ ,,, _._.. ._.,._.-____-...-,,,m _, -_ . _ _ . . . _ _ . . . , , , ~ . , _ . ,,._... .. _ , _ . - . . . . , - - , _ - .
'Rsvision: 1 Pegs 12 of 52 RESULTS REPORT ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the vessel and RPVRI (Reference 9.7). Westinghouse also undertook an effort to remove all debris from inside the cavity region (Reference 9.8).
The Project also examined Unit 2 to determine whether a similar problem could occur. Debris was detected and removed from the Unit 2 reactor cavity (Reference 9.9) and the same cooling system modifications were made.
Air flow tests performed after the modifications on Unit 2 demonstrated that adequate flow distribution exists around the circumference of the cavity, making modifications to the support ring unnecessary.
After all modifications were completed, the HFT was reperformed for Unit i under initial Startup test procedure ISU-282A, " Containment and Feedwater Penetration Room Temperature Survey". The results of the testing demonstrated that the as-built condition is g adequate. Calculations were developed for Unit 2 HFT conditions that demonstrated the adequacy of the cooling system for that unit. The third-party review of these tests and calculations are described in the following section. (It should be pointed out that, in addition to these calculations, the Unit 2 HFT will serve as a proof-test for Unit 2 cooling adequacy. The Unit 2 HFT will be conducted as part of the Unit 2 Startup Program.)
5.1.2 Third-Party Review The third-party review was conducted in two parts since cooling adequacy was demonstrated differently for each of the two units. The first part involved a review of the Unit i HFT data collected following modifications
( made to both the Neutron Detector Cooling System (increased capacity by adding another cooling coil) and the RPVRI support ring (removed debris and cut air flow holes in the channel). The second part involved both a review of Gibbs & Hill calculations that predict temperature behavior in the Unit 2 reactor cavity and a review of the results of air flow tests conducted after debris had been removed from the cavity annulus area.
The Unit 1 post-modification HFT results indicated that O
\s_/
one of the eight exhaust temperatures monitored (exhaust from the reactor cavity - see Figure 2)
R2 vision: 1 Ptge 13 of 52 i
RESULTS REPORT O)
\s- ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) exceeded the allowable value (Reference 9.10). The Technical Specifications indicate a temperature limit of 135'F for the detector wells (see Technical Specification Table 3.7-6) but the test results indicated a temperature in excess of 140'F (recorded at the exhaust line temperature element located outside the biological shield wall). TUGC0 memo TCF-85103 (Reference 9.11) requested Engineering to evaluate the problem, while pointing out that temperature measurements (recorded in ISU-282A) using temporary instruments located in the neutron detector wells established that the temperatures at the neutron detectors were in the 80 to 88'F range (well below the 135'F Technical Specification limit for the neutron detectors) (see Figure 1). Engineering replied in TUGC0 memo TSG-7786 (Reference 9.12) that the temperatures recorded were acceptable and that the Technical Specification limit should be raised to 150*F
[A Technical Specification Change Request was attached
( to this memo and this request has been submitted to the NRC for their review in TUGC0 letter TXX-4418, April 30,1985 (Reference 9.13)] . It is noted that the increased temperature limit (150*F) is based on preventing concrete deterioration in the upper portion of the reactor cavity where the vessel supports are located. (As depicted in Figure 1, the neutron detector walls are well below the vessel support region.) It should further be noted that ACI allows local concrete areas to have increased temperatures, not to exceed 200'F.
The explanation as to the cause of the single " hot .
spot" identified in the HFT is derived from two !
physical conditions unique to the Unit I reactor cavity: 1) an apparent eccentricity between the support ring and inner surface of the shield wall, and 2) obstructions that prevented hole cutting at certain locations on the support ring. The non-uniform gap between the support ring and inner surf ace of the shield wall was observed by the Project using fiberoptic inspection techniques. This finding was
)
' reported in TUGC0 memo CPP-13014 (Reference 9.14) as follows:
/~'T "The minimum clearance between the legs of
\s / the channel iron supporting the insulation l
l and the cavity wall varied from approximately ;
7/8" at azimuth 180 to 1/8" or less at 0 '
azimuth."
1 Rzvision! 1 Pags 14 of 52 RESULTS REPORT
}.
s_/
i ISAP VI.a '
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The small clearance at the 0 azimuth restricted cooling flow and consequently reduced heat removal from this area. It is this non-uniform gap that created the need to drill holes in the support ring, thereby increasing cooling flow rates in the narrow gap regions. Because the reactor vessel is concentric with the cavity (see SSER #8, pg K-101), the cause of the circumferential variance in gap width is suspected to be the cumulative effect of construction tolerances for both the 4
biological shield wall and the insulation on the vessel.
TUGC0 drawing 2323-M1-0550 (rev. CP-1) shows that the temperature element that recorded the high temperature (1-TE-5452) is located on the 12" diameter exhaust line at azimuth 0 (also 2323-M1-0551, rev. CP-2). Figure 2 depicts a cross-section of the upper reactor cavity region showing the exhaust pipe intake point. The 7- s temperature element 1-TE-5452 is located in a i)
'# downstream portion of this exhaust line outside the biological shield wall. TRANSCO (Westinghouse subcontractor for insulation) Drawing DR-4278C-12 shows the as-built condition of the support ring following modification (depicts hole locations). This drawing shows two areas, one on either side of the 0 azimuth, where holes in the support ring could not be made.
Between azimuth 0 and 25, the first 8.5 degrees of the ring contain holes, but the next 16 degrees do not (hardware obstructions made hole drilling impossible).
The position of obstructions and hence of the drilled holes is symmetric about the 0 azimuth. This situation left unchanged the reduced heat removal capacity for these specific locations. Further, the exhaust ports on either side of the one located at 0 azimuth (TE-5451, 315 azimuth and TE-5445, 45 azimuth) showed temperatures during the HFT that were essentially identical. These results support the supposition that the highest temperature (measured by TE-5452) occurred very close to the 0 azimuth.
From this information, it is concluded that the test results are acceptable, and that the cooling requirements for Unit I have been satisfied, provided that the Technical Specifications are changed to O provide a limit of 150*F for the exit air temperature (per Reference 9.13).
Rtvision: 1 Paga 15 of 52 r RESULTS REPORT ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Because the HFT had not yet been conducted on Unit 2, cooling adequacy for Unit 2 was demonstrated by the Project using a combination of Unit 2 reactor cavity air flow test data and Gibbs & Hill calculations.
TUGC0 memo SU-84350 (Reference 9.15) reported the results of the air flow tests which showed a uniform distribution of cooling flow at an adequate flow rate.
Gibbs & Hill used the Unit 2 flow rate data along with Westinghouse design information to predict the cooling flow temperatures at various points within the reactor cavity in calculation 2-0300-2, Revision O.
Calculation 2-0300-2A, Revision 0, was developed to map the temperatures in the cooling loop using the heat loadings taken from the Unit i HFT data (pre-modification) . The use of these data (i.e.,
higher heat loadings) assured conservative results because these heat loadings are considered higher than would be expected in Unit'2 for the following reasons:
b a uniform gap spacing between the support ring and biological shield wall will allow a more evenly distributed flow and less of a flow restriction (which caused the flow in Unit I to seep up between the vessel and insulation and acquire the heat) debris that accumulated at the top of the RPVRI support channel has been removed.
The two calculations provide a range of results: the first being a design baseline and the second providing an approximation for the worst case as-built condition.
The third-party review of these calculations is documented in Reference 9.16. During this review, one discrepancy was identified. DIR D-0002 was issued to document the fact that the value of radiation heating from the biological shield wall in calculation 2-0300-2 (Reference 9.17) uses data from a superceded reference without supporting justification. This DIR has been classified as an observation since the discrepancy did not have a significant effect on the results of the calculation, i.e., no further corrective action was required. The calculations demonstrate the adequacy of
Rsvision: l' Page 16 of 52 RESULTS REPORT
' /,,s\
k-/ ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the cooling system. Based on these calculations, the configuration of the Unit 2 cavity and the success of the Unit I retest under hot functional conditions, it is expected that Unit 2 will also meet its HFT performance requirements.
