ML20212P841
| ML20212P841 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/16/1987 |
| From: | Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2252 OL, NUDOCS 8702020064 | |
| Download: ML20212P841 (4) | |
Text
--
t 2.2.52 7
ftELAT ED COttHLstunus%%
WORSH AM, FORSYTHE, S AM PELS &CW EE)RIDOE THIRTV Two MUNDRED.2OOf BRTAN TowtR
.M.D.SAMpELS JOE A wCRSHAM DALLAS. TaxAs 75201 ROeERr A. wOctoRioot
,,,,,,,7,
.g7 agg 2) li9 '32 N m O A oERSON R NA DM ANSON TELEPHONE (214)S79 3OOO Or COUNSEL J. DAN eOMANNAN JOS. lRiON WORSH AM TR Aves E. vANDERPOOL EARL A. FORSYTHE JuoitM a.JOMNSON CffG ReCMARD L. ADAMS
%[f.'
OAvs0 C.LONERGAN s;l'*
D T E L ECORs E R-(2:4)880 0089 JOMN w. MCREYNOLDS TMOM AS F. LILLARD ROSERfM.wlSE flMotM* A. M ACR ROSERf M. FILLMORE WM STEPMEPs8070 MARm R wASEM CMRsSTOPMER R. McLTENoERGER ROSERT P. OLIVER M ARn SCMwamit RICMAND G. MOORE NateCYE L. SETMUREM January 16,1987 CECEL.A s..RuN E R JOE A DAVIS ER CM PETERSON W ALTER w, wMitt Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing Board 1107 West Knapp U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory Carib Terrace P. O. Box X, Building 3500 552 North Ocean Boulevard Oak Ridge, Tennessee 37830 Pompano Beach, Florida 33062 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50-445 and 50-446 - O O
Dear Administrative Judges:
Applicants have this date delivered to Mr. Vincent S. Noonan the following SRT approved Results Reports:
1.a.1 Heat-Shrinkable Cable Insulation Sleeves - Rev. I 1.b.4 Barrier Removal-Rev.1 II.c Maintenance of Air Gap Between Concrete Structures - Rev. I Vll.a.3 Document Control-Rev. I V.d Plug Welds - Rev.1 8702020064 870116
'~
hjd PDR ADOCK 05000445 0
4 s'
Administrative Judges January 16,1987 Page Two These reports should be placed in sequence behind the tab " Electrical" for I.a.1 and I.b.4; " Civil / Structural" for II.c; "QA/QC" for VII.a.3; and " Mechanical" for V.d in the results reports binders previously transmitted. Also enclosed is a revised Table of Contents reflecting the issuance of these reports.
Re' spec ly submitte Robert A. Wooldridge RAW /kiw Enclosures cc:
Service List i
i 4
1 i
k i
A J
i a
TABLE OF CONTENTS COLLECTIVE SIGNIFICANCE REPORT
- Later -
COLLECTIVE EVALUATION REPORTS
- Later -
RESULTS REPORTS Electrical I.a.1 Heat-Shrinkable Cable Insulation Sleeves -
Revision I.a.3 Butt-Splice Qualification - Revision 1 1.a.4 Agreement Between Drawings and Field Terminations
- Revision 2 I.a.5 NCR's on Vendor Installed Amp Terminal Lugs
- Revision 1 I.b.1 Flexible Conduit to Flexible Conduit Separation O
- Revision 1 I.b.2 Flexible Conduit to Cable Separation - Revision 1 I.b.3 Conduit to Cable Tray Separation - Revision 1 I.b.4 Barrier Removal - Revision 1 Civil / Structural 3
II.b Concrete Compression Strength - Revision 1 i
II.c Maintenance of Air Gap Between Concrete Structures
- Revision 1 Testina III.a.2 JTG Approval of Test Data - Revision 0 III.a.3 lechnical Specification for Deferred Tests
- Revision 0 III.a.4 Traceability of Test Equipment - Revision 0 O
III.d Preoperational Testing - Revision 1 4
4
.~a.
-2.w.
s 6
0 J
i
(
TABLE OF CONTENTS (cont.)
Mechanical V.a Inspection for Certain Types of Skewed Welds in NP Supports - Revision 1 V.c Design Consideration for Piping Systems Betw1en
+
Seismic Category I and Non-Seismic Category I j
Buildings - Revision 1 V.d Plug Welds - Revision 1 V.e Installation of Main Steam Pipes - Revision 1 i
I 0A/0C l
1.d.2 Guidelines for Administration of QC Inspector Test
- Revision 1 l
1.d.3 Craft Personnel Training - Revision 1 l
i VII.a.3 Document Control - Revision 1 1
l VII.a.4 Audit Program and Auditor Qualification -
Revision 1 VII.a.5 Periodic Review of QA Program - Revision 1 VII.a.6 Exit Interviews - Revision 1 VII.a.7 Housekeeping and System Cleanliness - Revision 1 VII.a.8 Fuel Pool Liner Documentation - Revision 1
(
VII b.2 Valve Disassembly - Revision 1 i
DSAPs
- Later -
1 t
i 1
CPRT-806 LOG N0. TXX-6223 FILE NO. 10068 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER
- 400 NORTH OLIVE lirFREET. E B. 51. DALLAm. TEXA5 7890 t January 16, 1987 www a coussn.
EuRCuttvt WsCE PeEsiOEsef Director of Nuclear Reactor Regulation ATTN: Mr. V. S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446 CPRT RESULTS REPORTS
Dear Mr. Noonan:
We transmit herewith the following SRT approved Results Reports:
I.a.1 Heat-Shrinkable Cable Insulation Sleeves, Revision 1 I.b.4 Barrier Removal, Revision 1 II.c Maintenance of Air Gap Between Concrete Structures, Revision 1 VII.a.3 Document Control, Revision 1 V.d Plug Welds, Revision 1 These reports should be placed in sequence behind the tab " Electrical" for I.a.1 and I.b.4; " Civil / Structural" for II.c; "QA/QC" for VII.a.3; and " Mechanical" for V.d in the results reports binders previously transmitted.
Also, enclosed is a revised Table of Contents reflecting the issuance of these reports.
The files which contain supporting documentation for these Results Reports have been reproduced in their entirety and are available for t
public inspection in our Dallas office.
Anyone wishing to inspect these files should contact Ms. Susan Palmer (214/979-8242).
We shall issue further Results Reports on a periodic basis as they are approved by the CPRT Senior Review Team.
Very truly yours,
/flA
/
. G. Counsil i
WGCitj Enclosures' LA l n
k ~b.
? 5 A DRVisiON UV TEKAN UTil2 TIER ELEClitlC COMVANY
O COMANCHE PEAK RESPONSE TEAM RESULTS REPORT l
ISAP:
I.a.1
Title:
Heat-Shrinkable Cable Insulation Sleeves REVISION 1 i
O f2 a/.e/sc Issue Coordinator Da(e L
A^^ - A l
N $$
Keview m Leader Datl
/
C& a. iL 12A./ra Jop W. Beck, Chairman CPRT-SRT Date I
bpr T
R vi::iont 1
Page 1 of 30 RESULTS REPORT ISAP I.a.1 Heat-Shrinkable Cable Insulation Sleeves i
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.
I
"...the lack of awareness of where the heat-shrinkable sleeves l
should be installed, as reflected in the QC inspection form, when the high percentage of missed and/or improperly documented i
inspections requiring witnessing, indicated that craft and inspection personnel lacked familiarity with these procedural requirements. This apparent lack of familiarity may be indicative I
of poor training."
2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Item i
- 6. (d)(1), Page J-31) i "TUEC shall accomplish the following actions prior to fuel load:
I 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) all QC inspections requiring witnessing for splices have been 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 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 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.
O
~
Rsvicion:
1 Pass 2 of 30 i-RESULTS REPORT i
i ISAP I.a.1 l
(Cont'd) 1 i
I
3.0 BACKGROUND
(Cont'd) 1 Heat-shrinkable insulation sleeves are used as required to complete the installation of:
Uninsulatedibutt-splices I
+,
Class 1E 480 V and 6.9 Kv motor terminations Cable reduction splices t
i Electrical penetration assembly cable connections j
The butt-splices inspected by TRT were AMP Pre-insulated j
Environmental Sealed (PIES) splices. Heat-shrinkable insulation i
sleeves are not required for AMP PIES splices, since they were i
qualified for their intended use without such sleeves *. However,
]
at the time of the TRT inspection, QC Procedure QI-QP-11.3-28 j
" Class LE Cable Terminations", Revision 21 dated June 8, 1984, did not specifically state that these spitees were not to be included l
{
in the class of connections requiring installation of I
heat-shrinkable insulation sleeven. That omission is what probably j
led to the TRT firdings. Though no aclual hardware discrepancy had j
thus been identified, due to the TRT concern over the apparent lack j
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 l
connections and splices are installed where required and are j
inspected.
