ML20210U066
| ML20210U066 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/16/1983 |
| From: | BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.) |
| To: | |
| Shared Package | |
| ML20209B909 | List: |
| References | |
| FOIA-85-59 CEI-20, NUDOCS 8606020169 | |
| Download: ML20210U066 (128) | |
Text
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BROWN & ROOT, INC. PROCEDURE EFFECTIVE CPSES NUMBER REVISION DATE PAGE i
CEI-20 [9 , 12/16/83 1 of 12 TITLE: ORIGINATOR A /2-/d'83 Date INSTALLATION OF REVIEWED BY: _wufM m.__,_/ -
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DatM "HILTI" DRILLED-IN '
BOLTS
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IUGC0 QA / Date APPROVED BY: / v $[ /[/4" CONSTRUCTION PROJECT MGR Date o.1 TABLE OF CONTENTS
1.0 REFERENCES
2.0 CENERAL 2.1 PURPOSE ,
2.2 SCOPE 2.3 RESPONSIBILITY '
2.4 DEFINITIONS
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- BE Uw 3.0 PROCEDURE 3.1 INSTALLATION 3.1.1 Locating Bolts 3.1.2 Drilling Holes an wg EEm s 3.1.3 Marking Bolts 3.1.4 Setting Bolts 3.1.5 Repair of Broken Concrete and Abandoned Holes 3.1.6 Modification 3.1.7 Rework of Bolts in 2-inch Concrete Toppine Areas 3.2 INSPECTION 0.11 ATTACHMENTS No. 1 Minimum Spacing Between Hilti Expansion Bolts No. 2 Minimum Bolt Clearances No. 3 Minimum Clearances to Embedded Plates l, No. 4 Length Identification System
1.0 REFERENCES
1.1 B&R Construction Procedure 35-1195-CCP-12 Concrete Patching, Finishing and Preparation of Construction Joints" 1.2 IM-13966, "Hilti Kwik-Bolt Testing Program".
1.3 TUF-4593, (May 22,1978) 1.4 B&R Quality Assurance Procedure CP-QAP-16. l, " Control of Nonconforming Items".
F01A-85-59 8606020169 860528
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t 0J JOB 35-1195 COMANCHE PEAK STEAM ELECTRIC STATION Construction Procedure DOCUMENT CHANGE NOTICE NUMBER 1 Notice applicable to Construction Procedure No. 35-1195- CEI 20 Rev. 9 .
This change will be incorporated in the next revision of the procedure.
Change the procedure as follows:
Please replace the following with the attached:
page 3 of 12.
Reviewed by:
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$ctT;inator sf-Z-M Date
.th / WrN' .PZN Brown & Roo H uility Assurance Date k
Approved by:
ks 6+ hew TUGC0 Quality Assurance sisn-
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[ h/s, <v 2- 4".9 $ 03/06/84 Construct'i6n Project Manager Date Effective Date
( 3RO'dN & RCOT, INC. INSTRUCTION REVISION EFFECTIVE CATE PAGc, CPSEs NUMB ER JOB 35-1195 CEI-20 9 12/16/83 2 of 12 1.5 TUSI Procedure No. CPP-EP-1, " Procedure for Preparation of Design Changes".
1.5 35-1195-IEI-13, B&R Instruction " Calibration of Micrometer Torque Wrenches".
1.7 CP-QP-11.2, TUGC0 Procedure, " Surveillance and Inspection of Concrete Anchor Bolt Installations".
1.8 QI-QP-11.2-1 TUGC0 Instruction, " Concrete Anchor Bolt Installation".
1.9 QI-QP-11.2-3, TUCCO Instruction, " Torquing of Concrete Anchor Bolts".
1.10 QI-QP-11.2-4, TUGC0 Instruction, " Inspection of "Hilti" Super Kwik Bolts".
2.0 CENERAL 2.1 PURPOSE 2.1.1 The purpose of this instruction is to describe the methods to be followed in the fic1d installation of Hilti drilled-in expansion anchors.
2.2 SCOPE 2.2.1 This instruction covers the location, repair and preparation of ex-pansion bolt holes, installation of the expansion bolts, and the per-manent marking of bolts for identification both prior to and af ter their installation. The provisions of this instruction apply to both Hilti Kwik-Bolts and Hilti Super Kwik-Bolts that are used for installation of safety related equipment, and for the installation of non-safety related equipment located in safety related structures.
Deviations from this instruction are permitted provided they are properly approved by the Engineer. Post nut caps may not be substi-tuted for hex head nuts without prior Engineering approval.
2.3 RESPONSIBILITY 2.3.1 Establishment of control points and lines for use in layout of bolt locations shall be the responsibility of the B&R Field Engi-neering Superintendent. Determination and marking of bolt hole location shall be performed by the craf t which preparer the holes and installs the bolts; and the superintendent of that craf t shall be responsible for this layout work and for preparation of holes and bolt ins talla tion.
r-BROWN & ROOT, INC. INSTRUCTION EFFECTIVE NUMBER REVISION DATE PAGE CPSES
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CEI-20 9 12/16/83 3 of 12 2.4 DEFINITIONS 2.4.1 " Drilled-in Expansion Bolts" are bolts having expansion wedges so arranged that, when placed in a drilled hole and the nut tightened, the wedges are expanded and the bolt is securely anchored, all as manufactured by Hilti Fastening Systems, Inc.
2.4.2 "Hilti" is Hitti Fastening Systems, Inc., supplier of the expansion bolts.
2.4.3 " Bolt Length" is the total overall length of the bolt. This*is the length dimension shown in the Bill of Material on the appro-priate drawings.
2.4.4 " Setting" a bolt means positioning the bolt and tigntening the nut or post nut to the extent required to complete the expansion of the wedges.
2.4.5 "Embedment Length" is the length of bolt extending below the sur-face of the 4000 psi (28-day strength) structural concrete prior to setting (tightening). Unless otherwise specified on the design drawings, the minimum embedment length shall be as follows and in no case shall the minimum embedment length be less than as follows:
BOLT DIAMETER MINIMUM EMBEDMENT Kwik-Bolts Super Kwik-Bolts 1/4 1 1/8 --
3/8 1 5/8 --
1/2 2 1/4 3 1/4 5/8 2 3/4 --
3/4 3 1/4 --
1 4 1/2 6 1/2 1 1/4 5 1/2 8 1/8 Dimensions are in inches, they are according to recommendations by Hitti and correspond to the minimums shown in Abbot A. Hanks, Inc. Test Report No. 8783a on Kwik-3oits and Test Report No. 8786 on Super Kwik-Bolts, as published in Hilti " Architects and Engi-neers Anchor and Fastener Design Manual.
CEI 20 Rev 9 DCN si p_ 03/06/84 Sheet 2 o" 2
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CPSES INSTRUCTION NUMBER RE7ISION EFFEC]VE CAic ,, G ,,
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' JOB 35-1195 CEI-20 9 12/16/83 4 of 12 The above minimum embedment lengths are into structural concrete.
On floors where 2-inch thick concrete topping (and thicker on roof slabs bui't up to slope to drain) has been placed separately, bolts shall be of sufficient length to provide embedment length or overall length at least equal to the thickness of the topping in addition to the length shown on the drawings. For floor mounted pipe supports only, the engineer shall evaluate and approve the support for sufficient embedment length on a case-by-case basis. The areas where this topping occurs are shown on the following drawings:
Drawing No. Sheet No. Building FSC-00421 1 Fuel FSC-00421 2 Fuel FSC-00422 1 Reactor #1 FSC-00422 2 Reactor #1 FSC-00422 3 Reactor #1 FSC-00422 4 Reactor #1 FSC-00422 5 Reactor #1 FSC-00423 1 Auxiliary FSC-00423 2 Auxiliary FS C-00423 3 Auxiliary FSC-00423 4 Auxiliary FSC-00423 5 Auxiliary FSC-00423 6 Auxiliary FS C-004 . 3 7 Auxiliary FSC-00423 8 Auxiliary FS C-00423 9 Auxiliary Safeguard #1 FSC-00424 1 FSC-00424 2 Safeguard #1 FSC-00424 3 Safeguard #1
- FS C-00424 4 Safeguard #1 FSC-00424 5 Safeguard #1 FSC-00424 6 Safeguard #1 FSC-00426 1 Service Water Intake FSC-00425 1 Safeguard #2 FSC-00425 2 Safeguard #2 FS C-00425 -
3 Safeguard v2 3.0 PROCEDURE 3.1 INSTALLATION e
3.1.1 Locating Bolts 3.1.1.1 As required by authorized engineering documents, bolt locations shall be determined by the installing craf tsmen using the control points and lines established by the Field Engineering Department; and, as
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f'. 3ROWN 1 RCOT, INC. INSTRUCTION NUMBER REVISION E-~ECTIVE CA E PAGE CPSES JOB 35-1195 CEI-20 9 12/16/83 5 of 12 an aid in locations where reinforcing steel integrity is considered to be critical, utilization of reinforcing steel placement drawings and suitable reinforcement detection equipment may be used. The minimum spacing and/or clearance for expansion bolts shall be pro-vided as indicated in Attachments 1, 2 and 3 unless specifically approved otherwise by the Engineer using appropriate design documents.
3.1.2 Drilled Holes 3.1.'.1 2 Expansion bolt holes shall not be drilled into structural reinforcing steel unless approved by the design engineer or his representative.
Holes for the expansion bolts shall be drilled into concrete by the use of suitable power drills using "hilti" carbide masonry bits of the same nominal size as the bolt and which are designed and recom-mended by the Hilti Corp. specifically for this purpose, or an ap-proved equal. The holes shall be drilled to depths at least one-half (h) inch greater than the embedment length of the bolt. This is in order that any accessible / usable abandoned bolt can be cut off and driven deeper into the hole and top covered with grout or other suitable filler to close the hole. Abandoned bolts that are not usable or accessible may be left in place without further re-work or approval.
3.1.2.2 Holes shall normally be drilled as near the perpendicular to the concrete surface as feasible. In no case shall the long axis of installed bolts be more than 6* f rom this perpendicular direction.
Excess dust shosid be cleaned from the hole af ter drilling.
3.1.2.3 Where cutting of structural reinforcing steel is permitted by the Engineer, Drillco water cooled carbide / diamond bits or equal shall be used. Once the structural reinforcing steel is cut, the re-mainder of the hole shall be drilled with a "hilti" carbide masonry bit per 3.1.2.1. Both bits shall be of the same nominal diameter as the bolt to be installed.
3.1.2.4 In limited access areas it may be dif ficult to drill holes for expansion bolts using equipment as required by 3.1.2.1. For this situation, a flexible drive drill with drill press / vacuum base and Drillco water cooled carbide / diamond bit or approved equal may be used. Caution shall be used when drilling to avoid the cutting of structural reinforcing steel. In no case shall structural rein-forcing steel be cut without prior approval of the Engineer.
3.1.3 Marking Bolts 3.1.3.1 The threaded end of bolts shall bear permanent markings which indicate the bolt length.
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SK0WN 1 RCOT, INC. INSTRUCTICN EFFICTIVE CPSES NUMBER RE7ISION CAi: FAGE 408 35-1195 CEI-20 9 12/16/83 6 of 12 3.1.3.2 These markings shall be made by the manufacturer by die-stamping a letter or a number on the top end of the bolt. This stamping shall indicate the bolt length in accordance with the " Length Identifica-tion System" (Attachment 4). Bolts may also be marked en-site by the same system if verified and documented by B&R QC. For Post ,
Nut Series Hilti Bolts, the letter or number designation shall correspond to the overall length of the assembly with the Post ,
Nut Cap completely installed (threads bottomed out) .
3.1.3.3 Hilti Super Kwik Bolts shall be additionally marked with a " star" on the end which will remain exposed upon installation. This marking will be performed by the craf t in a manner which does not obliterate the length marking. The stamp shall be controlled by the cognizant QC Inspector.
3.1.4 Setting Bolts 3.1.4.1 In no case shall bolts be set in concrete having strength less than the 28-day old design strength. Inserting bolts may be accomplished either by use of a mandrel or double nuts. In using double nuts, they shall be placed on the bolt so as to protect the bolt end and threads. The bolt shall be driven into the hole the embedment length by blows on the mandrel or nut. Projection of the bolt should be such that, after final tightening, the end of the bolt is not lower than flush with the top of the nut. Its projection above the top of the nut is not limited although its change in projection during tightening shall be within the limit specified below. The mandrel, if used, is then replaced by a nut, or the top double nut is removed and the bolt is " set". The setting will be accomplished by tightening the nut against the fix-ture being installed. At that time, the nut will be drawn down and the bol'c pulled to set the wedges by the use of a torque wrench, attaining at least the respective final values shown in the following table unless otherwise shown on the drawings. During tightening the nut, the change in bolt projection shall not exceed one nut height unless otherwise approved by the engineer. Where S/8" dia-meter bolts are used in erecting Uni-Strut members for instrument or conduit supports in such a way that the bearing surface under the nut, used with a flat washer, bears against the open side of the Uni-Strut, the nut shall be tightened to 80-foot-pounds torque.
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3ROWN 1 RCOT, UI. INSTRUCTION EFFEC]VE RE7ISION CA4e ,AG r c, CPSES NUMBER JOB 35-1195 CEI-20 9 12/16/83 7 of 12 BOLT SIZE TORQUE (Ft.-Lbs)
(Hilti Kwik or Super Kwik, all embedment depths) 1/4 8 3/8 17 1/2 70 5/8 120 3/4 150 1 230 1 1/4 400 These values were determined by field tests conducted by Hilti at the CPSES site which yielded a minimum static tensil load capacity equal to or greater than 115% of the tensile working loads given in Tables 1 and 2 of Appendix 2 of Specification 2323-SS-30.
The complete report on those tests is filed in the B&R QC Depart-ment. (Ref. CPPA-7240 or B&R IM-13966).
Bolts which cannot be torqued to the above minimum values shall be cut of f, driven deeper into the hole, and patched per Reference 1.1 or shall be removed and replaced in accordance with 3.1.4.2 below.
Torque wrenches used in this operation shall be calibrated and periodically recalibrated in accordance with Engineering Instruction 35-1195-IEI-13, " Calibration of Micrometer Torque Wrenches", Ref-erence 1.6.
3.1.4.1.1 For post nut series Hilti bolts, setting the bolts shall be done in accordance with Section 3.1.4 with the following exceptions applying to Section 3.1.4.1.
Inserting bolts may be accomplished by the use of a post nut, placed on the bolt so as to protect the bolt end and threads.
The bolt shall be driven into the hole the embedment length by blows on the post nut. Projection of the bolt should be such that, after final tightening, the end of the bolt has a minimum thread engagement of 3/16" for 1/4" dia, and 5/16" for 3/8" dia, bolts. The projection should also be limited such that, after final tightening, the threads on the post nut have not bottomed out on the bolt. The por: nut used to insert the bolt should then be remevad ;.d the F 1.t is " set". The setting will be accomplished by tightening a u. post nut against the fixture being installed. At that time, the nut will be drawn down and the bolt pulled to set the wedges by the use of a torque wrench and 3/8" driv. screwdriver adapter attaining
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3ROWN i RCOT, INC. INSTRUCTION EFFECTIVE
,A F G c, CPSES NUMBER R /ISION CATE _
'08 35-1195 CEI-20 9 12/16/83 e of 12 at least the respective final values shown in the above table unless otherwise shown on the drawings. During tightening the pos t nut , the change in bolt projection shall not exceed k" for a 4" dia. and 3/8" for 3/8" dia. bolts, unless otharwise approved by the engineer.
3.1.4.2 Replacement of expansion bolts that slip, loosen, pull out or fail to achieve the specified torque may be accomplished by one of the following methods:
3.1.4.2.1 The bolt shall be removed and replaced with a bolt that has an embed-ment depth increased by at least 4h bolt diameters for Hilti Kwik-Boles and 6h bolt diameters for Hilti Super Kwik-Bolts unless other-wise directed by the Engineer. QC shall be notified prior to com-mencing work.
3.1.4.2.2 The re-installation of an expansion bolt in an empty but " pre-used" hole is acceptable provided the following requirements are met:
- a. The existing hole has not experienced structural damage as may be exhibited if the previous bolt had been displaced through tension or shear causing severe concrete spalling. Severe concrete spalling are depths that exceed the dima.nsions pro-vided in 3.1.5.1 below.
- b. New " Replacement" expansion anchors are at least one diameter size larger.
- c. New embedment depth is equal to or greater than the previous bolt but in no case less than the minimum embedment required per 2.4.5 above based on the " replacement" bolt size.
- d. Bolts that cannot be replaced per the above may be replaced by a bolt meeting the requirements of 3.1.4.2.1 or may be cut of f, driven into the hole and patched per Reference 1.1.
- e. QC shall be notified prior to commencing work and after the bolt has been removed so that QC may inspect the " pre-used" hole in accordance with the applicable QC procedures.
- f. QC shall be notified prior to commencing work.
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3ROWN & RCGT, INC. INSTRUCTION EFFECTIVE NUMBER REVISION CATE PAGE CPSES JOB 35-1195 CEI-20 9 2/16/83 9 of 12 3.1.4.2.3 The re-installation of an expansion bolt in an empty but " pre-used" hole is acceptable provided the following requirements are met,
- a. The bolt being replaced has been removed from the concrete using a Diamond core bit of the same nominal outside diameter as the replacement expansion bolt. The replacement bolt shall be one diameter size larger than the bolt being removed.
- b. The existing hole after bolt removal should not show evidence of structural change as in the form of severe concrete spalling.
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Severe concrete spalling are depths that exceed the dimensions provided in 3.1.5.1 below.
- c. New embedment depth is equal to or greater than the previous bolt but in no case less than the minimum embedment required per 2.4.5 above based on the " replacement" bolt size.
- d. Bolts that cannot be replaced per this method may be replaced by a bolt meeting the requirements of 3.1.4.2.1, 3.1.4.2.2 or may be cut off, driven into the hole and patched per Reference 1.1.
- e. QC shall be notified p,rior to commencing work, and after the bolt has been removed so that QC may inspect the " pre-used" hole in accordance with the applicable QC procedures.
3.1.5 Repair of Broken Concrete and Abandoned Holes 3.1.5.1 Structural concrete that is broken or spalled as a result of bolt installation but is structurally sound shall be cleaned up and may be cosmetically repaired either in accordance with Construction Procedure CCP-12, or by the use of "NUTEC" //11S as manuf actured by and according to the recommendations of Southern Imperial Coating, Inc. Spalling of structural concrete to depths greater than those listed below shall be cause for rejection of the hole and redrilling will be necessary.
Max. Acceptable Hole Size Soall Depth 5/8" and under 1/2" 3/4" to 1 1/4" (incl.) 3/4" Spalling of the 2" topping in areas described in Section 2.4.5 shall be cle toed up and repaired in accordance with Construction Procedure CCP-12 using msterial described in Section 4.1.2.7 of CCP-12. Maximum spali depth is not to exceed depth of topping.
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3ROWN 1 2007, INC. INSTAUCTION EFFEC ~IVE NUMBEp REVISION CATE PAGE CF5Es l
JOB 35-1195 CEI-10 9 12/16/83 10 of 12
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3.1.5.2 Ahandoned holes shall be fillert and patched prior to coating the cencrete. This repair shall be in accordance with provisions of B&R Construction Precedure 35-1195-CCP-12 for f1111ng " Tie Holes" by the (;se of patching mortar prepared as deocribed in paragraph ,
4.1.1.3 of that procedure. However, abandone.d OVERHEAD 'nole6, orginally drilled for Hilti expansiot ogits, wt ich vill be com-pletely covered by t~nc base plates or angles of attacbed fixtures and which are farther than four bolt diametere (center-to-centet) from an active Hilti 'anit, .may be f411ed witti "Silpruf" water-proofing sealant or "CE 1300", both as manuf actdred by General ,
Electric, Inc. ifJles lccated 2( a distance of four bolt d$ametErs and closer, measured center-to-centur, from Filti holts shall be filled and patched according to Procedure 35-1195-CCP-12 described above prior to torquing.
3.1.5.3 Unused Richmond Screw Anchors which have been plugged oy Richmond screw-in plugs may be used for permanent anchorage or;1y af ter specific approval by the Engineer.
3.1.6 Modification 3.1.6.1 fWhen it is necessary, as the result of reinforcing 9 teel interfer-ence or on-site unavailability of correct lenght bolts of for other reason, Hilti bolts may be modified, with propdr QC wit;tessing, on-site shortening, rethreading, and stamping the pew le:;gth designation.
This shall be done only on a case by case basis upon approval of the g
)d[l design engineer responsible for the fixture or item fqvolved and
$ upon completion of appropriate permanent plant docuaientation (i.e.,
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1 DCA, CMC, FSE, Operational Traveler, Design Drawing, r;tc.) by the design engineer. Final bolt length shall be safficient to satisfy ,
the design requirement. l
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3.1.6.2 Substitution of a Hilti bolt of the next larger site is acceptable, provided all spacing and embed =ent requirements are met or exceeded for size Hilti bolt substituted. ,
3.1.7 Rework of Bolts in 2-inch Concrete Topping Areas 3.1.7.1 For areas in which the requirements of Gection 2.4,5 tanho; bc : net, ,
the following action shall be taken:
3.1.7.1.1 Expansion bolts which af te.e setting haya less than belo/ iMicated l embedment length into the structural concrete shall be reworbd by one of the methods provided in section 3.1.4.2 or as follows:
Bolt Type Fabedme tt t Af ter Setting i Kwik-Bolts 3h bolt dianeters l Super Kwik-Bolts 3b bolt diameters j i
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BROWN 1 RCOT, INC. INSTRUCTION EFFEC]'/E NUMBER RE7?SION OAic 4cG, CPSES JOB 35-1195 CEI-20 9 12/16/83 11 of 12
- a. Existing Location
- 1. Bolt removal - The removal of in-place expansion bolts shall be completed with care so as not to damage the enn-crete, thereby impairing its integrity. A hollow core hydraulic ram placed directly over an appropriately sized baseplate which is centered on the bolt may be used to apply direct tension to pull the bolt through the expan-sion wedges. The baseplate should be a inch thick square plate of a minimum of 16 expansion bolt diameters in width, bearing directly against the concrete surface.
- 2. Once the bolt is removed, use a high speed drill and bit to drill through the wedges remaining in the side of the hole. Remove any loose wedges in the hole.
- 3. Using appropriate equipment, re-drill existing expansion bolt hole so that the new embedment depth is a minimum of 4 bolt diameters for Hilti Kwik-Bolts greater than the previous existing embedment depth or to the specified embedment depth, whichever is greater unless otherwise directed by the Engineer by appropriate design documents. '
4 Reinstall the appropriate sized expansion anchor to meet the required embedment length,
- b. Relocation - Abandon existing expansion anchor bolts and re-locate support structure. Abandoned bolts should be cut of f, driven deeper into the hole, and patched per Reference 1.1.
3.1.7.1.2 Expansion bolts which have less than the specified designed embed- ,
ment length into structural concrete but greater than the values indicated above in 3.1.7.1.' shall be evaluated by the responsible design engineer. If found to be acceptable "as-is", appropriate design change documents shall be issued. If found to be unaccep-table, the expansion bolt shall be reworked in accordance with 3.1.7.1.1 a or b.
3.2 INSPECTION i
1.2.1 Inspection of Hilti bolt installation shall be performed in accor-dance with References 1.6, 1.7, 1.8, 1.9, and 1.10 and other appli-cable site QA/QC procedures and instructions.
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PROCEDURE EFFECTfVE l BROWN & ROOT, INC. NUMBER REVISION DATE PAGE CPSES l
JOB 35-1195 CEI-20 9 12/16/83 i 12 of 12 3.2.2 Removal of an inspected Hilti bolt shall be documented on an IRN in accordance with CP-CPM 6.10. Removal and replacement of non-Q Hilti bolts in Catagory I structures shall be documented on an IRN and submitted to QC for subsequent processing.
Note: An IRN is not required if a non-Q Hilti is only going to be removed and not replaced.