5.2 Definition of RPVRI/ Cooling Problem At the core of the issue of cooling adequacy in the reactor cavity is the existence of the RPVRI support ring in the annular air space between the RPVRI and the shield wall.*- The Westinghouse Specification for the reflective insulation (Reference 9.18, Westinghouse Proprietary) s*stes the following requirements:
" The reactor vessel coolant nozzles and/or reactor vessel supports shall support the insulation below the refueling seal ledge to include the shell, nozzle and f} bottom head insulation. The support steel in this
(,) region shall be contained within the insulation ou tlin e ."'
and, "The shell portion of the insulation and the nozzle insulation...shall not extend more than four (4) inches beyond the outside diameter of the reactor vessel at 90*F including canning and hardware..."
Gibbs & Hill use! this specification in developing the structural design for the reactor cavity and for cooling considerations. The size of the gap between the RPVRI and the shield wall was fixed by Gibbs & Hill HVAC designers based on developing a certain air flow velocity. Gibbs & Hill received Revision 3 of the RPVRI Specification in January 1974 Comments / questions were transmitted to Westinghouse in April 1974 (GTN-1081). Westinghouse responded to G&H questions in August 1974 (WPT-0439), in which Westinghouse stated in regard to the RPVRI:
"The insulation is supported from the primary nozzles.
Design specifics vary from supplier to supplier.
Fabrication drawings will be transmitted as they become availab le ."
Reference 9.19 provides a tabulation of the related history and lists the related documents.
R& vision: 1 Pags 17 of 52 RESULTS REPORT ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Gibbs & Hill received Revision 4 of the Westinghouse Specification in April 1976 as part of a transmittal of information related to the RPVRI (WPT-1064). This transmittal did not contain specific design information for the RPVRI. In July 1976, Gibbs & Hill issued for construction the structural drawings for the cavity area (drawings 2323-SI-545 and 549).
Westinghouse issued purchase orders to TRANSCO (subcontractor for insulation) in November 1976. TRANSCO completed drawings for Unit 1 RPVRI by late 1977, which Westinghouse subsequently approved and released for manufacturing. The insulation was sent to the site and installed in mid-1978. Up to this point in time, Gibbs & Hill had not been sent any drawings depicting the support ring on the outside of the RPVRI. In addition, no i
correspondence or other records have been identified in which Westinghouse notified the Project that the support ring was not contained within the insulation outline as stated in the specification.
() A design modification involving the support ring was authorized in June 1978 by Westinghouse. Site engineering identified a physical interference between the shield wall concrete at the nozzle penetration and the insulation support steel that is attached to the support ring on the RPVRI at one end and rests on the top of the vessel nozzles at the other (the interference was not the support ring itself). The modification involved changing the shape of the support steel and its attachment to the ring. The support ring was not altered by this design change. Gibbs & Hill was notified of the modifications by Westinghouse's letter authorizing the change (WPT-2327).
Numerous transmittals and meetings occurred in 1979 involving the design of non-crush insulation on the vessel nozzles. Of particular concern to ribbs & Hill at this time were interferences between this non-crush insulation and orifice rings around the nozzles. A sketch was prepared by Westinghouse in March 1979 (sketch #SK-GW-031679) that clearly showed the existence of the flow restriction caused by the presence of the support ring in the annular air space, in addition to non-crush insulation interferences. A meeting occurred in September 1979 in which this sketch was presented and discussed (personnel from TUGCO, Westinghouse and Gibbs &
Hill attended this meeting). No formal transmittal has occurred between Westinghouse and Gibbs & Hill involving this O\ sketch, nor has a written description of the flow restriction caused by the channel been formally transmitted, i
r,_.-,,- . ,,--.,--- - - -.,.~ - -,
1 1
Rsvision: 1 Pags 18 of 52 RESULTS REPORT p
\m- ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The above discussion clearly indicates that the cause of the problem was a breakdown in communication between Westinghouse and Gibbs & Hill during the development of the original design. While Westinghouse internally approved TRANSCO's design, they did not inform Gibbs & Hill in an appropriate or timely manner. Accordingly TUGCO's design change process c'annot be linked to this particular discrepancy. This interface communication problem was documented in DIR D-0016.
No other instances of communication breakdowns between Westinghouse and other CPSES contractors were identified during the implementation of this Action Plan. The DAP is addressing the subject of Westinghouse - contractor interface as part of the self-initiated review scope.
In view of the fact that the support ring, an NNS feature, affected a safety-related function, and in response to the TRT request, an evaluation was initiated to address NNS designs where the potential exists for adversely affecting safety-related systems, structures or components. This t, subject is covered in the following section.
5.3 Evaluation of the NNS Design Change Process The process used at CPSES to identify and resolve adverse interactions between NNS and safety-related items was evaluated by the third-party. The results of this evaluation are provided in this Section. The review indicated that the CPSES process included:
criteria imposed on the design of both safety-related and NNS items to preclude certain types of interactions, and
- programs that address standard industry-recognized interactions (see Table 2).
multi-discipline reviews of the design and design changes for both the safety-related and NNS items, From a programmatic perspective, the scope of this process was considered adequate in that the above program elements encompass all the methods necessary to address these interactions. However, review of individual program elements was necessary to determine if the process was adequate.
_ . . , - _ _ _ . , , , _ . . _ _ - . _ . _ _ _ _ _ _ _ _ . . . _ . _ , _ . _ _ _ , . . _ _ , - _.._--_y , ... - . _ . . . . _ _ _ _ _ . .
R: vision: 1 Pags 19 of 52 RESULTS REPORT
'g ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The Design Adequacy Program includes extensive reviews of the design criteria and their implementation for safety-related systems and components. These reviews include the design criteria related to controlling adverse interactions with NNS components (e.g. , electrical separation, structural and process isolation of piping at system boundaries).
All of the programs listed in Table 2 except for the seismic interaction portion of the Damage Study Program are included within the scope of the Design Adequacy Program. The seismic interaction portion of the Damage Study Program is evaluated under ISAP II.d (" Seismic Design of Control Room Ceiling Elements"). Seismic interactions by NNS (train C) conduit are evaluated under ISAP I.c (" Electrical Conduit Supports").
The remaining program segment to be evaluated under this action plan was the process for the multi-discipline review and approval of NNS design changes since the programs listed in Table 2 (and those aspects of the design of safety-related
( components that are intended to control interactions with NNS components) were covered in other CPRT reviews. An evaluation was made of the design change process implemented at CPSES through mid-1985. The results of this evaluation are discussed in the following sections (Reference 9.20).
5.3.1 History of Design Change Mechanisms at CPSES (through mid-1985)
Design work for CPSES began following award of the CPSES Architect / Engineer contract in 1972 to Gibbs &
Hill. The design was initially prescribed in drawings and specifications, and changed by revisions of the base documents or by using Design Engineering / Change Deviation (DE/CD) forms. During this initial phase, all design and change documents were controlled by the Gibbs & Hill New York office. Whereas Gibbs & Hill New York made use of the DE/CD, safety-related changes were initiated at the site using a Design Change / Design Deviation (DC/DD) form. Non-safety-related changes were initiated by the Field Problem Action Request (FPAR). Non-safety clarifications were made using mechanisms such as the Field Information Clarification Request (FICR). These clarifications, however, did not effect a design change.
O
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ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The first major evolution in the design change process occurred in 1977, when the TUSI Design Group was established on site. This group also had the authority to initiate design changes at the site. Design changes were approved by Gibbs & Hill-delegated representatives at the site and subsequently transmitted to Gibbs &
Hill New York for engineering review and design verification, as appropriate. Work called for by a design change package was initiated after Gibbs & Hill site approval.
Three (3) major design-related developments were instituted in the 1977/1978 timeframe. The first was the consolidation of site design engineering into one organization called Comanche Peak Project Engineering (CPPE). The second development was the initiation of two site-issued design change documents to replace the FPAR and DC/DD: the Design Change Authorization (DCA) and the Component Modification Card (CMC). DE/CDs Os continued to be issued by Gibbs 6 Cill New York; but after mid-1978, they were assigned a DCA or CMC number for site dispositiva. The CMC was developed to facilitate changes specific to piping and supports.