J i
4.0 CPRT ACTION PLAN I
4.1 Scope and Methodology j
The plan consisted of two basic parts. The objective of j
Part 1 was to clarify procedural requirements and provide j
additional training to TUGC0 craft'and QC inspectors with l
respect to the installations for which heat-shrinkable i
{
insulation sleeves are required.
r f
The objective of Part 2 was to provide reasonable assurance i
that heat-shrinkable insulation sleeven had been installed where required and inspected. This was accomplished via a j
sampling program that was designed in accordance with j
Appendix D of the CPRT Program Plan.
These splices are the subject of 15APs 1.a.2, " Inspection Reports on Butt-Splices," and I.a.3, " Butt-Splice Qualification."
1 i
-.-,-c-
,..--.-----r---
.--.,_,.,~--,~,y-_.%,.--,,,---.,r-*--ww4----+w--+w++=---+-+-
",~'---*-'~-~r~~
'+
i Rsvision 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:
The craft Construction Procedure EEI-8,
" Class 1E 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 sleeves 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, j
Quality Control inspectors were trained and certified to the revised procedures.
4.1.2 Part 2 - Sampling, Records Review and Reinspection g
A records review of irs for the termination of cables, 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:
R2 vision 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 configrration details), a population was identif.ted that consisted of those locations where these sleeves could have been required.
4.1.2.2 Random Sampling f'
The sampling plan was designed to provide a 95/5 s'creen in accordance with the guidelinea of Appendix D of the CPRT Program Plan. The minimum sample size required to achieve this level,of screening was determined from Appendix D.
The sample items were reviewed to ensure that systems that art important to safety were represented.
L During the conduct of the ISAP one subs t 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 j
the population.
t -
,.m,-.,
i Rsvision:
I rege 5 of 30 t
RESULTS REPORT ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The irs for each randomly-selected locction 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.
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 items for which it may have been necessary to reduce the size of the cable to facilitate termination. Had si: ices been found in any of these cables or pieces of equipment, the associated IR would have been reviewed to verify that there was documented evidence that the required sleeves had been inspected.
4.1.4 Use of Results When deviations were found, Nonconformance Reports g-s (NCRs) were issued by TUGC0 to document the finding and
(,)
initiate corrective action. Any deviations were evaluated for safety significance and adverse trends, and to determine root causes and generic implications, as necessary, in accordance with the requirements of
4 Rsvision:
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.
O' 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 construction procedures to verify that the installation requirements for heat-shrinkable insulation sleeves were clearly identified.
)
i 4.2.2.3 Reviewed all third-party irs and TUGC0 NCRs i
that were generated due to this ISAP.
4.2.2.4 Evaluated document review and physical reinspection results and associated TUGC0 O
responses and resolutions.
l
a Rsvision:
1 Pags 7 of 30.
RESULTS REPORT ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.5 Determined root causes and generic implicatiens, 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
4.2.2.9 Personnel (starting October 18, 1985)
Mr. J. J. Malfanda Review Team Leader Mr. J. R. Pearson Issue Coordinator Mr. M. B. Jones, Jr.
Third-Party Adviser Mr. E. P. Stroupa 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 Wrere 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 treined to the CPRT Program Plan.
I
s Rsvision:
1 Pags 8 of 30
{G s
RESULTS REPORT ISAP I.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) i Third-party participants in the implementation of this action plan have met the personnel qualification and objectivity 1
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 party reinspections:
~
Instruction No. QI-003, " Procedure for Class IE Heat-Shrinkable Cable Insulation Sleeves - CPRT Action Item 1.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 b
the sleeve);
where inner conductor splices have been covered by an overall sleeve, there is no bottleneck effect, which would indicate the 1 V inner conductor splices have not been l
staggered; and
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 indicata 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 in accordance with Section 4.5.2.
(Thus, hardware deviations can also be identified.)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summary 1
This action plan consisted of two basic parts. Part 1 involved revising craft Construction Procedure EEI-8, " Class IE and non-Class 1E 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, craf t 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 t
determine, by means of a document review using a sampling approach, whether heat-shrinkable insulation sleeves had been installed where required and inspected. Additional activities, beyond the ISAP scope presented in Section 4.0, For example, in some cases electrical penetration assembly pigtail leada, were of sufficient length to reach a terminal block, and thus, no field splicing was necessary.
i
- ~
J
Rsvision:
1 Pags 10 of 30 t
l RESULTS REPORT 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 i
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 i
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 ANP PIES splices.
Revision 22, dated December 10, 1984, incorporated changes that identify clearly the locations where these sleeves are required. This revision specifically states that 1'
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). Dua to the various types of heat-shrink kits utilized,'the procedurec reference the manufacturer's instructions accompanying the kits rather than providing detailed procedural installation instructicns for each specific configuration.
Further, althcugh the QC procedure had required the inspection of both splice-and sleeve installation, no associated hold points were stated in the craft procedure. Therefore, the 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 instsilations had been performed when required.)
In addition to the above procedure changes, the IR form was revised to provide for clearer documentation of inspections.
Some of these changes were:
- 1) Separate line itcas were provided for documenting different types of splices and terminations.
O
i Rsvision:
1
)
Paga 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 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 i
\\
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 C"RT.
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 war 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 acceptance criteria of Section 4.5.2.
In the process of carrying out the ISAP steps, a number of deviations and out-of-scope findings were noted, primarily by j
the third-party document reviewers. Each deviation and valid 1
out-of-scope finding has been forwarded to ~TGC0 for resolution. The Electrical Review Team has reviewed the NCRs generated by TUCCO 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.
l
Rsvision:
1 Page 12 of 30 RESULTS REFORT 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 l
related issues are discussed in Section 5.3.4.
1 5.3.1 Population Identification and Sample Size A population of locations that might have required i
i installation of heat-shrinkable insulation sleeves was l
assembled. The population consisted of Class 1E f
essential and associated cables in Unit I and Common that were terminated using electrical penetration i
assembly cable connectors, motor termination kits, or uninsulated butt-splices (used to terminate electrical-i devices), and those for which cable reduction splices 4
were known to have been used to facilitats termination.*
Based on the population size, which was determined to be 1359**,
the minimum sample size req'uired by i
Appendix D of the CPRT Program Plan was determined to be sixty. As detailed in Appendix A, one hundred eleven (111) randomly-selected samples, plus all known cable reduction splices and several other miscellaneous items, were actually reviewed..A review of the sample items confirmed that systems that are important to safety were represented.
l Cable reduction splices are used only when necessary to facilitate-termination. Known reduction splices were identified by TUGCO 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 pigtail leads in mild environments was later identified and reviewed.
s Rsvision:
1 Page 13 of 30
/
RESULTS REPORT k
ISAP I.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 criterion 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 additional 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 inepection of splicing, but contained no evidence of installation of heat-shrinkable insulation sleeves. A reinspection found heat-shrinkable insulation sleeves to be installed. TUGC0 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 insula. tion sleeves to be installed.
TUGC0 issued NCR E-85-100253S to document this finding.
~
v y
..+
Rsvision:
1 Page 14 of 30 0
RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
'l 5.3.2.3 Sample Number RS-08 (Cable Reduction Splice) i 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 l
not contain a requirement to inspect I
heat-shrinkable insulation sleeves. A reinspection found heat-shrinkable insulation sleeves to be installed. TUGC0 issued NCR E-85-100266S to document this finding.
l 5.3.2.4 Sample Number SF-01 The inspection of this termination (cable 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.
1 A reinspection found heat-shrinkable insulation sleeves to be installed. TUGC0 issued NCR E-86-103551% to document this l
finding.
5.3.3 Hardware Deviations i
1 i
~
Section 4.5.2 lists.the acceptance criteria that were t
used for the reinspection of heat-shrinkable insulation l
sleeves. Five (5) such locations were actually reinspected *. The results of reinspections performed for this ISAP with respect to these criteria are discussed below.
Sample Numbers 60-11, 35-08, RS-08 and SF-01, as discussed in Section 5.3.2; and Sample Number RS-05 (see footnote to Section 5.3.3.1).
l i.
,,.m..
n-,y-.--,-
e.,
,e-%5mg-,,ymr,--,,w_.c--y-
.m
-,-w-e.
+*y,n=
e-we,w--i
Rsvision:
1 Pags 15 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF. ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.3.1 Complete Shrinking of Visible Sleeves 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 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. TUGCO issued NCR E-86-103328X to document this finding.
The three remaining installations were found O
to be acceptable for this attribute.
5.3.3.2 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 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 Raycher 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) revecled that the material identified as the " laminate" was actually a glass This item is not among those with documentation deviations, since O
the inspection records do contain conclusive documented evidence of installation and inspection.
However, since it was installed prior to the addition (in Revision 1 of QI-QP-11.3-28) of the -rettirement to inspect sleeves, the Electrical Review Team requested this additional reinspection.
