ML20212H332

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Rev 1 to Comanche Peak Response Team Results Rept Issue- Specific Action Plan I.a.1, Heat-Shrinkable Cable Insulation Sleeves
ML20212H332
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 12/30/1986
From: Beck J
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20212H304 List:
References
NUDOCS 8701210363
Download: ML20212H332 (31)
v • d • e


Text

i 1 em COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.a.1

Title:

Heat-Shrinkable Cable Insulation Sleeves REVISION 1 O

A I ~

m 8 Iss'ue Coordinator Da(e '

d 1)s&fL A Keview m Leader 12/u/%

Datl /

owl ed. lL Jop W. Beck, Chairman CPRT-SRT

/2/3a ha Date O

B701210363 370116 PDR ADOCK 05000445 A PDR

Revision: 1 Page 1 of 30 RESULTS REPORT

, ISAP I.a.1 i

Heat-Shrinkable Cable Insulation Sleeves

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7 Page J-29)

"All splices inspected were missing the ' nuclear heat-shrinkable

, cable insulation sleeves,' as required by paragraph 3.2.15 of the procedures for 600-volt control and instrumentation connections.

"...the lack of awareness of where the heat-shrinkable sleeves should be installed, as reflected in the QC inspection form, when

, the high percentage of missed and/or improperly documented

l. inspections requiring witnessing, indicated that craft and inspection personnel lacked familiarity with these procedural requirements. This apparent lack of familiarity may be indicative of poor training."

1 2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Item

6. (d)(1), Page J-31)

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

4

! Provide additional QC inspector training with respect to the areas

! in which nuclear heat-shrinkable sleeves are required on splices and ensure that (1) such sleeves are installed where required, (2)

I all QC inspections requiring witnessing for splices have been i performed and properly documented..."

3.0 BACKGROUND

Heat-shrinkable insulation sleeves are installed over certain types of electrical connections in order to provide electrical

( insulation, including an environmental seal. In a typical installation these sleeves are placed over a crimped or bolted i'

connection and shrunk into place using either a hot air gun or a torch. Proper heat-shrinking is indicated when there is (1)

uniform shrinking, (2) smooth consistent contact between the sleeve i and the cable, and (3) presence of red adhesive flow at each end of

! the sleeve. Some installations involve kits with two or more

[ sleeves. In this case each sleeve is installed separately, and the above inspection attributes apply to each sleeve.  ;

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.t5 R:vicien: 1

'q Page 2 of 30 RESULTS REPORT i ISAP I.a.1 '

(Cont'd) i

3.0 BACKGROUND

(Cont'd) j Heat-shrinkable insulation sleeves are used as required to complete

, the installation of:

I Uninsulated butt-splices Class IE 480 V and 6.9 Kv motor terminations Cable reduction splices Electrical penetration assembly cable connections i The butt-splices inspected by TRT were AMP Pre-insulated Environmental Sealed (PIES) splices. Heat-shrinkable insulation sleeves are not required for AMP PIES splices, since they were qualified for their intended use without such sleeves *.. However, at the time of the TRT inspection, QC Procedure QI-QP-11.3-28,

" Class 1E Cable Terminations", Revision 21, dated June 8, 1984, did

! not specifically state that these splices were not to be included in the class of connections requiring installation of a heat-shrinkable insulation sleeves. That omission is what probably

led to the TRT findings. Though no actual hardware discrepancy had thus been identified, due to the TRT concern over the apparent lack of awareness of where heat-shrinkable insulation sleeves are

! required, the CPRT Action Plan that is described in Section 4.0 of this report was formulated to ensure that sleeves for the above

connections and splices are installed where required and are
g inspected.

I 4.0 CPRT ACTION PLAN i

i 4.1 Scope and Methodology The plan consisted of two basic parts. The objective of

{ Part I was to clarify procedural requirements and provide additional training to TUGC0 craft and QC inspectors with '

respect to the installations for which heat-shrinkable

' insulation sleeves are required.

, y <r i

! l ,/, l The objective of Part 2 was to provide reasonable assurance i

f (

g that heat-shrinkable insulation sleeves had been installed f- where required and inspected. This was accomplished via a i

sampling program that was designed in accordsuce with l Appendix D of the CPRT Program Plan.

  • These splices are the subject of ISAPs I.a.2, " Inspection Reports on Butt-Splices," and I.a.3, " Butt-Splice Qualification."

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U - - .- - -. .- .- - - .---.-.--.-. - - . - - - - - -

7-R. vision: 1 Pago 3 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.1 Part 1 - Procedure Revision and Additional Training The following subtasks were implemented in order to clarify the requirements regarding the installation of heat-shrinkable insulation sleeves:

1 i'

- The craft Construction Procedure EEI-8,

" Class IE and non-Class IE Cable Terminations " was revised to clearly identify installation requirements for heat-shrinkable insulation sleeves including hold points for process control.

The Quality Control Inspection Procedure, QI-QP-11.3-28, was revised to clearly identify locations where heat-shrinkable insulation sleevss are required.

Inspection report (IR) forms were revised to provide for clearer documentation of inspections involving heat-shrinkable insulation sleeves.

The following subtasks were implemented in order to provide additional TUGC0 craft and QC inspector ,

training:

- Craft personnel were trained to the revised procedures, t

Quality Control inspectors were trained and certified to the revised procedures.

4.1.2 Part 2 - Sampling, Records Review and Reinspection A records review of irs for the termination of cables, j for which heat-shrinkable insulation sleeves were required, was implemented to determine if there was conclusive documented evidence that sleeves had been installed where required and inspected. This records review was conducted on a sampling basis in accordance with the guidelines of Appendix D of the CPRT Program Plan. A sample review was considered to be a reasonable approach for the following reasons:

. Rsvision: 1 Page 4 of 30 RESULTS REPORT' ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

No programmatic deficiencies had been identified.