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BROWN & ROOT, INC. INSTRUCTION EFFECTIVE l NUMBER REVISION DATE PAGE CPSES JOB 35-1195 CEI-20 9 12/16/83 1 of 1 _ _ _
ATTACHMENT 1
- MINIMUM SPACING BETWEEN HILTI EXPANSION BOLTS FiTiti Bolt CENTER T0 CENTER SPACING T 0:
Size 1/4"Hilti 3/8"Hilti 1/2"Hilti 5/8"Hilti 3/4"Hilti 1"Hilti l 1/4"Hilti 1/4 2 1/2 3 1/8 3 3/4 4 3/8 5 6 1/4 7 1/2 5/16 2 13/16 3 7/16 4 1/16 4 11/16 5 5/16 6 9/16 7 13/16 3/8 3 1/8 3 3/4 4 3/8 5 5 5/8 6 7/8 8 1/8 1/2 3 3/4 4 3/8 5 5 5/8 6 1/4 7 1/2 8 3/4 5/8 4 3/8 5 5 5/8 6 1/4 6 7/8 8 1/8 9 3/8 3/4 5 5 5/8 6 1/4 6 7/8 7 1/2 8 3/4 10 7/8 5 5/3 6 1/4 6 7/8 7 1/2 8'1/8 9 3/8 10 5/8 1 6 1/4 6 7/8 7 1/2 8 1/8 8 3/4 10 11 1/4 1 1/4 7 1/2 8 1/8 8 3/4 9 3/8 10 11 1/4 12 1/2 Dimensions in inches.
- The Minimum spacing outlined in the above chart applies to Hilti bolts detailed on separate adjacent fixtures. Violation of mini-num spacing by the installation of two separate adjacent fixtures will be approved only by issuance of an Engineering Evaluation of 3eparation Violation Fonn by the CPPE design groups (Ref. CP-EP-4.3).
Hilti bolts detailed on an individual fixture drawing may have less than the minimum spacing tabulated above. Such fixtures have been derated by engineering justificatien and are the responsibility of the organization issuing the respective fixture drawing. Install-ation in this case shall proceed in accordance with the fixture drawing.
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BROWN & ROOT, INC. INSTRUCTION EFFECTIVE NUMBER REVISION DATE PAGE CPSES J08 35-1195 12/16/83 1 of 1 CEI-20 9 ATTACHMENT 2 MINIMCM BOLT CLEARANCES *
(INCHES)
MINIMUM OISTANCE TO Richnend Abandoned Hilti 801ts or Hilti Bolt Size Screw Anchors
- Concrete Edge
- Holes and Embedded Anchor 1-i nc h 14-inch Bolts that are Cut Off**
1/4 7 5/8 12 1/4 1 1/4 1/2 3/8 8 1/4 12 7/8 1 7/8 3/4 1/2 8 7/8 13 1/2 2 1/2 1 5/8 9 1/2 14 1/8 3 1/8 1 1/4 3/4 10 1/8 14 3/4 3 3/4 1 1/2 1 11 3/8 16 5 2 1 1/4 12 5/8 17 1/4 6 1/4 2 1/2
- Measured Center to Center of bolts and bolt center to edge of concrete in inches.
- Minimum spacing between holes covered by this column shall be measured center-to-center and based on size of hole being drilled. (e.g., Pilot hole spacing is based on pilot bit size.)
Locations closer than the above distances shall be used only upon approval of the engineer.
Hilti bolts may be installed as close as practical to unused Richmond Screw Anchors which have been plugged (i.e., grouted Richmond Screw-in plug or snap-in plug , etc. ).
Unused Richmond Screw Anchors located nearer to Hilti bolts than the respec-tive distances shown above may be used temporarily for construction purposes when the applied load is: ,
(a) For 1" Richmond Anchors, less than 8,000 pounds minus the actual load supported by the Hilti bolt; or (b) For lh" Richmond Anchors, less than 20,000 pounds minus the actual load supported by the Hilti bolt.
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BROWN & ROOT, INC. INSTRUCTION EFFECTIVE NUMBER REVISION DATE PAGE CPSES JuB 35-1195 12/16/83 1 of 1 CEI-20 9 ATTACHMENT 3 MIN!'4U4 CLEAAANCES TO EMBE00E0 PLATES is Where embedded steel plates are unoccupied by attachments, for a minimum distance of 12 inches on both sides of a proposed Hilti Bolt location as shown below, the center of the bolt may be as close as practical to edge of the plate without damage to plate.
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- 2. Where the embedded steel plates are occupied.by attachments within minimum distances shown above, the minimum clearance to Hilti Anchors shall be as follows:
Nelson Stud Edge of plate Hilti Anchor to Hilti Anchor Size to Hilti Anchor 1/4 5 1/4 3 3/4 3/8 5 7/8 4 3/8 1/2 6 1/2 5 5/8 7 1/8 5 5/9 3/4 7 3/4 6 1/4 1 9 7 1/2 1 1/4 10 1/4 8 3/4 Dimensions are in inches.
Distance measured with reference to center of tolts and studs..
Where location of the nearest Nelson Stud can be determined frem l
the "S" stamps on the embedded steel plate, the minimum center-I to-center clearance to the Hilti Anchor as shown above shall govern. Where location of the nearest Nelson Stud cannot be so determined, the minimum clearance to Edge of Plate" as shown above shall govern.
l 1
,_.._,_,w w .=w _ . - -. .a , - . . e = - .. ..,. _ a . ~ ._ _ s BROWN & ROOT, INC. INSTRUCTION EFFECTIVE NUMBER REVISION CATE PAGE CPSES 08 35-1195 9 12/16/83 1 of 2 CEI-20 ATTACISENT 4 LENGTH IDENTIFICATION SYSTEM Stamp On Lenath of Anchor (Inches),
Anchor From Up to (Not including)
A 1 1/2 2 8 2 2 1/2 C 2 1/2 3 0 3 3 1/2 E 3 1/2 4 F 4 41/2 G 4 1/2 5 H 5 5 1/2 I 5 1/2 '6 J 6 6 1/2 K 6 1/2 7 L 7 7 1/2 M 7 1/2 8 N 8 8 1/2 0 8 1/2 9 P 9 91/2 Q
9 1/2 10 R 10 11 S 11 12 T 12 13 0 13 14 V 14 15 W 15 16 X 16 17 Y 17 18 Z 18 19 4
L i ._ ._ - . . _ .
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-. =- -.
- . - e- -w BROWN & ROOT, INC. INSTRUCTION EFFECTIVE CPSES NUMBER REVISION DATE PAGE JOB 35-1195 12/16/83 CEl-20 9 2 of 2
. A1TACINENT 4 (cont'd)
LENGTil IDENTIFICATION SY3 TEM Stamp On Length of Anchor (Inches)
Anchor From Jp to (Not including)
AA 19 20 88 20 21 CC 21 22 00 22 23 .
EF 23 24 FF I4 25 ,
GG 25 26 HH 26 27 II 27 28 JJ 29
(.. KK 28 29 30 ,
LL 30 31 MM 31 32 NN 32 33 00 33 34 PF 34 35 QQ 35 36 RR 36 37 '
SS 37 38 TT 38 39 UU 39 40
- VV 40 41 l
l l
NOTE: 1. Stamped letters shall be on top (threaded) end of bolt.
- 2. Bolts of 19-inch length and greater may be stamped with number corresponding to the bolt length in inches in the same manner instead of the stamped
! letters as listed above.
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DATE OF CLOSURE iSPECTION REPORT CLOSING NO.
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O LICENSEE'S RESPONSE LETTER NO./DATE TfX-3293 LICENSEE *S RESOLUTION WHMOND SCREN ##fHOff, H//T/-KW/K Hel1~S JHD EUB[DDED PLATES ARE USED RS THE FR/HC/Bfl RNCHOR/Ns MEDIUM.
BETWEEN CONCRETE SURFACET /HD COMfDNENT SUPMRTS AT EM/ A EEAX. INSTALLATION REQUIREMENT 5 ESTABUSHED /A/ M/D-/97T D/D NOT
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D SPEGFICATIDH BY 678BS+ f//L (2323-SS-30) N///CH ALSO ADD I'
THE SPACING CR/TER/A AND /7#D T/EM BDI// /N EOMPI/9EEE.
DESCREPAN!Y REP 6R75 SHGDING THAT 0011/77 HME REVIE9ED WNIEDL IS INCPECT/NG THE SPAC/NG OF THE ANr#DRS.
BUILDING SURVEY : I HME REYlEWED INE PROCEDMRE FOR CURVEYING SPAC/DG BE7WEEA/
THE BullDINGC FOR JMD CORREC77EG /MPROPER PERSON (S) CONTACTED / TITLE: 3 C S(DTT - OA ST8(('
PRMIN PATEL ^ FSEG SUPERVISOR CP-EP-9,3 PEV 3 DOCUMENTS REVIEWED.(REVISION): PROCEDURES :
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NRC INSPECTOR DATE REVIEWER Sheet / of 1
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CON 11riUAT10N SHEET .
COMANCHE PEAK OPEN ISSUE INSPECTIO DATA SHEET NRC TRACKING NO.00-005 nernsrE'S 2ESOLUT/DN (MMT/NUED)' VARIOUS ANCHOR 77 PES, ASSl#NHC F_lllLJAAD_DEVEIDPMENT OM THE CONCEETE ANCHORS. THE /NETAllAT/OH RE00IECHENTS WEXE 70l' SED IN.IJTE /979 TO INCORPORATE PEOPER SEqC]NG. AS A RESlHT Of T/E PEV/S/ON, SOME Of THE /NSTallED FIX11/KES MEET /NC THE /N/77Al S'EPARAT/6M CRITEP/A BECOME NON-CDMPHANT.
THE IICENCEE ~REV/ SED THE INSTallATEN E 7ED(' DHRE Y 70 P PRDPER SEPARA7/AM l'F/TER/A FDP THE VAP/DUS ANCHOR T1 PES AND san.
00AllD' CDNTED1 ACTIV/T/ES INCLHDE VERIFIrA7 ION OF THE MINIMUM SPKING REDlHREMENTS.
A SURYE7 0F All BullD/NG AREAS WAS PERFORMED TO /DEDT/f7 SUPPOR73 LDHICH VIOLATED T/E FEV/ SED SEPARAT/OM CP/TEPIA. THE RES/2iT5 IDERE FMRNISHED TD ENC /NEEP/K TD BE EValMATED ON A CASE - By- ('ASE BASIS.
R GENERIC PROJECT TROCEDMRE /dAS DEVEl0 PED AND /SSHED TD ESTABl/SH EDNS/STANT METHODE FDR THE EValHAT/DN O/~ SEB1 RAT /dM J0MRTIDNS.
REsuG5 0F NRC FouadHP INSPECTION (COUT/AINED)! HilTl BOLTS AND Rl(HMDND CCREld ANCHORC (35-Il95-CEI-26) AND THE //ST OF NON-COh76HMING-SUPMRTS IDEUTIFIED (CPP 27Y AND CPP198). I Al.56 FEV/EblED TPE ACTION TMD/ DN EKH DESCREPAN(7 (CPP SI50). E 270T- C# erred CDMPONENT MODIFICAT/OD CARDf (CMD) PDR SEVERAl NON-(ONFORMIM SilPPORTS AS TD THE M170M TAFEN , IE REldDRM , MODIF7, RE-ANelIZE E'TC. I CAD F/ND ND INCDNSISTAMCIES OR FROBLEMS IN WHAT MS DONE.
Sheet 1 of 3
CONTINUA 710ti SHEET .
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THE 'PROCEDHRE COUTAINS /7VE NETHDD5 FDR EVALUATION. METH6D5
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All OF THESE' 70/E75 HAVE 274/ RESOLVED 77) MY SA175 FACT /dN DY THE //CENSEE AND Tf/5 DEFIr/EHCY CAN BE ClbSED DDCUMENTS REVIEldED (CONTINilED3 '
SPECIFICATION : 2323- SS- 30 PEV I MEMORANDA : CPP 299 CPP 290 CCHPbNEAIT MDDIFirATIDN CARDE :
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UNITED STATES OF AMERICA
, , NUCLEAR REGULATORY COMMISS)M FM 16 A10:07 i
)@Rl9 @ Ii.. Before Administra'tive Judges:
I 12 0FFI;.2 af h.d e.o-Peter B. Bloch, Chainnan00C:4ETinG & SE?vi. -
3 " C" Dr. Kenneth A. McCollom Dr. Walter H. Jordan Docket Nos. 50-445 In the Matter of 50-446 TEXAS UTILITIES ELECTRIC COMPANY (Application for
. OperatingLicense)
(Comanche Peak Steam Electric Station, Units 1 and 2) . March 15, 1984
. MEMORANDUM (Clarification of Open Issues)
This opinion is issued, at the request of all the parties, for.the
' ~
purpose of clarifying the issues that are open in this proceeding.1 For the most part, these matters arise' from our prior decisions, LBP-83-69, 18 NRC (October 25, 1983); LBP 83-60, 18 NRC 672 (1983),
and LBP 83-43, 18 NRC 122 (1983). Because we chose to issue a Proposed '
Decision, followed by a decision on the objections filed by the parties, followed by a further decision on a motion for reconsideration, the l
1 See Applicants' Identification of Issues and Proposal to Establish '
Hearing Schedule, December 3, 1983 (Applicants' Identification);
CASE's Response to Applicants' Identification of Issues and Proposal to Establish Hearing Schedule, December 23,1983 (CASE's Motion); NRC Staff Response to Applicants' Identification of Issues and Proposal to Establish Hearing Schedule, December 23, 1983 (First Staff Response); CASE's Clarification of Issues in 12/23/83
- Pleading (CASE's Clarification); Applicants' Reply to CASE's -
l Identification NRC of Issues, Staff Response January to CASE's )30,198423, (1 December (Applicants' 1983 ResponseReply);
to and i
Applicants' Identification of Issues, and (2) January 16, 1984 Clarification of Issues in 12/23/83 Pleading, February 2, 1984 l
(StaffResponse).
F01A-8b-os O nt .
$/9 ,7 f-
Open Issues: 2 parties have sought our assistance in simplifying the accumulated effect of our orders.
To some extent, we have dealt with concerns of the parties in prior j scheduling decisions or memoranda.2 We also have issued some individual
! memoranda declaring that carticular issues are part of this case.3 This decision does not rehash nor modify those prior matters. Furthermore,
~
nothing in this decision is intended to restrict the parties in filing findings concerning matters that were litigate'd with respect to the CAT Team's findings. L'astly, nothing in this decision affects the scope of the issues on design quality assurance as laid out in our prior decisions.
I. A General Issue Underlying the parties' request for us to identify the open issues is a fear, shared by the Board, that litigation of the quality assurance program of the Comanche Peak Plant may mushroom beyond the limited t
capacities of the parties and the Board. Part of the reason for this 2 Memorandum and Order (Scheduling Matters), December 28, 1983; Memorandum and Order (Additional Scheduling Order), January 4, 1984.
3 Partial Initial Decision (A-500 Steel), LBP 83-63, 18 NRC ,
October 6,1983; Memorandum (Records Retrieval), LBP-84-8,19 NRC
, January 30, 1984; Memorandum (Adequacy of Record: Deleval IResel Generators), January 31,1984 (unpublished); Memorandum and Order (Site-Visit Discovery), February 6, 1984 (unpublished);
Memorandum (Brandt Interpretation of Stiner Testimony), February 10, 1984 (unpublished).
Open Issues: 3 feeling is that we have already completed hearings on many issues that have been left open after the Board has deliberated on them. This leads to a feeling of lack of progress and frustration, shared by all.
The way to undo these fears lies primarily within the capability of the Texas Utilities Electric Company, g al. (Applicants), who must be sufficiently thorough to demonstrate the adequacy of their plant. At this point in our proceeding, each issue heard must be heard to its conclusion.4 If Applicant is thorough and the facts in its favor, it will prevail. If Applicant is not thorough or the facts unfavorable, those facts will be found against it and weighed in the balance.
On the part of Citizens for Sound Energy (CASE), we urge increased paring of arguments so that its efforts will be focused on matters it considers truly important. Clearly, there are many of those issues.
However, if CASE diverts this Board's attention to less important issues, it will squander its own resources and distract the Board from the important safety issues with which CASE is most concerned.
I Our caution of thoroughness also applies to the Staff of the Nuclear Regulatory Comission (Staff). Thorough Staff review prior to each hearing session will contribute to the adequacy of our record.
Careful, objective analysis by the Staff is an essential ingredient if these proceedings are to protect public safety.
4 It is unclear whether the allegation of intimidation of Ms. Darlene Stiner is part of the scheduled hearing on welding. Despite the (Footnote Continued) 1 e
d
Open Issues: 4 2 J
CYGt[A Services, which is not involved in the aspects of the proceedings c6Vered in this Order, also can contribute to the productiveness of our efforts. It should be prepared to explain its findings in clear English, with diagrams and tables where 'necessary for the understanding of the Board. It should be thorough and careful. It should disclose both its conclusions and its uncertainties. In each instance where CASE has raised a question, it should . indicate both the s
basis for its original conclusion and the basis for its current view on whether CASE's argument is correct.6 ,
Before these hearings are concluded, the parties and the Board will face their hardest task: assembling the kaleidoscope of facts into ,
meaningful overall conclusions about the safety of the physica-1 plant and the adequacy of management of the design and construction process.
(Footnote Continued) .
fact that the issue may be interwoven with other welding issues, it is the Board's understanding that the parties do not intend to I litigate that issue in the upcoming hearing session.
For 5 Tr. 9806/13-9807/12; Tr. 9837/4-9; see also Tr. 9794/6-17.
example, merely stating that ~a matter was not considered because it was resolved by the SIT Team would not explain to the Board whether CYGNA currently believes that the SIT Team's conclusion was correct or whether CYGNA has a basis for that belief. This is particularly important with respect to SIT findings already rejected by this Board.
6 We are concerned that whenever CYGNA relies on industry practice it be able to specify the scope of that practice. It also should be able to obtain and review the engineering analysis that supports the alleged practice. Then, and only then, will the Board know i
I whether the practice comports with the applicable regulations and Code sections.
l l
i
- i Open Issues: 5 Although 'we are litigating many subissues, that should not obscure the overall licensing concerns from view. Our clarification of the subissues does not remove these overall concerns from the proceeding, and we foresee the possibility that some evidentiary hearing sessions will be needed to resolve these more global issues.
Let us also caution the parties that should important new safety concerns or allegations, relevant to this contention, come to light, they will be admitted for consideration by thi.s Board. Furthermore, the trial of some isses may reveal interrelationships among issues or may give rise to new issues, and those implications may require exploration.
Given the large number of issues left for trial, we urge the parties to consider submitting some of the open issues to this Board on written pleadings. For example, if Applicants file a pleading on A500 Steel, it may be that the . parties would be able to stipulate that
~
responsive affidavits will complete the record on that pleading.
However, if the parties are unable to reach such a stipulation--
particularly with respect to matters that were already part of a hearing
! and with which CASE's witnesses have a good faith disagreement, it appears obvious that any of the parties would have a right to a hearing on those issues.
Lastly, we urge active consultation among the parties on technical l
issues. Interaction between CYGNA and the parties may occur providing i
l Open Issues: 6 7
that each of the parties is given a fair opportunity to be present and that meeting notes are kept and retained. We are hopeful that stipulations may succeed in narrowing some of the technical issues l
before trial. ,
II. Specific Issues A. Rock Overbreak
.There is no longer any issue left concerning what occurred. The possible significance of management's failure to implement quality assurance procedures for excavation activities will be considered after the record on quality assurance is closed.
B. Polar Crane Shim Applicants must satisfy the Board's request that they supply CASE with information about the evaluation of shims with clipped fingers.
Since we requested that this information be supplied to CASE on July 29, 1983, Applicants also should be sure to explain their tardiness in responding to the Board's request. Whether this issue will be set for a hearing will depend on whether CASE presents the Board with a statement of genuine issues of fact, supported by- an appropriate affidavit, concerning the adequacy of Applicants' filing. ,
7 Since Applicant and Staff apparently have felt that it was acceptable for two-party technical meetings to take place between (Footnote Continued)
.- ) .
Open Issues: 7 C. Protective Coatings Documentation Deficiencies CASE alleges that this Board's findings on protective coatings documentation deficiencies were incorrect. However, it does not supply any evidence with which we could draw this conclusion. Hence, this is not an open issue. _
D. Intimidation in the Protective Coatings Area This is clearly an open issue both with respect to 'the William Dunham allegations *and to the J.J. Lipinsky memorandum allegations.
Because this subject is being investigated by the Office of I Investigations, that aspect of the issue is deferred. Region IV ~also is pursuing this matter and is expected to issue its report in April 1984.
E. Protective Coatings Technical Issues The parties are agreed that technical issues concerning near white I blast, maximum roughness and Westinghouse coatings are open issues. .
However, we closed the issue concerning an allegation that any paint that passed an adhesion test would be acceptable and we do not agree I with CASE that our Memorandum (Procedure Concerning Quality Assurance),
l October 25,1983 (unpublished) at 2, stands for the proposition that .the technical aspects of the adhesion test issue are still open. We note, (Footnote Continued)
^
Cygna and the Applicants, without any invitation to the public to be present, it may be that they would now waive their right to be present at meetings between Cygna and CASE.
o
Open Issues: 8 however, that Board Notification 84-015, January 23, 1984, is relevant to this open issue. ,
F. Dismissal of Robert Hamilton This issue has been decided. Its significance, in context, may still be litigated after all the evidence on intimidation has been heard.
G. Favorability of Preliminary Findings on Protective Coatings 8
Pursuant to CASE's request Applicants should promptly, and without undue delay, provide to CASE the evidence.on which it relied when it stated that the preliminary results of its thorough paint reinspection program, as of February 25, 1983, were favorable. The accuracy of this representation to the Board is an open issue.
H. Inadequate Disposition of Paint Defect Repairs With the exception of the issue of Kelley heaters, which we have closed, the-issue of inadequate repairs is open.9 O
CASE's Motion at 12.
9 See Staff Response at 8.
Open Issues: 9 I. Undocumented Removal of Cable Trays This is an open issue, arising from the CAT Report hearings. It will be addressed by the Staff in its final walkdown reinspection ,
I 10 program.
J. Termination of Henry Stiner
~
This issue is open.11 If CASE seeks subpoenas to pursue this matter it is not barred from obtaining them.* It must apply for them within five weeks "from the date of issuance of this decision. We are hopeful that this open issue also will be addressed by.the Office of Investigations.
K. Welding Issues We have already begun hearings concerning welding issues and the l
Board has issued decisions on relevance in the course of the He'aring.
i l Some of these issues are open.
) L. Torque Seal We agree with the Staff that this matter has been closed based on the affidavit of Mr. Ronald Tolson.12 We have no basis for reversing 1
10 Staff's Response at 8.
11 See Staff Response at 9.
- Staff Response
- at 10 a.
l
j I
e Open Issues: 10 our decision.
M. Una~cceptable Gap in Support We agree with the Staff that this matter has been closed based on the affidavit of Mr. C. T. Brandt.13 There is no basis for reversing our decision.
N. Liquid Penetrant Testing of Fuel Pool Liner We agree with the Staff that this matter has been closed based on the affidavit of Mr. Ronald G. Tolson.14 An unsworn, unparticularized statement that "Mrs. Stiner still does not agree with the Board's assessment. . . ." does not provide a basis for reopening this matter.15 O. Ineffective Action on Pipe Hanger This matter has been closed.16 ,
P. Traceability of Materials With respect to this issue, which was closed, CASE refers to a i previously submitted affidavit by Stan Miles, stating that a " popular 13 Staff's Re ponse at 11.
r Staff 's ~ Response at 11.