Rsvision 1
Pags 16 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSI0N 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 l
4.0, an assessment was made of the CPSES Project QC involvement with the installation of both j
heat-shrinkable insulation sleeves 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 i
this assessment are discussed below:
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. TUCCO QA responded that for several sleeve installations, the underlying connections were referred to and documented as
" terminations" rather than splices, and thus 1
the irs were acceptable. Third-party
)
personnel confirmed that the subject irs did i
indeed indicate that the connections had bean inspected.
" Witness" is an inspection methodology that requires the QC.
i j
inspector to physically observe the entire operation being i
performed. In contrast, " verify" is an inspection methodology that allows the QC inspector to physically inspect an item after j
performance of an operation.
(Reference QC Procedure CP-QP-18.0.)
The requirement to witness splicing was added in Revision 5 to QC Procedure QI-QP-11.3-28, dated August 7.-1980 (Revisions 0 through l
4 had required verification). The requirement to witness heat-shrinkable insulation sleeves was added in Revision 10, dated 2
December 4, 1981 (Revisions 1 through 9 had required verification; j
Revision 0 included no requirement for sleeve inspection).
1
.. _, - _...... _, ~. - -
..._-.-.-.-m.
,m,.m
,-.m~_
..-,_.y
,m,m.,,w,.-_.m_.-mr.,
, ~, -.
i Rsvision:
1 Pags 17 of 30 RESULTS REPORT v
ISAP I.a.1
'l (Cont'd)
)
\\
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 I
witnessed or verified. Specifically,-the procedure required witnessing and the IR form indicated a "W" (for " witness") activity, but the IR imperative was phrased, " Verify heat shrinkable nuclear cable _ sleeves".
In response to the above_ issue, TUGCO QA reviewed those irs that had been identified by third-party document reviewers as " splice i
and/or sleeve verified rather than 1
witnessed." The review found that each inspection had been performed in accordance l
with the procedures in effect at the time. of the inspection. Further, each of the following four (4) attributes was found to be marked " SAT" on each IR:
" Verify prcper length of exposed conductors."
" Verify proper tools (Note:
applicable only when this inspection is actually observed)."
l k
--~
l Rsvision:
1 Page 18 of 30 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 process, TUGC0 QA concluded that the implementation of these inspection items effectively resulted in the witnessing of the 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 I ]'
each of the four attributes listed above.
\\*
This review found that these four ameributes had been verified on those irs reviewed by TUGC0 QA. However, this review was extended to sample items that had been indicated as
" satisfactory" and thus were nct 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 cases where the attributes were all verified.
However, since these attributes were not always verified, and considering the documentation deviations discussed in Section 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 Sections 5.3.2.2 and 5.3.2.4, a third case O-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.
1
Revision:
1 Pags 19 of 30 RESULTS REPORT ISAP I a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 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 this finding.
5.4 Related CPRT Activities S.4.1 Unit 2 Centrifugal Charging Pump The previous Electrical RTL discovered a heat-shrinkable insulation sleeve installation on one O
phase of the 6.9Kv connections 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 found that the heat-shrinking had been sufficient to meet the manufacturer's requirements for obtaining a proper environmental seal.
5.4.2 ISAP 1.a.2, Phase III 1
j As part of the TUCCO activities for Phase III of i
ISAP I.a.2, " Inspection Reports on Butt Splices," many heat-shrinkable insulation sleeves will have been refaspected. One such reinspection, which has been completed, found a sleeve installation overlapping the fiberglass braid on the vendor's" cable connected to Cable E9119865A. TUGC0 issued NCR E-85-101657S to docume:
this finding. Any additional results of Phase III of ISAP I.a.2 pertaining to heat-shrinkable insulation sleeves will be presented in the Results Report for that ISAP.
i
- O
i 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) l 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 1
None of the four documentation deviations was determined to be l
safety-significant, since the absence of conclusive documented evidence of heat-shrinkable insulation sleeve installation and j
inspection would not by itself result in the loss of capability of the sleeve to perform its intended safety function.
Neither of the two hardware deviations was determined to be 1
1 safety-significant.
In each case, the heat-shrinkable insulation sleeves were not located in harsh environmental 1
areas. Though the sleeves were not installed in full accordance with the manufacturer's instructions, the installations were adequate to provide electrical insulation j
in a mild environment.
t j
5.6 Adverse Trend Evaluation l
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 3
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 j
deviations remain undetected, and that such deviations, if j
occurring in harsh environments, could compromise the integrity of the environmental seals. Therefore, an adverse trend has been identified.
,,-ne
,,--.,,,y,.
.,-.--.,,.-,.--.n.
v
-_,---,,,_,.m.n_,.
,..._.n-
w Rsvision:
I f
Pags 21 of 30 RESULTS REPORT ISAP 1.a.1.
(Cont'd) 2 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Ccat'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-analysis is only preliminary. The corrective actions (see Section 5.9) will result in significantly more data being l
available. The analysis precented below will be reassessed at that time.
Each deviation that led to the adverse trend included the j
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 i
causes of this aspect are:
1 1
inadequate craft procedures governing the installation of these sleeves; O
]
inadequate craft training in the installation of these sleeves; 1
j craft personnel inadequately qualified to perform the
]
specific worksactivities; and l
inadequate craft supervision.
j Further, each deviation that led to the adverse trend included the failure of the QA/QC program to detect the discrepant installation. The potential root causes of this aspect are:
4 inadequate QC procedures governing the installation of j
these sleeves; i
inadequate QC inspector training / certification; QC inspector (s) inadequately qualified to perform-j inspections of these sleeves; and inadequate QA/QC supervision.
The governing craft procedure is EEI-8, " Class IE and Non-Class 1E Cable Terminations". This procedure specifically makes reference to the manufacturer's instructions
- \\
accompanying each kit, and requires the electrician to read
{
the instructions prior to installing the kit. This condition i
1
j Ravisiont 1
Page 22 of 30 RESULTS REPORT t
i ISAP I.a.1 (Cont'd) 4 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) has existed with little change since a time prior to either of i
i the deviations.* The Electrical Review Team checked several examples of Raychem's detailed instructions and found them to i
be clear and specific in stating that the discrepant conditions associated with both deviations are not acceptable.
I Therefore, craft procedures are considered to have been adequate.
The general issue of craft training is discussed in the l
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 I
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 I
with the deviations are indicated to have received training in the installation of heat-shrinkable insulation sleeves. The Electrical Review Team also attended a training session held i
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 l
connection card, the two deviations are attributable to two different electricians. Thus, the inadequacy of a single 1
craftsman's qualifications was not a possible root cause.
l In the opinion of the Electrical Review Team, correct l
installation of heat-shrinkable insulation sleeves primarily J
requires patience and careful attention to detail. There are i
j no skills necessary to properly install these sleeves beyond I
{
those of any qualified electrician. Therefore, inadequate
]
qualification of craft personnel was determined not to be e root cause.
The deviations involved installations performed in March, 1980.
1
i
/
Rsvision:
1 Page 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.
s 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 adequete.
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 IE 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.
()
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 period that Revision 0 had been in effect, the Electrical Review Team found no evidence that these installations had,
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 " hen there was no QC inspection requirement.
No direct evidence regarding the adequacy of QA/QC supervision 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 c ause.
1 i
i l
j l
Ravicion:
1 Fagt 24 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Co'nt ' d) l In summary, the primary root cause and three contributing -
causes that have been identified at this time are as follows:
1 (primary) inadequate craft supervision; (contributing) inadequate QC inspection procedure; (contributing) failure to backfit new QC inspection criteria to previously installed hardware; and (contributing) inadequate QA/QC supervision.
5.8 Generic Implications Evaluation l
l The generic implication of the primary root cause is that inadequate installations of heat-shrinkable insulation sleeves j
may still remain undetected.
In harsh environments, these
}()
inadequate installations could result in inadequate protection of the cables and connections from the environmental elements.
t 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.
i J
Corrective actions for the above generic implications are presented in Section 5.9.
The causes identified above have been forwarded to the QA/QC RTL for use in the collective 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 censideration 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 i
i l
l
i R;vicion:
1 Ptgo 25 of 30 RESULTS REPORT ISAP 1.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the review (beyond the scope of the original ISAP) 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 1
in Class 1E circuits in Unit 1, Unit 2 and Common to determine whether 1) there is conclusive documented evidence that these sleeves have been installed where required and inapected, and 2) there was adequate QC O'
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 1E 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.