The population of locations where heat-shrinkable insulation sleeves are required was considered to be homogeneous.*

4.1.2.1 Identification of Required Sleeves The first step in this records review was to identify the population of all locations where heat-shrinkable insulation sleeves are required. These sleeves are installed on electrical penetration assembly connections, motor terminations, uninsulated splice connectors, and cable reduction splices (splices from one size cable to a smaller one in order to facilitate termination). Since O '

all such devices may not require these sleeves (due to various configuration details), a population was identified that consisted of those locations where these sleeves could have been required.

4.1.2.2 Random Sampling The sampling plan was de' signed to provide a l 95/5 screen in accordance with the guidelines of Appendix D of the CPRT Program Plan. The minimum sample size required to achieve this level of screening was determined from l Appendix D. The sample items were reviewed I to ensure that systems that are important to

safety were represented.
  • During the conduct of the ISAP one subset of the population (cable reduction splices) was judged to have a different process by which

! sleeves are specified to be installed. As discussed in Appendix A, Item 2, this subset was treated separately from the remainder of i

the population.

1

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Rsvision: 1 Pcgs 5 of 30 RESULTS REPORT 3.(N ISAP I.a.1 I

(Cont'd) l

' 4.0 CPRT ACTION PLAN (Cont'd)

The irs for each randomly-selected location were reviewed to determine the existence of

, conclusive documented evidence that heat-shrinkable insulation sleeves had been installed and inspected. If such evidence did not exist, a reinspection or design review was performed to determine whether sleeves were both required and installed. If sleeves were found, they were further inspected to the post-installation criteria listed in Section 4.5.2. For randomly-selected locations that were determined not to require sleeves, additional samples were selected to ensure that the required minimum sample size per Appendix D was met. j 4.1.3 Inspection for Additional Cable Reduction Splices Cable reduction splices are field-installed and are-used as needed to facilitate termination. As a result, they are not identified by specific quantity and location on project drawings. All known locations of ,

cable reduction splices were included in the population.

In order to ensure that all possible locations for cable reduction splices were considered, an additional seven (7) cables and twenty-six (26) pieces of equipment containing cable configurations possibly requiring reduction splices were visually inspected to

, determine whether or not reduction splices were used..

These were all of the itene for which it may have been necessary to reduce the size of the cable to facilitate termination. Had splices been found in any of these cables or pieces of equipment .the associated IR would have been reviewed to verify that there was i documented evidence that the required sleeves ha'd been inspected.

4.1.4 Use of Results When deviations were found, Nonconformance Reports (NCRs) were issued by TUGC0 to document the finding and O initiate corrective action. Any deviations were evaluated for safety significance and adverse trends, j and to determine root causes and generic implications, as necessary, in accordance with the requirements of

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R; vision: 1 Pegs 6 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) the CPRT Program Plan. Results of the actions under this Action Plan were evaluated to identify any appropriate corrective action needed.

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

4.2.1 CPSES Project 4.2.1.1 Revised inspection and construction procedures. Retrained craft and inspection personnel.

4.2.1.2 Identified locations where heat-shrinkable insulation sleeves may be required.

b 4.2.1.3 Processed NCRs that were generated due to this action plan.

4.2.1.4 Reviewed. sample items to ensure that systems that are important to safety were represented.

4.2.1.5 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Provided the sampling plan.

4.2.2.2 Reviewed the revised inspection and i construction procedures to verify that the installation requirements for heat-chrinkable insulation sleeves were clearly identified.

4.2.2.3 Reviewed all third-party irs and TUGC0 NCRs that were generated due to this ISAP.

4.2.2.4 Evaluated document review and physical reinspection results and associated TUGC0 responses and resolutions.

Revision: 1 Pago 7 of 30 0 RESULTS REPORT ISAP 1.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.5 Determined root causes and generic implications, and evaluated safety significance and adverse trends.

4.2.2.6 Selected samples to be reviewed.

'{

4.2.2.7 Reviewed inspection documents for compliance with the acceptance criteria.

4.2.2.8 Personnel (prior to October 18, 1985)

Mr. M. B. Jones, Jr. Review Team Leader <

Mr. E. P. Stroupe Issue Coordinator 4.2.2.9 Personnel (starting October 18, 1985)

. Mr. J. J. Mallanda Review Team Leader Mr. J. R. Pearson Issue Coordinator Mr. M. B. Jones, Jr. Third-Party Adviser Mr. E. P. Stroupe Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Selected samples to be reviewed.

4.2.3.2 Reviewed inspection documents for compliance with the acceptance criteria.

4.2.3.3 Conducted reinspections.

4.2.3.4 Personnel Mr. J. L. Hansel Review Team Leader 4.3 Qualification of Personnel Where tests or inspections required the use of certified inspectors, qualification at the appropriate level was to the requirements of ANSI N45.2.6, " Qualification of Inspection, O

Examination, and Testing Personnel at Nuclear Power Plants".

CPRT third-party inspectors were certified to the requirements .

of the third-party employer's Quality Assurance Program, and specifically trained to the CPRT Program Plan.

(

Rsvision 1 Pcgs 8 of 30

' RESULTS REPORT ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

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

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

4.4 Procedures The following procedure was developed for use in the third l party reinspections:

Instruction No. QI-003, " Procedure for Class 1E Heat-Shrinkable Cable Insulation Sleeves - CPRT Action Item I.a.1."

{

4.5 Acceptance Criteria 4.5.1 The acceptance criterion for the inspection documents was:

there'is conclusive documented evidence that ,

the sleeves have been installed and inspected (in those cases where sleeves are subsequently determined to be required).