15 CASE's Motion at 16.
16 Staff Response at 12; CASE's Motion at 16.
L i
- _ _ _ , . - _ - . , e - , - . . _ - . %
- --- ,,. n_
)-
Open Issues: 11 trend at Comanche Peak was to classify safety related ~ structures to non-safety related structures [and] . . . ct a later date, they would again reverse the classification. . . . This latter charge, of reversing the classification, is a serious one. However, it is not accompanied by any particulars that would permit verification by this Board. CASE may, within five weeks, file a more particularized affidavit or may propose limited . discovery for the purpose of particularizing this overly vague charge. The proposed discovery must be reasonably designed to discover whether this charge is true. In addition, Mr. Tolson and Mr. Brandt shall file affidavits on reverse classification practices with two weeks, stating whether the- alleged practice has ever occurred.17 There is no issue concerning the derating of the polar crane since there is no reason to believe that a safety issue is involved.
Q. Heat Input for Welding This subject has been discussed et the public hearing on welding and the Board has made appropriate rulings.
~
17 We note that Applicant's Reply responded to the polar crane '
allegation but not to this one.
Open Issues: 12 R. Unqualified QA/QC Supervisory personnel -
The matter of the qualifications of quality assurance supervisory personnel was raised in this litigation, including within the context of the CAT Report, but not decided.18 In particular, Mrs. Stiner alleged that she was not qualified for the quality assurance position she held.
In these two respects (CAT and Mrs. Stiner) this issue is open, but there is no other evidence in the record concerning this allegation. We are not aware of whether or not the Staff has closed this item arising
, from the CAT Report. If the Staff issues a further report, it may be subject to litigation.
S. QC Surveillance of Chicago Bridge and Iron Although Mr. Atchison's specific allegations on Chicago Bridge and Iron supports were closed, based on the adequacy of follow-up inspection efforts, Inspection Report 82-25/82-13 raises questions concerning the seriousness of Applicants' oversight of CB&I's performance. Although 19 Applicants undoubtedly have taken corrective actions , this issue should be heard because of its possible bearing on the adequacy of the overall' quality assurance program at Comanche Peak. Hence, the implications of the Inspection Report are open issues.
18 LBP 83-43 at 144. All items litigated in the CAT Report are open unless specifically closed in this memorandum.
i 19 Applicants' Reply at 16.
.,y_ , . - . - - . - . - -m- - , - , . r,
5 Open Issues: 13 -
~
'T. NPSI's Adequacy to Fabricate Pipe Restraints Although the specific questions raised by Mr. Atchison have been )
resolved by the Board, the adequacy of Applicants' monitoring of NPSI
~ and the adequacy of one NPSI pipe whip restraint have been questioned by Inspection Report 82-22. Furthennore, Region IV has not yet completed its inspection of NPSI. Hence, the matters raised by' Inspection Report 82-22 are proper for litigation. In addition, the Region IV Report is Corrective action taken by likely to be proper for litigation.
Applicants may be considered in mitigation but does not avert the need
'for considering the significance of the alleged deficiencies.
U. Uncertified Employee Perfonning Liquid Penetrant Testing This issue was closed based on testimony by Mr. Thomas Brandt.
There is no adequate reason for reopening it.
V. Intimidation of QC Inspectors This issue is open.20 It relates to the extent of management's comitment to its QA program and to whether there has been a practice of discouraging the report of nonconfonning conditions. Because it relates l
to an allegation of a " practice" it is not confined to specific l
20 The only testimony of undue pressure on craftspeople appears to be from the Stiners. Except for that testimony, the issue with respect to the craft is not currently open, absent new developments l in connections with the ongoing investigations of quality assurance l practices.
\
_ - __ M i
Open Issues: 14 previously-known ,subissues. When significant new events arise, they are When the Office of Investigations within the ambit of this issue.
completes its reports, findings relevant to this issue will
. automatically be subject to litigation.
The issue of intimidation may be subject to an arbitrary cut-off .
date on motion of a party, subject to extension for good caure. The effect of such a cut-off would be to limit the time period as to which intimidation effects may be alleged for the p'urpose of trial; however,
- the outcome of tfie trial may affect the validity of continuing to i
enforce the cut-off. For example, if evidence of substantial intimidation is adduced, then either: (1) the case for impermissible f
intimidation may have been established, or (2) there may be a need for extending the cut-off. On the other hand, if there is insufficient evidence to demonstrate substantial intimidation, then there may be no need to extend the cut-off unless substantial new evidence is fiTed.
The purpose of such a cut-off is to avoid unduly prejudicing the plant's
- actual start-up date, whatever that may reasonably be expected to be, so that there will not be a substantial penalty unless there is a .
substantial' reason.
CASE enjoys current discovery rights with respect to this issue.
It should attempt, within its limited resources, to exercise those rights in a timely fashion rather than awaiting the termination of OI's work. Additional discovery may be appropriate later. But what is available now should be sought now.
4
_ . , . _ . ~e - _ , _
,, .% , . . . _ _ - _ . . . - , . _ - - , - - _ m _ _ _ _ _ _ _ _ . _ _ _ _ -
. . Op:n Issues; 15 -i
.W. Messerly Allegations -
We have been sufficiently concsrned with the allegations of Mr.
Robert Messerly to: (1) have suggested to the Office of Investigation, during the in camera session held with it by the Board, that it consider interviewing some witnesses named by Mr. Messerly but no longer working for Applicants, and (2) have authorized on-site discovery that could pennit CASE to demonstrate unsatisfactory construction activities on
. site. However (as we have previously intimated), we were not ,
sufficiently impressed by Mr. Messerly's affidavit to consider ordering ;
destructive examination of supports. .
At the present time, CASE has not indicated any specific way in which the Staff's already published inspection of this matter is ,
deficient. It also has indicated that it will not undertake to discovery provided to it by Board order.21 Hence, we do not consider 22 to be open.
any other Messerly matters P
X. Component Modification Cards l
This is an open matter from the CAT phase of the proceeding.
l Since the CAT investigation was a " slice" in time, our record is not yet l
21 Telephone status report requested from Mrs. Ellis by' the Board, March 15, 1984 at 10:35 am.
22 We do not include Mr. Messerly's allegation of intimidation within l the phrase "Messerly matters." The intimidation allegations may be
! litigated.
~
l
. Open Issues: 16 i
adequate with respect to this matter.
Y. Torquing pb The torquing of A-490 bolts was closed based on the testimony of Mr. Brandt. There is no reason' to reopen this issue. ,
Z. Weld Quenching .
. This iss'ue was resolved based on testimony by Mr. Brandt. There is no reason to reopen this issue. .
AA. Nurber of Inspectors This matter eas addressed in the CAT hqarings ,but is othenvise ,
closed. Staff follos-up could result in further consideration for this matter.
BB. Cold Springing of Pipe :
We t:losed this issue and see no reason to reopen it.
1 CC. Operating Quality Assurance Program :
i
~
This issue was closed. The matter CASE raises, regarding the possible interrelationship between this issue and others, does not require further litigation of this issue. The issue stays closed.
l t i
k l l l
_- ~ . , . ., . . ~ . . , , , _ . , . . _ , . _ _, __ _ _ _
$2 I
Open Issues: 17 DD. Separate Licensing Hearings for Unit 2 CASE argues that a possible implication of the evidence in this ]
case may be that there should be separate licensing hearings for unit 2, t
It specifically references intimidation issues as likely to reflect on )
the need for separate licensing.
However, we consider this to be more in the nature of an anticipated remedy, related to other issues, than to be an independent issue. CASE will not be precluded from making this argument, based on 1
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evidence adduced with respect to other issues. However, this does not 4
appear to be an independent issue requiring trial.
EE. Reactor Yessel Mirror Shield The. Board does not at this time regard its inquiry about the
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reactor vessel mirror shield to have created an issue in this case.
However, we do not understand yhy the staff has taken so long to clarify the ambiguous wording we found (and imediately asked about) in l
Inspection Report 83-34/83-18 (September 12,1983). Prior to licensing, we will review staff's response (or, in the absence of a timely respons'.:, applicant's evidence on this subject) to our question and will determine whether or not additional evidence or a trial on this issue is necessary for the adequacy of our record on quality assurance.
FF. Computerization of Non-Conformance Reports This subject was treated in our previous order, LBP 84-8. Because Applicant's response is likely to be complex and to involve evidence of
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Open Issues: 18 how the use of inspection reports (irs) actu' ally works at the plant, we consider it likely that this issue will need to be scheduled for ,
hearing.23 Depending on the thoroienes's and persuasiveness of the response, CASE may be regired to indicate what genuine issues require litigation. We consider this issue to be likely to require further litigation. ,
GG. Low Worker Morale By previous Board order, this is no longer an independently litigable issue. To the extent that it is directly relevant to charges of intimidation or of lack of comitment to quality assurance, the morale of quality control inspectors will not be excluded from evidence.
This is not, however, an independent issue.
HH. Intimidation of Mrs. Stiner -
This issue may be litigated as part of the intimidation issues in the case. CASE shall file its evidence on this issue within fcur weeks of the issuance of this memorandum.24 23 We consider it likely that problems in generating punchlists for items to be resolved prior to completion are related to problems in tracking nonconfant.ances during construction. .
24 See Applicants' Reply, at 26, n. 16. -
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Open Issues: 19
- II. Staff Walldewn Inspections We have declared these walkdown3 to be relevant evidence concerning the effectiveness of .the quality assurance program.
JJ. .Cygna Report In litigation.
KK. Protective Coatings .
See Paragraph C., above.
Recent Changes in QA/QC Program Lt.
Agreed by all to be litigable.25 MM, Offics of I,nvestigations Reports Admitted as an issue. All agree. ;
i l NN. Site Tour ,
Covered by previous orders.
- 00. A500 Steel -
I See,p. 2, n. 3, above.
25 See CASE's Motion at 31.
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Open Issues: 20 PP. Walsh/Doyle Allegations Now also referred to as Design Decision allegations, since the Board shares many of these concerns. Obviously a continuing, litigable concern.
QQ. Credibility of Witnesses Not a separate issue. Implicit in pending issues.
RR. Tren$sorPatternsofNon-conformingConditions If CASE believes that evidence filed in this case indicates, or 4
will indicate, that there have been undiagnosed trends or patterns of I
non-conforming conditions, it would be permitted to file findings to that effect. Such findings would be relevant to its contentions on the adequacy of the construction quality assurance program.
However, Staff is correct in fearing surprise.26 To avoid surprise and to permit Staff and Applicant to assess and respond to this irgument, CASE should file expected findings of fact on this issue, pursuant to the Board's previous order on expected findings of fact, within five weeks of the issuance of this decision.
26 Staff Response at 30.
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Open Issues: 21 0RDER For all the foregoing reasons and based on consideration of the entire record in this matter, it is this 15th day of March 1984 ORDERED:
The action of the Board in the accompanying memorandum, detemining the issues still pending in this case and setting forth certain ,
obligations of the " parties with respect to pending issues, is effective as an order of the Board.
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FOR THE ATOMIC SAFETY AND LICENSING BOARD
'1 Peter B. Bloch, Chaiman ADMINISTRATIVE JUDGE
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l Walter H. Jor# n ADMINISTRATIVE JUDGE i
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- Xenneth A. McCollom ADMINISTRATIVE JUDGE Bethesda, Maryle.nd t
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COMANCHE PEAK SPECIAL REVIEW TEAM REPORT .
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I Executive Summary and Conclusion II Background III Review Approach IV Review Findings A. - Management Organization B. - Quality Assurance /Quelity Control C. - Equipment Turnover and Preoperational Testing D. - Electrical ^
E. - Design Activities / Control
- F. - Installation of Safety Related Fluid Systems G. - Civil Construction H. - Heating, Ventilation, and Air Conditioning Systems I. - Formal Interviews with QA/QC Personnel (General) s t
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', 3 I. EXECUTIVE
SUMMARY
tion of the applicant's management control of the construction, inspection and test programs, 2) provide an indepth understanding and background information to the NRC new management team estaotished by the Executive Director for Operations memorandum of March 12, 1984, and 3) obtain informa-tion necessary to establish a management plan for resolution of all cuc-standing licensing actions.
The team consisted of eight reviewers, a team leader and team manager. The
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- 3. ,;-- : .' """ T: _ _ . _ ---l- ' "'---'- . The team was assembled in Region II headquarters where it was briefed by NRR, IE and ELO.
The team conducted its review from Anvil 1 ta Acril 13. 1984. The review consisted of an audit of significant elements and processes of the appli-cant's management control in construction, inspections and testing of systems important to safety. These included:
. Component and material receipt inspection and control.
. St-ucture, systems, and component fabrication and installation.
Structure, sy s tem, and component acceptance, and preoperational testing.
Quality assurance and control documentation and procedures to effect items 1 through item 3 above.
The portions of the system evaluated inci" dad ei ni ng ';; : " ---- a n e al supports, instrumentation and control, electrical cable separation and cable tray sGpports, component qualifications, and allegations relating to these areas.
The reviews also included briefings from the Applicants' management and interviews with QA/QC, Document Control, and craft personnel. The total effort was conducted with little or no advance notice of areas, personnel or documentation to be reviewed.
Each member of this team was chosen because he had both many years experi-ence in the discipline he was reviewing, and he had performed evaluations at a wide range of nuclear facilities. The team spent over 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> per-forming this review. The following is a list of the special review team members, their positions, and field of expertise:
Paul Bemis, Section Chief, Management Organization, Qualification and Training Paul Fredrickson, Project Engineer, Quality Assurance / Quality Control, Bill Orders, Senior Resident, Preoperation and Startup Kim VanDoorn, Senior Resident, HVAC and QC inspector interviews e
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Al Ruff, Reactor Inspector, Electrical Louie Jackson, Reactor Inspector, Quality Assurance / Quality Control )
W nston Liu, Reactor Inspector, Design Activities / Control u s The teams findings indicated that the applicants management control over the construction, inspection, and testing programs is generally effective and is receiving proper management attention. The findings identified three potential enforcement actions (See Sections B&E);
requiring Applicants management attention; (josWWWWWBuumb) and seven areas
'where Applicants activities exceeded normal and accepted practice (See Sections A, B & E). The team also found improvements in the relationship between the' current GA/QC management and inspectors which in the cast has caused communication problems (See Section I).
The findings and c r of the design adequacy of the plant.
II. Background On March 17, 1984, the EDO directed NRR to manage all NRC actions leading to licensing decisions for Comanche Peak and Waterford. The purpose is to assure the overall coordination and integration of the outstanding regula-tory actions and achieving their resolution prior to a licensing decision.
This effort is to encompass all licensing, hearing, inspection and allega-tions issues.
Soon thereafter, the newly established Comanche Peak project team found that there was a need to 1) obtain current information relative to the management control of the construction, inspection and test programs and 2) obtain information necessary to establish a management plan for resolution of all outstanding licensing actions. To help achieve this objective expeditiously and objectively it was decided that an unannounced review of Comanche Peak plant was necessary. As a consequence, NRR in coordination with OIE and the Region II and IV Administrators formed a review team. Because of resource limitations in Region IV, the team was staffed with Region II personnel.
4 The team was assembled in Region II Headquarters on April 2, 1984. The team was briefed on significant issues raised as a consequence of the licensing review, the hearing contentions and the allegations. The team leader and the reviewers were not provided with the names of the allegers in order to assure their confidentiality. The team conducted their review from April 3 to April 13, 1984.
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5 III. Review Approach The teams' review approach was to first obtain an understanding of Comanche Peak management and management control systems. This was accomplished by briefing from the Applicants management.
With this understanding, the team reviewers commenced their efforts. These included examination of appropriate documentation, formal and informal interviews of plant personnel, and specific technical allegations related to their areas. The allegations were not reviewed separately but were subsumed in the total review in order to provide further assurance of alleger confidentiality and not compromise any on going or future investigations.
In addition to the review of the Quality Assurance program, from a program-matic point of view, each of the reviewers examined the implementation of the QA/QC program in their individual areas of expertise in an attempt to identify any breakdowns that could exist in a narrow area.
IV Review Findings The team conducted its review of the following areas:
A. - Management Organization B. - Quality Assurance / Quality Control C. - Equipment Turnover and Preoperational Testing D. - Electrical I , 1 - . , , .
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G. - Civil Construction H. - Heating, Ventilation, and Air Conditioning Systems I. - Formal Interviews with QA/QC Personnel The review, findings and conclusions in each of these areas are provided below:
A. Management Organization The construction and operations organization were reviewed to insure a working relationship between the organizations as well as functional relationships within each organization. The qualifications of the individuals in positions of authority were reviewed against regulatory standards and the applicant's commitments. In addition to qualifica-tions, a review was made of the interface between all levels of the command chain.
The limited review revealed that in all areas, individual qualifications appear to meet requirements, the interface between construction and operations appears to be functioning in a workable manner and interface between all levels of the management chain appears to be functioning in an acceptable manner. There appears to have been a communication e
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problem in the onsite QA/QC chain in the past, but according to interviews conducted during this review the problem has and is being corrected.
This review found the management and craft at Comanche Peak appear to be competent and management to possess a positive attitude which is a strength at this project. Management exhibited a sufficient level of consciousness for both safety and employea concerns, These management attitudes were confirmed by the attitudes they manifested in their employees and the attention to detail in the required quality of work.
B. Quality Assurance / Quality Control The following areas were reviewed primarily from a programmatic point of view: nonconformance control; training, audits; records (maintain-ability and retrievability); document control; receipt, storage and handling of materials; and procurement.
Within the areas reviewed, there were several findings identified. The following is a brief description of each according tc category:
- 1. Potential Enforcement Issues.
a) ASME record packages were not being maintained in a fire proof container, b) At least two vendor audits had not been performed within the required time period.
- 2. Weaknesses a) Certain drawing packages issued to the field contained non-applicable DCAs and/or CMCs, which had been deleted by engineering.
b) Many non-ASME Section 3 drawings contained a large number of DCA's and CMC's (over 300 in some cases) outstanding without being incorporated by revision.
- 3. Strengths a) The QA/QC training program is extensive and comprehensive.
b) The use of a recently established computer system drawing control instead of stamped drawings referancing design changes.
c) The vendor witnessing prog.am is extensive in its audits and source inspection of purchased materials I
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Overall the current QA/QC program appears to be functioning satisfactorily. The recent management changes seems to have corrected past ccmmunication problems.
C. Equipment Turnover and Preoperational Testing l
The processes of turnover of safety related equipment from construction '
to startup as well as ore-requisite ana pre-operational tests of the I equipment were reviewed to determine adequacy of: methocology employed )
in tur ;ver of equipment to startup, return equipment to construction ,
for rework, and ultimate release of equipment to operations; technical '
and administrative controls over preoperational testing; and preopera- l tional test procedures, both technical content and administrative control.
This review found the majority of the tests to be performed are retests or reperform's and could be conducted in parallel with the remaining initial test. The performance of the remaining test should not impact an October 1984, fuel load date. In addition, the turnover methodology and control of the preoperational test program appears adequate.
D. Electrical The assessment in this area was to determine acceptability of the safety related electrical equipment installed and inspected in accord-ance with NRC requirement and applicant commitments. A review was made of the overall program to incitje: drawings, procedures, quality control inspections, and records.
The review found that the safety-related electrical equipment is being installed and inspected as required.
E.
This review focused on the following areas: requirements of IEB 79-02; IEB 79-14: Al+
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. The review of this area was directed towards assessing the adequacy of installation of safety related fluid systems used for safe operation and shutdown of the plant. This review contained: first handocuummusung r; e 6, exa.
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Civil Construction Activities G.
Examination of site civil design activities, including design change process, procedures and QA records of completed work activities (such as the SSI dam, cable tray supports and whip and moment restraints),
and procedures and work activities for ongoing work (such as applica-tion of protective coating) was performed.
The limited review found that the applicant was meeting requirements in these areas. Two areas of note: (1) protective coatings and (2) thermo lag, appear to be progressing in a manner such that they will not impact an October fuel load.
H. HVAC This effort followed up on previously identified discrepancies at Comanche peak and other sites which used the HVAC vendor. In all tacas reviewed where discrepancies had been identified the applicant appears to have addressed the problem either through rework or reanalysis. The HVAC system appears to be adequate.
I. Formal Interviews with QA/QC Personnel Formal interviews of five (5) management / supervisory personnel and twenty-eight (28) inspectors were conducted to assist the team in assessing quality of work and management support of quality. It was felt discussions with inspection personnel would give a conservative insight into the quality of site construction.
The major thrust of the interviews was to determine if; (1) the personnel had any plant safety or quality concerns; (2) intimidation was experienced; (3) training was adequate; (4) inspectors could freely talk to NRC; (5) management supported problem identification; (6) was there feedback on identified problem evaluation.
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9 With the exception of two inspectors who were " unsure" due to lack of knowledge, all personnel interviewed felt the plant was being built in a sifety and quality manner. There were some concerns raised which will be forwarded to the Comanch Peak Project Director for evaluation; in some cases, Region IV was already aware of the concerns and performing followup. The major problem in the past appears to have been communication between inspectors and their supervision, but it is apparent that for the past couple of months and presently, this problem is being addressed properly.
In addition to formal interviews, each reviewer performed numerous informal interviews to determine problem areas. The overall conclusion from all interviews was that the Comanche Peak Project is being built safely and with quality.
V. Conclusion The purpose of the special team review has been met in that (1) an assessment of the applicant's current management control of the construction, inspection and test programs has been made; (2) an in depth understanding has been achieved and (3) information has been obtained to establish a management plan for the resolution of all outstanding licensing actions.
With respect to the assessment of the applicant's management control of the construction, inspection and testing programs, the special review g,m 6aci ity.
Further, the review provided a sufficient understanding of these programs and their strength and weakness to assist in the development of the l
" Comanche Peak Plan for the Completion of Outstanding Regulatory Actions."
l This plan was approved for implementation on June 5,1984.
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A. Management Organization
- 1. Entrance Meeting The afternoon of April 3 the special review team arrived onsite unannounced. The team spent the afternoon of April 3 and the morning of April 4th meeting with the applicant's Senior Corporate Management, Site Management, Site QA Management, and Document Control Supervision being briefed on the organization, functions, and location of areas under their control.
- 2. Management Organization The nuclear portion of Texas Utilities Generating Company is organized in the following manner for its senior management:
a) The highest level executive is the President of the company. The President has recently turned over all possible non-nuclear duties to his Executive Vice President-Plant Operations. The President's primary responsibility is to complete the Comanche Peak Steam Electric Station as safely and expeditiously as possible.
b) Reporting directly to the President are the Executive Vice President Engineering and Construction and the Vice President Operations. Even though there are fossil plants presently being built in the system and the licensing organization reports to the Executive V.P. Engineering and Construction he spends between 60-80*4 of his time at the Comanche Peak Site. He has also delegated his non-nuclear responsibilities in an effort to focus on the nuclear station completion. The Vice President-Operations (V.P. OPS.) spends approximately 80". of his available time on site directly observing the operations group preparation to take over the plant upon construction completion. He is also an active participant in construction and startup meetings and the decision making process. A few months ago the V.P.0PS. was moved from his normal reporting path to Executive V.P.-Plant operations, directly reporting to the President.
c) Reporting to the Executive Vice President Engineering and construction is the Vice President Engineering and Construction (V.P.E.&C.). The V.P.E&C. has been located on the Comanche Peak site since 1977 and during the same year he assumed the additional title of Project General Manager for Comanche Peak. In January 1984 he delegated his non-nuclear responsibilities in order to devote his full attention to Comanche Peak completion.
d) The Assistant Project General Manager (APGM) reports to both the V.P.E&C and the V.P.0PS. He reports to the V.P.E&C. in the areas of construction and onsite engineering and to the 'I.P.0PS for startup (S/U). This positicn is where the common tie between e
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2 construction and operations is most decisive. The APGM has been on site since 1977.
e) In addition to the APGM, the V.P.0PS has reporting to him: The manager of Nuclear Operations, who is located at the site, and the Manager of Quality Assurance who is located in the corporate office but has a Quality Assurance / Quality Control Manager on site who is responsible for all QA/QC on site.
The current positive management attitude is a strength exhibited at Comanche Peak from both the operations and the engineering and construction sides of the company. This positive attitude appears to manifests itself in the attitudes of the workers, the training, and in its consciousness for quality.