The DCA was more suitable for addressing changes to specifications and other design documents. The third change was TUGCO's decision to exercise the option to waive prior Gibbs & Hill approval of design changes (DCAs and CMCs only - drawing revisions continued to be reviewed before issuance). The appropriate change document (e.g., DCA or CMC) was completed and transmitted to Gibbs & Hill for review and approval in parallel with the field work release. If the requested change was not approved, the already-effected field changes were removed and the necessary modifications were made in accordance with the approved Gibbs & Hill design documents.
t The next major evolution in the design process occurred in 1979, when the Pipe Support Engineering Group was formed to more effectively address the small-bore pipe
- hanger design effort. Although this group used the same design change mechanisms as the other engineering organizations, it was responsible for the ensuing review process. Pipe Support Engineering (PSE) became i
O a discipline at CPSES in 1981, assuming responsibility for all pipe support activities.
, , . , . _._..-__.,,_-._,____-..,,.,_.-m .,___,,,.,..,______.c . . _ - . - _ . , . . _ _ , , . _
R3vicion: 1 Paga 21 of 52 p-, RESULTS REPORT ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
TUSI Nuclear Engineering (TNE) assumed responsibility for various aspects of the design process in late 1982.
Soon afterwards, they also gained custody of the original vendor drawings. In late 1985, TNE became the principal engineering body on site, absorbing CPPE and PSE.
5.3.2 Non-Safety Design Change Mechanisms 5.3.2.1 Design Engineering / Change Deviation (DE/CD)
The DE/CD mechanism has been used by Gibbs &
Hill New York from the beginning of the design effort to document both safety and non-safety-related design changes. From 1975 to 1977, these forms, in addition to drawing revisions, effected design changes. During this period of time, approximately 150 DE/CDs were issued. Following the institution of
'O '
CMCs and DCAs, Gibbs & Hill DE/CDs were assigned a corresponding CMC or DCA number for disposition.
5.3.2.2 Field Problem Action Request (FPAR)
The FPAR was used by the site to initiate a non-safety design change. This mechanism was used from the beginning of the design effort until it was replaced with the CMC /DCA.
During its effsetive timeframe, approximately 700 FPARs were issued.
5.3.2.3 Design Change Authorization (DCA) and Component Modification Card (CMC)
The DCA and CMC mechanisms replaced the FPARs and site-originated DC/DDs, and were still in use as of mid-1985. The CMC lands itself to depicting hardware changes easily, particularly in the piping and support areas.
The Project used these forms to effect both safety and non-safety design changes. As of June 1985, there were approximately 26,000
() DCAs and over 100,000 CMCs that had been written for Units 1 and 2 and common areas.
R;visioat 1 Peg 2 22 of 52 RESULTS REPORT
('
ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.2.4 Vendor Drawings (Revised by the Project)
Throughout the course of the project, some vendor supplied equipment and related vendor drawings required modifications. In some situations, the vendor made the necessary changes on the drawings. However, in many cases the Project (CPPE/TNE) made the ch.inges themselves and issued the drawing with a "CP" prefix to the revision number. There are approximately 2,000 such drawings including both safety and non-safety items, including incorporation of previously issued DCAs and/or new design work. Before being issued to the field, all vendor drawings are approved by Engineering (CPPE/TNE).
5.3.2.5 Gibbs & Hill Drawings (Revised by Gibbs &
()
U Hill New York)
Much of the design is defined through the use of drawings, the bulk of which have been originated by the Architect / Engineer, Gibbs &
Hill. Towards the end of the design work, control of drawing updates was transferred to CPPE/TNE. However, the majority of the drawing revisions were made by Gibbs & Hill in their New York office. The population of drawing revisions as of the end of 1985 was i
approximately 55,000 and includes both safety and non-safety changes.
5.3.2.6 Gibbs & Hill Drawings (Updated by CPPE/TNE)
As mentioned above, CPPE/TNE assumed responsibility for drawing updates towards l the end of design work. When CPPE had
- occasion to revise a drawing, they reissued it (following Engineering review) with a "CP" prefix to the revision number. There have been approximately 10,000 such updates for which DCAs, CMCs, or new design work have been incorporated over the course of the project as of the end of 1985. As in the
'. above two cases, these revisions receive
'- engineering approval prior to field issuance.
Rsvision: 1 Paga 23 of 52 RESULTS REPORT
(
() ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.2.7 Pipe Support Engineering CMCs Due to the large quantity of hanger sketches, it became necessary for PSE to track their own drawings (through HITS - see below) as well as modifications to these drawings through the CMC mechanism. All CMCs come from a common pool and are sequentially numbered and controlled. To date, there are approximately 40,000 CMCs originated by PSE.
These CMCs include both safety and non-safety design changes.
5.3.2.8 Pipe Support Drawings The Hanger Inventory Tracking System (HITS) contains most of the drawings within the PSE scope of design. Not included are approximately 10,000 balance-of-plant
('/g) typicals, which are in the DCC tracking system. Within HITS, the population of non-safety drawings is approximately 16,200, with each drawing having an average of one revision. Revisions to hanger sketches are usually performed when a significant change is required (otherwise, a CMC is used).
5.3.3 Evaluation of NNS Design Change Procedures The process for the review and approval of DCAs and CMCs in effect at the time the third-party investigation began (June 1985) is shown in Figure 3.
j This process includes a verification of the NNS classification and any effects on safety-related equipment. The procedures that control this process are listed under each of the activities in Figure 3.
The overall process and the procedures involved are the same for both safety-related and NNS design changes except for the Design Verification activity. Design verification (same as 10CFR50, Appendix B design review) is performed for safety-related items and certain NNS items such as the fire protection system.
Design verification is not required for the majority of the NNS design changes.
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, Paga 24 of 52 RESULTS REPORT ISAP VI.a i
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) j The. key activity in the review of NNS design changes for identification and resolution of adverse interaction with safety-related items is the Engineering Review performed under procedure TNE-DC-8-1. This is a multi-discipline review where the affected disciplines are indicated on the Change Verification Checklist (CVC) by the reviewing engineer. ,
The use of a multi-discipline review for this purpose
- is a standard industry practice.
4 e
The third-party has reviewed .the historical Gibbs t Hill and TNE procedures that controlled the design j
process and concluded that the implementation of multidiscipline engineering reviews has been a basic function within the CPSES design process since the beginning (Reference 9.21).
l 5.4 Review of Selected NNS Design Changes 5.4.1 Selection of the Sample 2
As discussed in Section 5.3 changes to the design of
} NNS items during the early stages of conttruction were 1
made primarily by revisions to drawings and
[ specifications. Later, CMCs and DCAs, or their J predecessor change documents, were used to initiate j many of these design changes. It was concluded that review of a representative sample of DCAs and CMCs
' would provide an effective test of the implementation 3
of the NNS design change process. The basis for this conclusion was:
i CMCs and DCAs have been in use throughout most of the design process (mid-1977 to present).
They were used by all disciplines and i
therefore include a broad spectrum of design activities.
2 i
iO i
i 1
l
_ . - _ _ . _ . ~ . . _ _ _ _ _ _ _ _ . . _ . , _ . _ _ . . _ _ _ . . . _ _ _ . _ _ _ . . . , __ .-
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Both drawing / specification revisions and DCA/ CMC-initiated changes were subject to the same basic review process. However, because CMCs and DCAs were not always immediately incorporated in the base document at the time of their design review, the Project review process could be more complex than the review of an equivalent drawing or specification change, especially where there are multiple unincorporated changes outstanding against the base documents at the time of the review.
The review of drawing or specification changes was performed prior to their issuance, whereas review of CMCs/DCAs was sometimes performed after they were issued for construction. While this approach is an acceptable practice that has been used elsewhere in the nuclear power industry, it O' increases the potential for adversely influencing the review process.
The computerized drawing control system data base was used to identify the population of CMCs and DCAs from which to sample. This data base does not uniquely distinguish between NNS and safety-related CMCs and DCAs, but it has the capability to identify those CMCs and DCAs that do not require design verification. As shown in Figure 3, the CMCs and DCAs that do not require design verification are NNS changes. However, some NNS design changes (e.g., fire protection system) are subject to design verification. In addition, some CMCs and DCAs that were initially designated as safety-related were later determined (during the design verification review) to be NNS changes. Thus, while i
the group of CMCs and DCAs identified in the data base as not requiring design verification are NNS changes, this segment does not include all of the NNS CMCs and DCAs in the population.
l l
l i
1----. . _ . . _ _ .