O\\
v p
3
-r-y-
o-Rsvision:
1 Pags 26 of 30 RESULTS REPORT s_ /g ISAP I a.1 (Cont'd)
6.0 CONCLUSION
S Craft and QC procedures were 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 apaociated 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 Action Plan did not test this familiarity (or lack thereof), but rather explored the consequence of concern if indeed this familiarity were lacking - that is, whether the sleeves are a
actually installed where required. CPRT reviewed one hundred eleven (111) randomly-selected items and found no cases where heat-shrinkable insulation sleeves had not been inscalled where required. The Electrical Review Team considers that sufficient evidence has been reviewed to provide reasonable assurance that sleeves are instal 3ed where required. Thus, while the specific concern expressed by TRT (lack of familiarity) and hypothesized root cause (poor training) were neither substantiated nor refuted, they have nevertheless been fully addressed.
I 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 I
replaced due to unrelated problems identified involving electrical penetration assemblies. When a final determination is made of those items that will remain, the reconcended 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 j
will be presented in a supplemental report.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE t
The corrective actions will ensure that the existing installations are adequate. The current procedures, amended as discussed in Section 5.3.3, will provide adequate instructions for tha l
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.
Training accomplished to date together with ongoing periodic j
training will ensure that craft and QC personnel are adequately aware of the installation and inspection requirements. No other actions are considered necessary.
i i
(
I i
i 1
O 4
1
R visiunt 1
i Page 28 of 30 RESULTS REPORT ISAP I.a.1 (Cont'd)
Appendix A l
Sunmary of Events for Document Review 1.
The 1 SAP required a document review of sixty (60) randomly-selected samples from the population. This review was performed in January, j
1985, and these samples are referred to as the " Original 60" in the j
working files.
2.
The previous Electrical Review Team Leader _(RTL), M. B. Jones, i
observed that none of the heat-shrinkable insulation sleeves for I
the fourteen (14) cable reduction splices in the population had
)
been randomly selected for inclusion in the Original 60 samples.
i Because he considered these to be an unusual application, he f
requested that a document review for each of these splices be l
performed. This review was performed by third-party personnel in January and February, 1985.
i 3.
Based on one finding (Sample No. 60-28*)-in the Original 60 that was initially considered to be a deviation, the Electrical RTL jO decided to expand the sample. Accordingly, a document review of thirty-five (35) additional randomly-selected samples,' as l
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.
1 1
i" 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 l
-heat-shrinkable insulation sleeves. As such, to reach the required j
sample size of 95, at least 4 additional samples were required.
i Accordingly, a document review of seven (7) additional l
random 1"-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).
t Sample numbers were assigned for easy reference. In this case 60-28 refers to the twenty-eighth sample item from the Original 60.
i j
See the final paragraph in this appendix for a list of all sample i
number codes.
Seven was an arbitrary choice to ensure that at least four valid samples were attained.
[
l
.__g____.
)
Ravision:
1 Pags 29 of 30 i
RE'SULTS REPORT ISAP 1.a.1 (Cont'd)
Appendix A (Cont'd) i i
i
~ 5.
In addition to the document reviews discussed above, an additional j
action was taken by CPRT to obtain further information about the i
quality of the sleeve installations. TUGCO developed I
post-installation inspection criteria and a special inspection l
report (reviewed by the Electrical RTL) for the reinspection of all 1
1 reasonably accessible heat-shrinkable insulation sleeve installations whose original inspection documents had been reviewed j
by third-party personnel.
Fifty-three such installations were reinspected. These activities were conducted from August to i
October, 1985. No deviations were found by TUGCO. It is noted j
that these inspections were beyond the scope of this ISAP, and were not overviewed by CPRT. No credit is taken for these inspections j
in reaching the conclusions stated in this report.
1 4'
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 vere not included in the original population for this ISAP since i
the installations were not in harsh environments.- However, to i
attain reasonable assurance that sleeves had been installed in j
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 from a population of 146. These items are referred to as the "Extendt.d Population" in the working files.
I 7.
Since two cases were found where a "short form" IR had been used when the long fore 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 froa this investigation, which was conducted in August, 1986, and referred to as the "Short Form Investigation" in the workin5 files.
8.
Due to errors in the original calculation ef the random sample, one i
population seaber that should have been reviewed with the Additional 35 was inadvertently omitted. This ites was later 1
reviewed by the Electrical Review Team in September, 1986, and is I
referred to as the " Missed Sample" in the working files. This review brought the total number of valid randomly-selected items to 111 (98 from steps 1,3 and 4; plus 12 from step 6; plus i from this step).
}
1
. ~.
.=
Ravision:
1 Page 30 of 30 l
RESULTS REPORT ISAP T.a.1 (Cont'd)
Appendix A (Cont'd) 4 1
9.
Often, there were notes generated about superceded irs and other documents 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 dash, followed by a two digit number. The two character code identifies the ISAP activity involved as follows:
1 60 = original 60 (see 1 above)
RS = Reduction Splices (see 2 above) 35 = Additional 35 (see 3 above) 07 = Additional 7 (see 4 above) i ()
EP = Extended Population (see 6 above)
SF = Short Form Investigation (see 7 above) j MS = Missed Sample (see 8 above) 1
~
OB = Observation (see 9 above)
The two digit code simply represents a sequential number within the given activity.
For example, Sample No. 35-10 refers to the tenth j
item from the Additional 35.
1 4
h i
1 4
9 I
, -,, _, - - ~..,. -,. _, _,, -.,,.. _,.,,, - - _,, _ -. -.
l' 4
D COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP:
I.b.4
Title:
Barrier Removal REVISION 1 i
O 0 b'- di Asmlsa>11 19AL Issue Coor/Inato#/
Date llll!$
L view Leader Dat6
%G W izbr/ec.
JelM W. Beck, Chairman CPRT-SRT Date
- O ge1 +a1 +.3 %
- b
+
Rsvision:
1 Page 1 of 24 RESULTS REPORT
~
ISAP I.b.4 Barrier Removal *
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No.
7, Page J-42)
"The TRT determined that the missing barrier (used to separate redundant devices in auxiliary feedwater panel CPI-EC-PRCB-09) and the' field wiring not being separated by the required 6 inches (inside panel CP1-EC-PRCB-03) were the only two instances of Class IE panel-mounted devices in violation of the separation criteria viiich require corrective action."
2.0 ACTIONIDENTIFIEDBYNRC(NUREG-0797,Supplemen[No.7,ItemNo's 6(c) & 6(d), Page J-44)
"TUEC shall accomplish the following actions prior to fuel load:
t Take corrective measures to provide a barrier in auxiliary feedwater panel CP1-EC-PRCB-09 separating redundant flow and pressure instruments.
Take corrective action to ensure that the required minimum separation of the redundant field wiring identified inside y
panel cpi-EC-PRCB-03 is maintained either by distance or by en acceptable barrier."
\\
d
3.0 BACKGROUND
5 Barrier material supplied by the control board manufacturer was removed, creating a separation violation (panel CP1-ECPRCB-09).
In addition, field wiring was within one (1) inch of device 1-HS-5574, creating a separation violation (panel CP1-ECPRCB-03).
The general subject of the Electrical-Action Plans I.b.1. I.b.2, I.b.3, and I.b.4 is electrical separation between cables of redundant ** trains. Action Plan I.b.3 deals with electrical separation outside of electrical panels and is not related to this i
action plan. However, Action Plans I.b.1 and I.b.2 both deal with Title remains same as that given in Action Plan I.b.4 for historical purposes. However, this report covers the more general topic of electrical separation in multi-train panels.
All separation requirements in this report are for redundant.
cables. The word " redundant", as.used herein means tliat th'e cables requiring separation belong.to different trains, i.e., Class IE train A, Class 1E train B, or non-Clias IE train C.
' bt
R& vision:
1 Paga 2 of 24 RESULTS REPORT
,s ISAP I.b.4 (Cont'd)
3.0 BACKGROUND
(Cont'd) electrical separation inside electrical panels. As such, separation findings from these action plans that are similar to the findings found by the NRC-TRT are discussed in this Results Report.
4.0 CPRT ACTION PLAN 4.1 Scope and Methodology
)
The original objective of this action plan was to resolve the identified separation violations.
To achieve this objective, the following tasks were implemented:
g Replaced missing barrier material Reworked field cables In the process of inspecting the control boards and vertical ventilation panels pursuant to Action Plans I.b.1 and I.b.2, additional separation violations involving missing barriers and cable-to-device separation violations were identified. As a result, the scope of this action plan was revised to address all internal panel separation violations not already covered by Action Plans I.b.1 and I.b.2.
4.1.1 Rework of NRC-Identified Deviations The barrier material was replaced and the field cables reworked to resolve the separation violations.
Nonconformance Reports were issued to assure proper disposition of these items by TUGC0 Engineering.
The CPRT third-party reviewed the NCRs for adequacy of
)
disposition and subsequent closure.
1 4.1.2 Evaluation of Other Separation Violationo As a part of Action Plans I.b.1 and I.b.2, the Unit 1
)
control boards and vertical ventilation panels were inspected by CPRT third-party inspectors to identify separation violations. TUGC0 QC inspectors performed s vclidation of the CPRT third-party findings and an inspection of the panels for those separation C
~ attributes that had been revised to more stringent requirements than those used in the previous Project inspection.