One additional strength was noted in that the applicant is using operations' maintenance procedures to perform periodic maintenance on equipment in the plant, and the applicant is using full Anti-C dresscut and respirators for the craft (for training) to perform maintenance activities so when the equipment becomes contaminated the workers will be use to the confining clothes and equipment. This practice should significantly reduce exposure and therefore dose received by these individuals after the plant is operational.
- 3. Project Management Meeting Every Saturday morning a project management meeting is held, wherein work activities, progress, startup and test problems, and QA/QC coverage is discussed. This meeting is attended by Senior Corporate Management; including the President of Texas Utilities Generating Company, and the Senior management from construction and operations; it is also attended by the site management of construction and startup.
Several members of the review team attended this meeting on April 7, 1984. The meeting appeared to be well managed, with problem areas being openly discussed (even though senior company management and NRC were in attendance, the dialogue between individual managers and
- upervisors was not toned down). An example of an area of concern which was discussed was the completion of the application of protective coatings in the containment. It was the general consensus that additional manpower was required to complete the work effort. An additional 100 people were authorized with the expectation they would .
be available within one week.
During this meeting it was decided to change the concept that was presently being used for plant completion. The applicant had been using a Building completion methodology, but after consultation and reviews by an acknowledged industry expert is was decided to prioritize systems completion, with buildings to follow, or run in parallel where possible.
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. 3 The highest level of the Company's management in attendance at this meeting allows for immediate decisions to be made for the next weeks prioritics for plant completion. This method of holding project meetings appears to have kept the applicant in position to meet their projected fuel load date.
B. Quality Assurance / Quality Control
- 1. Nonconformance Control
References:
CP-QAP-16.1, R20, Control of Nonconforming Items CP-QP-16.0, R13, Nanconformances CP-QP-16.1, R5, Significant Construction Deficiencies CP-QP-17.0, R3, Corrective Action CP-QP-15.7, R2, Tracking of Audit Reports /Correc-tive Action Reports
- a. General This portion of the review was performed to verify that:
nonconformances are being identified items were considered for reportability to NRC corrective action prevented recurrence the licensee has an adequate trending program
- b. Review Effort The reviewer selected NCRs from various safety related systems to verify the following:
logged numerically for control maintained even when later cancelled considered for reportability to NRC corrective action initiated which prevented recurrence considered in a trending program The following NCRs were reviewed:
C-84-01030 M-83-01162, R2 M-84-00965 M-11678N M-82-01528, R2 M-11660N M-83-01454, R1 M-11675N M-04729, R1 M-11687N M-05689, R0 E-84-01031 M-06244, R1 M-01695N M-09765 M-01692 M-09766 M-098125, R1
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The responsibility for closing NCR M-09812 S, R1, has been transferred to TUGC0 startup because these Westinghouse valves are required to be disassembled during system flushing. The valves are to be reassembled under a startup work authorization (SWA).
Valve stroke tin.e testing of these valves will be verified under the SWA. The relief valves listed on NCRs h-09765 and M-09766 were required to be reset because the vendor had not been furnished the correct back pressure information to set the valves.
- c. Conclusion The limited review found that nonconformances were being written when identified, the items were considered for reportability to NRC, that corrective action to prevent recurrence was being initiated, and items were being trended.
- 2. Quality Assurance / Quality Control Training
References:
CP-QAP-2.1, RIO, Personnel Training and Qualifica-tion QI-QAP-2.1-1, R6, Nondestructive Examination Personnel Certification QI-QAP-2.1-5, R5, Training and Certification of Mechanical Inspection Personnel
- a. General The purpose of this part of the review was to verify that the licensee has:
a formal training program conducted required training to qualify personnel requirements for on-the-job training objective evidence of personnel qualifications evaluated the candidate's education, experience, and training prior to certification reevaluated personnel on a periodic basis records of personnel qualifications
- b. Review Effort A review was made of the documents listed above, and the reviewer held discussions with responsible corporate and site personnel to verify that procedures are consistent with regulatory require-ments. A review was made of General Examination Tests, RT-II-G-A, UT-II-G-B, PT-II-G-B, and MT-II-G-F; also Practical Examinations MT-II-P-04 and PT-II-P-07. These examinations confirmed the tests to meet the requirements of ASNT-TC-1A, Recommended Practice. The records of seven QC inspectors were reviewed. The records contained objective evidence of QC inspectors qualifications by O
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5 general and practical examination, on-the-job training, classroom, specialized training, education, and work experience records were 1 available to confirm QC inspectors meet the requirements of ASNT-TC-1A and ANSI N45.2.6-1978. Confirmation of annual documented evaluations of qualifications of inspectors was verified.
- c. Conclusion The training requirements for QA/QC personnel listed in the procedures appear to be complete. When personnel were questioned as to the training they were actually receiving, they confirmed the depth of training which the procedures required.
- 3. Audits
References:
QI-QAP-2.1-4, Auditors Certification DQI-CS-4.6, R6, Conduct of Internal, Prime and Subcontractor Audits
- a. General The TUGC0 QA audit program is based on FSAR Section 17.1.2 which addresses ANSI N45.2.12, Draf t* 3, Rev. O. TUGC0 Corporate Office is responsible for audits both internal and external. The audits spanned contractors, engineering, construction and corporate.
Audits are listed in five areas, Site Construction / Engineering /
Quality Control, Operations /Startup, Vendor, Pre-award Surveys, and Vendor Surveillance. Audits scheduled in the five areas were 107, 158, and 80 during 1982, 1983, and 1984, respectively,
- b. Review Effort A review was made of the licensee's implemented audit program to verify whether it meets the requirements of the accepted QA Program and ANSI N45.2.12 (Draft 3, Revision 0 - 1973) as endorsed by the QA Program. The reviewer also verified the following aspects of the audit program:
The scope of the audit program has been defined and is consistent with FSAR commitments Responsibilities have been assigned in writing for the j overall management of the audit program l
Methods have been defined for taking corrective action when j deficiencies are identified during audits The audited organization is required to respond in writing to audit findings l
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6 Distribution requirements for audit reports and corrective action responses have been defined Checklists are required to be used in the performance of audits The reviewer selected audits TPC 40, 43, 56, 57, 61, 69, 70, and TUG 22 performed during 1982 and 1983 for review. The audits were preplanned to cover specific functions and were comprehensive.
The reviewer noted that some audits had not been distributed in accordance with ANSI N45.2.12-1977; however, proper corrective action had been taken by QA audit supervision and was documented by memorandum dated August 16, 1983. Subsequent reports were distributed in a timely manner. Review of the vendor audit program is discussed in paragraph B.7.
The records of four lead auditors and two auditors were reviewed.
The qualifications of auditors and lead auditors were verified to be in accordance with the requirements of ANSI N45.2.23-1978.
Confirmation of annual documented evaluations of qualifications of auditors were verified.
- c. Conclusion As a result of this limited review, the reviewer concluded that TUGC0 ' Corporate Management, site QA/QC, and engineering audit activities are acceptable.
- 4. Records
References:
(a) CP-QP-18.2, R2, Implementation of the Permanent Plant Records Management System (b) CP-QP-18.3, R2, Permanent Plant Records System Organization (c) CP-QP-18.4, R2, Permanent Plant Records Receipt Control and Storage (d) CP-QP-18.5, R2, Automatic Records Management System Implementation (e) CP-QP-18.6, R0, Record Turnover to TUGC0 Operations Group (f) CP-QP-18.7, RO, N-5 and N-3 Code Data Reports (g) CP-QP-18.8, R1, Records Verification
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. 7 (h) CP-QAP'-11.1, R3, Fabrication and Installation Inspection of Components, Components Supports, and Piping (i) CP-QAP-16.1, R20, Control of Nonconforming Items (j) CP-QAP-12.1, R8, Inspection Criteria and Documentation Requirements Prior to System N-5 Certification (k) CP-QAP-18.1, R2, Processing QA Records (1) CP-QAP-18.2, R4, QA Review of ASME III 0.ocumentation
- a. General The quality assurance records program is based on FSAR Section 1A (B) which addresses ANSI N45.2.9 (Draft.1, Rev. O,1973) for the design and construction of Comanche Peak. The site records program is managed under the control of the Site QA Manager. The Permanent Plant Records Vault (PPRV) houses most of the design and construction records for completed work and have had final review performed. Completed reco~rds are being turned over to the control of the operations records control system on a regular basis.
Temporary storage of records is also ongoing at several working locations at the site utilizing one-hour fireproof cabinets.
i Records, where possible, are filed, by system and component. The PPRV uses smoke detectors tied into the site fire station for records fire protection; a water hose adjacent to the main PPRV door provides fire extinguishing capability, as do portable fire extinguishers in the area.
A computer is used to aid record retrievability, but is not essential, as records are maintained in hard copy. Records flow to the PPRV through both a regular site construction /QC path and ,
an ASME path,
- b. Review Effort -
A review was made of various nrocedures to verify that provisions had been made to maintain various types of quality records, and that responsibilities had been assigned to carry out the records +
storage requirements. Records storage procedures were also reviewed to ensure that they described the storage facilities, the filing systems used, methods of receipt, and handling and disposal of the records. The Brown and Root (B&R) program for flow of ASME o
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.. 8 Section III records to the PPRV was reviewed. The reviewer also verified retrievability of records from the PPRV.
To verify general record retrievability, the reviewer selected several general construction and inspection packages such as weld data, concrete placements, equipment packages, and equipment travelers. All records were retrieved in a short period from the PPRV. During the review, other records were retrieved of specific design / construction / inspection activities. No significant difficulties were identified during these real-time challenges to the records retrievability system. The ability to expeditiously locate and retrieve records is identified as a strencth. This ability appears to be primarily due to indexing and storage of records by component or material, when possible, instead of by record type.
To review the B&R ASME records flow, the records associated with safety injection isometric SI-2-RB-13-4; Core Spray CS-1-SB-032; Chemical and Volume Control CT-1-SB-14; Component Cooling CC-2-SB-042; Boron Recycle BR-1-SB-05 Spool 103; BR-1-SB-004 Spool 103, BR-1-SB-006, and Main Steam MS-1-SB-050 were reviewed.
These records contained the inspector's identification, the type of inspections, the acceptability, verification of review and approval, and were readily retrievable. Heat numbers on materials installed in the field were recorded during a site tour.
Certified Materials Test Reports (CMTR) were requested and
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furnished which verified traceability for those items recorded during the tour. Also CMTRs, for selected subassemblies were verified ta meet ASME code requirements. Review of records for the subassemblies listed above confi rmed that Design Change Authorizations (DCAs) and Component Modifications (CMCs) were incorporated into the as-built drawings prior to the ASME code stamp being applied to systems. This program of records review, approval and turnover f rom B&R, the ASME "N" stamp holder, to TUGC0 appears to be very thorough, though complex. Records for work performance by B&R are assembled, reviewed, and approved, then submitted to the Authorized Nuclear Inspector (ANI) for review, then submitted to TUGC0 for filing. A task force comprised of B&R and TUGC0 personnel, then make another review of these records. Any discrepancies noted are then resolved between B&R and TUGCO. These records are then red labeled, and can not be removed from the vault without written approval of QA management; thereby, preventing loss of QA records.
A review was made of the temporary storage of records in the field. Although records are best protected in the PPRV, record storage in adequate fire proof cabinets is allowed based on the record storage equipment qualification in NFPA No. 232-1975, which ba:es fire protection on exterior fire load calculations.
Although the reviewer did not check any fire load calculations
, - . p. - - - - - M , - - _ . - - - .
.. 9 justifying the use of one-hour fire cabinets, those cabinets observed appeared to be adequa,tely protected. During this review, the cbseryalion was niada that several concleted ASME moment restraint record package!, being mair.tained in a nor.-fireproof cabinet in the AStiE Shf eguards Building .QC trailer. This failure to store q;alitv asse-ance recorcs in a #ireproof cabinet is a potential enforcement issue. Prior to conclusion of the review, these paccrds were relucated to fireproof cabinets. Based on the above problem, the reviuer noted some confusjon at the site on the doncrol of "decumt.nts" as they p.ogr6ss thrtugh design / con-struction/0C and a: to whan they become "recoros." Tnis was evident as little distinr:tica appeared te he made for the storage of "decuments" or "reccrdt" in the field. Worting "docurr. ants" were prev 4ded equa'i to or bettaa protection tren records" in soin,e instances. Other than i.he exampic :tated, ne nthir storage probiem was identified. Cortanch3 Peak had e r *.aol i shed , on March 30,1984, rcc.ords con 1toring teams to ieview the recorcs flow prograrr. Tie clarificatjon of tb6 document / records interface for storage gentrcl is a weakness and is to be addresstd by the monitor teams. This weakre,ss is consicered part of the potentia) enforcemer.t issue addressed above. <
Tho physical construction of the ppRV was revievcd. Tne construc-tion of tne PORV is satisfactory for protection frtm ext.eMor fire damage. For inside origin &tcc fire damage, the PORT has a fire detection systtm but doet not have the industry standard water or '
halon automatic fire suppress 1cn sy s ten.. 'The system for
, unattended PPRV fire contrcl was reviewed. With the fire detec-tion alarms annunciating in the close-cy fire station, the fire station personnel having ready access to the PFRV and the locatien of a fire hose reel outside the PPRV doo , the fire protection appears adequate. Verification was made that the operatiors +
vault, into which all the PPRV records will be transferred, contains an automatic fire suppression system.
- c. Conclusion s The records control of the PPRV appears to meet all requirements, with sufficient staff to control the activity. Records flow to the PPRV needs clarification, but appears adequate in implementa-tion. Records personnel appeared knowledgeable as to PPRV operation.
- 5. Document Control
References:
(a) DCP-3, R17, CPSES Document Control (b) DET-12, RO, DCC/ Task Force Interface e
e
. 10
- a. General Controlled documents, primarily drawi r.g s , specifications, and procedures are maintained and contrelled by the site Document Control Center (DCC). The predominance of document control within s
the sphere of the DCC relates to cri. wing control and changes to those drawings. The DCC has established satellite document control centers which control and distribute most of the working documents. These satellite,s provide centrolled document copies to crafts and the Unit 1 Task Force Paper Ficw Groups (PFG).
Controlled documents and changes are provided to the satellites from the DCC. Tne CCC also ~provides controlled dccuments to several " controlled number recipicnts" directly. The PFG provides ,
controlled documents te craft working in that specific building task force. Revisiens to controlled drawings and docu: rents that affect controllea drawingst such as design change authorizations (DCAs) or component modification cards (CMCs) are distributed upcn l receipt to the satellites and controlled number recipients. For drawings, a comouter system keeps track of drawing; and that DCA.s and CMCs that affect those drawings. When new drawing $, drawing revisions, DCAs, or CMCs are generated the computer is updated.
When the satellites receive a new drawing revision, CMC or DCA, ,
any controlled drawings checked out to the craf ts or under the '
control of the PFG are updated by the satellite DCC personnel. .
This maintains current the controlled drawings in use by insuring that drawing packages contain the correct revision with applicaole DCAs and CMCs. Drawings checked out to the craft from the PFGs or s directly from the satellites are returned at the end of the working day. Prior to checking out drawings from a satellite directly to the craft, a computer run is made to insure that drawing packages contain the apprcpriate revtsion and applicable .
CMCs and DCAs. When craft personnel return drawing packages to l the : stellite or PFG, a drawing, CMC and DCA check is again perfcrmec to verify return of the controlled documents.
- b. keview Effort A review was made of the references listed to verify they met the ,
requirements .of the accepted QA Program. The reviewer also verified that adqinistrative controls have been established for -
the centrol of drawings and that indices are maintained for drawings, manuals, specifications, and procedures which indicate i current revisions.
In order to verify the control of drawings, the reviewer selected several drawings to determine if the current drawing revision with applicable DCAs and CMCs located in the DCC, was also onhand in the control and auxiliary building PFGs. Two drawing discre-pancies were noted. Drawings 2323-El-2011, R8 and 2323-El-0900, Sheet 1, R6 maintained in the PFG had several DCAs in the package 3 i
S
, -,,,--,,-e-- --r- e w - -
.e----
. 11 that were missing from the current drawing package computer printout. The verification was performed on April 12, 1984, using a current drawing status. This problem appears to be from engineering eliminating CMCs and DCAs from its data base applic-able to particular drawings without informing DCC of the change.
Although the computer change keeps satellite issues current, no
" trigger" device causes satellite personnel to remove the CMCs and DCAs from the PFG drawing package. A review of the engineering mechanism for updating the data base found the procedure satis-factory and a review of having non-applicable CMCs or DCAs in the drawing package revealed that while possibly confusing, the practice is not a technical problem. As the working contro' led drawing packages are expected to be current at all times, this mechanism whereby non-applicable CMCs and DCAs remain in con-trolled drawing packages is identified as a weakness.
The computer assisted drawing control program was reviewed.
Specifically, with the sole reliance on the current ccmputer printout to determine drawing package adequacy, the controls of computer input and changes were reviewed. Access codes have been established so that a limited number of engineering and DCC personnel have access to affect their respective data base. A procedure and training exists to define appropriate computer changes authorized for each grcup. The system appears to be adequately controlled and use of a computer system versus stamped drawings referencing DCAs and CMCs is identified as a strength.
During this review, a frepuent observation from all reviewers was the continued maintenance of a large number of CMCs and DCAs in drawings packages, rather than making a revision to the drawing incorporating the completed changes. Interviews with craft and QC personnel revealed that other than the inconvenience of the sheer volume of a large number of CMCs and DCAs in a package, they had not encountered construction errors due to accumulation of DCAs and CMCs. In that no problem appear to be developing, but the potential to lose control is high when drawings are not revised periodically to keep outstanding drawing changes reasonably low, the maintenance of working drawings with a large number of completed CMCs and DCAs without a drawing revision is identified as a weakness. The applicant does have a program under way which began two years ago to update those crawings identified by operations as needed for safe operation. This program is scheduled for completion by fuel load.
c. Conclusion
The limited review revealed that the responsib ities and how their job was performed. The DCC, satellites, and PFGs reviewed appeared to be adequately staffed.
n
r 12 The - n' +'^ - 'n' -^a*-^' -"* appears to keep craf t personnel up-to-date in an expeditious manner.
- 6. Receipt, Storage, and Handling of Materials
References:
(a) CP-CPM 8.1, R1, Receipt, Storage, and Issuance of Items (b) CI-CPM 8.1, R1, Color Coding of Piping Materials (c) CI-CPM 8.2, R5, Control of Spare Parts (d) MCP-10, R7, Storage and Storage Maintenance of Mechanical and Electrical Equipment (e) ICP-5, R3, Control of Permanent Plant Instrumentation (f) CP-QAP-8.1, R7, Receiving Inspection (for ASME items)
(g) CP-QP-8.0, R2, Receiving Inspection
- a. General Warehousing activities are managed under the Project Support Services organization. Safety-related material is stored in several warehouses and also in an outside laydown yard. All material is received at one warehouse and then moved to the appropriate storage location. Shipping damage inspections are conducted by warehouse personnel and receipt inspections are performed by QC inspectors. Environmentally sensitive material is stored in a temperature and humidity controlled storage location.
A preventive maintenance program exists to insure that mechanical and electrical equipment is maintained in an operable condition while in storage,
- b. Review Effort A review of the licensee's program for the receipt, storage, and handling of equipment and material with respect to selected elements of the licensee's accepted QA Program was performed. The review was to verify that administrative controls had been established concerning receipt inspection of safety-related materials, preparation and retention of required documentation, control of nonconforming and conditional release items and control of items in storage. Implementation of the program was reviewed
~l
3!
-i
'- 13 by selecting several safety-related items in storage and verifying document and item control to be in accordance with the program.
The reviewer also toured the warehousing locations. Storage discrepancies were not identified. The QC receipt inspection program was also reviewed. QC inspections appeared to be conducted in a satisfactory manner,
- c. Conclusion Based on the limited review of the warehousing and receipt inspection program and implementation, both programs appear adequately managed. Storage locations appear adequately staffed.
Warehousing and QC personnel were knowledgeable and professional in their respective areas.
- 7. Procurement
References:
(a) CP-EP-5.0, R7, Procedure for Field Procurement (b) DQP-CS-2, R6, Procurement (c) DQP-CS-4, R9, Procedure to Establish and Apply A System of Pre-Award Evaluations, Audits, and Surveillances
~
(d) DQI-CS-4.1, R3, Vendor QA Manual Reviews (e) DQI-CS-4.2, R3, Generating and Maintaining the TUGC0 Approved Vendors List (f) DQI-CS-4.3, R4, Vendor Performance Evaluation System (g) DQI-CS-4.4, R4, Conduct of Vendor Pre-Award Evaluations (h) DQI-CS-4.5, R6, Conduct of Vendor Audits (i) DQP-VC-1, R7, Final Inspection and Release for TUGC0 (j) DQP-VC-2, R7, Witnessing Trip (k) DQP-VC-3, R3, Initiating Yellow Flag Sheets (1) DQP-VC-4, R6, Guidelines for Certifying Vendor Compliance Inspection Personnel e
4
~
.. 14 (m) CP-QP-5.0, R1, Quality Assurance Review of Site Generated Procurement Documents
- a. General Safety-related purchase requisitions are generated by TUGC0 engineering at the site and are converted to purchase orders by the site procurement and subcontracts section. Technical and QA requirements are determined by engineering. A QA review of all safety-related purchase orders is conducted on site to verify QA requirements and use of an approved vendor. Each purchase order requires the vendor to inform TUGC0 when a product is ready to ship. TUGC0 QA determines whether to perform a pre-shipment inspection at the vendor's location or to waive this inspection.
Approximately one-third of all safety-related shipments are source inspected. TUGC0 also maintains a vender audit program to insure that vendors can meet the requirements imposed by the purchase orders. The vendors that are satisfactorily audited are placed on the approved vendors list. TUGC0 has also initiated an annual review of supplier performance.
- b. Review Effort .
A review was made of the licensee's procurement program with respect to selected elements of the accepted QA Program. The review was to veri fy that administrative controls had been established for the preparation, review, approval and revision of procurement documents. A review of the licensee's procedures to verify that acceptable methods were being used to qualify vendors which provide quality goods or services; that these procedures required the maintenance of records of supplier qualifications and audits; and that responsibilities have been assigned to perform the vendor qualification program was performed. Several purchases orders at the site and at the TUGC0 offices in Dallas were reviewed. Purchase orders, based on the limi.ted review, appeared to be handled satisfactorily.
Also reviewed was the source inspection or witnessing program implemented from the TUGC0 QA office. The program is quite extensive and appears to be very effective at performing material inspections at the source and identifying potential problems difficult to detect by a receiving inspection alone.
A portion of this program, though, needs clarification. Although, the witnessing procedures describes how to perform the source inspection, criteria is not documented for the decision on what purchase orders are source inspected and which are waived. This is considered a procedure weakness, but not a program weakness.
The entire witnessing program is a strenoth.
t *
. 15 Also reviewed was the vendor audit program, which is used to maintain the approved vendors list. The reviewer selected several vendors on the current list and reviewed their most current audits. All audits reviewed were considered satisfactory. Two of the vendor audits, Dresser Industries and Forney Engineering were last audited in 1978. The licensee, through the FSAR, utilizes ANSI N45.2.12, Draft 3, Rev. O to develop the audit program, a part of which is the vendor audit program. Paragraph 3.4.2 of this standard requires the performance of annual audits or at least one audit during the lifetime of the activity. NRC Regulatory Guide 1.144, Revision 1, Auditing of Quality Assurance Programs for Nuclear Power Plants, which the licensee has not endorsed, clarifles this annual requirement with respect to vendor audits, in that vendors may be audited triennially providing that ,
annual evaluations continue to show the vendor performing satisfac- +
torily. The TUGC0 vendor audit program does not provide for an annual, triennial or any periodic vendor audit schedule. Vendors are reaudited primarily on a usage and performance history basis.