Revision: 1 Pag 2 26 of 52 RESULTS REPORT
\d ) ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
While this limitation in the structure of the data base precluded sampling from the entire population of NNS CMCs and DCAs, the use of this data base was considered representative from an engineering viewpoint since all of the NNS CMCs and DCAs were subject to the same multi-discipline review process regardless of whether they subsequently went through part or all of the design verification process.
To provide a critical test of the effectiveness of the NNS review process in identifying potential interactions with safety-related items, screening criteria were established to eliminate those CMCs and DCAs which had little chance of leading to such int erac tions. In addition, it was anticipated that a common interaction resulting from NNS design changes would be seismic interactions of the type addressed by the Damage Study Program. Since this type of interaction was the subject of extensive investigations
under ISAPs I.c, " Electrical Conduit Supports", and II.d. " Seismic Design of Control Room Ceiling Elements", it was concluded that the investigations under this action plan should focus on non-seismic types of interactions.
The screening criteria used in selecting the sample were:
The change must involve some physical alteration in the plant as opposed to changes only in the documentation.
The change must be reflective of the currently approved plant configuration.
The change must be in a Category I structure.
The change should have the potential for interactions other than seismic.
The NNS DCAs and CMCs reviewed were selected randomly and evaluated against these screening criteria.
Sampling continued until 60 change packages were
- obtained. This sampling process required the review of nearly 3800 NNS change packages to obtain 60 that met Os the above screening criteria (approximately 1% of the
.-,.---,,w , c -- m-.--.-,---_-,-.-.m- - , - - - - - -----,v -,--. . . , - ,m--- -
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Rsvision: 1 Pegs 27 of 52 RESULTS REPORT
~
ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) control population could meet the above screening criteria). As samples met these screening criteria, they entered the review phase.
~
A review of the sampling program conducted under this Action Plan was performed by the CPRT Statistical
, Advisor. The review consisted of evaluating the soundness of the sampling program and the computational accuracy of the selection process. The findings of this review identified errors made by the Project in the random selection and associated documentation process. These errors appeared not to be systematic or 4
biased in nature (e.g., errors of transposition) and were few in number compared to the total number of items checked. The findings were addressed by the third-party and corrections made to all identified documents. There was no impact to the 60 that entered the design change review portion of the investigation
(~'} (Reference 9.37).
%l Therefore, it was determined by the third-party that the possible occurrence of other such errors in the sampling program would have no significant effect on the conclusions of the review effort for the following reasons:
The review of the sampling program conducted by the CPRT Statistical Advisor found no evidence of bias in the errors identified and, thus, it appears that the randomness of j the selection process was not affected.
The number of errors identified by the CPRT Statistical Advisor were small in relation to the number of items checked (i.e., low error rate).
Over 25% of the control population was screened in the process of identifying the 60 samples to be evaluated, and None of the errors identified and i subsequently corrected had any effect on the 1
g-s sample examined (the 60 DCAs/CMCs), i.e.,
, ( j none passed through the screen such that further evaluation was required.
R; vision: 1 Pag 2 28 of 52 RESULTS REPORT
/
\w ' - ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.4.2 Results of the Review of Selected NNS Change Packages The review of the sample of NNS design change packages was performed it. two steps. First, the change packages were re-reviewed by the Project using the process shown in Figure 3. After this review was completed the third-party conducted an independent review of each change package using a multi-discipline team (Reference 9.22).
The Project review of the sample of 60 NNS change packages did not identify any adverse interactions with safety-related systems, structures or components. The third-party review identified one case (DCA 21,181, Revision 0) in which an affected discipline was not included in the review of the change. This change, which authorized a generic increase in the thickness of insulation for a group of pipe sizes including s safety-related lines, had not been reviewed by the
( piping discipline to assess the effect of the change on pipe support or pipe stress levels. Further investigation by the Project and the third-party confirmed that the increased weight of insulation had not been accounted for in the pipe support and pipe stress analysis. This discrepancy was documented as DIR D-0053.
The Project initiated immediate corrective action (Reference 9.23) to assure that the piping re-analysis being performed by Stone & Webster (SWEC) utilized the correct insulation sizes.
The Project conducted analytical studies to determine l
if the oversight had safety significance. The third-party reviewed these studies and concurred with l
the Project conclusion that the oversight did not have safety-significance because the increase in stresses associated with piping, piping components, and supports were shown to be below code allowables (Reference 9.24). Additional assurance that the insulation changes will not adversely affect safety-related piping is provided by SWEC's decision to include insulation as f
a walkdown attribute in the as-built verification O
R vision: 1 Ptga 29 of 52 RESULTS REPORT
-( ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) effort (Reference 9.25 and 9.26). Consistent with the above, DIR D-0053 was determined by the third-party to not be safety-significant (see Secti,n S.6). Three other DIRs were written by the third-party in reviewing the Project studies. DIR D-2372 documents the identification of certain Gibbs & Hill piping analyses that failed to include the weight of insulation. DIRs C-0200 and C-0201 documented discrepancies identified in the SWEC studies related to nozzle loadings. These DIRs do not affect the conclusions drawn regarding the outcome of the study and have been transferred to the DAP action plan addressing piping issues (DSAP IX).
Since no other discrepancies were encountered in the review of the 60 change packages, and since the discrepancy in DCA 21,181 was not safety-significant, no further investigation was necessary.
Two weaknesses were identified by the third-party in their investigation of the NNS DCA/ CMC design change N
l review process as controlled by and documented on the CVC:
l -
Documentation accompanying the DCA/ CMC and CVC was considered insufficient in some cases. The missing information (e.g.,
referenced documents, a complete discussion explaining the nature of the change, or the basis of the justification) made it difficult to arrive at a conclusive decision regarding the possible existence of adverse interactions. The information not included within the DCA/ CMC and CVC was subsequently found to exist (following third-party requests for specific documents, or by third-party contacting individuals knowledgeable of the design change and the associated equipment / structure). Once acquired, the additional information made determination of the existence of adverse interactions possible for the third-party reviewers. Although it is recognized that obtaining information by directly contacting the individual responsible for the design change may be a necessary part of the
R3visien: 1 Pega 30 of 52 RESULTS REPORT ISAP VI a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) process, the absence of any written bases for decisions made by affected parties encumbers the review for adverse interactions and, therefore, increases the risk for such interactions remaining undetected.
Instances were identified where the reviewer did not send the change package to all affected disciplines in the Interdisciplinary Review phase. The procedure (TNE-DC-8-1) did not provide any guidance to the reviewer on how this assignment was to be made, nor did this procedure require any check that the selection of affected disciplines made by the reviewer was complete.
Since initiating the NNS change process review, TUGC0 has established a new set'of policies and procedures organized within the Nuclear Engineering and Operation Policies and Procedures manual. In addition to specific changes to the implementing procedures related to DCAs and CVCs, the establishment of a cohesive set i
of policies and procedures would result in a
! strengthening of documentation practices within the engineering organization. Confirmation of improvements in this area will be made by SRT in its overview of the Project's response to programmatic issues related to design control.
In the review process for design changes, the Project has committed (Reference 9.27) to modifying the procedure that controls review of DCAs (ECE-DC-8-1) by the inclusion of the following:
The Supervising Engineer will be responsible for the Interdisciplinary Review distribution.
The Supervising Engineer will use the review matrix provided in ECE-DC-7 for guidance in assigning the Interdisciplinary Review distribution for DCAs against drawings. For other deeuments (e.g., specifications), he will use the original review distribution for the affected document.
R vicion: 1 Pag 2 31 of 52 RESULTS REPORT ISAP VI.a (Cont'd) 5 . ')
IMPLDfENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The procedure now includes instructions which give disciplines charged to perform the Interdisciplinary Review the option of adding additional disciplines to those already indicated on the Interdisciplinary Review.
Reference 9.27 also states that this approach will be adopted for other design change mechanisms used at CPSES. The third-party has concluded that these procedural changes vill enhance the Interdisciplinary Review process in its ability to detect and prevent adverse interactions that may be caused by NNS design changes (Reference 9.22).