4.5.2 The acceptance criteria for any reinspected location that actually required installation of heat-shrinkable insulation sleeves were:

complete heat-shrinking of visible sleeves (evidenced by smooth consistent contact between sleeve and cable, the sleeve being uniformly shrunk onto the cable, and presence of red adhesive flow at each end of l the sleeve);

where inner conductor splices have been covered by an overall sleeve, there is no bottleneck effect, which would indicate the

( inner conductor splices have not been staggered; and I . . _ _ _ _ _ . . _ . _ _ _ _ _ _ _ . _ . , _ . , , ._ . _ _ _ , _ . _ _ ,_m.. _ _ _. _ _ , _ _ _ , . , , _ _ _ _ . _ . _ _ _ _ . , . . . , _ - _ _ , _ _ . . , - - . . . _ _

Rsvision: 1 Page 9 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) the outer surface of the sleeve exhibits no blistering or flaking, which would indicate overheating.

4.6 Decision Criteria The decision criteria were as follows:

If any IR does not contain conclusive documented evidence that heat-shrinkable insulation sleeves have been installed and inspected, a reinspection or design review shall be performed by third-party personnel to determine if sleeves were both required and installed. If it is then determined that sleeves were not required *, an additional randomly-selected population member will be added to the sample. If instead it is determined that sleeves were required, the sample will constitute a documentation deviation, and the location will be further inspected to determine whether sleeves were installed -

O in accordance with Section 4.5.2.

can also be identified.)

(Thus, hardware deviations 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summary This action plan consisted of two basic parts. Part 1 involved revising craft Construction Procedure EEI-8, " Class 1E and non-Class IE Terminations," and QC Inspection Procedure QI-QP-11.3-28, " Class IE Cable Terminations," to clarify the installation requirements for heat-shrinkable insulation sleeves. After these changes were incorporated into the subject procedures, craft and QC personnel were trained to the revised procedures. These activities are discussed further in Section 5.2.

Part 2 of the action plan was initially formulated to determine, by means of a document review using a sampling approach, whether heat-shrinkable insulation sleeves had been installed where required and inspected. Additioral activities, beyond the ISAP scope presented in Section 4.0,

  • For example, in some cases electrical penetration assembly pigtail leads were of sufficient length to reach a terminal block, and thus, no field splicing was necessary.

+

Rsvision: 1 Pags 10 of 30 RESULTS REPORT O ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) were undertaken to assess the CPSES Project QC involvement in

~

the installation of both the heat-shrinkable insulation sleeves and the underlying electrical connections. Part 2 activities are discussed in Section 5.3. Other CPRT activities related to this Action Plan are discussed in Section 5.4. The results of safety-significance, adverse trend, and root cause analyses, and generic implications evaluations are presented in Sections 5.5 through 5.8.

Recommended corrective actions are presented in Section 5.9.

5.2 Procedure Revision and Additional Training As discussed in Section 3.0, the QC procedure revision (QI-QP-11.3-28, Revision 21) in effect at the time of the TRT investigation did not specifically state that heat-shrinkable insulation sleeves are not required for AMP PIES splices.

Revision 22, dated December 10, 1984, incorporated changes that identify clearly the locations where these sleeves are O' required. This revision specifically states that heat-shrinking is not required for insulated butt splices.

This procedure was also revised to identify clearly installation requirements for heat-shrinkable insulation sleeves (Revision 24, dated June 13, 1985). Substantially the same information was incorporated into craft Construction ,

Procedure EEI-8 (Revision 5, dated June 13, 1985). Due to the various types of heat-shrink kits utilized, the procedures reference the manufacturer's instructions accompanying the kits rather than providing detailed procedural installation instructions for each specific configuration.

Further, although the QC procedure had required the inspection i of both splice and sleeve installation, no associated hold

! points were stated in the craft procedure. Therefore, the i craft procedure was revised to state explicitly the required

( hold points. (As discussed in Section 5.3, the third-party

[ document review checked whether the inspection of splice and sleeve installations had been performed when required.)

, In addition to the above procedure changes, the IR form was i revised to provide for clearer documentation of inspections.

Some of these changes were

(

j 1) Separate line items were provided for documenting different types of splices and terminations.

I l

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Rsvision: 1 Page 11 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

2) The "short form" IR, which was intended for documenting post-installation verification inspections, was eliminated in order to preclude the possibility of it being used in the wrong application. (Instances
involving the misuse of this form are discussed in d

Section 5.3.)

The craft and QC personnel have been trained to the revised procedures in accordance with applicable site procedures.

The Electrical Review Team has reviewed the revised procedures _

and verified that the installation requirements for heat-shrinkable insulation sleeves are clearly identified.*

5.3 Results of Document Review and Reinspection A review of inspection documents of cable terminations was conducted in order to determine whether there was conclusive documented evidence that heat-shrinkable insulation sleeves O had been installed where required and inspected. Additional activities were undertaken to assess the CPSES Project QC involvement in the installation of both the heat-shrinkable insulation sleeves and the underlying electrical connections.

This document review was conducted on a sampling basis in accordance with Appendix D of the CPRT Program Plan. The population identification is discussed in Section 5.3.1.

Though the action plan originally required a document review of sixty samples, various additional document reviews and related activities were undertaken by CPRT. A summary of the events leading to these additional activities, and a

description of the activities themselves, is provided in Appendix A. Where evidence of sleeve installation was not found, reinspections or design reviews were performed to determine whether sleeves were both required and installed.

Where sleeves were found, they were inspected to the i acceptance criteria of Section 4.5.2.

l l In the process of carrying out the ISAP steps, a number of l deviations and out-of-scope findings were noted, primarily by l the third-party document reviewers. Each deviation and valid out-of-scope finding has been forwarded to TUGCO for resolution. The Electrical Review Team has reviewed the NCRs generated by TUGC0 for adequacy of technical disposition and

  • See Section 5.3.3 for a discussion of additional procedure changes needed as a result of hardware reinspection findings.

, Rsvision: 1 Page 12 of 30 RESULTS REPORT

(

ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) has provided comments to the CPSES Project for resolution.