As a result of these inspections,
-y e
~
Ravision:
1 Paga 3 of 24 RESULTS REPORT V
ISAP I.b.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) additional separation findings were noted. Those findings not addressed in Action Plans 1.b.1 and I.b.2 are included in this action plan.
As described in Action Plans 1.b.1 and I.b.2, the Electrical Review Team examined all remaining multi-train panels containinig cables that require electrical separation to determine where SERVICAIR flex
- is used. During this examination, the Electrical Review Team noted additional separation violations.
These findings are also addressed in this action plan.
4.1.3 Use of Results i
Results (,f the actions taken under this plan were evaluated to establish root causes, generic implications, and appropriate' corrective action.
4.2 Participants Roles and Responsibilities s
The organizations and personnel that participated in this effort are described below with their respective work scope.
4.2.1 TUGCO Comanche Peak Project 4.2.1.1 Will process NCRs that were generated due to this action plan.
4.2.1.2 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed inspection reports.
4.2.2.2 Will review NCRs generated due to this action plan.
4.2.2.3 Determined root cause and generic implications of unclassified deviations.
SERVICAIR flexible metallic conduit (referred to in this report as SERVICAIR flex) is the flexible conduit used for separation inside the control room panels.
Ravision:
1 Paga 4 of 24 RESULTS REPORT ISAP 1.b.4 (Cont'd) 1 l
4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.4 Personnel (prior to October 18, 1985)
Mr. M. B. Jones, Jr.
Review Team Leader Mr. E. P. Stroupe Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985)
Mr. J. J. Mallanda Review Team Leader Mr. R. J. Bizzak Issue Coordinator Mr. M. B. Jones, Jr.
Third-Party Adviser i
Mr. E. P. Stroupe Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Inspected completed rework performed to resolve the NRC-TRT findings.
4.2.3.2 Inspected Unit I control room control boards i
and vertical ventilation panels for compliance to separation guidelines.
4.2.3.3 Personnel Mr. J. L. Hansel Review Team Leader -
QA/QC 4.3 Qualification of Personnel Where inspections required the use of certified inspectors, qualifications at the appropriate level were to the requirements of ANSI N45.2.6, " Qualification of Inspection.
Examination, and Testing Personnel at Nuclear Power Plants."
CPRT third-party inspectors were certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the CPRT Program Plan.
Third-party participants in the implementation of this action plan met the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.
O i
I
--...-.,,.,,.--c.
Revision:
1 Page 5 of 24 i
RESULTS REPORT O
i ISAP I.b.4 (Cont'd) r
\\
4.0 CPRT ACTION PLAN (Cont'd)
[
Other participants were qualified to 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.
J 4.4 Procedures The following CPRT procedure was developed for use in the third-party inspection of the Unit I control room control boards and vertical ventilation panels:
i 1
Quality Instruction QI-004, "CPRT Action Item I.b.1 1 i Flexible Conduit to Flexible C nduit Separation; CPRT 9
Action Item I.b.2 -' Flexible Conduit to Cable Separation."
4.5 Acceptance Criteria The separation requirements of Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details," will be used as the 4
acceptance criteria for this action plan.
i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summary of Implementation i
The two violations to the separation criteria for panel-mounted devices identified by the NRC-TRT (NUREG-0797, Supplement 7) have been corrected.
For the separation violations in multi-train panels identified i
during,the implementation of Action Plans 1.b.1 and I,b.2, Nonconformance Reports (NCRs) have been issued. These violations are discussed in Section 5.3.
All violations not involving electrical separation that were identified during the implementation of this action plan,'as well as Action Plans I.b.1 and I.b.2, are covered in Section 5.10, "Out-of-Scope Findings."
5.2 Results of Investigation of NRC-Identified Findings The two findings relative to the separation criteria inside l
panels CP1-ECPRCB-09 and CPI-ECPRCB-03 noted by the NRC-TRT,
--,.----..-w
.-------.--,,-v-..
r- - -
m+wwm-u u.
B Rzvision:
1 Paga 6 of 24 RESULTS REPORT ISAP I.b.4 (Cont'd)
.5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) one concerning the missing barrier and one concerning inadequate cable-to-device separation, were confirmed to be devictions from the Project separation criteria.
Nonconformance reports (NCRs) E-84-100526 and E-84-100524 were issued to address these deviations.
Upon completion of the rework associated with the NCRs, the Electrical Review Team Leader requested that a CPRT third-party inspector verify that the deviations had been satisfactorily resolved. The inspector verified that the rework specified by NCR E-84-100524 dealing with the missing barrier had been properly implemented. However, a cable-to-device separation violation was found involving the same cable and device as those addressed in NCR E-84-100526. g This violation was subsequently documented on an Electrical Equipment Deficiency Report attached to Inspection Report PCV-1-0055859 and corrected by adding cable ties so that
. (Q) proper separation is maintained even if movement of the cable is attempted. This corrective action was reinspected by a CPRT third-party inspector and found to be acceptable.
As noted above, a separation violation involving the same cable and device identified in NCR E-84-100526 was found after the NCR had been completed. The inspection report closing out the NCR as satisfactory was dated October 18, 1984; the CPRT third-party inspection of the rework was performed January 4, 1985. Two possible explanations for this are either that the rework specified by the NCR was not performed satisfactorily or that the rework was done properly, but later activities resulted in movement of the cable.
It is unlikely that the rework was not performed satisfactorily since a QC inspection was performed for the rework initiated by the NCR (the NCR only addressed this single separation violation), and the i
rework was found acceptable.
In addition, at inast ten work i
authorizations on the subject panel were active between the
)
completion of the NCR and the CPRT reinspection.
Therefore, it is likely that subsequent work activities in Panel CP1-ECPRCB-03 resulted in movement of the cable. Two possible expSanations for this are:
- 1) Construction, startup, and operations personnel were not sensitized to the fact that work they perform must not result in separation violations, and Y
Ravision:
1 Page 7 of 24 RESULTS REPORT ISAP I.b.4 i
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- 2) Cables that can be moved and remain in a position that creates separation violations were not adequately secured.
The action taken to resolve the first issue identified above 4
was to institute a training program to sensitize craft, QC, startup, and operations personnel working in multi-train panels to the importance of maintaining electrical separation.
1 The second' issue involv'es cables that can be moved to create separation violations and remain in the new position. To prevent this from occurring in the future,-QC Inspection Procedures QI-QP-11.3-28, " Class LE Cable Terminations,"
QI-QP-11.3-40, " Post Construction Inspection of Elect.rical.i Equipment and Raceways," and QI-QP-11.3-55, " Turn-Over j
Walkdown," were revised to include a check to identify unsecured cables that can be moved to create a separation l
violation and remain in that position. QC Inspection i O Procedure QI-QP-11.3-40 will be used for the final baseline
- v inspections discussed in Section 5.7.
1 5.3 Additional Separation Violations This section discusses all of the additional separation findings identified during the implementation of Action Plans
{
I.b.1 and I.b.2.
These findings can be grouped into the following two categories:
i a)
Separation violations in the control room control boards and vertical ventilation panels identified by i
the CPRT third-party inspectors and TUGC0 QC I
i inspectors.
i b)
Separation violations in multi-train electrical panels other than the control boards and vertical ventilation panels. These violations were noted by the Electrical j
Review Team during its examination of multi-train j
panels for SERVICAIR flex, by the CPRT third-party l-inspectors during their activities associated with i
Action Plans I.a.2 and I.a.3, and by TUGC0 QC i
inspectors during their review of the Electrical Review-Team's findings.
5.3.1 Deviations in the Control Roo's Control Boards and O
Vertical Ventilation Panels The CPRT conducted a third-party inspection of the control room control boards and vertical ventilation 8
i c
Rsvision:
1 Paga 8 of 24 y'~g RESULTS REPORT t
ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) panels to identify all cable separation violations.
This inspection was performed shortly after the TUGC0 post-construction inspection of these panels.
As discussed in Action Plans I.b.1 and I.b.2, the CPRT inspectors used preliminary, conservative separation guidelines. When the final separation criteria
- were developed. TUGC0 validated the CPRT findings against the final criteria. Since this validation, in some cases, required field verification, it was decided to perform concurrently a reinspection of the control boards and vertical ventilation panels for those separation attributes that were revised to more restrictive requirements. During this reinspection process, the TUGC0 inspectors noted additional t
separation violations unrelated to either the CPRT third-party findings or the revised attributes.