This failure to establish measures to audit vendors at least triennially is considered a potential enforcement issue. The ;
inspector found no indication that a failure to audit periodically resulted in maintaining an unsatisfactory vendor on the approved ,
vendors list. Also, although the vendor witnessing program does -
not review the vendor's QA program, and is not a substitute for a '
TUGC0 audit, the large number of source inspections would mitigate the possible consequences of not performing periodic vendor audits. [
- c. Conclusion '
The procurement program appears to be satisfactory. The vendor witnessing program is an asset and appears well managed. Other f than the missing timetable for the vendor audit program, the conduct of audits and vendor annual evaluations appears to be well managed. Personnel in the procurement QA staff appear to be i knowledgeable and professional in their work. .
C. Equipment Turnover and Preoperational Testing
References:
CP-SAP-3, Custody Transfer of Station' Components STA-802, Final Acceptance of Station Systems, i Structures, and Equipment CP-SAP-21, Conduct of Testing ?
i I
t
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' .. 16
- a. General The processes of turnover of safety related equipment from construction to startup as well as pre-requisite and pre-operational testing of said equipment were reviewed in order to determine if:
(1) The method employed for transferring custody of components, partial subsystems, subsystems or systems from construction to
. startup; tne return of equipment to construction for rework or modification; and the ultimate release of custody from startup to operations are technically and administratively adequate.
(2) The administrative controls over preoperational testing are technically and administratively adequate.
(3) The preoperational test procecures both performed and yet to be performed are technically viable and administratively sufficient,
- b. Review Effort (1) Equipment Turnover The turnover of safety related eautoment from Construction to Startup is administratively controlled by Startu; Adm131strative Procedure CP-5AP-3, Custody Transfer of Station Components. This procedure establishes the requiremints and responsibilities fer transferring custody of components, partial subsystems, subsystems or systees from:
(a) Construction to Startup (b) Startup back to Construction for rework or. modification (c) Startup to Operations The Startup group determines the turnover boundaries necessary to perform pre-cperational testing activities. Tha Completions Group (a subgroup of Startup) assembles the turnover packages consisting of equipment, valve, piping and instrument lists, drawing lists such as flow, instrumentation and control, and auxiliary one-line diagrams ac required to sufficiently describe the content and boundaries of the turnover.
The Completion Group is also respensible for initiating and processing turnovers consistent with established schecules in the turnover package, such as to:
(a) identify the equipment (b) indicate the scope of the turnover e
.. 17 (c) assemble the late revisions of the appropriate diagrams /
prints and applicable design change documents (DCA's) ,
(d) list deficiencies, including design changes that have not been implemented The Completion Group coordinates all required pre-turnover walkdowns and punchlist activities for the purpose of establishing the status of remaining work to be done prior to turnover of that equipment to startup.
Startup personnel review the packages and perform a walkdown of the equipment / system to determine if the equipment identified in the package is ready for turnover. Any deficiencies requiring resolution prior to turnover are resolved prior to transfer; those deficiencies not requiring pre-turnover resolution are added to the Master Data Base (a computerized tracking system) to facili-tate future disposition. tJpon completion of the startup walkdown and correction of required deficiencies, custody / turnover of the equipment is transferred to startup.
Custody of station components may be returned to construction for performance of work such as major modifications, repair or clearing of construction deficiencies. The return of equipment to construction voids all preoperation testing on said equipment.
After the completion of applicable prerequisite tests, (construc-tion tests), including initial operation of the equipment, startup may relinquish " operational control" to Operations yet maintains custody of the equipment pending completion of preoperational testing.
The turnover packages for the following systems were reviewed:
(a) Component Cooling (b) Auxiliary Feedwater (c) Containment Spray (d) Chemical and Volume Control (e) Residual Heat Removal (f) Safety Injection (g) Hydrogen Recombiners (h) Reactor Protection System D
9
,, 18 The turnover of equipment from Startup to Operations is detailed in Station Administrative Procedure STA-802 Final Acceptance of Station Systems, Structures and Equipment. Pursuant to tnat Procedure, Operations initiates a cetailed review of the turnover package and walks down the applicable equipment. Followir.g successful completion of the reviews and walkdowns, Operations accepts the equipment / area. At this time all responsibility for that equipment lies with operations.
There has been no safety related equipment transferred to operations, thus the review of the process was in terms of programmatic sufficiency. I (2) Preoperational Testing Program The preoperational test progrsm was reviewed in order to verify that the tests to be performed have been identified and that each of the identified tests entailed at a minimum, test objectives, summary of the test, necessary prerequisites, and acceptance criteria.
The test organization was reviewed in order to verify that the lines of authority and responsibilities of test personnel are specified and that where interfaces exist between organizations involved in the test program, that organizational responsibilities are clearly established.
The administration of the test program was reviewed in order to verify that methods are established to receive (from construction) the jurisdiction over systems before commencement of testing.
The administrative mechanisms established for jurisdiction control of systems before, during, and af ter testing were reviewed in order to verify that those mechanisms adequately provide for:
control of systen status before preoperational testing including the completion of adequate prerequisite (construction) testing; the return of systems to Construction if necessary to support modifications and/or reports; the control of system status subsequent to testing including measures necessary to prevent invalidation of test results; the control of the system during testing; only the assigned System Test Engineer or his designate may conduct system testing.
The conduct of testing was reviewed in order to verify that adequate administrative measures provide for: methods to change a test procedure during the conduct of testing; the criteria for interruption of a test and continuation of an interrupted test; methods to coordinate the conduct of testing; methods to document significant events, unusual conditions or interruptions to testing; methods for identifying deficiencies, documenting their T
19 resolution and documenting retesting; methods for providing the current test procedure to operations and coordinating test activities with the shift supervisor; methods to ensure that the systems test engineer has the appropriate latest revision of the required documentation / references.
The program for evaluation of test results was reviewed in order to determine Mt: deficiencies are clearly identified and appropriate co,e sctive action proposed, reviewed and completed; subsequent to corrective actions or modifications have been completed, tests or portions of test have been rerun as necessary to ensure that tests of the as-built system are adequate; the results of the evaluations were reviewed by the appropriate licensee personnel responsible for approving the original proce-dure.
(3) Prerequisites Tests Selected prerequisite tests were reviewed in order to determine if the tests provide and adequate mechanism of accomplishing vital testing and operation of the associated equipment. The tests reviewed appeared technically and administratively sufficient.
The prerequisite tests when performed in ccmpliance with Startup Administrative Procedure Cp-SAP-21, Conduct of Testing, and as required by the applicable preoperational tests, appear to provide an adequate mechanism for initial equipment checkout and operation.
(4) preoperational Tests Selected preoperational test procedures for tests which are yet to be performed, were reviewed in order to ascertain adequate implementation of the following:
(a) Management review and approval (b) Procedure format with emphasis on clarity of testing required (c) Clarity of test objectives (d) Pertinent prerequisites identified, e.g.
- 1) required plant systems are specified
- 2) procer facility procedures and other references are specified ard unicuely identified
- 3) completion of calibration checks, limit switch setting protective device setting, included where applicable
- 4) special supplies, and test equipment specified.
9
. 20 (e) Special environmental conditions, if any, identified.
(f) Acceptance criteria are clearly identified and the procedure requires comparison of results with acceptance criteria.
(g) The source of the acceptance criteria is identified, i.e.,
FSAR, T/S, Reg. Guide, engineering drawing, etc.
(h) Initial test conditions are specffied
- 1) Valve line-ups
- 2) Electrical power and control requirements
- 3) Temporary installations (instrumentation, electrical, and piping)
- 4) Temperatures, pressures, flows (i) The procedure includes reference to appropriate FSAR sections, T/S, drawings, specification, codes and other requirements.
(j) Step-by-step instructions for the performance of the proce-dure are complete to the extent necessary to assure that test objectives are met.
(k) Provisions are available for documenting that all items, including prerequisites, are verified as having been per-formed.
(1) Provision is made for recording details of the conduct of the test including observed deficiencies, their resolution, and retest.
(m) Procedure requires that temporary connections, disconnections or jumpers be restored to normal or refers to another procedure.
(n) Procedure provides for identification of personnel conducting the testing and evaluating the test data or refers to another procedure.
(o) Procedure provides for independent verification of critical steps or parameters, including QA holdpoints.
These procedures included but were not limited to the following:
1-CP-PT-11-01 Component Cooling 1-CP-PT-29-2 D/G Control & Functional O
e
- i a
. 21 1-CP-PT-48-01 Containment Spray 1-CP-PT-49-02-RT-1 CVCS - Seal Water & Letdown Performance Retest 1-CP-PT-49-03-RT-1 CVCS - Chemical Control Purification and Makeup Retest 1-CP-PT-57-01-RT-1 SI Pump Performance Retest Selected completed preoperational procedures were reviewed in order to ascertain, at a minimum that:
(a) The licensee is performing an adequate evaluation of test results (b) All test data are either within previously established acceptance criteria, or that deviations are properly dispositioned.
(c) The licensee's methods for correcting deficiencies and for retesting are adequate.
(d) The adequacy of the licensee's administrative practices in maintaining proper test discipline concerning test execution, test alteration, and test records.
(e) The licensee is following his procedures for review, evaluation, and acceptance of test results.
These procedures included, but were not limited to:
1-CP-PT-57-06 RHR - ECCS 1-CP-PT-67-01 Hydrogen Recombiner 1-CP-PT-64-02 Reactor Protection System 1-CP-PT-57-02 Centrifugal Charging Pump 1-CP-PT-57-01 SI Pump Performance 1-CP-PT-48-01 Containment Spray 1-CP-PT-29-04 D/G Sequencing 1-CP-PT-02-08 Class I-E Switchgear (5) Systems Status System walkdowns were performed in crder to deternine the current status of safety related components / systems. The following systems, among others were selectively reviewed in that assess-ment:
(a) Residual Heat Removal (b) Chemical Volume and Control (c) Safety Injection (d) Containment Spray (e) Auxiliary Feedwater -
(f) Component Cooling O
i 4
~
. 22 Preoperational test status reports were also reviewed and inter-views conducted in order to assess the current status of completed and remaining testing. The review revealed that of the 198 original preoperational test procedures, 45 have yet to be performed; of the 34 preoperational/ retest procedures, 33 have yet to be performed; that of the 39 preoperational/reperform proce-dures, 37 have yet to be performed. Thus of 271 total procedures, 115 or 42% have yet to be performed. It should be noted however that the " Retests" and "Reperforms" are, as a general rule, much less in scope than the original preoperational test and as such should require less time to complete. Further the " Retests" and "Reperforms" will be run on essentially " debugged" systems, thus should run much smoother than the original tests. (Note: The retests and reperforms were necessitated by extensive electrical rework and station modifications.)
There is no preoperational testing currently ongoing, nor has there been any significant testing in the past 10 months, the result of the aforementioned electrical rework and other modifi-cations. Plans are currently underway to recommence preopera-tional testing during the month of April 1984.
A statistical analysis of the preoperational testing which has been performed, spanning the period of July 1982 to June 1983, in essence the period immediately proceeding a virtual shutdown of testing necessitated by the modifications as aforementioned, revealed that in that 11 month period,177 of the 198 original tests were performed. This calculates to be an average of 11 tests completed per month. Applying this rate to completion of the total testing remaining,115 tests, it would take approxi-mately 10 months to compTete the preop program. If, however, one assumes that rate would apply only to the original preoperational tests, not the retests or reperforms, and a valid assumption that the retests and/or reperforms can be run in conjunction with or at least during the time frame of the preop tests, then the 45 remaining original preops can be run in 4 months. Assuming preop testing resumes in April 1984 as planned, preop testing could conceivably conclude by August 1984, if no major undisclosed problem is identified.
It should be noted that a mechanism / method now embraced by the utility to facilitate turnovers, is that of room / building turn-overs in conjunction with the equipment inside. This is cumber-some and could impact preoperational testing. Preoperational testing is performed on a system related basis, thus if a system is complete, yet the room in which the system is placed is not (i.e., painting, etc.), preoperational testing may be, and is under the current program, delayed until room turnover. (Note:
See Section A fer changing completion methodology).
i 1
, 23 I
- c. Conclusion Based on the above limited review, the following conclusions were formed:
(1) The administrative process of custody transfer of systems appears to be adequate.
(2) The preoperational test program appears to be intact, viable and adequate.
(3) Preoperational tests appear to be technically and administratively adequate.
(4) Preoperational testing could conclude by August 1984.
D. Electrical
References:
QI-QP-11.2-3, Torquing and Scacing of Concrete Anchor Bolts QI-QP-11.3-23, Class IE Conduit Raceway Inspection QI-QP-11.3-26, Electrical Cable Installation Inspection QI-QP-11.3-27, Class IE Power Cable Meggering QI-QP-11.3-28, Class IE Cable Terminations QI-QP-11.3-29.1, Verify Electrical Separation QI-QP-11.3a38.1, Installation of Class 1E Electrical Equipment QI-QP-11.3-40, Post Construction Inspection of Electrical Equipment and Raceways QI-QP-11.3-42, Electrical Inspection of Seismic Category 1 Instrumentation Rack Assemblies QI-QP-11.10-1, Inspection of Seismic Electrical Support and Restraint Systems QI-QP-11.3-50, Cable Grip Support Installation Inspection
- a. General The assessment in this area was to determine if safety-related electrical equipment was being installed and inspected in accordance with NRC requirements and licensee commitments and to determine if Texas Utilities Services Inc., (TUSI) programs which includes drawings, procedures, quality' control and construction inspections, and quality records are adequate to accomplish work in this activity.
Discussions were held with craf tsmen and other Comanche Peak Steam Electric Station (CPSES) project personnel to determine their ability and knowledge to carry out their individual responsibilities and to evaluate their morale and opinion with regard to the Comanche Peak nuclear project. No adverse comments were made by the Comanche Peak e
m
. 24 project employees and all considered the project to be of high quality construction.
The licensee recently organized his manpower into a Building Management Organization (BMO) to make the most efficient use of project resources.
There are four main BMOs - Containment Building, Safeguards Building, Auxiliary Building, and Electrical Control Building. Each organization is an integrated group of engineering, construction, and QA personnel.
This group supports the effort to complete the construction in their area of assignment under the direction of a Building Management Director. The department supervisors are responsible for the technical direction of their personnel, and QC personnel report to the applicable QA Department manager. There is an exchange of problems and resolution of problems among the project personnel and bi-weekly BM0 meetings.
As a room or area is considered nearly complete an Electrical Separa-tion Verification (QI-QP 11.3-29.1) is performed on the room and/or area. The completion or near completion of the final Electrical Separation Verification items usually triggers the Post Construction Inspection of Electrical Equipment and Raceways (QI-QP-11.3-40). When both these procedures are complete, or essentially complete, and/or at the discretion of the BM0 director, the room and/or area becomes controlled. Access is limited to correct minor outstanding deficien-cies or complete other known outstanding work. The BM0 Director determines when this room and/or area is to be turned over for an inspection and acceptance by the Stations Startup and Test Group. This turnover usually follows the inspections and completion of most of the deficiencies found during the performance of QI-QP 11.3-29.1 and QI-QP 11.3-40.
An inspection walk down was performed on many uf the rooms / areas that the BM0 Director considered to be essentially complete. This walkdown showed that the rooms / areas were clean, that electrical / mechanical separation, including barriers, cable tray attachments, identification of cable trays, conduits, and cables, cable tray fill and cable spacing (where applicable) in trays, and cable supports (Kellen grips or equivalent) were satisfactory.
- b. Review Effort ,
I (1) Review of Quality Assurance Implementing Procedures The referenced procedures were examined to assure that FSAR requirements and commitments were being complied within the areas relating to the installation and inspection of electrical equip-ment and components.
These procedures provided check lists and acceptance criteria for QC inspector.
I 1-l
25 (2) Electrical Cable Installation The following installed safety-related (S/R) electrical cables that had been accepted as satisfactory by site construction QC inspectors were examined. A physical examination was made to determine compliance with applicable design and installation criteria relative to type, location / routing, identification tags at termination points, minimum bend radius (where applicable),
cable color compatible with designated raceways and separation of trains, excluding barriers, which are performed prior to or concurrent with QI-QP-11.29-1, " Verify Electrical Separation."
The routing was checked by using a signal generating device.
Cable No. Type From To EG100483 3/C No. 10AWG MCC1EB2-1 MOV 1HV5540 EG113626 9/C No. 12AWG MCC1EB2-1 CP1ECPRTC08 EG113646 9/C No. 12AWG MCC1EB2-1 CPIECPRTC05 EG112219 2/C No. 12AWG MOV IHV4759 CP1ECPRTC05 EG100497 3/C No. 8AWG MCCIEB2-1 MOV 1HV4759 EG112216 5/C No. 12AWG MCCIEB2-1 MOV 1HV4759 E0100009 1/C No. 4/0AWG SWGRIEA-1 TBXCSAPCH01 E0112206 5/C No. 12AWG MCCIEB3-1 MOV IHV4758 E0112207 7/C No.'12AWG MCC1EB3-1 CP1ECPRTC04 E0112209 2/C No. 12AWG CPIECPRTC04 MOV IHV4758 The cable identification is accomplished by an alphanumeric coded tag and by the color of the cable jacket. The first character of the alphanumeric code indicates whether the cable is safety or channel oriented (E), associated train (A) or non-safety (N). The second character identifies the 'olor of the cable jacket and with recpect to safety-related (S/R) applications they are "0" (Orange), "G" (Green), "W" (White), "B" (Blue), "R" (Red) and "Y" (Yellow). All cables are to be tagged with their unique alphanumeric number at termination points in equipment and junction boxes. Cables that enter and leave a junction box but are not terminated in that junction box are not required to be identified in that box with their alphanumeric number. All of the above cable were properly identified.
l The routing of the above cables was checked with signal tracers.
Using' this method, junction box covers, cable tray covers, fire barriers and other items did not have to be removed. This check showed that cable tray systems and conduits appeared to be properly installed with proper attachments and supports, that these systems were properly identified, and that the cables travelled the route indicated on the cable pull cards.
QC records showed applicable inspections were made in accordance with the following procedures:
I e
L .. .1 -
i
26 (a) QI-QP-11.3-26, Electrical Cable Installation Inspection (b) QI-QP-11.3-27, Class 1E Power Cable Meggering (c) QI-QP-11.3-28, Class 1E Cable Terminations (3) Electrical Cable Termination A physical examination was made on terminations of selected class IE electrical cables in the Hot Shutdown Panel on elevation 832' of the unit 1 safeguards building. The examination ve.-ified that terminations were in compliance with requirements, including proper lug material and size, accurate location, and identifica-tion of terminal block and conductor. The cable wiring diagram was used to determine the proper termination points and conductors identification. Cable Terminations that were checked were for cables EG104556, EG111148, EG104551, EG139204, E0104791, E0104740, E0122101, E0104742, E0130596, and E0122103.
The QC records showed that inspections were made on these termina-tions in accordance with QI-QP-11.3-28, " Class IE Cable Termina-tions."
QI-QP-11.3-40, " Post Construction Inspection of Electrical Equipment and Raceways" states: " Separation between field run redundant Class IE cables and Class 1E/Non-Class 1E cables within a cabinet shall be maintained in accordance with the equipment specification. If the specification gives no separation require-ments, the minimum separation distance between redundant Class IE and Class 1E/Non-Class 1E cables shall be greater than or equal to 6 inches. In cases where the above separation criteria cannot be maintained, barrier shall be installed between the cables."
Acceptable barriers include the following:
(a) Metallic conduit; including Servicair Company FC 33 flexible conduit (b) Two sheets of fire retardant material separated by a minimum of " of air space or thermal insulating material (c) A single barrier with a 1" maintained air space or thermal insulating material between the components or devices and the barrier During the cable termination inspection in the Hot Shutdown Panel, it was noted that barriers were installed but there still existed some separation problems. The licensee's representative indicated that QI-QP-11.3-40 inspection had not been performed on the panel and that the remaining barriers would be installed as needed to meet the separation criteria before QI-QP-11.3-40 was signed off for that room or panel.
6
.. 27 To-insure that internal electrical separation in panels was being adhered to, several panels in which QI-QP-11.3-40 was essentially complete were examined. These panels were located in the cable spreading room and control room. The panel examined included termination cabinets TC-22, 23, Auxiliary Relay Panels 1, 2, and
- 5. These panels showed that internal separation was satisfactory even though work was still in process in some of these panels.
During the inspection for electrical separation in the above panels it was noted that some cables in the panels were being spliced. This was was determined to be satisfactory and meets FSAR commitments which state in paragraph 8.1.5.2.5., " Wire splices are used in limited applications on field cables that terminate in certain Class 1E panels, cabinets or racks. The normal design is to terminate field cables without the use of wire splices. The wire splices are only used where additional length is required for the field wire and it was not judged reasonable to pull a new field cable. The use of such wire splices has been minimized. The wire splices are butt splices. The crimping technique, device and materials used for the splices are identical to those used for the terminal lugs in that panel. The wire splices are only allowed on low power applications such as control cables. Since previously accepted crimping methods and materials are used, the splices are limited to low nower circuits and to field cables that already terminate in the panel, and the required wire separation and wire bundles support is maintained..."
Interviews with CPSES project personnel which were conducted by other members of this review team indicated that there may be a
~
problem with cable terminations to Weidmuller Terminal Blocks.
These terminal blocks employ a screw clamp connection. The manufacturer's literature for these terminals blocks states, "The screw clamp" refers to a connection in which the wire is stripped of its insulation to a recommended length and clamped without any
- further preparation. A screw clamp and current bar are used to insure the connection; and since the clamping screw does not make direct contact on the wire, damage is prevented." As inspectors were making inspections for QI-QP-11.3-40, " Post Construction i Inspection of Electrical Equipment and Raceways," they would tug and flex the conductor to insure that the connection was tight.
- This action caused the conductor wire strands to slightly sprerd l and thereby reducing the tightness of the screw clamp connection.
Since these connections were previously verified as satisfactory per QI-QP-11.3-28 " Class 1E Cable Termination" ins _pections and the fact that equipment may be energized, the licensee now calls for a visual inspection with regard to QI-QP-11.3-40 termination checks.
The Weidmueller Terminal Blocks used at CPSES are qualified per the manufacturer's literature for nuclear applications including environmental qualification. Tests for this qualification were l
~
l l
I
. . 28 l
1 performed by Franklin Research Center and are documented on their reports FC 4959 and 5205.
(4) Electrical Conduit and Cable Tray Installation Conduit and cable tray raceway systems were inspected in rooms and/or areas in which both QI-QP 11.3-29.1, " Electrical Separation Verification" and QI-QP 11.3-40, " Post Construction Inspection of Electrical Equipment and Raceways," were essentially completed and access to these rooms and/or areas were controlled. This inspection was to verify completeness of work in the electrical area, including electrical separation, power cable spacing in trays and cable supports on vertical runs of cable systems. All items were condidered to meet construc; ion criteria.
Specific Conduit System checked including support and spacing were:
Conduit No. Location Remarks C13005319 Safeguards Bldg #1, Elev 773, Room 56S Access Controlled C1304036 Safeguards Bldg #1 Access Controlled Elev 773, Room 565 C13012998 Safeguards Bldg #1 Access Controlled Elev 773, Room 56S C13010777 Safeguards Bldg #1 Access Controlled Elev 773, Room 56S C14013679 Safeguards Bldg. "I Access Controlled Elev 773, Room 54 C22G08188 Aux. Bldg. Elev. 790 Only Room 170 was Various Rooms Access Controlled C22G08189 Aux. Bldg. Elev. 790 Only Room 170 was Various Rooms Access Controlled The inspection of these conduits showed that they were installed to the construction requirement and that electrical separation was satisfactory. QC records for these conduit systems showed that applicable inspection were made in accordance with the following procedures:
QI-Qp- 11.3-23, Class IE Conduit Raceway Inspection QI-QP- 11.2-3, Torquing and Spacing of Concrete Anchor Bolts 4
m 1
- v , ~w-
-t
k 29 ,
QI-QP 11.10-1, Inspection of Seismic Electrical Support and Restraint Systems QI-QP 11.3-29.1, Verify Electrical Separation [For Room 56S, Inspection Report (I.R)# E-1-0013485/3-84; for Room 54, IR# E-1-0013480/3-84; for Room 170, IR# E-1-0017514/1-84]
Several additional conduit runs were examined in the field to verify electrical separation. These conduit runs were located in the cable spreading area and are identified below:
(a) Conduit C12019632, orange safety train, goes under ladder tray T16GCCM02, green safety train, at one point and separa-tion is approximately 6 inches. At another point it goes over ladder tray T14GCDH41, green safety train, and separa-tion is approximately 2" with a barrier installed between the two.