The Electrical Review Team will ensure that these comments are resolved. Each deviation and valid out-of-scope finding has also been communicated formally to the QA/QC Review Team Leader (RTL) for consideration in the collective evaluation program. In addition, several findings related to other CPRT ISAPs or DSAPs were forwarded to the appropriate RTLs.

Deviations are discussed in Sections 5.3.2 and 5.3.3. Other related issues are discussed in Section 5.3.4.

5.3.1 Population Identification and Sample Size A population of locations that might have required installation of heat-shrinkable insulation sleeves was assembled. The population consisted of Class IE essential and associated cables in Unit 1 and Common that were terminated using electrical penetration assembly cable connectors, motor termination kits, or

. g j. uninsulated butt-splices (used to terminate electrical devices), and those for which cable reduction splices were known to have been used to facilitate termination.*

Based on the population size, which was determined to be 1359**, the minimum sample size req'uired by Appendix D of the CPRT Program Plan was determined to l be sixty. As detailed in Appendix A, one hundred l

eleven (111) randomly-selected samples, plus all known cable reduction splices and several other miscellaneous itees, were actually reviewed. A review of the sample items confirmed that systems that are important to

safety were represented.

l l

  • Cable reduction splices are used only when necessary to facilitate termination. Known reduction splices were identified by TUGC0 via craft interviews, installation and design document review, and physical examinations. The total number of known cable ends that had been spliced by cable reduction splices was fourteen.
    • This total includes only those electrical devices with pigtail leads that were in harsh environments. As detailed in Appendix A, an extended population consisting of electrical devices with O pigtail leads in mild environments was later identified and reviewed.

Rsvision: 1 Pags 13 of 30

N RESULTS REPORT

[U ISAP 1.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

To ensure that no additional cable reduction splices existed in Unit 1, an inspection of all equipment with configurations that might have led to the use of these splices was performed by third-party inspectors. No additional splices were found.

5.3.2 Documentation Deviations The acceptance criterien for the document review was that there be conclusive documented evidence that heat-shrinkable insulation sleeves had been installed where required and inspected. Of one hundred eleven (111) randomly-selected items, two were found where such documented evidence did not exist. Additional reviews conducted by the Electrical Review Team uncovered two additions 1 cases where such evidence also did not exist. Each of these findings is discussed below. (Sample number designations used below are

() explained in Appendix A.)

5.3.2.1 Sample Number 60-11 The IR for cable EG113717 indicated installation and inspection of splicing, but contained no evidence of installation of heat-shrinkable insulation sleeves. A l reinspection found heat-shrinkable insulation sleeves to be installed. TUGCO issued NCR E-86-102939 to document this finding.

5.3.2.2 Sample Number 35-08 The inspection of this termination (cable AG100925) had been improperly documented by using a "short form" IR that was intended for post-installation verification and that did not contain a line item for inspection of heat-shrinkable insulation sleeves. No evidence of either splicing or installation of heat-shrinkable materials was indicated.

(The craft connection card did, however, indicate use of the applicable Raychem heat-shrink kit.) A reinspection found O

heat-shrinkable insulation sleeves to be installed. TUGC0 issued NCR E-85-100253S to document this finding.

Rsvicion: 1 2 Page 14 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) '

5.3.2.3 Sample Number RS-08 (Cable Reduction Splice)

The IR for cable EG102866 indicated splicing as "not observed," and made no reference to heat-shrinkable insulation sleeves. The inspection of this. cable termination had been made at the time that Revision 0 of the QC Procedure QI-QP-11.3-28, dated November 21, 1979, was in effect, and that revision did ,

not contain a requirement to inspect heat-shrinkable insulation sleeves. A reinspection found heat-shrinkable insulation sleeves to be installed. TUGC0 issued NCR E-85-100266S to document this finding.

i 5.3.2.4 Sample Number SF-01 The inspection of this termination (cable i O EG100924) had been improperly documented by using a "short form" IR that was intended for post-installation verification and that did not contain a line item for inspection of heat-shrinkable insulation sleeves. No evidence of either splicing or installation of heat-shrinkable materials was indicated.

A reinspection found heat-shrinkable

insulation sleeves to be installed. TUCCO issued NCR E-86-103551X to document this finding.

l l 5.3.3 Hardware Deviations l

l Section 4.5.2 lists the acceptance criteria that were l used for the reinspection of heat-shrinkable insulation l sleeves. Five (5) such locations were actually l reinspected *. The results of reinspections performed i

for this ISAP with respect to these criteria are discussed below, i

l

!

  • Sample Numbers 60-11, 35-08, RS-08 and SF-01,-as discussed in f Section 5.3.2; and Sample Number RS-05 (see footnote to Section 5.3.3.1).

1

R vision: 1 Pass 15 of 30

'g RESULTS REPORT

ISAP I.a.1 i (Cont'd) 5.0 IMPLEMENTATION OF. ACTION PLAN AND DISCUSSION OF RESULTS .(Cont'd) 5.3.3.1 Complete Shrinking of Visible Sleeves t

In one case (Sample Number RS-08, also see Section 5.3.2.3), the sleeve was not uniformly shrunk and did not maintain contact

with the cable (EG102866) throughout the entire length of the sleeve. TUGC0 issued l

NCR E-85-100266S to document this finding.

In a second case (Sample Number RS-05*),

there was no visible red adhesive flow evident at the upper end of the sleeve for either of the two conductors of a cable (E9102538) that had been spliced with cable reduction splices. TUGC0 issued NCR E-86-103328X to document this finding, i

The three remaining installations were found

() 5.3.3.2 to be acceptable for this attribute.

No Apparent Bottlenecks There were no cases identified where this condition was not met.

5.3.3.3 No Blistering or Flaking on Outer Surface of Sleeve i

There were no cases identified where this condition was not met.