5.4.3, Closure The sampling effort described in Sections 5.4.1 and 5.4.2 identified no occurrences of a NNS design change O causing an adverse interaction. The third-party has concluded that there is reasonable assurance that the review process related to DCAs/CMCs to detect and correct such interactions was effective. Although this conclusion is based on sampling from the control population, it is considered to be applicable to the entire DCA/ CMC population because the control population was considered to be representative of the entire population (see Section 5.4.1). Because of the reasons cited at the beginning of Section 5.4.1 (which support the selection of the DCA/ CMC as an effective test of the overall NNS design change process), it is also possible to extend the conclusion reached for the DCA/ CMC review process to the entire NNS design change review process. This result from the sampling investigation, in concert with the thoroughness of the scope of hardware and design evaluations provided by the CPRT yields reasonable assurance that NNS design changes have not adversely affected safety-related systems.
O
Rsvision: 1 Pegs 32 of 52 RESULTS REPORT ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.5 Critical Spaces Program This program had three objectives:
Identify spaces in the plant where debris could accumulate and be undetected or difficult to remove. l
- These spaces were associated with safety-related equipment or structures such that the presence of debris in the space (e.g., flow path, seismic gap, thermal expansion slot, etc.) could jeopardize the item's functioning (hence, the term " critical spaces"),
Verify the cleanliness of the identified critical spaces through QC inspections, and Provide procedural controls to assure that the spaces remain clear.
, The following sections further describe these objectives as l
l
, well as the processes and results developed to achieve them.
5.5.1 Development of Critical Spaces List The first step in the investigation of critical spaces was the development of a general list of areas where debris could accumulate and impair the proper functioning of a safety-related item. The list was compiled with input from each Project discipline, Gibbs
& Hill, and the third-party. The resulting list consisted of 25 items as shown in Table 3. .
Following completion of this list, each ites was considered for inspection. Some of the 25 items had already been inspected through various start-up test programs (i.e., not part of CPRT) or had been verified to be free of debris by other Project activities.
Table 4 lists those items exempted from further inspection and the reason for the exemption. The remaining items were subjected to further review to obtain a complete listing (population) for each item to facilitate the subsequent inspection. This final listing was also reviewed by third-party in addition to the justifications provided for the exclusion of items from the inspection program.
R2 vision 1-Pago 33 of 52 RESULTS REPORT
-ISAP VI.a (Cont'd) l 5.0 1
IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.5.2 Critical Spaces Inspection The completed critical spaces list was then forwarded to QC for inspection. TUGC0 procedure CP-QP-11.24,
" Cleanliness of Critical Spaces", was developed for i these pre-fuel Inad inspections with concurrence on the approach given by third-party. TUGC0 QC performed the inspections in accordance with this procedure for all completed plant areas. Some items on the critical 4
spaces list, mostly in Unit 2, could not be inspected at this time due to construction activities that are j
on-going. These items will be inspected prior to transfer of responsibility to Operations (see Section j
7.0). In addition, some items could not be inspected i
because the items were inaccessible. These were
! identified on NCRs for subsequent disposition by TNE.
The Project will resolve the NCRs by either completing inspection of previously inaccessible items, or by providing appropriate technical justification for
- j. "use-as-is" dispositions. Since the corrective action is driven by NCRs, the Project's NCR technical review j
will verify the adequacy of NCRs containing "use-as-is" dispositions (Reference 9.28).
Southwest Research Institute (SwRI) performed a i third-party overview of the QC inspections in accordance with the SwRI procedure (Reference 9.2). A summary of the SwRI overview is presented in their I report (Reference 9.29). SwRI concluded that both the
! procedure and the QC personnel were effective in l assuring that all identified items were properly inspected.
I j After completing these inspections, the Project
] inspectors were requested to list the kinds of debris 4
that were removed from the various spaces. This list t
showed that some critical spaces had accumulated various construction debris (Reference 9.30). These i
findings confirmed the TRT concern regarding debris in critical spaces [ debris in seismic gap (ISAP II.c) and debris found in the Reactor Cavity (References 9.8 and 9.9)]. The original concern was documented in DIR E-0268. The occurrence of debris in various critical '
l spaces has been categorized as an unclassified i v h deviation. Root cause and generic implications associated with debris in critical spaces at e addressed l
in Section 5.8.
l,
--r-~,~.- . , . . - _,_ .-.._..m..__-,.-.-.w,_m,
R vicion: 1 Pag 2 34 of 52 g RESULTS REPORT ISAP VI.a (Cont'd)
~
i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.5.3 Operations Program for Critical Spaces The TRT had required that TUGC0 define a program that specifically addresses the maintenance of critical spaces subsequent to fuel load (see Section 2.0). From a logistics standpoint, this program is most effectively initiated at the time of room turnover, i.e., the time at which Operations begins to accept responsibility for plant equipment. To assure the adequate maintenance of critical spaces at CPSES, fit was agreed between Project Construction and Operariens organizations, and the third-party, that the Operations critical spaces program needed to be fully implemented at the time Operations responsibility for plant equipment began.
The inspections described in Section 5.5.2 provided a
" baseline" for establishing the cleanliness of most critical spaces. As the critical spaces in a room, O group of rooms, or an area of a building are verified as being satisfactory, Construction will inform Operations so that the spaces are incorporated into the.
Operations' surveillance plan (Reference 9.31). t' The Operations program for critical spaces was reviewed by third-party (Reference 9.32). The elements of the ',
program are detailed in TUGC0 memo QIM-86125. The key elements are the training program and procedural controls that include periodic inspection. The TUGC0 meno includes a discussion of the training program its content, to whom it applies, arid how it will be
- implemented. Two procedures have been revised to include provisions for ensuring critical spaces are maintained. Station procedure STA-607 (" Housekeeping Control", Revision 7), nov includes a definition of critical spaces as well as inspection requirements.
Surveillance instruction QAI-001 (" Plant Housekeeping and Equipment Inspection Plan") also includes critical '
space definitions as well as instructions to verify the effectiveness of STA-607 in maintaining the cleanliness of critical spaces.
QIM-86125 includes as an attachment a Generic Critical Space List / Action Response summary. This summary O incorporates information from Construction and the results of the critical space " baseline" inspection to
. (] k 1 J
R, vision: 1 Pcg2 35 of 52 i
' RESULTS REPORT O*: '; , ISAP VI.a (Cont'd)
, \ , r 5.0 IMPLEMENTATION OF ACTION' Pt.AN AND DISCUSSION OF RESULTS (Cont'd) e .;, ,.;
i f[ ]
- define the scope of the Operations program. Each of the twenty-five critical space types is addressed and given a disposition as to the need for inspections
, undre the Operations program. Some items have been
- 4 excluded from the inspection scope due to their being 3
' addressed under an existing program / procedure (e.g.,
, pneumatic instruments are periodically checked by I&C calibration, polar crane gaps are addressed by maintenance instruction MMI-317 Rev. 2). Each critical space type is adequately addressed within this summary in terms of those needing subsequent inspection as well as those that do not need to be in the Operations a
program. The summary is consistent with the L
surveillance instruction QAI-001 in that the list of Generic Critical Space items in QAI-001 includes all
% j the iter.s marked for inclusion in the Operations
} Critical Space Program with QIM-86125.
i The Operations' program as defined in QIM-86125 is i
s ,
, considered to be adequate to maintain critical spaces i ; <
free of debris subsequent to fuel load. In the interim j
.)' between initial inspections under the new procedures and the time the facility has been completely turned l over to Operations' custody, th impact of having a i' significant work force still in the plant may place a strain on housekeeping activities.
1 <
'However, trending of inspection findings will allow
- , TUGC0 to monitor housekeeping efforts. Should trending results indicate an adverse trend, TUGC0 will conduct a
! comprehensive reinspection / reverification of critical
- spaces \to provide assurance that all critical spaces i are free of debris prior to fuel load (References 9.33
] ,
and 9.34).
j 5.6 ' Summary of DIRs Eleven-(11) DIRs have been written relative to the VI.a Action j Plan. They are susunariced in Table 5. Four of the eleven DIRs were identified through review of external source documents. One of these DIRs (E-0985) documents the TRT uncertainty regarding the results of the Unit 1 i post-modification HFT (test results were not available for TRT review at the time SSER 8 was published). This DIR has been
- closed with the particular issue being unsubstantiated based k en a third-party review concluding that test results were
- t '
O l
McVicien: 1 Pcga 36 of 52 7 RESULTS REPORT
\/ ISAP VI.a (Cont'd)
'4 /
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) adequate. DIR E-1273 has also been closed with a !
classification of " unsubstantiated". This DIR related to the concern that non-nuclear safety design changes could have an ]
adverse impact on safety-re, lated equipment. The investigation l described in Section 5.4 ccncluded that a basis for this concern does not exist.