(b) Conduit C15R10537, red protection channel, at one point goes under ladder tray T13GCCM15, green safety train, and separa-tion is approximately 2 inches.
(c) Conduit C15B11396, blue protection channel, at one point goes under ladder tray T130CCM0, orange safety train, and separa-tion in approximately 2 inches.
(d) Conduit C12G21191, green safety train, goes under solid tray T140CDJ31, orange safety train, and separation is approxi-mately 3 inches.
The above are acceptable per QI-QP 11.3-29.1 " Verify Electrical Separation" and Gibbs and Hill Specification 2323-ES-100 Section 4.11.3.2.
Spacing of power cables in trays is to follow requirements of Gibbs and Hill Specification 2323-ES-100 section 4.2.1.4. , which in essence, states that minimum spacing between power cables shall be a minimum of one quarter of the diameter of the largest cable.
The spacing of cables in the following trays and rooms were considered to meet this requirement:
Electrical Separation Tray Numbers Location Verification per QI-QP-11.3-29 T120ABA05-12 Room 174, Aux. Bldg. Not complete T120ABB01 Room 174, Aux. Bldg. Not complete T110AA01-05 Room 174, Aux. Bldg. Not complete T110SAA30 Room 54, Safeguards Bldg. Complete
-p
4
. 30 T120ABA96* Room 219, Aux. Slag. Approx. 90*;
complete T11GAAB11* Room 214, Aux. Bldg. Complete T120ABA98* Room 241, Aux. Bldg. Approx. 90f; complete T120ABA47-50 Room 241, Aux. Bldg. Approx. 90?;
complete T120ABB93 Room 219, Aux. Bldg. Approx. 90?;
complete
- Asterisked trays contained vertical runs of cable. Cables were supported properly by Kellem Grips in accordance with QI-QP-11.3-50, " Cable Grip Support Installation Inspection."
A review of some of licensee Inspection Reports (irs) that were performed for QI-QP-11.3-29.1 " Verify Electrical Separation" showed that I.R E-1-0024985 of 2/28/84 and IRE-1-0036072 of 4/12/84 applied to the same room (room 219) in the auxiliary building. Neither of these reports indicated that they were performed as a result of a specific job or Inspection Item Removal Notice (IRN). Both were designated as final inspections. It is recognized that the licensee can perform re-inspection as deemed necessary; however, it is considered that there should be only one final inspection for post construction work. If additional final inspections are required in this area for IRN's, Design Change Authorizations (DCA), etc., they should be referenced in the
. remarks section of the IR. The one "fina'1" electrical separation inspection, which could be performed concurrent or before QI-QP-11.3-40 " Class 1E Electrical Post Construction Verifica-tion," would indicate that electrical work in this area in almost complete and would aid in triggering the performance of QI-QP-11.3-40. The licensee stated that this area would be reviewed to see if the " final" inspection in this area could be clarified.
- c. Observation and Conclusions There appears to be a good working interface between construction inspectors and the craft. For the most part the electrical construc-tion inspectors appear to be knowledgeable and conscientious in their l- work areas. The inspector encountered no cases of hostility or
! harassment with the Comanche Peak Project employees.
E.
References:
QI-QAP-11.1-28, Rev. 23, 1 --_ _ _ . _ _
31 QI-QAP-11.1-28A, Rev. 5, Installation Inspections of ASME Cice' ' ' '"'
u . . % ,. ,
Procedure AB-5, Rev. 5, A Simplified Method for Design and Analysis of : Z'""
o,--
TUSI Engineering Guidelne, Section IV, L ...u ,
Rev. 11 CPSES, XCP-ME-10, Rev. 1, PA ; _ y r _ . - n% mme ns TUSI CP-EI-4.5-1, Rev. 9, General Program for issuesumF Pgsgsmen'manesessuSMP TUSI Engineering Guideline, Section II, General Engineering Sectopm II Criteria for M , Rev.giubumutnummut 8 Specification 2323-MS-46A, Nuclear Sa Rev. 5 supports Construct 4an Procedure Field Surveys 35-1195-CCP-9, Rev. 4, TUSI CP-EI-4.6-9, Rev. 1, Performance Instruction for QuumuuuuuM49uWPby SSAG TUSI Engineering Guideline, Hilti Concrete W l Section V, Rev. 3 &
M Static and Dynamic Pipe Design and Stress Analysis, Arthur D. Little, Inc. , May 1981
- a. General The organization of the general site engineering, construction, and procurement efforts were defined in procedure CP-EP-3.0. By this procedure, the Project Manager is responsible for the Comanche Peak Steam Electric Station (CPSES) d Teuuuumeessee o d other organizations. However, the li av retains overall respon-sibility for design activities and performs desion functions as necessary. T e FSAR Chapter 3 provided the licensee's requirements for the design of structures, components. eouipment, and systems. The N n O
__ - _ _ , _ _ _ , . _ _ -,-------m-- . , .
32 proc 'te
^ '~ '-- * ^ " '- *~- '-'- -'
pro w - -- - ~ ~ ~ ' ~ '
^^^--~ures sati s.
- b. Review Effort The reviewer held discussions with the design engineering personnel in the pipe support group to determine whether they understood the applicable design control procedures; whether they were able to verify design parameters that were within the applicable criteria and/or design specifications; and whether the person doing the design review was independent from the individual who performed the design. The reviewer also held discussions with the engineering personnel in the piping system Site Stress Analysis Group (SSAG) to determine whether they performed their work activities in accordance with established instructions, procedures, and specifications. The seismic responsa spectra with respect to operating basis earthquake (DBE) and safe shutdown earthquake (SSE) were discussed with the responsible g engineers. It was noted that these e^4 -4n
-a - -*^ -ec'~ --
f g_ < e sna u. '~ '
std EW W EM W P ThefoY1owkg major areas were reviewed te determine a conclusion:
(1) IE Bulletin 79-02, Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts, Requirements (a) Factor of Safety foQoncre& Expansion Anchor Bolts DesiQ A review of the Pipe Support Engineering Guidelines Manual, - ~ ~ ~'
Section V, revealed that a * .
'a more conservative value) has been used for establishing the allowable loads (tension and shear) for the wedge bolt calculation. In - "'
, the factor of safety of four could be used (Comanche Peak pipe stpport installations use Hilti wedge bolt only). .L ^ " ' '
(b) Pipe Support Base Plate Design IE Bulletin 79-02 states that pipe support base plate f1, y 4 s 4 , 4 . ,, % a -
s-----
.o ;ne caicuiu.uo J ..in l tp Discussions with the responsible engineers indicated that the pipe support group personnel do consider base plate flexibility into their design calculations.
F" t : 2 . _4 :'La4 Lbase plate flexibility censideration)
W "" _c:" #;r :- m . d (other than four anchor bolts in one plate) +=ea '-': ... a sis. FUB II base plate program has been util*ized for all typical (four anchor bolts in one plate) base plate analysis. The FUB II program generally 1
l l
i 33 produces led :- -~ =h~' S" " - " ^ - *h=a 'ha inads c
approach exceeds the NRC requirements.
(c) Anchor Bolt Tension - Shear Interaction IE Bulletin 79-02 oermits a formula to be used for calcula-tion of coin tension-shear merectiorr. This formula can be interpreted from a linear distribution to an elliptical distribution. Comanche Peak pipe support group has elected to us2 ' ' . z distribution f' - *~'+' -
: - n) for all concrete expansion ancnor bolt calculations.
(2) I ain _ o - Seismic Analysis for As-Built Safety-Related PiW Sy~ , Z :irements This bulletin states that the seismic analysis input information conforms to the actual configuration of safety-related piping systems. Lic 4.r. -
- r. . - - - ' m g _+ .-- --<-- ,,-2 4 __ e..m e--
__ ___7__
AlW W!T!Ntw r cir - " - -
_ .., ..~ v4 we ..~ .aive operator 1.... ...., eno weigats. To . accomplish the above requirements, the site pipe support group and the site stress analysis groups are responsible for verification The as-built configuration is id ..- _,
.+ . This field survey team, which consists of three surveyors and one QA l inspector, is to perform field measurements by utilizing equipment such as transits, levels, theodolities, etc. The high accuracy of the information obtained through the field survey is a highlight for implementing the IE Bulleting 79-14 requirements.
(3) Alternate Analysis for Small Bore Piping Systems The revi_ ewer examined portions of procedure AB-5, A P" "_
rretnoa tor oc .,
- " " - ., : _- -- c'- "', ,, Rev. 5, May 1982. It was noted that tb ;- - " _--- -- d^"alaaad bv Gibbs =ad 2 $3 T-- ___ 42 2 vo~ -- _ ,__ _ _ _
je +-e - . - - , , i~
__ s me ,4- ing ~2,-.,,,.<--
Furthermore, approximately 30% of small bore (2 inches and under) low energy pipe lines in Unit 1 and 10% in Unit 2 are analyzed by the Alternate Analysis Method (i.e., a simplified method for design and analysis of small size piping). The balance of small bore piping is analyzed by the computer application.
(4) Rigorous Analysis for Safety-Related Piping Systems -
M The computer program involved in the analysis is one of the typical programs being used in the l
_ . . . - _ _._.__ _ . - __J.__.-..______ .
34 industry. This computer program,gStatic and Dynamic Pipe Design and Stress Analysis, has Veen developed and upcated by Arthur D. Little, Inc., since the early 1960s.
(5) Iterative Design Process The reviewer held discussions with responsible licensee represent-atives in the area of safety related pipe supports and piping systems. It was noted that the Iterative Design Process was utilized for implementing the design of pipe supports and the analysis of piping systems. In accordance with the licensee's description: "the process for the design of piping and supports is iterative in nature. It is unrealistic to expect to design piping and supports to satisfy all applicable requirements the first time through the process. Such an iterative design approach is employed throughout the nuclear industry, and is utilized in the design of other nuclear components as well." The reviewer noted that the gp , --.4ces a+ -. -. ~. .o,. #2-414 4=e in terms of using the iterative design process in the area of designing pipe supports and piping systems.
(6) Review of Design Calculations for Pipe Support Support No. Pipe Size Pipino System AF-1-002-705-S33K, Rev. 3 10" dia. Auxiliary Feedwater CC-1-158-701-A43R, Rev. 2 16" dia. Component Cooline SI-1-031-709-A32R, Rev. 2 12" dia. Safety Injection SI-1-029-702-S32R, Rev. 2 24" dia. Safety Injection 1
BR-1-AB-001-005-3, Rev. 1 2" dia. Boron Recycle The above design calculations were randomly selected and were partially reviewed for conformance to analysis criteria, applic-able codes, NRC requirements, and the licensee commitments.
Furthermore, these calculations were evaluated during the review l for thoroughness, clarity, consistency, and accuracy. Deflection criteria used for support design were discussed with the respon-sible engineers and were partially verified. Weld size calcula-tion and snubber size determination were also verified for adequacy. In ceneral, the d-'#ra -m'-"'"'-: _rr_..-- 1: i.
_ _ wa .e in t e ... . m ~,.3 wa.r ...r., reference, units (dimension, force, and moment), equations, tables, and sketches.
I
e I
l
. 35 1 1
l (7) Review of Stress Analysis for Piping Systems Calculation No. Piping System AB-1-19A Safety Injection AB-1-30 Containment Spray AB-1-69 Residual Heat Removal anc Safety Injection AB-1-135E Auxiliary Steam and Main Steam AF-1-SB-006 Auxiliary Feedwater 1
)
AF-1-SB-007 Auxiliary Feedwater l J
The above piping stress analyses were partially reviewed fc-conformance to design specification, applicable code, NRC require- ;
muits, and the licensee commitments. These analyses were also evaluated for thoroughness, clarity, consi stency, and accuracy.
The NRC reviewer examined portions of the seismic inputs to be '
used in the stress analysis. These seismic inputs in terms of pe-iods versus accelerations from th'e corresponding floor response spectra curves under OBE and SSE cenditions were partially verified for accuracy. Furthermore, the reviewer belc discussions with the responsible _ engineers to ensure that seismic anchor i
movement, nozzle thermal movement, and valve orientations were '
properly considered in the stress analysis.
During the review the rp '-- . . . - O This 3/4" diameter vent and drain pipe was analyzed for support requirements. Results from the a-t': _. :'^' ' " -- "'
w r" -
-^a h for the pipe.
t C -
_p . The responsible er.gineer stated '
that this CMC was reviewed by a well qualified engineer. Based on his en ineering judgement, no detailed calculations were required.
6 In addition, a- "
to ensure that no other similar _CMCs .were accepted without performing detailed evaluation. The responsible _ lira"mrepre- .
sentative took imme* - -: --- to perform detailed calculations for the vent sno arain piping system due to the addition of the CMC (No. 90567). Furthermore, a sam ling program was immediately initiated to review 50 otFar similar cac aces. This matter will be identified tNComanche Peak Project Director for followup.
e e
36 Results from the detailed calm""~ - bd *%* ao em Jgr as the original evaluation indicated.
- b Pipin ystem AF-1-SB-007 was partially reviewed. It was noted pq .
that -- - _, . . . . . . . . . . - _ . . . ~. m., .. __ _ _ _ . _
Z i h ac*' Some minor mathematical errors were no.e . ne CMC was not addressed properly by the licensee reviewer. The pipe support group reanalyzed this 3/4 inen piping
- system by hand calculations (alternate analysis) and also by computer application (rigorous analysis). Results from the two ,
! analyses were consistent and conservative. Four pipe supports were required by the analysis. Loads used for support design were verified and were found conservative.
- a. -
T- ---*-- '
'_ i l (8) Field Inspection / Verification The NRC reviewer performed a field walkdown at the l' cit 1 containment building area and noted the following discrepancies:
Support No. Status CC-1-218-012-C53K Snubber connection cotter keys missing i CC-1-295-005-C53R Sway strut installed over 5 tolerance
{
CT-1-038-436-C62K Snubber connection cotter keys missing; no washers in rear bracket CT-1-117-405-C62K Snubber connection cotter key missing CT-1-117-415-C62K Snubber safety wire broken CT-1-053-444-C62K The south snubber was installed improperly 00-1-046-020-C65R Snubber cotter keys missing FW-1-096-705-C62K Snubber safety wire broken FW-1-102-002-C62k Snubber cotter key missing; needs relative adjustment on snubber FW-1-102-003-C62K Snubber cotter keys not bent MS-1-151-025-C52K Snubber installed over 5 tolerance CC-1-RB-066-008-3 Snubber cold setting over the limit 6
--,__-,.-+,- - .. , . - . _ , - _ . , . , - - - - - - . - - , -- - ---
37 I
CC-1-RB-066-007-3 Snubber cold setting over the limit CC-1-RB-068-007-3 Spring hanger cold setting incorrect (15 lbs. versus 11 lbs.)
The above pipe supports discrepancies were verified with the licensee's QC inspector in accordance with detailed drawings. All the above pipe supports were vendor certified and were previously inspected by the licensee QC inspectors. The licensee representa- ,
^
tives stated that a final walkdown inspection / verification for all /
pipe supports is to be implemented in accordance with procedure [ ~ 3, CP-QAP-12.1, Inspection Criteria and Documentation Requirements '
f ([ j l
- Prior to System N-5 Certification.
The . '
wh ch l were not installed in accordance with the detailed drawings. The fact that these two supports were inspected by QC is considered as
^
(9) Design Consiceration for Piping Systems Between Safety neiatea and Non Safety-Related Buildings The NRC reviewer held discussions with the licensee representa-tives in the area of piping stress analysis and pipe support design. Stress Analysis No. AB-1-135 E for the Auxillary Steam and Main Steam System was partially reviewed and discussed with respect to design considerations between safety-related and non safety-related buildings. The piping system was classified as high energy line and safety-related. The pipe run starts from the l Turbine Building into the Electrical Control building. Since l seismic classifications for the two buildings _are different, the l criteria used for the piping system analysis should a'TWtie~
diTTerent. TE w_u re_:o r % + -u-' - . . . . Li'-., ,
_- n , 7 + ,, . u 1; 3; -,
y _. . a e , a , ,% ,, .Qg J j f .% a; .,+m . , - _m
- , ---3,,,a ,,," t _ ;--f- The responsible 1 m .oe
- .w -'"'
.- , .;d __ r_.'- -- ; f h with regard to the above concerns. This matter will be ,
identified to the Comanche Peak Project Director for resolution.
(10) Interpretation of Tolerance for Snubber Installation During the field review, three reviewers interviewed the licensee's QC inspectors with respect to their interpretation of five degrees tolerance reauirements for strut and snubber
, installation. These QC inspectors appeared to be confused witir $f2 7 - $
l the interpretation of the tolerances on the detailed drawings.
I e
l
! i j)p S Y~
,- 7 m 38 g,5 9 h e/
The reviewers held discussions with the licensee representatives 1 with regard to the above conce ns. It was determined that the l ,Te n e .
~'*to *k~ .ae e. . on w .euu; - .. ..w . ., . . ~ i J
- -*"'qg(
.+/e-.Ahm. -- ' ~ - ' - - - '
$m 4ae*allA**^^ 2 b_
fo; - ^2 ' - -a--^--
.. cre inov <=. p2pe suppu.. ::-_ ;ons.
Th;, .....c. b: -_ ......cu . . . .m e v...c o n c .cas croJect Dire N icwup.
(11) Final Adjustments for Spring Hangers and Snubber Settings The reviewers held discussions with the responsible licensee representatives with regard to implementing the final adjustments for spring hangers and snubber settings. It was determined that, a&ber c..e le.' ^"';,"- '.....__ "'
___ ..r f . .e ' arm N: ## _' ..wn.. .ap... - . - - - '^ o"<'*D *LS* 2II
- ]__"_-_"*
/
/
ad eaubber< "a "f_:t;- _: . . _.'-va...un. This matter will be #
P o IEe attention of Comanche Peak Project Director for
~
br ,
followup.
(12) Technical Training The reviewer held discussions with the responsible pipe support engineering (PSE) personnel to determine whether they performed their work activities in accordance with established procedures and specifications, and whether the design engineering personnel received proper training with respect to technical applications and NRC requirements.
A review of the training record revealed that since 1980, the PSE personnel have received extensive training activities in terms of technical applications and code interpretations.
Portions of the training courses are listed as follows:
Date Course Attendance (Engineers)
(a) 06/16/80 Introduction to Nuclear All Codes and Standards, QA for Engineers (b) 10/13/80 ASME Code Seminar All 10/14/80 (NF Design Philosphy) -
(c) 04/13/81 Alternate Analysis Method 26 for Small Size Piping (d) 06/21/81 Vent and Drain Piping 8 Seismic Qualification (e) 05/11/82 Design Verification 34 05/13/82 Process e
e w --
. 39 (f) 07/14/82 Pipe Support Snubber 24 07/15/82 Installation (Instructed by Manufacturer)
(g) 07/27/82 Analysis of ASME Class 16 2 and 3 piping (h) 11/12/82 Seismic Analysis of 65 11/16/82 Pipe Supports 11/17/82 (1) 06/14/83 Finite Element Method 19 thru (including ASME 1, 2 & 3 08/06/83 pipin analysis)
(j) 06/29/83 Current Version of ADLPIPE 9 Computer Code (Stress Analysis)
(k) 11/17/83 Quality - It's Your Job All (1) 03/08/84 Snubber Reduction Program 6 (m) 03/19/84 Stability Problem in the 26 Design of Pipe Supports The above trc 2 '^e in the ara = a' ^'-^
' ; __.i.. '"---'"-':--
.rrm_.
.. mJ~__. .. .~ oc.. __ :--" This observation was supported by the extensive discussions with the responsible engineering personnel and by reviewing the procedures and results of the design calculations.
c. Conclusion
Discussicns with the responsible personnel revealed that the enginee-ring per anoe, m.. ' -" '- tha =-^' ^#
stress analveie #-- :r 3 9 7, . e ... . 4ua r . r_ .
"-ts aa-^- __
~-
"a knowledaeabla A review of portions of the alternate analysis criteria and related documents was perfn--od It was noted that the nm.ooos anc r.me.- .. '"
.ic -
c m eria were . __ -A review of the eleven calculation packages indicated that co.T.puter applications were extensively used in ;
the stress analyses, pipe suppcrt designs and, base plate and concrete expansion anchor bolt calculations. Design calculations, in general, were good.
- During the review, the NRC reviever noted that v=,,cc ,u. .- m. ,_ '"-
-a --- '
-These conserva-
,,m-e -< gee 4,- : _
tive considerations iniluced: factor of safety used for concrete ,
expansion anchor bolt calculation, cciputer program (FUS II) used for '
base plate analysis, weld stress allowables for welding connections, ,
^
4 40 c
alternate analysis for small bore piping, and seismic icads used in design and an aly ssi s . These consecutive design considerations are
[/
)' ,j considered strencths in the applicants program. Finally, the reviewer , .,0 noted that the 9.__ __ ,_ __ . . ....a... . . .. ,_;
, ... '. --'_ 4 i .
-': ._ ris( in ne uni tec dtateT in accordance with the criteria e specified in Uniform Building Code. k d S[
^'
p.- . . . , ...e ...-oo> :e>m.. _-
)
_4,,,, me-~^'-'" #-
E a vs a a r t., uso naa oeen previousiy ' /
j- --.e my +so 1 4 ,. n e e , ^ ' -' "-'---
In.o .a... w... a ,. _- d '
to the Cc an--o o=k Dmin-+ -D'~-+^- '- - * - - " " -
- nto
-'m - at cafotv-r ___ g, , 3 4,,1 ,, y, , ___ ,_ L_,_.;_ 5
=-- , - _ - +n verifv +ha+ ~
n' - -----
t^ 'he a N- - .. . _ __ -
_r ie, are acequateiy i mp i =.. 5rted in
,c --- ^ ~ s, a e' M i rW ~ ~ ^ 're s .
_____ ~ . .
- 14. Installation of Safety-Relatec Fiuic Systems
References:
(a) QA-QAP-11.1-26, Rev. 14, "ASME Pipe Fabrication and In-tallation Inspec-tions" (b) QI-QAP-11.1-28, Rev. 23 " Fabrication, Installation Inscection of ASME Component Supports, Class 1, 2, and 3" (c) QI-QAP-11.1-28A, Rev. 5, " Installation Inspections of ASME Class 1, 2, and 3 Snubbers" (d) CP-QAP-12.3, Rev. 3, " Testing Phase Quality l Assurance Functions
- Prior to ASME Code l Certification and
, Stamping" l
(e) CP-QAP-12.2, Rev. 7, " Inspection Procedure and l Acceptance Criteria for ASME Pressure Testing" l
l a. General The review of this area was directed to assessing the adequacy of the l
. licensee's construction program as it pertained to installation of l safety-related fluid systems required for safe operation and shutdown j of the plant. The assessment was undertaken through selective examina-i tion of installed systems and installation related activities to determine whether they were accomplished in accordance with good i engineering practice and with licensee commitments and NRC require-ments - including the requirements of the applicable code, ASME l
l
I 9
41 Section III. The review in this area did not undertake to evaluate the licensee's final checks and analysis of system piping in accordance Inspection and Enforcement Bulletin 79-14, and did not examine attach-ment of the fluid systems to concrete building structures.
- b. Review Effort (1) Tour of Areas Containing Safety-Related Fluid System Components The reviewers toured the Safeguards, Auxiliary, and Reactor Buildings and the Service Water Pumping Station to observe installed safety-related fluid system components for any visually apparent signs of unsatisfactory or questionable items - such as g ,, v visual weld defects, undersize welds, improperly or insufficiently / N
supported piping, damage to more susceptible support components (e.g., snubbers . corrosion, missing or loose fasteners and -
spacers, etc. , was identified duri he t spr..3 w.. 'e #-""
. r.r..., ._
_ _.. a 2 . g i . . . i c 4 ri a uw.iuur .. . . . . . . . . _- ;. e .r; so-inc- The licensee was informed of this spring can, which was identified Serial No. 942-12. The rusting in this item did not appear to be so severe as to significantly impair its function but the course of the rusting and its significance to the functioning should be evaluated further by the licensee.