The inspection of cable EG113717 (Sample Number 60-11) found that the heat-shrinkable insulation sleeves were -

installed over a laminated braided jacket on the vendor cable. This condition was initially considered to be a deviation, because the Raychem instructions require braided jackets to be removed from the area of sleeve installation. However, discussions by the CPSES Project with Raychem and the equipment vendor (American Air Filter Company) revealed that the material identified as the " laminate" was actually a glass

  • This item is not among those with documentation deviations, since _

the inspection records do contain conclusive documented evidence of Os, installation and inspection. However, since it was installed prior to the addition (in Revision 1 of QI-QP-11.3-28) of the requirement i

to inspect sleeves, the Electrical Review Team requested this additional reinspection.

i 4 s Rsvision: 1 Page 16 of 30

, RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) shield and was the correct surface on which to install

^

the sleeves. The Electrical Review Team has recommended that the craf t and QC procedures be revised to include more detailed requirements on the removal of braided material. The CPSES Project has agreed to make these changes.

5.3.4 Related Issues In addition to the ISAP objectives stated in Section

4.0, an assessment was made of the CPSES Project QC involvement with the installation of both heat-shrinkable insulation s.leeves and the underlying
. electrical connections. The initial approach to this task was to determine whether sleeves and splices had been inspected (verified or witnessed *) in accordance with site procedures. Three issues that arose during this assessment ars discussed below

!O l

j 5.3.4.1 Terminology The document review initially identified several connections as " unsatisfactory" since the irs did not indicate that the splices had been verified or witnessed. TUGC0 QA l responded that for several sleeve installations, the underlying connections were referred to and documented as

" terminations" rather than splices, and thus the irs were acceptable. Third-party personnel confirmed that the subject irs did indeed indicate that the connections had been inspected.

  • " Witness" is an inspection methodology that requires the QC inspector to physically observe the entire operation being performed. In contrast, " verify" is an inspection methodology that allows the QC inspector to physically inspect an item after performance of an operation. (Reference QC Procedure CP-QP-18.0.)

The requirement to witness splicing was added in Revision 5 to QC l Procedure QI-QP-11.3-28, dated August 7, 1980 (Revisions 0 through 4 had required verification). The requirement to witness heat-shrinkable insulation sleeves was added in Revision 10, dated O December 4, 1981 (Revisions 1 through 9 had required verification; Revision 0 included no requirement for sleeve inspection).

Rtvision 1 Paga 17 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) i

! 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.4.2 Splices and Sleeves Indicated as Verified Rather Than Witnessed The document review initially identified many of the samples as " unsatisfactory" on the basis of record entries that indicated that the splice and/or sleeve had been " verified" or " verified rather than witnessed". These findings fell into two categories. The first involved installations performed prior to the QC procedure requirements to' witness these items. The second was due to conflicting information in the QC procedure (evidenced on the IR form) as to whether splices were to be witnessed or verified. Specifically, the procedure required witnessing and the IR form indicated a "W" (for "vitness") activity, but the IR imperative was phrased, " Verify

() heat shrinkable nuclear cable sleeves".

In response to the above issue, TUGC0 QA reviewed those irs that had been identified by third-party document reviewers as " splice and/or sleeve verified rather than witnessed." The review found that each inspection had been performed in accordance with the procedures in effect at the time of the inspection. Further, each of the following fcur (4) attributes was found to be l _

marked " SAT" on each IR:

i

" Verify proper length of exposed conductors."

" Verify proper tools (Note:

applicable only when this inspection is actually observed)."

l l

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s Rsvision: 1 Page 18 of 30

'N RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

" Verify proper lug or connector / connections type, size and final crimps."

" Verify heat shrinkable nuclear cable sleeves."

Since some of these important attributes could only be verified in-process, and due to the relatively short duration of the installation prccess TUGC0 QA concluded that the implementation of these inspection items.

effectively resulted in the witnessing of the l process, even at times when witnessing was not explicitly specified in the QC procedure.

The Electrical Review Team reviewed the same irs to determine the inspection results for O each of the four attributes listed above.

This review found that these four attributes had been verified on those irs rev.iewed by TUGC0 QA. However, this review was extended to sample items that had been indicated as

" satisfactory" and thus were not included in the TUGC0 QA analysis, and some irs were found where some of these attributes were not marked as verified *. The Electrical Review

Team concurs with the TUGC0 QA analysis for i

cases where the attributes were all verified.

However, since these attributes were not always verified, and conside_ ring the documentation deviations discussed in Section i 5.3.2, there is insufficient evidence to provide reasonable assurance that there was adequate QC involvement in every ,

, heat-shrinkable insulation sleeve installation.

5.3.4.3 Short Form IR Used

, In addition to the two cases discussed in i

Sections 5.3.2.2 and 5.3.2.4, a third case was found where the termination of a cable (AG100920, Sample Number 60-28) had been

  • These findings have been forwarded to TUGC0 for resolution, and to the QA/QC RTL for consideration in the collective evaluations under that program.

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Revision: 1 Page 19 of 30 Q RESULTS REPORT

'V ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) k documented using the "short form" IR. In this case, however, a line item, " nuclear heat shrink," had been written on the IR and marked as satisfactory. Though the wrong form had been used, the Electrical Review Team found that there was conclusive documented evidence that sleeves had been installed and inspected, and thus this did not constitute a documentation deviation.

TUGC0 issued NCR E-85-1000395 to document i

this finding.

4 5.4 Related CPRT Activities 5.4.1 Unit 2 centrifugal Charging Pump The previous Electrical RTL discovered a heat-shrinkable insulation sleeve installation on one phase of the 6.9Kv contections to the motor of a Unit 2 centrifugal charging pump. There was no evidence of red adhesive flow at one end of the sleeve. TUGC0 issued NCR E-85-100699S to document this finding. As

part of the disposition of this NCR, the subject sleeve was removed and examined by TUGCO. This examination 4

found that the heat-shrinking had been sufficient to meet the manufacturer's requirements for obtaining a

proper environmental seal.