Another external source DIR (E-0268) documents the TRT concern that debris may exist in critical spaces. This DIR has been categorized as an unclassified deviation as a result of the
~
stated concern (debris in critical spaces) being confirmed through inspections. Root cause and generic implications is addressed for this DIR in Section 5.8.
S J The fourth external source DIR (E-0666) has been categorized as unsubstantiated based on the conclusions reached by the investigations described in Sections 5.3 and 5.4.
s Of the remaining seven DIRs, two (D-0002 and D-0016) have been closed as observations, i.e., the identified discrepancies have been determined not to be violations of design criteria, commitments, or specifications. Another DIR (D-0001) has been found to be unsubstantiated as a result of further investigation into the related issue (control of design input).
DIR D-0053 has been categorized as a deviation. The investigation described in Section 5.4.2 concluded that the deviation did not have safety significance.
The remaining three DIRs (D-2372, C-0200, and C-0201) were initiated within ISAP VI.a. but have been transferred to the action plan addressing piping issues within DAP (DSAP IX).
5.7 Safety Significance Assessment In the course of implementing this Action Plan two deviations have been identified. The first was documented on DIR E-0268 and involves confirming the existence of debris in critical spaces. Because the Action Plan specifically required the inspection of all critical spaces to verify cleanliness, and since final corrective action is being taken in response to all identified cleanliness infractions, an assessment of safety significance is not required by Appendix E of the Program Plan. The DIR has been categorized as an unclassified s
deviation. Root cause and generic implications are assessed in Section 5.8.
Revision: 1 Pego 37 of 52 RESULTS REPORT
()
(s,/ ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The second deviation was identified in conducting the review of NNS design changes and their potential for adversely affecting safety-related items. The selected design change (DCA 21,181) increases the thickness of insulation associated with piping 6" in diameter and smaller, by altering a table in the insulation specification (2323-MS-30). The associated DIR (D-0053) was classified a deviation because the engineering review for this NNS DCA failed to identify the safety-related piping analysis specification (2323-MS-200) as an affected document (MS-200 contained a copy of the table in MS-30 that was revised by DCA 21,181) which resulted in the Gibbs & Hill New York piping analysis group being unaware of the change.
The piping analysis for 6" and under lines after this change did not accurately account for the additional mass associated with the increased insulation thickness. As described in Section 5.4.2, the Project performed studies to show that the increase in weight would not result in a safety-significant impact to piping or supports. The third-party reviewed and concurred with these studies. Accordingly, the associated DIR O has been classified as a deviation.
5.8 Root Cause and Generic Implication Assessments 5.8.1 Debris in Critical Spaces The circumstances that lead to debris existing in the various critical spaces inspected as part of this ISAP were examined from two perspectives: (1) why was debris allowed to enter the space, and (2) why was the debris not detected and removed prior to this ISAP?
This section summarizes the potential causes that were evaluated and the conclusions reached.
The source of debris that accumulated in critical spaces cannot be confined to any one particular phase of plant construction or to any one organization.
Construction and modification activities extend into the startup testing program and, following turnover, continue into the operations phase. Various areas and systems at CPSES have gone through the entire turnover process (e.g., Construction has turned a system over to Startup who, in turn, has turned the system over to Operations). At the time of conducting the critical spaces inspection, the Fuel Building was the only area in the plant in the custody of Operations (other areas
l Revision: 1 1 Page 38 of 52 RESULTS REPORT ISAP VI.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) that had previously been turned-over to Operations were -
turned-back to the Construction organization to facilitate the reinspection required as part of the CPRT effort.)
Since debris has been found in critical spaces that are Operations' responsibility (i.e., debris found in turned-over equipment), and since it cannot be ascertained from the critical space inspection results at what point in time the identified debris entered the space, it is reasonable to assume each organization shares some responsibility for allowing debris to collect and remain undetected in a critical space.
This is supported by the fact that the work activities themselves in general do not change from one phase of plant status to another (e.g., the work done in an electrical cabinet and the kinds of debris associated with this work is independent of whether the cabinet is under Construction, Startup or Operations control).
The source of debris is also generally difficult to link with a specific construction activity. For example, a block of wood in a pipe sleeve may have been placed as a temporary support for the pipe during erection of the line early in the construction phase.
Alternatively, the wood block may have been inadvertently forgotten in the sleeve during the removal of temporary scaffolding completed recently.
Typically, emphasis on verification of cleanliness (and identifying and correcting nonconformances) increases as the plant evolves from a construction site to an operating plant, with personnel and material access rigidly controlled (personnel access is controlled in the Fuel Building but material access control had not yet been instituted at the time of conducting the critical spaces inspection). Moreover, the question of
, why debris had not been detected and removed prior to j the critical spaces inspections is more significant from the standpoint of root cause and generic implications than how debris entered the space initially, I
l lO l
l 3
, - -,-.-_-_-----i
R vision: 1 Peg 2 39 of 52 RESULTS REPORT (s) s_ ,f ISAP VI.a (Cont'd) 5.0 IMPLD4ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The control of debris is typically addressed through programs for housekeeping and housekeeping surveillance. The QA/QC Review Team was requested to evaluate these programs in light of the findings from the critical spaces inspection (Reference 9.35). The QA/QC Review Team response (Reference 9.36) made three observations:
- 1. The historical housekeeping and housekeeping surveillance programs were typical of normal industry practice,
- 2. Housekeeping and housekeeping surveillance procedures did not address the cleanliness of critical spaces, and
- 3. Design specifications did not identify the critical nature of these spaces or define requirements for cleanliness and protection.
\
Based on the above, the QA/QC Review Team postulated that the root cause was the failure of design specifications to adequately define cleanliness requirements for critical spaces (documented within DIR E-0268).
The corrective actions implemented as part of this Action Plan comply with the requirements imposed upon TUGC0 by the TRT. The corrective actions described in Section 5.5 conservatively anticipate inadequacies in both procedural requirements and implementation, and comprise an aggressive approach to ensuring the cleanliness of critical spaces. Because of the comprehensive nature of the critical spaces program and the corrective actions implemented, generic implications considerations are considered to be completely addrassed through the corrective actions implemented.
I
6.0 CONCLUSION
S Based on the third-party reviews of hot functional testing results for Unit 1, and review of flow tests and calculations for Unit 2, s
cooling flow in the annulus between the RPVRI and biological shield s.l wall for both units is adequate. The reviews were based on tests and calculations that consider the current as-built configuration i
Revision: 1 Paga 40 of 52 RESULTS REPORT-ISAP VI.a (Cont'd)
6.0 CONCLUSION
S (Cont'd)
(i.e., post-modification). Although not within the review scope of this Action Plan, it is noteworthy that further proof of Unit 2 cooling adequacy will be demonstrated by the hot functional testing required as part of the Unit 2 Startup Program.
A review of the cirewstances that gave rise to the issue (RPVRI support ring) was conducted by the third-party. It was concluded that the cause of the problem was a breakdown in communication between Westinghouse and Gibbs & Hill during the development of the original insulation design. No other instances of communication breakdowns between Westinghouse and other CPSES contractors were identified during the implementation of this Action Plan. The DAP is addressing the subject of Westinghouse - contractor interface as part of the self-initiated review scope.
The investigation of the potential for NNS design changes to have an adverse impact cn safety-related systems, structures, or components caused the third-party to conclude that there is no basis p to suspect that this has occurred. No safety-significant Q interactions were identified during the course of the review.
This, and the thoroughness of the scope of hardware and design evaluations provided by the CPRT, yields reasonable assurance that NNS design changes have not adversely affected safety-related systems. Weaknesses in the design change review procedures have been identified by both the third-party and the Project, with the Project constitting to strengthen these procedures. The procedural changes proposed by the Project were determined to be acceptable by the third-party.
The Critical Spaces Program implemented by this Action Plan achieved the objectives established to satisfy the TRT requirements, namely:
Spaces in the plant where debris may collect and be undetected or difficult to remove were identified.