(2) Control of Welding Materials The reviewers examined the licensee's control of the welding materials used in installation of safety-related piping system components at the issuance stations to verify compliance with code requirements and good practice. Specific attention was directed to the adequacy of the licensee's:
segregation, identification, and control of filler metals, including consumable inserts oven storage of low hydrogen electrodes to limit moisture pick-up preparation of issuance records handling of returned filler metals documentation of current welder qualification limitations The reviewers also observed areas toured in the plant, as des-cribed in (2) above, and plant areas entered for specific item inspections for evidence of inadequately controlled filler materials.
- d. The licensee welding material
42 controls observed by the reviewers met or exceeded code require-ments anc good practice (3) Piping and Supports The reviewers visually examined examples of installed runs of safety-related piping and associated supports to verify they were in accordance with good engineering practice and that they were in compliance with code requirements and with licensee drawing and procedure requirements. Three runs were selected which had most or all of their final acceptance inspections completed. Two of these were nearly ready for the final code review required for ASME certification (referred to as N-5 certification) that the installations were in accordance with the code. The third had the certification complete.
-^- - - '
Th .... ......m.... ... ft,' ; ...;.,r... a2 m:
=*r T ..o on. 1:t, Inc. This contractor was responsible for _
assuring compliance with code requirements, including obtaining code inspector certification therefor (on N-5 Data Reports).
Licensee procedures applicable to and ut.ilized by the reviewers in the examination of piping and supports were examined for compli-ance with code requirements. The procedures were as follows:
(a) QA-QAP-11.1-26, Rev. 14, "ASME Pipe Fabrication and Installation Inspections" (b) QI-QAP-11.1-28, Rev. 23 " Fabrication, Installation Inspection of ASME Component Supports, Class 1, 2, and 3" (c) QI-QAP-11.1-28A, Rev. 5, " Installation Inspections of ASME Class 1, 2, and 3 Snubbers" (d) CP-QAP-12.3, Rev. 3, " Testing Phase Quality Assur-ance Functions Prior to ASME Code Certification and Stamping" (e) CP-QAP-12.2, Rev. 7, " Inspection Procedure and Acceptance Criteria for ASME Pressure Testing" l
l6 I
l t . T
, . 4
-)
.. 43 The runs of piping and supports installed that were examined by j the reviewers were described on isometric drawings. Tne runs examined, identified by the drawing numbers, and the examination checks made by the reviewers are as follows:
Run: 3" Containment Spray (ASME Section III, Class 3), Drawing BRP-CT-1-SB-019, Rev. 6 The reviewers visually selectively examined the installed safety-related piping to verify the following in accordance with the drawing, code, procedures; and good engineering practice:
configuration apparent pipe size valve identification visual appearance of welds heat numbers on pieces 2,10, and 18 and serial number on valve piece 14 were traceable through installation records to original receipt and acceptance records The reviewers examined the records for the above piping to verify the following in accordance with code and procedural requirements:
proper installation and inspection steps completed for all components mill test reports for all materials hydrostatic testing Run: 2" Reactor Coolant (ASME Section III, Class 1), Drawings BRP-RC-1-RB-10, Rev. 8 and BRHL-RC-1-RB-10, Rev. 2.
The reviewers visually examined the installed piping and supports to verify the following, in accordance with the drawings, code, procedures and good engineering practice:
configuration apparent pipe size snubber and spring can sizes offset for snubber RC-1-015-707-C41K spring can settings visual appearance of welds size of piping welds support serial numbers 19050,17791 and 17789 traceable to installation and receiving records heat numbers on material pieces 1 and 12 that were traceable to acceptable mill test reports serial numbers on valves IRC-8057A and -8058A that were traceable to installation and acceptable receiving inspection records e
!l
-\
l d4 l visual appearance of fasteners snubber pins and washers evidence of damage to or deterioration of any components The reviewer examined the records for the above piping and supports to verify the following, in accordance with code and procedural requirements:
proper installation and inspection steps comoleted for piping hydrostatic testing Run: 8" Auxiliary Feedwater (ASME Section III, Class 3),
10" Drawings BRP-AF-1-SB-006, Rev. 17 and BRHL-AF-1-SB-006, Rev. 3 The reviewers visually examined the installed piping and supports to verify the following, in accordance with the drawings, code, procedures and good engineering practice:
configuration apparent pipe size snubber sizes and settings visual appearance and size of welds serial number on valve 1AF-031 traceable to acceptable receiving records snubber pins and washers evidence of damage to or deterioration of any components Note: ,
ammessousadame-The reviewers examined the records for the above piping and i
supports to verify the following in accordance with code and procedural requirements:
i l
proper installation and inspection steps completed for ,
piping
( -
hydrostatic testing t
The licensee's procedures and installation appeared to generally meet or exceed the applicable requirements and were in accordance with good engineering practice. Records proved readily retrievable and complete. Licensee QC inspectors who accompanied the NRC reviewers in their examinations of the l installations appeared knowledgeable. ,
tru
i
! - 45 angles specified by drawing. This concern is discussed in 4 paragraph E.b(10).
l- (4) Residual Heat Removal Heat Exchangers (RHR Hxs Supports)
The reviewers requested the licensee to identify and provide for review the bolting requirements, the drawings and the installation records for the RHR Hxs. The drawings and some of the installa-tion records were provided. The bolting requirements were not identified and the welding records were not provided by the completion of the inspector's visit. The records and information l had been requested about 1 to 2 days before the end of the visit l and licensee personnel indicated insufficient time was allowed to provide all of what was requested.
The reviewers examined the RHR Hx supports for visual weld quality
~(si a nd location were not checke and installation of bolting.
w i yo. .
.. (in accordance with code th Also r . . . . _ ____
'"hm - " " a n d.
l t., 7- ,
. _ _ _ __ _ .... .. __ , pparently inadvertently).
The status of the f,_' A
- ...uns to oe per;. " nn tha Hxs way '
6t the reviewers were informed that a final inspecuan of welds and to verify that bolting was in place and remained to i be performed.
t I As already indicated above, - '-~ '
- c. Conclusions Based on their examination and findings described above, the reviewers $R -[
generally concluded that the licensee's program for installation of safety-related fluid system components assures compliance with require-ments, commitments and good engineering practice. As their assessment .
. ew w_t11 ha N +4 N d to tha Cp ayha n
_ - _ , . . _ , , - _ . , . . , . . _ _ - .,_..,.__,__,._,,,__.,_.,,_,_,4 ,___..m , - , , , . , , , _ . , , , , - , , , . , , _ _,
s 46 G. Civil Construction Activities-
- a. General The objective of this portion of the review was to determine the adequacy of the implementation of the licensee's quality control /
quality assurance program for civil construction activities. During the review selected quality assurance records were examined to verify the records were complete and retrievable. Emphasis was also placed on examination of the document control system. The reviewer examined site civil design activities, including the design change process, proce-dures and QA records for completed work activities such as the SSI dam, selected cable tray supports, and whip and moment restraints; and procedures and work activities for ongoing work including application of protective coatings and testing of Richmond inserts. The reviewer also interviewed QC inspectio'1 personnel.
- b. Review Effort (1) Safe-Shutdown Impoundment Dam, Units 1 and 2 (a) Review of Construction and Quality Control Procedures The reviewer examined specifications, drawings, .and quality control procedures for construction of the safe-shutdown impoundment (SSI) dam. Acceptance criteria utilized by the reviewer appear in FSAR Section 2.5.4.5 and NRC requirements.
Construction of the SSI dam was completed in Spring of 1977.
The dam was designed by Freese and Nichols, consulting engineers, and was constructed by Brown and Root. The onsite quality control inspection activities were performed by Freese and Nichols and the firm of Mason-Johnston and Associates. Quality assurance was provided by Brown and Root site quality assurance group and the Texas Utilities Services, Inc., (TUSI) site QA surveillance group. Documents examined were as follows:
Freese and Nichols drawing numbers FN-SSI-3 through FN-SSI-7, Safe Shutdown Impoundment Dam Freese and Nichols specification FNSSI-1, Contract Specification for Safe Shutdown Impoundment Dam Brown and Root Construction Procedure numbers 35-1195-CCP-2 through CCP-8 Brown and Root Quality Control Procedure CP-QCP-7.1, i Surveillance of SSI Dam Activities e
m
l 47 The Mason-Johnston and Associates Corporate OA Manual and Mason-Johnston field and laboratory testing proce-dures (b) Review of Quality Records The reviewer examined selected records which document quality control inspection and quality assurance activities during construction of the SSI dam. Acceptance criteria utilized by the reviewer are the procedures listed above. Records examined were as follows:
Records of QA workshops conducted by Freese and Nichols and Mason-Johnson and Associates. These workshops were conducted to provide training for field inspection personnel.
Weekly field corrective action reports for April - July 1976 and January - March, 1977.
Results of quality control tests performed on filter materials, and impervious core materials placed between April and July 1976. These records included results of Atterberg Limits, ficld density tests, and proctor tests performed on the imprevious core materials, and results of field density, relative density and mechanical analysis tests performed on the Type A and B filter materials. .
Stop work urders Brown and Root QA Audit Reports Training records of QC inspection personnel Design Change / Design Deviation request numbers FN-81, FN-82 and FN-84 Based on review of the records, the reviewer concluded that the dam was constructed in accordance with the requirements of the construction drawings and specifications and as stipulated in the FSAR. The records were neat, legible, complete, and retrievable.
(2) Unit 1 Reactor Building Internal Pipe Whip Restraints (a) Review of Quality Control and Construction Procedures The reviewer examined specifications, drawings, and quality control procedures for construction and inspection of the pipe whip restraints in the reactor building. Acceptance e
.. 48 criteria utilized by the reviewer appear in Section 3.8 of the FSAR. The pipe whip restraints are non-ASME since they are not attached to the piping. The restraints are treated as part of the reactor building internal structure and are constructed in accordance with the American Institute of Steel Construction (AISC) Standard Practices, as is all other non-ASME structural steel members (cable tray supports, structural steel building frames, stairwells, non-ASME equipment supports) in the power block. This is standard industry practice. The whip restraints were fabricated by the Chicago Bridge and Iron (CB&I) Company. Onsite installa-tion was performed by Brown and Root. Documents examined by the reviewer were as follows:
Gibbs and Hill Specification 2323-SS-16B, Structural i Steel (Category I)
Gibbs and Hill Drawing numbers 2323-S1-0581, 0581-01, 0584, and 0585, Reactor Building Internal Structure, Pipe Whip Restraints TUGC0 Instruction Number QI-OP-11.14-1, Inspection of Site Fabrication and Installation of Structural and Miscellaneous Steel The reviewer also examined the outstanding (unincorporated) design changes against the above specification and drawings.
There were 29 DCAs against the specification, 12 against, drawing number 0581, 3 against drawing number 0581-01, 11 ~
against drawing number 0584, and 11 against drawing 0585.
The re' wer examined the document packages maintained in DCC Satellite 306 for the above specification and drawings and verified that they were complete and contained the latest (current) revisions of the drawing and design changes.
(b)
The reviewer, accompanied by a QC inspector, examined pipe whip restraint numbers M-22 and M-25 which are located in steam generator compartment numbers 4 and 1, respectively, on elevation 900 of the reactor building. Acceptance criteria utilized by the reviewer are those documents listed above.
Examination of these and other restraints on the 900 eleva-tion, and discussions with the QC inspector and design engineers, disclosed the following problem. DCA number 14,813, Rev. 2, against drawing number 2323-S1-0581 revises the erection notes for the whip restraints to require installation of Jam nuts (or spoiling of threads) on bolts which have nuts installed hand tight for holes noted on the drawings. Discussions with various design engineers and the e
e
l 49 inspector disclosed that there was some confusi the use of Jam nuts was reauired_. In addition, t as to wherea J zev.cn '
"n' =a1 liirgrrons wnere w ., r.%s,M ~ '#
__;_ - - _m u n- wo -, r e w c,.,i_ & - =
hewumempo. This item will be turned over 'to the Comanche /t T-Peak Project Director fer followup.
(c). Review of Quality Records The reviewer examined quality records documenting construc-tion (site erection) and QC inspection of whip restraint numbers M22, M25, and M-37 on elevation 900 of the Unit 1 reactor building. These records included weld travelers, QC inspection of structural steel bolting, QC inspection af welaing, and as-built drawings showing as-built dimensions, elevation and location for the restraints. The reviewer noted that inspections for installation of Jam nuts required per DCA 14813, R2, was not documented in the inspection packages. There was no resolution of this item during the review, therefore, this item will be refered to the Cemanene Peak Proje:t Director for followup and resolution. The reviewer did not examine the CB&I whip restraint fabricatica records.
(3) Review of Nonconformance (NCR) 10453 The reviewer examined NCR 10453 which was written to document and disposition a problem which developed during field erect. ion of four moment limiting component supports on the feedwater lines in the Unit 1 Safeguards Building. The supports, which are ASME components, are similar to pipe whip restraints. The purpose of a-the supports, which were erected around the feedwater lines, is to limit movement of the pipes during pipe break accidents. The restraints are constructed from heavy beams and columns which were fabricated offsite by CB&I. During field erection of the restraints (which was acaplished by Brown and Root) cracks developed in welds rhip at ached small (6 inch by 9 inch) gussett plates to the colurn v e
- ams when the bolts in the beam-column connections were tirt xi The reviewer examined the NCR and discussed the corrective action with QC inspection personnel. Review of the NCR disclosed that it had been revised five times. Some of these revisions resulted from changes to the corrective action after further evaluation of the problem. Other revisions were as a result of changes to the administrative handling of the NCR, e.g., to repair all four restraints under one NCR is lieu of writing a separate NCR for each restraint. These types of revisions are normal during disposition of NCRs. Review of the NCR and discussions with responsible inspectors disclosed that the problem was resolved by removal of the damaged gusset plates (i.e., the plates where welds
g:
, i O
I
- r ; , 50
- , had cracked) from the b'eam and columns, non-destructive examina-tion (NDE) of the base n.atal in the beams and columns at the points where the gusset plates had been attached, fabrication of new gusset plates, and rewelding of ~ the new gusset plates to the beam columns. The reviewer examined selected auality records associated with repairs of one of the restraints, including weld travelers, PT inspection report number 19059 and 19054 and design documents including CMC 96060 and Brown and Root drawing number MSB-0683-CBI. The corrective action to resolve this NCR was completed in March 1984.
(4) Unit 1 Cable Tray Supports (a) Review of Quality Control and Construction Procedures The reviewer examined specifications, drawings, and quality control procedures for construction and inspection of cable tray supports. Documents examined by the revieveer were as follows:
- G&kDrawingNumber2323-El-0713-01-S,CsbleTraySupport Plan, El 792'-0"& 790-6", Aux & Elect. Control Bldgs.
- - G&H Orawing numbers 2323-S-0901, C302, and 0903, Cable Tray Support Details, Sheets 1-3
,- G&H Specification number 2323-S5-168, Structural Steel (Category T) .
Brown and Root drawing number FSE-00185, Sheets 1-3, 3 Reference Drawing for Cable Tray Hangers Brown and Root drawing number FSE-00159, sheet numbers 527, 537, 557, 2895, 2898, 2904, 2905, 2908, 12530, 12600, 12608. These are the . fabrication drawirgs for the cabie tray . hanger supports. The sheet number corresponds with the hanger number.
The reviewer also examined the outrtanding (unincorporated) design changes ag/ inst the above G&H drawing. There were 344 CMCs and 19 GCAs against drawing 0713-01-S, 6 CMCs and 9 CCAs against drawing 0901, 4 CMCs and 10 DCAs against drawing 0902, and 26 CMCs and 29 DCAs against drawing 0903.
The reviewer examined the document packages maintained in DCC Satellite 306 for the above drawings and verified that they were complete ar.d contained the latest (current) revisions of the design changes. During examination of the design changes the reviewer noted that the majority of t em h were originated as a result of minor constructien problems. For example, most of the design changes to drawing 0713-01-S, which is the N
i a
l 51 cable tray support location plan, were as a result of interferences encountered during construction and were requested by construction personnel. These interferences required relocation of some of the supports shown on this drawing. Dften the relocated supports were only moved a few inches.
(b) Field Inspection of Cable Tray Supports The reviewer, accompanied by a QC inspector, examined randomly selected cable tray supports located on eleva-tions 790'-6" and 792"-0" of the electrical control building.
The supports and the acceptance criteria utilized by the reviewer appear in the table below.
TABLE Support Applicable Number
- Supcort Type Desion Chance 527 8-2 (Dwg 0901) CMC 8250 537 D-1 W/ Brace -
(Dwg 0901) 557 A-1 (Dwg 0901) CMC 94628 DCA 1946 DCA 2687 2895 SP-2 (Dwg 0903) QMC 50474 2898 SP-2 (Dwg 0903) CMC 4521 CMC 2646 2904 SP-2 (Dwg 0903) CMC 52473, R2 DCA 3494 2905 SP-2 (Dwg 0903) DCA 6299-R7 CMC 2646 2908 B-2 (Dwg 0903) -
.12580 B (Dwg 0601-015) CMC 61731 12600 A (Dwg 0500-04-5) CMC 67033 12608 SP-7 (Dwg 0903) CMC 68393 CMC 1969 DCA 19973
- Support number and location shown on B&R drawing number FSE-00185
~
._ _ ~ ,
52 During the field inspection, the reviewer verified the following were in accordance with requirements specified or design drawings: method of attachment to wall and/or ceiling, dimensions, elevation of support, proper size of structural steel members, joint connection details, and configuration of support.
The reviewer also walked down- other areas in the auxiliary and electrica! control building and examined cable tray supports for general configuration and quality of workman-ship. During examination of supports in the Unit 1 cable spreading room, the reviewer noted that six and eight inch siderails had been added to four inch deep trays. The practice of increasing the height of siderails on cable trays and its effect on the design of cable tray supports was examined by the reviewer. Details of this review are discussed in paragraph G.b.(7).c below.
(c) Review of Quality Records The reviewer examined quality records documenting constr7c-tion and QC inspection of the cable tray supports listed .in the paragraph above. These records included construction travelers, weld filler material logs, and cable tray inspection reports for installation of cable tray hangers, cable tray clamps, and installation of expansion anchors or Richmond Inserts. Based on review of the records, and the walkdown inspection discussed above, the reviewer concluded that the cable tray supports were constructed and inspected in accordance with the requirements of the construction drawings. The records were neat, legible, complete, and retrievable.
(5) Inspection and Testing of Richmond Inserts (a) Review of Program for Verification of Installation of Richmond Insert Bolts During review of records, the licensee determined that documentation of QC inspections were incomplete for installa-tions of Richmond Insert bolts. In order to verify that bolts of the proper length were installed in the Richmond Insert sleeves, the licensee carried out a reinspection program for the Richmond Insert bolts. The reviewer examined TUGC0 procedure number QI-QP-11.14-8, Verification of Installation of Richmond Insert Bolts, which was used to control the reinspection program. During the reinspection O
l 53 program, QC inspectors verified the length of the bolts either through ultrasonic testing or physical measurement, and checked bolt diameter, minimum embedment length, and
" snug tight" condition of the bolts. The reviewer discussed the reinspection program with mechanical QC inspectors responsible for its implementation in the electrical control building. Based on review of the procedures and discussions with the QC personnel, the reviewer concluded that the reinspection program to verify installation of the Richmond Insert bolts was comprehensive.
(b) Observation of Testing of Richmond Inserts The licensee is performing extensive onsite testing of the Richmond Inserts to confirm the strength values used in design of structures using this type of anchorage. The reviewer examined TUGC0 Engineering Instruction number CP-EI-13.0-13 which specifies the method of installation of test specimens, and describes the test apparatus and specifies the technique used in application of the test l o , .'s . The reviewer examined the testing . apparatus and .
verified that the test equipment had current calibration stickers. The reviewer observed the tension test of specimen 28, a 1 inch EC-2W Richmond Insert, and the shear-tension test of specimen 6, a 1 inch EC-6W Richmond Insert. During the tests, the reviewer verified that application of the test load was accomplished in accordance with the procedure requirements and that the test data was accurately recorded.
Following completion of the above tests, the reviewer examined the results of tension and shear-tension tests that had been previously completed and _ noted that those results were consistent with the results of the tests witnessed by the reviewer. The majority of the modes of failure resulted in failure of the high strength bolts, not the concrete or insert sleeve. The reviewer also examined the concrete cylinder unconfined compressive test data to verify the strength of the concrete was recorded for use in evaluation of the test results.
(6) Program for Application of Protective Coatings in the Unit 1 Containment Building (a) Review of Specification and Quality Control Inspection Procedures The reviewer examined specifications and quality control procedures for application and inspection of Service Level I protective coatings, for steel structures, including the polar crane and liner plate, inside the Unit i reactor building. Acceptance criteria utilized by the reviewer l
I' l
s-s 54
, appear in ANSI Standard N101.2-1972 and FSAR Section 3.8.1.6.5.g.
Procedures examined were as follows:
G&H Specification 2323-AS-31, Protective Coating, TUGC0 procedure number CP-QP-11.4, Inspection- of Protective Coatings TUGC0 Procedure number QI-QP-11.4-1, 11.4-5, 11.4-17, 11.4-22, 11.4-26, and 11.4-28. These procedures cover inspection of storage and handling of protective coating materials, surface preparation, application of the primer and finish coats, and when necessary, coating repairs.
TUGC0 Procedure Number QI-QP-11.4-23 and 11.4-29. These procedures cover reinspection and testing of coated steel for which inspection documentation was incomplete.
(b) Observation of Protective Coatings Work Activities The reviewer witnessed application and inspection of protective coatings on steel structure inside the Unit i reactor building. During this onsite review the bulk of tM protective coating application work in progress consisted of repairs to the primer and finish coats, and surface prepara-tion for application of coatings. The reviewer verified environmental conditions were being monitored and were acceptable in the reactor building at time of application of coating. The reviewer observed that application of the coatings and QC inspection of the coatings were being performed in accordance with NRC and procedure requirements.
c (7) Onsite Civil Design Activities (a) General Onsite civil design activities are performed by Gibbs and Hill (G&H) civil-structural engineers who work under the-direction of the G&H lead civil-structural engineer who reports to the TUGC0 Nuclear Engineering Manager. The onsite G&H engineers have access to the FSAR, codes, standards and design criteria, and copies of the original design calcula-tions. The bulk of the design work presently being performed onsite relate to review and approval of design changes (CMCs and DCAs). Many of the design changes are originated at the request of construction personnel and involve minor changes, usually due to construction interferences.
W 6
-.- m__-- __ _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _
i
- i
. -l
. 55 l (b) Review of the Design Change Program The reviewer examined G&H Project Guide-29, Site Review of
+
CMCs, DCAs and S-0910s. This procedure establishes the guidelines under which onsite design change reviews are performed. Acceptance criteria examined by the reviewer were ANSI N45.2.11 and NRC requirements (Criteria III to Appendix B, 10 CFR 50).
The reviewer discussed the design change program with lice se engineers. These discussions disclosed that when a req;ost for des 1gn change is made by construction craf: or QC personnel, the design change is prepared by civil project engineer. During preparation for the design change request, the civil project engineer usually performs some preliminary calculations in order to arrive at a feasible and workable solution to the problem. After the design change request is prepared, it is transmitted to the G&H onsite design engineers and to construction. Construction personnel implement the design change "at risk." That is, if the G&H design engineers do not approve the design change, a removal notice is issued and the work affected by the design charge is either removed or reworked in order to comply with the approved design change request. Discussions with licensee engineers disclosed that approximately 99 percent of the design changes are approved by the G&H design engineer without revisions and therefore, do not require rework after they are implemented by construction. After receiving the design change request, G&H civil engineers perform a detailed review. Approval of the design changes consists of a
- detailed review by an engineer, followed by an independent review by another engineer serving as a checker. If the design change does not meet the requirements of the design criteria, it is revised as necessary. After it is reviewed and approved, the design change is distributed per procedural requirements.