5.4.2 ISAP I.a.2, Phase III

! As part of the TUGC0 activities for Phase III of ISAP I.a.2, " Inspection Reports on Butt Splices," many heat-shrinkable insulation sleeves will have been reinspected. One such reinspection, which has been completed, found a' sleeve installation overlapping the fiberglass braid on the vendor's cable connected to Cable E0119865A. TUGC0 issued NCR E-85-101657S to -

document this finding. Any additional results of Phase

{

III of ISAP I.a.2 pertaining to heat-shrinkable

insulation slaeves will be presented in the Results
Report for that ISAP.

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1 Rsvision: 1 Page 20 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND' DISCUSSION OF RESULTS (Cont'd) 5.4.3 ISAP VII.c ISAP VII.c, " Construction Reinspection / Documentation Review Program" includes a reinspection and document review of randomly-selected Class 1E cables.

Heat-shrinkable insulation sleeves that are installed on any of those cables will be reinspected. The results will be reported in the Results Report and/or working files for that ISAP.

5.5 Safety Significance Evaluation None of the four documentation deviations was determined to be safety-significant, since the absence of conclusive documented evidence of heat-shrinkable insulation sleeve installation and inspection would not by itself result in the loss of capability of the sleeve to perform its intended safety function.

O Neither of the two hardware deviations was determined to be safety-significant. In each case, the heat-shrinkable i

insulation sleeves were not located in harsh environmental areas. Though the sleeves were not installed in full accordance with the manufacturer's instructions, the installations were adequate to provide electrical insulation in a mild environment.

5.6 Adverse Trend Evaluation Part 2 of this ISAP had a very specific objective - to determine from document reviews whether there was conclusive documented evidence that heat-shrinkable insulation sleeves had been installed where required and inspected.

, Reinspections were used only in cases where the documentation

! did not provide such evidence. Accordingly, five installations of these sleeves were reinspected. Two of these installations were found not to conform fully _to the manufacturer's instructions. A related deviation has been discovered for ISAP I.a.2, as discussed in Section 5.4.2. The Electrical Review Team considers it likely that similar deviations remain undetected, and that such deviations, if occurring in harsh environments, could compromise the integrity of the environmental seals. Therefore, an adverse

/N trend has been identified.

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Rsvision: 1 Page 21 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.7 Root Cause Analysis An analysis was performed to determine the root cause(s) of

, the adverse trend discussed above. Due to the low number of hardware deviations (2) and actual reinspections (5), the i

analysis is only preliminary. The corrective actions (see Section 5.9) will result in significantly more data being available. The analysis presented below will be reassessed at that time.

! Each deviation that led to the adverse trend included the failure of craft personnel to install heat-shrinkable insulation sleeves in accordance with the manufacturer's (i.e., Raychem's) detailed instructions. The potential root causes of this aspect are:

inadequate craft procedures governing the installation of these sleeves; i -

inadequate craft training in the installation of these r sleeves; I

craft personnel inadequately qualified to perform the j specific work activities; and 1 -

inadequate craft supervision.

Further, each deviation that led to the adverse trend included the failurs of the QA/QC program to detect the discrepant installation. The potential root causes of this aspect are:

inadequate QC procedures governing the installation of these sleeves; inadequate QC inspector training / certification; QC inspector (s) inadequately qualified to perform inspections of these sleeves; and inadequate QA/QC supervision.

The governing craft procedure is EEI-8, " Class 1E and Non-Class 1E Cable Terminations". This procedure specifically makes reference to the manufacturer's instructions O accompanying each kit, and requires the electrician to read the instructions prior to installing the kit. This condition

Rsvisiont 1 Page 22 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) has existed with little change since a time prior to either of the deviations.* The Electrical Review Team checked several examples of Raychem's detailed instructions and found them to be clear and specific in stating that the discrepant conditions asscciated with both deviations are not acceptable.

Therefore, craft procedures are considered to have been adequate.

The general issue of crsit training is discussed in the Results Report for ISAP I.d.3, " Craft Training." For the specific issue of training in the installation of heat-shrinkable insulation sleeves, the Electrical Review Team found that Raychem had been contracted on several occasions to perform onsite training of craft and QC personnel. The first of these sessions took place prior to either of the noted deviations. The Electrical Review Team checked training records and found that each of the electricians associated with the deviations are indicated to have received training in O the installation of heat-shrinkable insulation sleeves. The Electrical Review Team also attended a training session held by Raychem at CPSES in October, 1986. The Raychem-

, representatives provided detailed explanations of the purpose and function of their materials, insisted on hands-on

, participation, and provided adequate opportunities for questions to be answered. Further, they emphasized the importance of following the detailed instructions supplied with each kit. The Electrical Review Team found_the training given in this session to be adequate. Based on the above review, craft training is considered to have been adequate.

As indicated by the terminator badge number on the cable -

connection card, the two deviations are attributable to two different electricians. Thus, the inadequacy of a single i craftsman's qualifications was not a possible root cause.

In the opinion of the Electrical Review Team, correct installation of heat-shrinkable insulation sleeves primarily requires patience and careful attention to detail. There are j no skills necessary to properly install these sleeves beyond those of any qualified electrician. Therefore, inadequate qualification of craft personnel was determined not to be a root cause.

)

  • The deviations involved installations performed in March, 1980.

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Rsvision: 1 Pegs 23 of 30 RESULTS REPORT ISAP I.a.1 .

(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

No direct evidence regarding the adequacy of craft supervision was available. However, both deviations are attributable to craft inattention to the detailed installation requirements for heat-shrinkable insulation sleeves. This inattention to detail may be indicative of inadequate craft supervision.

Based upon the limited information available at this time, this is considered to be the primary root cause, especially considering that craft procedures, training, and personnel were found to be adequate.