The identified spaces are now verified to be free of debris by existing records or by inspections done as part of this Action Plan. Nonconformances were identified and the appropriate corrective action taken (i.e., debris removal or development of a technical justification for not inspecting and/or removing debris in specific cases), and O
- - - - - -r,. . ~. ,--- , - - . . . ~ , . . . _ . _ _ . . . - - . - - - - -
. . , ,,_.-,..y._._ _ , ,., 7-_m_., y,.,, ,, _ _ , . _ - - . - . - - , _ . _ . _ . _ . . , . . . . . - - . . , , -
1 Rsvision: 1 Page 41 of 52 !
RESULTS REPORT
) ISAP VI.a (Cont'd)
6.0 CONCLUSION
S (Cont'd)
A program (i.e., procedures and training) to minimize the collection of debris in critical spaces following turnover to Operations has been developed.
Each phase of the Critical Spaces Program listed above has been reviewed or overviewed by third-party and has been was determined to be adequate.
The third-party has evaluated the unclassified deviation associated with debris found in critical spaces to identify root causes and generic implications. This evaluation found that the failure of design specifications to define cleanliness requirements for critical spaces was the probable root cause. It was concluded that, due to the comprehensive nature of the corrective actions implemented, generic implication considerations have been completely addressed.
7.0 ONGOING ACTIVITIES
' O As noted above, the adequacy of the Unit 2 reactor cavity cooling flow will be further verified (i.e., in addition to the calculations prepared and reviewed as part of the scope of this Action Plan) by hot functional testing required as part of the Unit 2 start-up program. This activity will add to the assurance that the cooling system for the reactor cavity meets FSAR/ Technical Specification requirements.
Based on the satisfactory results of the NNS design change investigation, there are no ongoing activities related to this area.
Inspections of identified critical spaces will continue as the associated equipment / structures become available through the room turnover process. Nonconformances identified as part of the completed inspections are being resolved through NCR dispositions.
The NCRs with dispositions that exempt an item (or items) from inspections are subject to a technical review being conducted by the Project.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE No actions are required relative to the reactor cavity cooling i problem. In regard to the NNS design change process, the Project fh Nl has identified all design change mechanisms and is strengthening m the corresponding procedures relating to the Interdisciplinary Review. The improvement of documentation practices has been a i
Rsvision: 1 Pags 42 of 52 RESULTS REPORT ISAP VI.a (Cont'd) r 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE (Cont'd) principle consideration in both the restructuring of the CPSES Engineering organization as well as the development of a new set of plant engineering procedures.
As part of the Critical Spaces Program defined in this Action Plan, the third-party has reviewed procedures established by Operations designed to prevent the accumulation of debris in critical spaces.
The third-party has determined the procedures are adequate in this regard and satisfy the TRT requirement communicated to TUGCO.
9.0 REFERENCES
9.1 Safety Evaluation Report, Supplement 8, NUREG 0797, Related to the Operation of Comanche Peak Steam Electric Station Units 1 and 2, Docket Number 50-445 and 50-446, February, 1985.
9.2 SWRI Surveillance Procedure, "SWRI Surveillance Plan for Verification of the Implementation of Inspection Procedure CP-QP-11.24, ' Cleanliness of Critical Spaces,' CPRT File Number VI.a.5a.
9.3 Gibbs & Hill Calculation 2323-0300-2, Revision 2 " Containment Neutron Detector Well Ventilation System".
9.4 Impell memo, IMT-0509, 9/29/86, from J. Everett to Peter Turi, i
" Neutron Detector Qualification Status".
9.5 TUGC0 letter, TXX-4054, 9/26/83, from R. J. Gary (TUGCO) to G.
L. Madsen (NRC), re: SDAR-118.
l 9.6 American Concrete Institute Standard 349-85, " Code Requirements for Nuclear Safety Related Concrete Structures", Section 6.3.8.
9.7 Westinghouse letter, WPT-6789, 11/18/83, from T. R. Puryear to J. T. Merritt, re: Reactor Cavity Cooling Problem.
t 9.8 Westinghouse Memo, MP-84-223, 8/8/84, from D. M. Trombola to Ray Moller, re: Debris Removed form RV Annulus - Unit #1.
9.9 Westinghouse Memo, MP-85-057, 1/28/85, from D. M. Trombola to R. L. Moller, re: Reactor Vessel Annulus Search and Retrieval.
1 1
R1 vision: 1 Page 43 of 52
-~x RESULTS REPORT
'~'
]
ISAP VI.a (Cont'd)
9.0 REFERENCES
(Cont'd) 9.10 TUGC0 Startup Test Summary Report, ISU-282A, Revision 2,
" Containment and Feedwater Penetration Room Temperature Survey" 9.11 TUGC0 Memo, TCF-85103, 1/8/85, " Neutron Detector Well Exhaust Air Temperatures", from R. A. Jones to R. D. Calder.
9.12 TUGC0 Memo, TSG-7786, 1/8/85, " Neutron Detector Well Exhaust Air Temperatures", from F. W. Madden to R. A. Jones.
9.13 TUGC0 Letter, TXX-4418, 4/30/85, from J. W. Beck to V. S.
Noonan.
9.14 TUSI Memo, CPP-13014, 7/22/83, " Reactor Vessel Cavity High Temperature", from C. K. Moehlman to M. R. McBay.
9.15 TUCCO Memo, SU-84350, 4/23/84, " Air Flow Data for Unit II Neutron Detector Well Cooling System", from T. P. Miller to C.
/~'}
N/
K. Moehlman.
9.16 TENERA Memo, CPRT-054, 9/16/85, from P. Turi to C. Moehlman, CPRT File Number VI.a.4f.
9.17 Gibbs & Hill Calculation 2323-2-0300-2, Revision 0,
" Containment Neutron Detector Well Ventilation System".
9.18 Westinghcuse Equipment Specification #676449, Revision 4, 1/30/76, " General Reactor Vessel Insulation Specification",
Westinghouse Proprietary.
9.19 TUGCO Memo, CPP-18006, 3/14/85, from C. K. Moehlman to C.
Mortsat.
9.20 TENERA Memo, 9/19/86, "ISAP VI.a Results Report Sections 5.3.1 and 5.3.2", from J. Miller to R. Calder.
9.21 TENERA Memo, 8/15/86, " Design Control Procedure Review", from D. Timmina to P. Turi.
9.22 TENERA Memo, 2/27/87, " Evaluation of NNS Design Change Packages", from P. Turi to file.
9.23 TUCCO Memo, CPPA-48988, 4/1/86, " Piping Insulation", from R.
P. Baker to J. C. Hicks.
O
Rsvision: 1 Page 44 of 52 O RESULTS REPORT k -)
s ISAP VI.a (Cont'd)
9.0 REFERENCES
(Cont'd) 9.24 CPRT File Number VI.a.4e, review package associated with DCA 21,181.
9.25 SWEC Calculation GENX-019, Revision 3, pg. 8A, " Impact Study -
Effect of Change in Insulation Type Thickness / Weight on Pipe Stress". !
9.26 SWEC Calculation GENX-063, Revision 3, pg. 6C, " Generic Calculation of Evaluation of Effects of Calcium Silicate Insulation Due to Increase in Thickness".
9.27 TU Electric Letter, NE 4555, 2/19/87, from J. Krechting to J.
Miller, " Interdisciplinary Reviews of Design Changes".
9.28 SWEC Project Procedure PP-041, "Nonconformance Evaluation Procedure".
9.29 EWRI Report, " Surveillance Report for the Verification of the
(
(,,j}
Implementation of Inspection Procedure CP-QP-11.24 Cleanliness of Critical Spaces at CPSES, Unit 1", 8/86, CPRT File Number VI.~a.5C.
9.30 TUGC0 Memo, TUQ-4361, 9/23/86, " Critical Spaces Program", from J. D. Hicks to J. C. Keller.
9.31 TUGC0 Memo, NP-0991, 9/29/86, " Maintenance of Critical Spaces", from R. E. Camp to R. A. Jones.
9.32 TENERA Memo, 10/14/86, " Review of Operations Critical Spaces Program", CPRT File Number VI.a.4f.
9.33 TUGC0 Memo, 9/15/86, " Maintenance of Critical Spaces", from D.C. Snyder to S. Ali.
9.34 TUGC0 Memo, 9/22/86, " Maintenance of Critical Spaces", from D.
C. Snyder to S. Ali.
9.35 QAP/DAP Document Interface Transmittal Form, Number S-1081, 10/7/86, to M. Obert from J. Miller.
9.36 ERC Memo, QA/QC-RT-4642, 11/24/86, " Evaluation of Housekeeping / Surveillance Relative to Critical Spaces", to J.
Miller from G. W. Ross.