The cable separation deviations found during the two (sh inspections noted above can be grouped into the following ten categories:
1)
Cable-to-SERVICAIR flex separation violations (deviations noted in Action Plan I.b.2) 2)
Missing or inadequate barriers (similar to one of the NRC findings quoted in Section 1.0 of this report) 3)
Cable-to-device separation violations (similar to one of the NRC findings quoted in Section 1.0 of this report) 4)
Cable-to-cable separation violations 5)
Cable-to-wireway separation violations 6)
Cable-to-conduit separation violations 7)
Cable-to-barrier separation violations 8)
SERVICAIR flex-to-conduit separation violations p
1
~
The final separation criteria are the separation criteria developed as a result of Action Plans I.b.1 and I.b.2.
See Detail 61 of Drawing 3323-El-1702-02and DCA 21,445," Cable and Raceway Separation Typical
- Details, Revision 1
-_. (
j Revision:
1 Pags 9 of 24 RESULTS REPORT
- O f
ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 9)
Separation not maintainable 1
10)
Findings related to the design of the electrical panel (wireway covers missing,-
j.
gaps in wireway, wireways touching wireways)
I Note that neither inspection resulted in any deviations j
associated with Action Plan I.b.1 - SERVICAIR flex-to-SCRVICAIR flex. The deviations found by the CPRT l
thfrd-party inspectors and TUGC0 QC inspectors for each of the categories listed above are summarized in Table 1.
CPRT findings that did not meet the preliminary, conservative separation guidelines, but did meet the final separation criteria, are not included in Table 1, regardless of whether or not a Nonconformance Report was written. Deviations found by both the CPRT third-party inspectors and the TUGC0 QC inspectors are 3
1 only listed once.
5.3.2 Deviations in Other Multi-Train Panels l
During the Electrical Review Team's examination of multi-train panels for SERVICAIR flex performed for Action Plans I.b.1 and I.b.2, separation violations were noted in panels other than the control boards and vertical ventilation panels. The Electrical Review Team did not perform a complete inspection of the-panels for separation violations; the violations noted were those found while examining panels for the use of SERVICAIR flex.
. The subsequent TUGC0 review of these panels to validate the CPRT third-party findings resulted in the identification of additional findings.
j l
In addition, the CPRT third-party inspectors, during 4
their inspections associated with Action Plans I.a.2 and I.a.3, noted four panels with separation violations.
There are 13 Unit I control room control boards end i
vertical ventilation panels and 75 other Unit 1 and 4
cosmon area electrical panels that require separation between redundant trains. In these other 75 panels, the CPRT third-party identified 47 that contained separation violations. These violations were I
transmitted to TUGC0 for resolution. For 17 of the panels, the violations had previously been identified i
on Nonconformance Reports and either accepted use-as-is i
by engineering evaluation or had not yet been dispositioned.
j N.-----..-
,. ~ -.. - - - - -, -
Rsvision:
1 Page 10 of 24 RESULTS REPORT ISAP 1.b.4 (Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Thus, there were 30 of these other panels in which j
separation violations were found that previously had not been identified by the Project. During the TUGC0 i
review of these panels, several additional deviations in the same panels were noted; all deviations were reported on Nonconformance Reports (NCRs). All deviations were violations of the original separation criteria as well as the final separation criteria.
t i
The majority of the items reported on the NCRs (40 out j
of a total of 61) were for cable-to-cable separation violations.
Fifteen of the NCR items involved cable j
and some form of conduit, i.e.,
rigid metallic, 5
SERVICAIR flex, Greenfield flex, or Sealtite flex. The remaining six items involved cable-to-device, cable-to-j wireway, and improper barrier material violations.
l 5.4 Safety Significance Evaluation The CPRT third-party and TUGC0 inspections of the control room control boards and vertical ventilation panels resulted in 227 separation violations being found. The NRC-TRT identified two separation violations, as noted in Section 1.0 of this report.
Examinations of multi-train panels other than the control boards and vertical ventilation panels resulted in 61 j
separation violations being found.
A Those cases in which only the final separation criteria were not satisfied are not deviations since they do not represent violations of the criteria in existence at the time of installation. The fact that the original separation criteria were changed when construction was essentially complete is addressed in Section 5.8, " Observations."
In order to determine whether or not the remaining separation violations, i.e., violations of the original separation criteria, are safety-significant, it would be necessary to j
conduct an extensive testing and analysis program for the various types of cable insulation and circuit functions for the cables involved. Rather than perform this type of safety significance evaluation, the Electrical Review Team decided to i
classify the above deviations as " unclassified deviations."
As such, a root cause analysis and generic implications i
I evaluation were performed, and a corrective action program i
vill be implemented.
t 4
e
-=
i Rsvision:
1 Pags 11 of 24 RESULTS REPORT O
ISAP I,b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.5 Root Cause Analysis Because separation violations were found to be so widespread in the multi-train panels for Unit 1 and common areas, the CPRT third-party considered that the following must have occurred:
1 The original installation was not properly performed i
j AND
- The subsequent Quality Control (QC) inspection did not detect and ensure correction of the violation t
AND/OR Work and/or testing performed subsequent to the cable installation and inspection resulted in separation violations.
Each of the above events was investigated to determine if the
{
root causes and/or contributing causes of separation i
violations could be identified. The elements of organization, personnel, procedures & criteria, and environment were examined to determine how they might contribute to produce the above circumstances. The number of deviations that were found j
indicate that the deviations are not isolated to any one panel or person.
i From this investigation, the Electrical Review Team i
hypothesized that the following factors were possible contributors to the separation violations identified in this report:
t Insufficient supervisory emphasis on establishing and j
maintaining separation I
Inadequate craft, QC, startup, and operations procedures Lack of effective training
' Major modifications to panels in the late stages of.the construction process i O Panel designs that are'not conducive to maintaining separation i
J
=
'l Rsvision:
1 Page 12 of 24 i
w i
RESULTS REPORT ISAP I.b.4 i
(Cont'd) 1 1
l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The lack of a requirement that cables be secured to prevent inadvertent movement that could result in a j
separation violation Inadequate coordination among engineering, construction, QC, startup, and operations I
Because the separation violations were not restricted to any one group on site, i.e., construction, QC, startup, or J
operations, the root cause(s) must address all the
]
organizations involved. The following factors are considered to be root causes of separation violations in multi-train j
panels:
}
-t
- Insufficient supervisory emphasis on establishing and maintaining separation i
Informal discussions with Project personnel indicate that separation may not have been a major concern to craf t and inspection personnel during cable 4
j installation activities. For example, during the human factors engineering (HFE) modifications performed on
{
the control boards, the major emphasis was on completing the physical work.
Inspections for l
separation were made only for the particular conductors being terminated, per the in-process inspection
}
procedure. The identification of any separation violations that were inadvertently created during the j
installation process, involving cables other than those being installed, was not emphasized. The rationale was that the final post-construction inspection would 1
identify all violations, which then would be corrected.
j Though this may have been an efficient method of completing the modifications, it may have had a detrimental impact on craft and QC inspection personnel in that they may have been given the impression that separation is not a critical element of proper installation.
I j
A review of the post-construction inspection of the i
control boards that was performed in late 1984 and early 1985 indicated that the number of violations found was too large to allow for a proper inspection.
Over 350 violations were found in the eleven control
'l ()
boards. The large number of violations that were found would indicate that the inspectors were confronted with a difficult inspection task and could have failed to i
- 6
,--..x--_--_-.-.--.--------.-
Revision:
1 i'
Paga 13 of 24 RESULTS REPORT 3
l ISAP 1.b.4 (Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) find all violations.
Furthermore, subsequent rework to i
correct these separation violations and other nonconforming items not related to separation was undoubtedly extensive and could have resulted in additional separation violations.
The final assurance of electrical separation relied on the final post-construction inspection.
In-process work did not receive the attention to detail that it I
deserved. The " wait till we are done" attitude resulted in many violations. This can be verified by j
examining the post-construction inspection reports for l
the control boards.- The extent of the violations that were found (approximately 350 ) obviously made the
.t l
final inspection more difficult than it would have been i
otherwise.
i j
The impression that the Electrical Review Team received was that the Project did not place the proper emphasis i
on electrical separation, that the prevailing attitude was that somehow everything would be shown acceptable I
prior to fuel load, and that the existing system for establishing and maintaining separation would work.
4 The practice of deferring separation considerations and the supervisory attitude inferred from it is determined j
to be a root cause affecting both the craft's inability j
to establish and maintain separation and QC's failure j
to detect and ensure correction of the separation j
violations.
Inadequate craft, QC, startup, and operations l
procedures The craft procedure fer terminating cables, 35-1195-EEI-8, " Class IE and non-Class IE Cable Terminations," did not contain separation requirements until June 1985. Therefore, the only formal direction l
provided to the craft prior to that time was the separation criteria presented in~ Electrical Erection l
Specification 2323-ES-100, which was referenced by the i
craft procedure. The omission of separation l
requirements in the termination procedure is judged to have had the effect of minimizing to craft personnel l
the importance of establishing separation inside j
panels.