Neither of the deviations had been detected previously by the CPSES QA/QC Program. Both of the deviations occurred in the time period that Revision 0 of QC Procedure QI-QP-11.3-28,

" Class 1E Cable Terminations," was in effect. This revision included no requirement to inspect heat-shrinkable insulation sleeves. Therefore, a contributing cause was the inadequacy of the QC procedure.

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Revision 1 QI-QP-11.3-28, dated August 7, 1980, added a requirement to inspect heat-shrinkable insulation sleeves.

However, for the two deviations that occurred during the time l period that Revision 0 had been in effect, the Electrical i

Review Team found no evidence that these installations had l been reinspected after the requirement was added in

! Revision 1. Therefore, a contributing cause was the failure to backfit new inspection criteria to previously-inspected hardware.

The Electrical Review Team did not conduct a detailed investigation of QC training / certification or QC inspector qualifications. Neither of these areas was considered to be a potential root causes, because both deviations occurred when there was no QC inspection requirement.

1 No direct evidence regarding the adequacy of QA/QC supervision I was available. However, the two contributing causes discussed

! above (QC procedure inadequacy, failure to backfit new inspection criteria) are indicative of inadequate QA/QC supervision, and thus this is also considered a contributing cause.

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,p RESULTS REPORT G ISAP.I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

In summary, the primary root cause and three contributing

causes that have been identified at this time are as follows

(primary) inadequate craft supervition; (contributing) inadequate QC inspection procedure; (contributing) failure to backfit new QC inspection criteria to previously installed hardware; and (contributing) inadequate QA/QC supervision.

I 5.8 Generic Implications Evaluation The generic implication of the primary root cause is that l inadequate installations of heat-shrinkable insulation sleeves l may still remain undetected. In harsh environments, these inadequate installations could result in inadequate protection of the cables and connections from the environmental elements.

The generic implication of the three contributing causes is that other installations of heat-shrinkable insulation sleeves performed while Revision 0 of QI-QP-11.3-28 was in effect may not have been inspected.

Corrective actions for the above generic implications are l presented in Section 5.9. The causes identified above have been forwarded to the QA/QC RTL for use in the co11 active evaluation program.

5.9 Corrective Action Recommendation The Electrical Review Team has developed a set of recommended ,

corrective actions. These recommendations are a result of the consideration of the following items:

the adverse trend discussed in Section 5.6 above together with the root cause analysis and generic implications evaluation discussed in Sections 5.7_and 5.8; the results of the sampling plan which did not result in reasonable assurance that all heat-shrinkable insulation sleeves have been inspected; and O

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'Pags 25 of 30 RESULTS REPORT l O. '

ISAP I.a.1

[ (Cont'd) -

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the review (beyond the scope of the original 1 SAP) to determine whether there had been adequate CPSES Project QC involvement in the installation of both the heat-shrinkable insulation sleeves and the underlying electrical connections.

The following corrective actions have been recommended to ensure that required inspections have been performed and that

, installations are adequate:

5.9.1 Document Review of Sleeve Installations A review of QC documentation should be performed for all installations of heat-shrinkable insulation sleeves in Class 1E circuits in Unit 1. Unit 2 and Common to i

determine whether 1) there is conclusive documented evidence that these sleeves have been installed where required and inspected, and 2) there was adequate QC

involvement in the installation of both the sleeves and the underlying electrical connections. Where the document review indicates inconclusive evidence of QC involvement, further corrective action should be determined on a case-by-case basis.

5.9.2 Reinspection of Installations in Harsh Environments

A reinspection of all heat-shrinkable insulation sleeve

! installations in Class IE circuits in harsh environments in Unit 1, Unit 2 and Common should be performed to assess the adequacy of the sleeve installations to perform their intended function.

Results of these reinspections should then be assessed '

to determine whether any additional action is required for installations in mild environments.

The CPSES Project has proposed a set of actions in response to these recommendations. The Electrical Review Team considers that the CPSES Project approach complies with the recommendations. The corrective actions will be overviewed by third-party personnel.

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Rsvisicn: 1 Paga 26 of 30 0 RESULTS REPORT ISAP I.a.1 (Cont'd) ,

6.0 CONCLUSION

S Craft and QC procedures vr.re revised and appropriate. training was accomplished as discussed in Section 5.2. Thus the objectives of Part 1 of this ISAP were met. However, as discussed in Section 5.3.3, the need for additional procedure revisions was identified during the hardware reinspections. The CPSES Project has agreed to make these revisions.

Based on the results of the document reviews and associated reinspections, the Electrical Review Team concludes that there is reasonable assurance that heat-shrinkable insulation sleeves have been installed where required. However, these same activities failed to provide reasonable assurance that the sleeves have all been inspected. Thus, the objective of Part 2 of this ISAP has only partially been met. Implementation of the corrective action specified in Section 5.9.1 will complete the remainder of that objective.

In addition to_the ISAP objectives, the reinspection activities led O' to the identification of an adverse trend as described in Section 5.6. Implementation of the' corrective actions specified in Section 5.9 will address the safety concerns associated with that trend.

~

The concern expressed by TRT was over an apparent lack of '

familiarity with procedural requirements governing where heat-shrinkable insulation sleeves should be installed. This j Action Plan did not test this familiarity (or lack thereof), but l

rat'.ner explored the consequence of concern if indeed this familiarity were lacking - that is, whether the sleeves are ~

actually installed where required. CPRT reviewed one hundred I eleven (111) randomly-selected items and found no cases where heat-shrinkable insulation sleeves had not been installed where required. The Electrical Review Team considers that sufficient evidence has been reviewed to provide reasonable assurance that sleeves are installed where required. Thus, while the specific concern expressed by TRI (lack of familiarity) and hypothesized root cause (poor training) were neither substantiated nor refuted, they have nevertheless been fully addressed.