() 9.37 Memo, CPRT-848, 03/18/87, " Evaluation of Errors in Sampling Program", to VI.a File from F. Webster.
i Revision:
i 1 1 Page 45 of 52 l l
1 RESULTS REPORT 1 1
ISAP VI.a (Cont'd)
Figure 1 Cross-Section View of Reactor Cavity
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- 3/4" CLEAR ANCE
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Ravision: 1 Page 46 of 52 RESULTS REPORT A ISAP VI.a (Cont'd)
Figure 2 Diagram Showing Relationship of Components Near RPVRI Support Ring
/
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.. .t.. .-
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- I2* 8 AIR EXHAUST PPE
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0 J REACTOR VESSEL E' EI I.,A *.* *,
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BIOLOctCAL SHIELD WALL
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AIR FLOW RESTRAINT APO .'.** * -
SITE FOR DESRi$ ACCUMUt.ATION
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. REFLECTIVE INSULATION b'*.* *-
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DCA/ CMC _ p* m ENGINEERING cuss v[3 _ DESIGN e
e ,
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]mut REVIEW I UR ~
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THE-DC-21 INE DC 1 0
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- 9 c e H PaoJ cusoE SECT. 29
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o I- l ua*9 #a 9W Q TO DCC/DCTG , ., - m 1
FOR DIST. QUAUTY 5= 2
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CONTROLLED DESIGN
.... err a n o w ran ISSUE TO e G t H JOB s 2 meuw atsotuim CHANGE PKG. e ENGINEER J FIELD TO DCTG APPROVAL DCP-3 TE-DC-8 l TE-AD-4 G t H pro ' GUIDE SECT. 29 2' il?
%3 o9 DCA/ CMC REVIEW PROCESS *
(as of June 1985)
M-
Rsvision: 1 Pags 48 of 52 RESULTS REPORT ISAP VI.a (Cont'd)
Table 1 Summary of Acronyms / Abbreviations CMC Component Modification Card CPPE Comanche Peak Project Engineering CVC Change Verification Checklist DAP Design Adecuacy Program DCA Design Change Authorization DCC Document Control Center DC/DD Design Change / Design Deviation DE/CD Design Engineering / Change Deviation
. DIR Discrepancy / Issue Resolution Reports DM Design Modification DSAP Discipline Specific Action Plan FICR Field Information Clarification Request FPAR Field Problem Action Request HFT Hot Functional Testing HVAC Heating, Ventilation, Air Conditioning ISAP Issue Specific Action Plan NCR Nonconformance Report O NNS PSE Non-Nuclear Safety Pipe Support Engineering QC Quality Control RCS Reactor Coolant System RPVRI Reactor Pressure Vessel Reflective Insulation SwRI Southwest Research Institute TDR ast Deficiency Report TNE 7CCO (or TUEC or TUSI) Nuclear Engineering O
Revision: 1 Paga 49 of 52 RESULTS REPORT ISAP VI.a (Cont'd)
Table 2 Programs that Address Interactions Between Safety-Related and Non-Safety-Related Items CPSES Program Description CPRT Review Area Damage Study Program Seismic Category 2/ Category 1 (General) ISAP II.d Train C Conduit Seismic Interactions ISAP I.c Moderate & High Energy Line Breaks DSAP X Internal Plant Flooding DSAP X Internal Plant Missiles DSAP X l
Fire Protection Program DSAP XI Environmental Qualification Program DSAP XI Single Failure / Failure Modes and
() Effects Analysis DSAP XI i
l l
P l
l l
t O
i Rsvision: 1 Page 50 of 52
~~ RESULTS REPORT ISAP VI.a (Cont'd)
Table 3 Critical Spaces List
- 1. Pipe Bumpers (Crush-pipe and Honeycomb types)
- 2. Moment Limiting Components
- 3. U-Bar Type Pipe Whip Restraints 4 Metallic Expansion Joints (Bellows)
, 5. Expanding Equipment (slotted footings for equipment experiencing thermal growth)
- 6. RPVRI/ Shield Wall annular area
- 7. Containment Spray Sump Screens
- 8. Tank Diaphragas
- 9. Dry Pipe
- 10. Reactor Blowdown Tubes
- 11. Electrical Panels with ventilation requirements
- 12. Mechanical Penetrations
- 13. Critical Floor Drains
- 14. Fire Dampers
- 15. Platform Beams O Seismic gap at tops of secondary walls
- 16.
- 17. Polar crane gaps
- 18. Seismic gap between Containment Liner and interior structure
- 19. Tornado Vents
- 20. Guide Tube Pipe Supports
- 21. Rotating Platform Pivot Bearing
- 22. Pipe Vents
- 23. Pneumatic Instruments with one side vented to atmosphere
- 24. Steam Generator, Reactor Coolant Pumps, and Pressurizer Restraints
- 25. Building Separation Gaps Item transferred to ISAP II.c, " Maintenance of Air Gap Between Concrete Structures", inspection scope.
- Item transferred to ISAP VI.b, " Polar Crane Shimming".
O
1 l
Ravision: 1 )
Page 51 of 52 '
RESULTS REPORT
,, ISAP VI.a
[v ,} (Cont'd)
Table 4 Critical Space Items from Table 3 Exempt From Inspection Item Reason For Exemption Moment Limiting Components Gaps verified by HFT U-Bar Type Pipe Whip Restraints Gaps verified by HFT RPVRI/ Shield Wall Annular Area Westinghouse contracted to remove debris. Area now protected by re-installing seal ring.
Containment Spray Sump Screens Readily inspectable by routine housekeeping activities (CPSES instruction QAI-001)
Electrical Panels Panels verified clear of debris during turnover process.
Operations procedures STA-607 and STA-612 ensure continued cleanliness A
( ,) Fire Dampers Outer perimeter of damper verified clear of debris as part of resolution to SDAR-132. Inner area verified clear by execution of start-up test procedure XCP-ME-3, and is maintained by operability tests required by Tech. Spec.
3/4.7.12.
Platform Beams Slotted holes to allow for thermal growth protected from significant accumulation of debris by washers.
Rotating Platform Pivot Bearing Cowling over bearing prevents debris intrusion (should not have been included on list)
Seismic Gaps at tops of Addressed within ISAP II.c Secondary Walls Containment Wall / Internal Addressed within ISAP II.c Structure Polar Crane Addressed within ISAP VI.b g Pipe Vents Not applicable at CPSES (should not have been included on list)
Rsvision: 1 Paga 52 of 52
,_s RESULTS REPORT l )
\u/ ISAP VI.a (Cont'd)
Table 5 Summary of Related DIRs RELATED REPORT DIR # TITLE CLASSIFICATION SECTIONS E-0268 Contact Between Reactor Unclassified 5.1,$.2,5.5 Insulation and Wall Deviation 5.7, 5.8 E-0666 Impact of Non-Safety Unsubstantiated 5.2, 5.3, Related Design Changes 5.4 E-0985 Gap Between RPV Insulation Unsubstantiated 5.1' and Shield Wall E-1273 Reactor Pressure Vessel Unsubstantiated 5.4.2 Reflective Insulation D-0001 Control of Design Input Unsubstantiated N/A D-0002 Superseded Reference in Observation 5.1 NNS Calculation D-0016 Gibbs & Hill / Westinghouse Observation 5.1, 5.2 Interface D-0053 Incorrect Insulation Deviation 5.2, 5.3 Thickness use in Piping 5.4 Analysis D-2372 Analysis Consideration of Discrepancy
- 5.4.2 Piping Insulation C-0200 SWEC Piping Analysis Study -* 5.4.2 C-0201 SWEC Piping Analysis Study -* 5.4.2 O
- Transferred to DSAP IX
_ . . _ _ _ , __ . . - - _ _ _ _ . _ . _ _ _ _ . _ _ _ _