1 i
i 4.-.-
..___,__.-_.__...__...-_._.-___a__-..-~..
h j
Rsvision:
1 Pegs 14 of 24 9
i l~
RESULTS REPORT
- O ISAP I.b.4 (Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
}
During a review of startup and operations procedures, it was observed that the separation criteria were never j
explicitly discussed in the procedures. Therefore, if 4
work requiring partial disassembly of the wiring in the panels was necessary, the cognizant person would not, by procedure, have access to the detailed separation requirements.
In addition, the procedures allowed startup and operations personnel to perform certain work activities in multi-train panels without requiring j
a subsequent inspection of the work.
i i
The QC procedure for the in-process inspection of a termination is QI-QP-11.3-28, " Class 1E Cable i
Terminations." The following historical shortcomings t j
were identified in QI-QP-11.3-28:
l
- Verification of separation attributes was deleted from the procedure from 4/80 through 8/80
- The procedure does not address inspection of-non-Class 1E cables in multi-train panels j
- The procedure only addresses field-run, redundant a
cables.
)
Taken individually, none of these shortcomings, except-the last one, would affect the final installation since j
a post-construction inspection is performed to QC l,
Procedure QI-QP-11.3-40, " Post Construction Inspection i
of Electrical Equipment and Raceways." The fact that i
non-Class IE cables were not required to be inspected j
could have a major impact on installations made after the post-construction inspection since all separation violations of non-Class 1E cables with installed Class IE cables would neither be inspected nor identified by I
QC inspectors.
i I
Until 1986, both QI-QP-11.3-28 and QI-QP-11.3-40 only addressed field-run, redundant cables. The assumption appeared to be that the vendor-installed cables would i
have adequate separation as provided by the vendor.
Since subsequent work in the panels could create separation violations, the procedures should not have limited inspections to field-run cables.
1 l
i w-c
Revision:
1 Pags 15 of 24 RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Lack of effective training -
Prior to May 1985, craft training dealing specifically with electrical separation was comprised of reading the Electrical Erection Specification ES-100 and associated procedures, classroom instruction, and on-the-job training (0JT). The subject of internal panel separation in ES-100 consists of one paragraph, Paragraph 4.11.3.3 (2), and an associated three-page Design Change Authorization (DCA). Considering the size of the overall specification (approximately 140 pages plus over 65 active DCAs as of May 1986), it is clear that the reading assignment would not, by itself, ensure adequate training on the subject of separation 6 inside panels. As noted above, the procedure for terminating cables did not mention separation requirements prior to June 1985.
O The CPRT third-party reviewed the lesson plans used for training craft personnel involved with terminating cables. Separation requirements were not included in the lesson plans reviewed, although personnel attending these classes state that separation was discussed.
It would appear that the majority of the training would i
have occurred on the job when new personnel were placed with experienced craftsmen familiar with the job requirements. Since a majority of the electrical panels do not require cable separation (i.e., they contain only one train), it is possible that some of the craft trainees were not provided with sufficient experience in dealing with cable separation requirements.
The training of quality control inspectors was similar to that provided to the craft. Training consisted of classroom reading of the procedures, written examinations, and on-the-job training.
It is difficult to reconstruct the extent of training that was provided to craft and QC inspectors in the late 1970s and early 1980s. Indications are that training on separation was provided, but the extent of the training is difficult to, determine. However, the O
effectiveness of the training was limited by the lack of emphasis placed on separation during in-process installation of cables.
O
,m..
...-m ~
--_m---,--v~=m'm,----m-n~--'4'1m" D'~
^ **" M
u Rsvision:
1 Pcgo 16 of 24 RESULTS REPORT ISAP 1.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The training of startup and operations personnel was not investigated since the applicable procedures did not explicitly, address the separation criteria.
Although they contributed to the problem, the following factors were not found by the Electrical Review Team to be root causes:
Major modifications to panels in the late stages of the construction process j
Modifications made to the control boards to accosmodate i
human factors engineering (HFE) requirements were l
extensive and made the establishment of electrical i
separation within the panels more difficult.
4 However, the fact that not all panels in which separation violations were found were extensively l
modified after construction was essentially complete
}
indicates that this factor, though it may have resulted in some separation violations, is not a root cause.
Panel designs that are not conducive to maintaining separation j
One aspect of the panels that makes separation i
difficult to establish and maintain is that there are a minimal number of wireways provided for field-run cables. This results in cables being exposed between the panel entry point and the termination blocks or devices. This, in turn, results in the need for larger separation distances between exposed cables than would otherwise be required if the cables wers routed in wireways. Additionally, support attachment points are relatively sparse, which makes it difficult to secure cables in a way so as to prevent separation j
violations due to inadvertent movement of cables.
In addition, the control boards are very congested and contain fairly complex wiring arrangements.
However, the fact that separation violations exist in a large percentage of the panels, many of which are relatively uncongested, indicates that the above factors are not the root causes of separation violations. They are, however, contributing factors for the greater number of deviations found in the control boards and vertical ventilation panels than in other multi-train panels.
i, i
s-Rcvisiont 1
Pags 17 of 24 RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The lack of a requirement that cables be secured to prsvant inadvertent movement that could. result in a separation violation
~
The Electrical Erection Specification does not state that wiring should be secured to prevent separation violations as a result of inadvertent movement of the cables. As discussed in this Results Report, this is a concern in maintaining separation throughout the life of the plant. The lack of properly-secured cables in combination with subsequent work activities undoubtedly resulted in separation violations.
However, the lack of a requirement to properly secure i cables does not by itself cause separation violations; securing cables is an additional preventive measure.
Furthermore, violations were found to exist where it was apparent that the cables had not been moved from their installed position.
Inadequate coordination among engineering, construction, QC, startup, and operations There appears to have been a lack of coordination among the groups involved, i.e.,
engineering, construction, QC, startup, and operations. Separation problems have been recognized as an issue since the arrival of the control boards on site; however, no particular emphasis had been given by startup and operations to this issue.
Operations has an electrical specification. TES-100, similar to the Electrical Erection Specification 2323-ES-100. Nonetheless, changes made to ES-100 were not incorporated into the Operations specification.
Engineering maintains two sources of separation criteria -- Electrical Erection Specification 2323-ES-100 and Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details." The craft procedure references the specification; current Quality Control procedures reference the drawing. The QC procedures are more detailed in that they list multi-train panels where separation is not required; the craft procedures contain no such information.
l O
Operations and startup procedures do not contain the detailed, internal panel separation criteria, nor do 1
they reference engineering documents where the criteria
- y
l R2 vision:
1 Pags 18 of 24 RESULTS REPORT t
ISAP I.b.4 (Cont'd) 4 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) can be found. An adequate interface among the groups 1
involved (:ould have ensured that the separation criteria are presented more precisely and are sufficiently detailed to be implemented.
Inadequate coordination among the groups involved does j
not itself cause separation violations. However, proper coordination would likely have led to early detection and correction of the problem.
The previous discussions detail the identified root causes and other contributing factors that collectively explain why separation violations were found to be so widespread throughout the multi-train panels for Unit 1 and cosanon areast As noted above, the factors of major panel modifications and panel designs not conducive to maintaining separation do not apply to all the panels where separation violations were noted. The lack of a requirement to properly secure cables l
does not by itself cause separation violations; securing i
cables is an additional preventive measure. Furthermore, violations existed where it was apparent that the cables had i
[
not been moved from their installed position.
]
Inadequate coordination among the groups involved is a factor that does not itself cause separation violations. However, proper coordination could have detected and corrected the problem.
l In summary, the root causes appear to be inadequate craft, QC,
]
startup, and operations procedures; a lack of effective craft i
and QC training; and insufficient s apervisory emphasis. All the groups involved, i.e., craft, QC inspectors, startup 4
personnel, and operations personnel, were affected by one or i
more of the above root causes.
In addition, the effects of these root causes would apply to all multi-train panels.
1 5.6 Generic Implications Since the criteria, procedures, and personnel associated with the control boards and vertical ventilation panels are the same as those f e other multi-train panels, the implications of the root cause are not limited to the control boards and j=
vertical ventilation panels, but extend to all multi-train panels. As noted above, separation violations were noted in i
43 of the 88 multi-train panels. Therefore, corrective actions must address all multi-train panels.
1
. e 4*
,. -,-,..,, - - --,-_,~,.-,.-----
_(
~ _ _ _
T Rsvisiont 1
Pego 19 of 24 f
i j
l RESULTS REPORT l
ISAP I.b.4 (Cont'd)
}
r l
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i The procedures, training, and supervision related to cable separation inside electrical panels are limited to multi-train electrical panels. Based on the above, it is judged that the l
generic implications of the above root causes are confined to I
1 multi-train panels. The possibility that similar concerns may j
exist in other areas of plant electrical separation will be i
l investigated in Action Plan VII.c.
l 4
The facts related to the root causes have been transmitted to I
the QA/QC Review Team for further evaluation during their collective evaluation program.