The reviewer examined randomly selected design changes which had been made to drawing number 2323-El-0713-01-S, Cable Tray Support Plan. These included two which were currently being reviewed by the G&H design engineers, (CMC 8229, R12 and CMC 8235, R3), several which had recently been reviewed and approved by the G&H design engineers, and several 'others which had been reviewed by G&H engineer since 1979, the last date drawing 0713-01-S had been revised.
Based on this limited review of the design change control program implemented at the site, the reviewer concluded that design changes are being properly reviewed and that 6.
design changes are being accomplished in accordance with NRC ,
requirements.
6
s 56 (c) Review of Cable Tray Loading As discussed in paragraph G.b.(4) above, the reviewer noted during field walkdown inspections that siderails had been raised on some cable trays'in order to accommodate additional electrical cables. The reviewer also noted that fire barrier materials, commonly known as thermolag, were being added to the cable trays (electrical raceways). The reviewer examined the design controls usad to verify the structural adequacy of the cable trays from the increase in loadings due to the addition of thermolag ind/or addition of cables to the trays.
Details of the review are discussed below.
Evaluation of Effect of Thermolag Fire Barriers on Structural Adequacy of Cable Trays / Supports The reviewer examined TUGC0 engineering procedure CP-EI-4.0-49, Evaluation of Thermolag (TSI) Fire Barrier Material on Class 1E Electrical Raceways. This procedure outlines the program to be implemented to verify that cable trays and supports meet se i::mic design criteria after installation of the thermolag is completed. The program will verify that the combination of the weight of the cables in the trays, the dead weight of the trays, and the weight of the thermolag will not exceed the maximum design allowable load of 35 psf. The procedure outlines steps to be followed when the allowable design load is exceeded. The reviewer discussed this program with licensee engineers who stated that the "as-building" of the cable trays to account for the installation of the thermolag will begin in the near future.
After the as-building program is completed, the evaluation of the effect of additional weight of the thermolag on the cable trays will be performed per procedure CP-EI-4.0-49 require-ments. This area is being referred to the Comanche Peak Project Director for followup.
Evaluation of Increases to Height of Cable Tray Side Rails During the field walkdown discussed above, the reviewer randomly selected for review three four-inch cable trays in the Unit 1 cable spreading room which had 6 or 8 inch side rails. These were tray numbers T-13-0CC-007, T-13-GCC-M10, and T-13-GCC-M33. The above trays are 30 inches wide. The reviewer examined sheets 1 and 12 of drawing number 2323-El-0712, and the 133 DCAs against sheet I and 4 DCAs against sheet 12. These drawings detail the layout and size / type of the above cable trays. The reviewer also examined the document packages I
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l 57 maintained in DCC Satellite 307 for the above drawings and verified that they were complete and contained the latest (current) revisions of the design changes. From review of the design change documents, the reviewer verified that addition of the 6 or 8 inch side rails to the 4 inch deep trays was authorized by DCAs. For example, the addition of 8 inch side rails to cable tray 13-0CC-Q07 was authorized by DCA 15207.
The reviewer discussed the effect that raising the side rails of cable trays has on the tray and support design load of 35 psf with project civil and electrical engineers. These discussions disclosed that the side rail depths were increased because cable extended above the side rails of the 4" deep trays. This often occurs at intersections (TEES) of trays and is a result of cable pulling problems. The engineers statet that whenever the height of siderails is increased, the total loading of the trays is checked to verify it is below the design allowable of 35 psf. The cable load for each tray is documented in the G&H Cable Raceway Schedule, 2323-E-1-1700. Various other schedules maintain the identity of each cable in each tray and the weight of each cable. The raceway schedule expresses capacity of the trays as percent filled. Review of the schedules disclosed the data shown in the Table below:
TABLE Tray Number Number of Cables Percent Filled T-13-0CC-Q07 198 28 T-13-GCC-M10 288 31 T-13-GCC-M33 217 28 From review of the cable schedule, the reviewer deter-
, mined that the average weight of the cables in tray T-13-0CC-007 was approximately 0.11 pounds per linear foot. Therefore the cable load in this tray is (number of cables)(w +/ cable) = (198)(.11) pound /ft =
8.8 PSF Width of tray = 2.5 Ft This is well below the design allowable load value.
Based on review of the above schedules and discussions with responsible engineers, the reviewer concluded that the design values used to determine the structural adequacy of cable tray supports are conservative.
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. 58 (8) Personnel Interviews The reviewer conducted informal interviews with nine civil and six mechanical QC inspectors. Subjects covered during the interviews were the inspector training program, ability to discuss their safety concerns with their management and/or the NRC, cooperation between craf t and QC personnel, and availability of technical assistance from engineering personnel. From the interviews, the reviewer concluded that the QC inspectors felt freedom to express their safety concerns to management and/or the NRC, that the inspectors felt that craft personr.el were aware of the require-ments to do the work properly, and that the craft recognized the importance of QC inspection activities and cooperated with the inspectors. The inspectors stated that ergineering assistance in resolution of problems was available whenever they requested it.
The interviews al:o disclosed that the licensee has an extensive training program which the inspectors are required to complete prior to becoming certified and being able to inspect and accept work. The training program involves classroom training, on the job training, and passing written and practical exams (the exams contain essay typ questions, not multiple choice). The training program for the inspectors performing inspection of structural steel protective coating involved 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of classroom training and 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of on the job training. The inspectors did state that the large number of unicorporated design changes against some drawings made their jobs more difficult at times, but most said that after working in an area for a period of time they became familiar with the changes and were able to overcome this problem.
- c. Conclusions (1) The licensee has effectively implemented the QA program require-ments in the areas examined by the reviewer.
(2) QC inspectors are knowledgeable of their inspection requirements and perform their inspection in accordance with the licensee's QC procedures.
(3) The licensee's QC inspector training program is comprehensive.
(4) The licensee's present document control system is good. Though the number of unincorporated design changes against some drawings is large, the availability of a package containing a complete set of the documents made review of the documents possible without too much diffculty to an experienced inspector. The licensee's new unique DCC system (use of computers) exceeds NRC requirements in the area.
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59 (5) The quality records examined by the reviewer were neat, legible, retrievable, and complete. ,
(6) One negative point noted by the reviewer is the larger number of unincorporated design changes against some drawings. This results in a cumbersome package to be reviewed when performing work or inspections. This item allows opportunity for errors and requires additional time to be consumed for work to prevent these errors.
The reviewer did not identify any hardware problems resulting from the licensee's system, except for the item identified in paragraph G.b.(2) above.
(7) The design change process is controlled and complies with NRC requirements. The "at-risk" design change process described in paragraph G.b.(7) above is not unique since it has been used on other nuclear construction projects. The design change program is laid out, but could allow for implementation problems if not meticulously followed.
H. Review of Heating Ventilation and Air Conditioning Systems (HVAC)
References:
Drawings, standards, and specifications applicable to this equipment are as follows:
Hanger Dwg. SG-790-2J-1R, Rev. O Hanger Dwg. SG-790-2J-1V, Rev. O Hanger Dwg. SG-790-2J-R18, Rev. O Hanger Dwg. SG-790-1J-R1L, Rev. 1 Hanger Dwg. SG-790-1J-10C, Rev. O Hanger Dwg. SG-790-1H-R1G, Rev. 0 -
Hanger Dwg. RB-832-1E-1A, Rev. O Hanger Dwg. RB-832-1E-1L, Rev. O Dwg. 2323-M2-0651-HAN, Rev. 2 Dwg. 2323-M2-0651-HBSC, Rev. 1 Dwg. 2323-M1-0651-HAN, Rev. 6 Dwg. 2323-M1-0651-BSC, Rev. 6 Dwg. 2323-M1-0551-BSC, Rev. 10 Dwg. 2323-M1-0551-HAN, Rev. 9 Dwg. 2323-M1-0554-BSC, Rev. 12 Dwg. 2323-M1-0554-HAN, Rev. 7 Dwg. FCUS-0010-HAN, Rev. 5 Dwg. 2323-S1-0600, Rev. 17 Dwg. MC-134-680C Dwg. MC-143-689C Dwg. DCA 3262, Rev. 1 Dwg. ANS D1.1 Specification 2323-MS-85, Rev. 3 Procedure WP-TUSI-001, Rev. O Procedure DFP-TUSI-003, Rev. 8 e
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- a. General The reviewer conducted
- um J. containment, auxiliary building, safeguards building, and building for both units to generally observe quality, work in prugress, material control, and protection of HVAC equipment, as well as weld rod control. Discussions were held with craft and inspection personnel during these tours relative to plant quality.
- b. Review Effort Previous discrepancies identified by NRC regarding HVAC installation served as a driving force for this review effort. A review was made of evaluations and calculations performed as a result of the previously identified problems. In addition, the reviewer observed HVAC ducting and supports for conformance to applicable drawings, specifications, and standards'.
The reviewer generally observed ducting in various areas of the containments, auxili uy building, safeguards buildings, and control building for both units for proper bolting, proper gaskets, and structural integrity. In addition, the inspector observed duct and equipment supports for conformance to requirements. Supports reviewed included unit 2 duct hangers 2J-1R, 2J-IV, and 2J-RIB; Unit I duct hangers 1J-RIL, IJ-10C,1E-1A, IE-1L, and 1H-RIG; floor mount of Unit 1 Train A Containment Spray Pump Room fan coil unit; and the two unit 1 Safety Injection Pump Room Fan Coil unit hangers.
- c. Conclusion No significant problems were identified relative to ducting. Only minor problems, ,, ell within previous discrepancies evaluated, were found in duct supports. Dimensional variations were noted in the hangers for Safety Injection Pump Room Coolers. These deviations were analysed during the review indicating that these hangers were accept-able. Several minor drawing errors were also noted which were corrected during the review. The evaluations and corrective actions performed as a result of previously identified problems with HVAC installation appear to be adequate.
I. Formal Interviews of QA/QC Personnel 4
- a. Formal interviews were conducted of QA/QC personnel in order to assist in assessing site quality and management support of site quality. It was felt that discussions with inspection personnel would give a good conservative insight into whether or not the plant was being const-ructed pronerly. Interviews of five management personnel and twenty-eight inspectors were conducted. Inspectors were selected at random with one exception. Electrical inspectors were primarily selected from a group of inspectors which had recently been involved in a personnel O
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. 61 h incident involving a dress code "(Tee Shirt)" issue in order to assess whether these persons had significant technical concerns. In addition,
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two electrical inspectors indicated a desire to talk to NRC and were interviewed. Several additional electrical inspectors were chosen in addition to inspectors in various other disciplines.
. The group included inspectors working for eight different supervisors.
. Experience of these personnel ranged from persons who had been in QC E less than a year, to persons who had been at Comanche Peak from early construction (mid 1970s). Most had some previous experience such as site craf t, non-nuclear industry or military experience. Some had j worked at other nuclear facilities.
- The major thrust of the interviews was to determine if the personnel
- had any plant safety or quality concerns. Concerns in these areas were i solicited from all those interviewed. Discussions of other subjects f were also held with most of the individuals interviewed. These '
l' subjects included intimidation, support for identifying problems, ability to have problems evaluated and corrected as necessary, feedback a on evaluation of problems, adequacy of training program, and relation-7 ship with NRC.
All but two inspectors stated they felt the plant would be safe which i meant they had no. significant quality problems which they felt would compromise safe operation. One inspector, who was not sure of the i plant's safety, stated .he was assigned to an area which was less controlled than he was used to, e.g., non-ASME code work versus ASME code work (which has the most stringent requirements), and was uncomfortable with the leeway allowed in this area. This person also indicated he had doubts about QA at nuclear plants in general. The other individual who was unsure of plant safety indicate he was satisfied with quality with one exception. This involved a specific problem which he was not sure was adequately evaluated. This item was described to the NRC:RIV Senior Resident Inspector for followup. Two inspectors who stated they had decided on their own that they wanted to talk to NRC, expressed very strongly that the plant quality was
( " excellent" and there was no plant safety concern. Another inspector, L with over twenty years' experience, who was at his fifth nuclear plant said Comanche Peak was the "best" plant he had seen.
Seven inspectors expressed one or more specific concerns. These i concerns involved questions on whether a particular procedure require-ment or whether a particular technical evaluation was appropriate, 9 documentation problems not involving quality of construction, questions b whether certain personnel transfers were discriminatory, inaccuracies L
in some written Nonconformance Report (NCR) evaluations, and concerns which had recently been brought up and were yet to be evaluated by the i licensee. All concerns have been forwarded to the Comanche Peak
- Project Director for followup for review and evaluation as necessary.
1 Several concerns were given to NRC:RIV personnel during this inspection l and followup showed that there was no technical problem identified.
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62 The NRC Resident Inspector was familiar with one of the concerns and had already evaluated the condition as technically acceptable. Several addftional concerns were given to RIV personnel verbally on the last day of this inspection for timely followup.
The special team interviewer reviewed the concern regarding transfers of six of seven individuals mentioned in the personnel transfer concerns. These transfers appeared to be non-di scrimi nato ry . It should be noted that in all cases of concerns involving specific hardware discrepancies these discrepancies had been identified to appropriate licensee personnel and had b,een or were being evaluated.
All in:pectors questioned (21) as to their ability to identify problems such as via NCF.s, indicated no suppression in this area. Several inspectors indicated that NCR written evaluations could be more clear and cceplete in some cases.
Feedback regarding problems, such as via explanations of NCR evalua-tions, was considered good by 19 of the individuals questioned. One individual indicated he did not always receive complete feedback but these items did not involve significant technical concerns. Two individuals stated they felt uncomfortable with some "use-as-is" NCR evaluations. One stated that more feedback was needed as to reasons for procedure changes.
Many of the in:pectors indicated that communications were improving and the assignment of the new site QA manager was a positive step in improving communications. It was clear that some communications problems had existed in the past and rapport between inspectors and their management had been strained previously in some areas. Communi-cations in the ASME code construction area appeared to be exceptionally positive.
All but a few inspectors were questioned regarding intimidation by craft. No significant problems were identified although two indivi-duals mentioned two incidents when the craf t were upset with inspectors when problems were found. No threats were made during these incidents.
Generally, the rapport between craft and inspection appeared to be very good.
Adequacy of the training program was discussed with approximately half of the inspectors. Several indicated that the formal training could be better, i.e., tougher (not necessarily more extensive) but formal l training, plus on-the-job training was adequate to perform the inspection functions. Many stated that the training was excellent.
Twenty inspectors felt no hindrance at all to talking with NRC and indicated that the freedom to talk with NRC has been continually stressed by management. Several indicated some apprehension about talking with NRC which appeared to be a natural fear of the position e
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63 NRC holds. Several were under the impression for a short while that they must have their "act together" if they were going to see the NRC, but now appear to feel no hindrance. Most indicated they saw NRC inspectors regularly in the field but a majcrity indicated that they had not talked directly with NRC in the field.
Interviews of management indicated tFey were very supportive of inspectors and sensitive to inspector concerns. There appeared to be a strong encouragement for personnel to come forward with any concerns, as evidenced by a memorandum dated March 22, 1984, to all QA/QC personnel from the Site QA Manager. Postings indicating management support for inspectors and other personnel in identifying problems were prominently displayed along with NRC Form 3, NRC Information Notice 84-07 and 10 CFR 21 information.
In summary, although some concerns were expressed recuiring further review, these concerns did not appear to be excessive in number or serious and would be normally expected during the interview process.
Generally, the most experienced inspectors had a high confidence in the quality of the plant. Past problems in communication and some past apprehension about management support had existed but there : ems to have been a marked improvement in this area. No one indicated that past communication problems had caused them to not perform inspections properly or not to identify problems when found. Inspector freedom to identify problems and freedom to talk with NRC has apparently been strongly stressed. Management appeared to be sensitive to employee concerns and appeared to be seriously evaluating existing concerns.
- b. In addition to formal interviews, numerous informal discussions were held between the NRC team personnel and site managers, craft, inspec-tors, engineers, and office personnel as indicated previously in other sections of this report. The comments received from these individuals were consistent with those received during the formal interviews.
These discussions covered topics such as plant quality, training, management support, and document control.
Appendix A, which follows, is a sanitized listing of concerns raised by individuals during the interview process. The concerr., are only those which will require followup by the Comanche Peak Project Director.
The interviews were sanitized only so far as confidentiality is related.
3 64 i
APPENDIX A Inspector Name: A-1 Date Interviewed:
General
Background:
Interviewee Comments:
Uncomfortable with less structured program for non-ASME versus ASME; e.g. , seem to change dwg. when structure doesn't meet original, can add welds in field and he doesn't think it gets incorporated into dwg., QC lead can approve changes to travelers for non-ASME structures, not much QA involvement in this area.
Specific: Procedure QIQP 1114-12, electrical mounting backfit, craft complained so procedure was revised to reduce number of inspections, 4 revisions made to delete requirements (bolt tight-ening,etc.)
Has the impression that QA has been generally deficient at nuclear plants and QC has not been supported at Comanche Peak in the past.
Indicated main problem is probably him being able to adjust to non-ASME work: is not aware of code violations taking place.
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- 65 Inspector Name: A-2 Date Interviewed:
General
Background:
Interviewee Comments:
Has some concern with use-as-is NCR situations, use-as-is seems particularly prevalent when using Specification ES-100.
Specific Technical Concern: NCR was writter when cable damage occurred during Biso Seal removal using a threaded rod. This occurred in Auxiliary Building, elev. 832'. NCR said no damage was done to cable but some insulation had been scraped off by rod. Feel further evaluation may be in order for these cables and there may be similar problems elsewhere.
Specific: Wrote 2 NCR's regarding traceability of fuse blocks.
Blocks were not marked "Q". NCR said OV as-is because no non-Q .
blocks were purchased via order MS-605. Feels other similar non-Q blocks have been purchased via different purchase order and could have been installed as Q. Thinks this a possible paperwork problem.
Specific: Wrote recent NCR (not yet evaluated) on GE Motor Control Centers. Compression lugs have bends as much as 180 degrees (more than normally done done by site construction).
Don't think GE can violate requirements and may be a problem elsewhere in GE MCC's. Also have some broken wire strands which we are fixing as we find.
Specific: Had previous paperwork conflict problem in solving rework of terminal blocks. 6 page RFIC involved and Proc. SAP-6 involved. Wrote 2 NCR's. NRC inspectors Creek and Johnson were aware, Creek told NRC inspector Taylor, Taylor told to have an answer. Never got feedback as to results.
Specific: Repaired a solenoid, shortly af+.er coming to Comanche Peak in craft, without paperwork. Pon't know if it was safety related. Not concerned with soir.noid technically - did a good job.
Notes: The specific concerns were given verbilly to the SRI - Construction on 4/12/84 for further_ followup. It was indicated during the interview he would get more specifics for SRI. MCC problem was still being evaluated. I -
suggest allowing the licensee to evaluate and then followup for adequacy of corrective action.
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.. 66 Inspector Name: A-3 Date Interviewed:
General
Background:
Interviewee Comments:
Generally concerned with finding numerous problems during past construction inspection and procedure being changed to delete inspection, e.g., loose terminations found in lighting.
Some NCR's are answered simply that the problem is not addressed in Specificatian ES-100.
Recent NCR written because restraint cable (lighting) crimp gages were worn & therefore, inspection was inadequate. This is still being evaluated.
Wires cf two different gages were terminated at some lugs and many terminations are loose. _
Have more pressure not to write NCR's during turnover.
Found loose LB's (elbow termination fittings) @ East & South ends of Unit 1 Diesel Generators, wrote two NCR's, was accepted as is.
Found cables not trained (routed) in workmanlike manner in Unit 1 Cable Spread Room 9 junction boxes 1058 and 1059. NCR said OK because cable radius was OK but did not admit workmanship problem.
Feels post construction inspectors were transferred to Unit 2 as retaliation for finding problems.
Heard second hand that IR's (inspection reports) were being written falsely (without reinspection) to clear IIRN's (discrep-ancy report) on cable trays. Heard from lady in paper Flow Group (PFG) and lady in vault. Said he would get back to NRC with more specifics.
Notes: Some review of the lighting termination issue and post check procedure was conducted by team member Ruff. The site inspector indicated he had told of most of these issues and QA was evaluating. I forwarded concern relative to 1058 & 1059 junction boxes to RIV: Martin and he indicated he inspected these boxes and sees no technical problem. Resident Inspector: Smith partic-ipated in most of the interview and indicated he was aware of the D/G loose fittings and sees no technical problem. I evaluated reasons why 6 personnel including were transferred to Unit 2 and this move does not appear to be discriminatory.
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- 67 Inspector Name: A-4 Date Interviewed:
General
Background:
Interviewee Comments:
Uncomfortable with some use-as-is situations, e.g., cable separation problem found in fuel building during walkdown did not meet procedure but was evaluated as use-as-is. He can show someone where it is.
Wrote NCR on lack of 5-thread engagement on a conduit fitting
- poor evaluation in that they simply said that couldn't see it; a second NCR was written en this area for cable damage, seemed to be looking for a way to buy this area off, took two tries to get everything evaluated. knows about this but didn't get back to him on fact that NCR's were poorly handled, i.e. , non-tech-nical aspects.
Feels discriminated against in that he was transferred to Unit 2 where there is no overtime. Got grilled on cable damage NCR at the same time as being counseled on a personnel issue so it appeared that his transfer had something to do with NCR.
Management is aware of this concern.
Note: I did not review this person's transfer situation.
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- s 68 Inspector Name: A-5 Date Interviewed:
General
Background:
Interviewee Comments:
Had problems with post' check, e.g., loose lighting terminations and junction boxes. Took lighting out of procedure and made it more difficult to look at junction boxes. Management was made aware of these concerns. (Has no significant safety concern)
More tendency toward use-as-is when pressure is on (safety requirements are being met, however)
Has had some fear of talking with NRC, didn't think reporting on-site would ever get off-site, doesn't have NRC RIV phone number Feels discriminated against by being transfarred to Unit 2 Some NCR evaluations are inaccurate or unclear, e.g., statement that workmanship was not compromised when in fact w?rkmanship was poor but the item was technically acceptable Notes: I reviewed the transfer situation; appears to be reasonable but not as clear as reasoning on other 5 transfers. NRC Form 3 appears well posted so I'm not sure why he doesn't have the number. He does not appear to fear talking with NRC now.
Although, he stated he does not have significant safety / quality concerns, his comment on NCR answers is interesting. Similar general comments were received from other inspectors and this could indicate a need for better answers on NCR's. An example would be that if a workmanship question was not addressed properly then perhaps needed retraining of personnel as preventive action would not get performed. Perhaps the licensee needs to improve in this area.
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69 Inspector Name: A-6 Da*.e Interviewed:
General
Background:
Interviewee Comments:
Added higher sides to some cable trays to keep cables in trays Also there may be cable density / compaction problem in this area It's tough to keep people off trays to keep from damaging them
- - Have had problems with clearance of pipe a'nd cables, have to notch insulation, place metal between insulation and trays There is alot of rework to get proper separation Notes: This man was questioned primarily to get input for RIV review of cable spread room as to where there could be problems. He personally has little problem with plant quality. RIV - Martin was at the interview and verbal feedback on the first two items indicated that the situations were acceptable.
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.o 70 Inspector Name: A-7 Date Interviewed:
General
Background:
Interviewee Comments:
Had problems with Paper Flow Group (PFG), when first implemented, with completeness of packages. Getting better and does not know of safety problem involved Some inaccurate NCR answers Site has problem with lost records, 2 people are assigned full time in the vault, NCR's are not written on lost records, reinspect when record is lost but this reinspection may be very difficult or very impractical . He has no evidence that reinspections are not getting done. This problem could relate to competance of PFG people, i.e., maybe they lost records.
Note: Various special team members looked 'quite extensively at records.
Results are in the team report.
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