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Rsvision: 1 Page 27 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 7.0 ONGOING ACTIVITIES As a result of TUGC0 Corrective Action Request (CAR) 55, a substantial number of heat-shrinkable insulation sleeves will be replaced due to unrelated problems identified involving electrical penetration assemblies. When a final determination is made of those items that will remain, the recommended corrective actions discussed in Section 5.9 will be performed. These actions will be overviewed by third-party personnel. When all data are available from these activities, the root cause analysis discussed in Section 5.7 will be reassessed. The CPSES Project will also revise the NCR dispositions and make the procedure revisions discussed in Sections 5.3 and 5.3.3, respectively. The results of all of these actions will be presented in a supplemental report.

8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE The corrective actions will ensure that the existing installations

, are adequate. The current procedures, amended as discussed in i Section 5.3.3, will provide adequate instructions for the

[ installation and inspection of heat-shrinkable insulation sleeves.

Holdpoints have been included in the craft construction procedure to help preclude the possibility of inadequate inspections.

l Training accomplished to date together with ongoing periodic

training will er.sure that craf t and QC personnel are adequately l aware of the installation and inspection requirements. No other actions are considered necessary.

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Rsvision: 1 Page 28 of 30 p . RESULTS REPORT U ISAP I.a.1 (Cont'd)

Appendix A Summary of Events for Document Review l

1. The.ISAP required a document review of sixty (60) randomly-selected samples from the population. This review was performed in January, 1985, and these samples are referred to as the " Original 60" in the working files.
2. The previous Electrical Review Team Leader (RTL), M. B. Jones, observed that none of the heat-shrinkable insulation sleeves for the fourteen (14) cable reduction splices in the population had been randomly selected for inclusion in the Original 60 samples.

Because he considered these to be an unusual application, he requested that a document review for each of these splices be i performed. This review was performed by third-party personnel in January and February, 1985.

3. Based on one finding (Sample No. 60-28*) in the Original 60 that was initially considered to be a deviation, the Electrical RTL decided to expand the sample. Accordingly, a document review of thirty-five (35) additional randomly-selected samples, as prescribed by Appendix D of the CPRT Program Plan, was performed in February, 1985. These samples are referred to as the " Additional 35" in the working files.
4. Of the first ninety-five (95) document reviews of randomly-selected items, four (4) of the samples were found to be invalid, since they represented locations that were found not to require heat-shrinkable insulation sleeves. As such, to reach the required sample size of 95, at least 4 additional samples were required.

Accordingly, a document review of seven (7) additional randomly-selected samples was performed ** in March, 1985. These samples are referred to as the " Additional 7" in the working files.

All seven (7) of these samples were valid, and thus the total number of valid samples reviewed was ninety-eight (98).

  • Sample numbers were assigned for easy reference. In this case 60-28 refers to the twenty-eighth sample item from the Original 60.

See the final paragraph in this appendix for a list of all sample number codes.

    • Seven was an arbitrary choice to ensure that at least four valid samples were attained.

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Rsvision 1 Page 29 of 30 RESULTS REPORT ISAP 1.a.1 (Cont'd)

Appendix A (Cont'd)

,5. In addition to the document reviews discussed above, an additional action was taken by CPRT to obtain further information about the quality of the sleeve installations. TUGC0 developed post-installation inspection criteric and a special inspection report (reviewed by the Electrical RTL) for the reinspection of all reasonably accessible heat-shrinkable insulation sleeve installations whose original inspection documents had been reviewed i by third-party personnel. Fifty-three such installations were reinspected. These activities were conducted from August to October, 1985. No deviations were found by TUGCO. It is noted that these inspections were beyond the scope of this ISAP, and were not overviewed by CPRT. No credit is taken for these inspections in reaching the conclusions stated in this report.

6. Phase III of ISAP I.a.2, " Inspection Reports on Butt Splices,"

resulted in the identification of many additional locations that could have required heat-shrinkable insulation sleeves, but that O were not included in the original population for this ISAP since the installations were not in harsh environments. However, to attain reasonable assurance that sleeves had been installed in these locations where required and inspected, a proportional sample of this additional population was subjected to a document review in May and June, 1986. The document review was performed by the Electrical Review Team. The sample consisted of twelve (12) items j from a population of 146. These items are referred to as the

" Extended Population" in the working files.

7. Since two cases were found where a "short form" IR had been used when the long form should have been used, and the cables for the two cases were close in both cable number and location, the Electrical Review Team investigated three other related population members to determine whether similar problems existed. The documentation deviation reported for Sample No. SF-01 resulted from this investigation, which was conducted in August, 1986, and referred to as the "Short Form Investigation" in the working files.
8. Due to errors in the original calculation of the random sample, one population member that should have been reviewed with the Additional 35 was inadvertently omitted. This item was later reviewed by the Electrical Review Team in September, 1986, and is referred to as the " Missed Sample" in the working files. This review brought the total number of valid randomly-selected items to O III (98 from steps 1,3 and 4; plus 12 from step 6; plus 1 from this step).

Rsvision: 1

, Page 30 of 30 RESULTS REPORT O' ,

ISAP I.a.1-( (Cont'd)

Appendix A (Cont'd)

9. Often, thete were notas generated about superceded irs and other docuvents outside the scope of this ISAP. To provide a mechanism for tracking such-items, these are referred to as " Observations" in the working files.

.10. Sample numbers consisted of a two character code, followed by a

.;1gsh, followed by a two digit number. The two character code Vientifies the ISAP activity involved as follows:

60 = original 60 (see 1 above)

RS = Reduction Splices (see 2 above)

,. 35 = Additional 35 (see 3 above) 1 07 = Additional 7 (sea 4 above)

EP = Extended Population (see 6 above)

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[} SF = Short Form Investigation (see 7 above)

MS = Missed Sample (see 8 above)

OB = Observation (see 9 above)

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The two digit code simply represents a sequential number within the given activity. For example, Sanple No. 35-10 refers to the tenth l , item from the Additional 35.

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