?
1 i
j 5.7 Corrective Actions i
l 4
i All deviations to the separation criteria have either been i
noted on Nonconformance Reports or otherwise corrected. The Project is currently dispositioning the NCRs; the disposition of the NCRs will be reviewed by the Electrical Review Team.
TUGC0 is developing a corrective action program to resolve i
separation issues identified during the implementation of l
Action Plans I.b.2 and I.b.4.
The major elements of the program are described below.
}
TUGC0 recognizes the need to establish and maintain cable I
separation inside electrical panels for all stages of plant i
life -- constructiot., start-up, and operations. Key elements j
to achieving these objectives are the establishment of precise j
criteria, the training of responsible personnel, the timely j
performance of inspections, and the control of activities j
performed after inspections have been completed. To this end, TUGC0 is currently taking the following actions:
i t
)I
- 1) Updating of all procedures, drawings, specifications, etc., dealing with internal separation to clarify the j
criteria 2)
Instituting a special training program to ensure that personnel involved with multi-train panels, i.e. craft, QC inspectors, engineers, start-up personnel, and j
operations personnel, are sensitized to the need to j
establish and/or maintain separation
- 3) Job-specific training for craft, QC inspectors, start-up, and operations personnel to the revised j
documents J
.l[.
Rrvision:
1 Pag 2 20 of 24 RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLDiENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- 4) Performing a baseline inspection, which includes verification of all separation attributes, to ensure that the required separation criteria have been met
- 5) Controlling access to panels requiring cable separation after the baseline inspection indicates a satisfactory configuration.
The above corrective actions are aimed at establishing and maintaining electrical separation in electrical panels. The responsibility of establishing and verifying separation lies with construction and QC personnel. To enhance the performance of these groups, the craft Procedure EEI-8, " Class IE and Non-Class IE Cable Terminations," and the QC procedureg I
for in-process and final inspections of cable separation will be revised to define more precisely the requirements for cable separation.
In addition, training will be performed to sensitize personnel to the necessity of establishing and maintaining separation.
After construction of a panel has been completed, maintaining separation is the responsibility of startup and operations personnel. Procedures will be revised or new procedures written that specifically address the separation criteria.
Startup and operations personnel involved with multi-train panels will also receive training to sensitize them to the necessity of establishing and maintaining separation. Prior to turnover to operations, a complete reinspection of the panels to assure proper separation will be performed, and the panels will be tagged as multi-train panels. For those panels currently under Operations' custody, the above reinspection and tagging will be performed af ter the necessary document revisions and training have been completed. Subsequent work will be performed via a Work Order in accordance with Operations Proce<*ure STA-606, " Work Requests and Work Orders."
The Electrical Review Team has reviewed the corrective actions proposed by the Project and concurs that, if implemented as planned, these actions will correct the identified deviations and adequately address the root causes determined by the Electrical Review Team.
The above program adequately addresses the generic implication associated with all multi-train panels.
j n
G
R: vision:
1 Pcg2 21 of 24 i
RESULTS REPORT l
ISAP I.b.4 l
(Cont'd) i 1
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l 5.8 Observations i
i Two observations were made by the Electrical Review Team during the implementation of this action plan. The first j
observation involves recent changes in the separation criteria i
for power cables inside panels.
In mid-1985, more stringent separation criteria were specified for 120 Vac lighting and i
convenience receptacle wiring. Criteria for other power I
cables are being developed. The revision of separation l
criteria for power cables after the electrical penals have i
essentially been completed suggests a design issue requiring further investigation by the Design Adequacy Review Team.
l The second observation involves the method by which criteria t are issued. The primary source of separation criteria is Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical l
Details." Revisions to the separation criteria are made to this drawing. Since the separation criteria are not i
explicitly incorporated into craft, quality control, startup, and operations procedures, changes to the separation criteria i
{
do not result in changes to procedures.
Since the procedures are not revised, training to the new criteria is not ensured.
i The above observations have been transmitted to the Design l
Adequacy and QA/QC Review Team Leaders, as appropriate, to be included in their collective evaluation programs.
5.9 Unit 2 Electrical Panels The inspections and examinations performed under this action plan involved Unit 1 and common area electrical panels.
i However, the TUGC0 program outlined in Section 5.7 will apply to Unit 2 also. This corrective action will ensure that the installed configurations meet the final Project separation criteria.
5.10 Out-of-Scope Findings i
During the implementation cf the I,b Action Plans, findings unrelated to electrical reparation were identified. These findings can be summarized in the following categories:
l a) Loose fittings and couplings, loose or damaged support clamps, loose light fixtures, etc., for the electrical
]
metallic tubing (DtT) and rigid conduit used in the l
control room control boards and vertical ventilation i
- h
i Ravision:
1
}
Pegs 22 of 24 i
I l
RESULTS REPORT i O ISAP I.b.4 r
l (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) j panels. These findings were noted during the CPRT j
third-party inspection of the control room control j
boards and vertical ventilation panels.
i l
b) Drawing errors involving the identification of two J
associated cables as Class 1E cables; drawing error for j
switch locations in CPK-ECPRCV-03; drawing error on the j
labeling of lighting transformer KF-SCI-3.
l c) Incorrect tagging of four conductors in an electrical panel as train A rather than train B.
I j
d) The lack of or inadequate supports on SERVICAIR flex and other cables.
- 6 e) Two vendor drawings'specifying different current l
l ratings for the same fuse.
i These categories do not relate to electrical separation and i
have been transmitted to the appropriate Review Team Leaders
{
as "out-of-scope findings" for their evaluation. The specific j
findings have been addressed by TUGC0 and either accepted as is or, in most cases, Nonconformance Reports or Design Change
)
Authorizations to drawings have been issued. It should be noted that the requirement to support SERVICAIR flex at least
)
every three feet is a requirement added to the final j
separation criteria. Therefore, the findings in category (d)
{
do not represent hardware installation deviations.
4 i
6.0 CONCLUSION
S The actions identified by the NRC in Section 2.0 of this report i
were to take corrective measures to correct two instances of l
separation violations noted in panels CPI-ECPRCB-03 and j
CPI-ECPRCB-09. The two violations have been corrected.
1 In NUREG-0797, Supplement No. 7, Page J-53, the NRC states that, "The TRT concludes that the unjustified installation of cables and flexible conduits inside panels that do not meet minimum separation j
requirements has generic implications.... The TRT findings on j
cable saparation may be indicative of poor QC personnel training in l
procedural requirements for installation and inspection."
O
~
i i
i
,-.--4-.r,--....w,-
-.,*.---,--._,em.i...---.---,,e,..
--m..,--r.iw,..
..--y,
,-__..y,~e
.--,c v,-w-
{3
,,.w
-,.y
1 Ravision:
1 4
Ptgs 23 of 24 i
i lo RESULTS REPORT i
{
ISAP I.b.4 i
(Cont'd)
{.
I
6.0 CONCLUSION
S (Cont'd)
As discussed in Sections 5.5 and 5.6, the Electrical Review Team j
has investigated the situations leading to the various separation l
findings and concurs with the NRC that there are generic j
implications that extend, as a minimum, to all multi-train panels.
i However, the Electrical Review Team believes that the root cause is l
broader than the one hypothesized by the NRC, i.e., poor QC j
training. The root causes determined by the Electrical Review Tesa j
involve inadequate procedures, a lack of effective craft and QC j
training, and insufficient supervisory emphasis on separation.
j j
TUGC0 has proposed a corrective action program, as discussed in i
Section 5.7, that addresses the updating of all procedures, j
drawings, specifications, etc. dealing with internal separation.
Subsequent training, base-line inspections, and controlled access.g
{
to the panels will ensure that all concerns involving separation in d
electrical panels are resolved.
O 7.0 ONGOING ACTIVITIES NCRs issued for the control room control boards and vertical ventilation panels as a result of deviations related to this action plan and Action Plan I.b.2 have not yet been completely resolved.
}
The Electrical Review Team will review the disposition of the NCRs.
j After the NCRs are closed TUGC0 will perform a post-construction l
inspection of these panels, which will include verification of adequate separation. This inspection will be overviewed by the CPRT third-party.
In addition, the CPRT third-party will review the disposition of NCRs for all other multi-train _ panels issued to resolve separation i
deviations identified during the implementation of the I.b Action Plans.
1 l
As discussed in Section 5.7, TUGC0 also is in the process of developing and implementing a program to establish and maintain
)
separation within electrical panels. The Electrical Review Team j
will review this progras as it is being developed.
i j
Upon the completion of the above ongoing activities, a Supplemental Report will be issued; this supplement will provide the results of the activities described above.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE The program described in Section 5.7 will ensure that separation 4
inside multi-train panels in Units 1, 2, and common areas will be established and maintained.
a 4
R:visiont 1
Pcgs 24 of 24 RESULTS REPORT ISAP I.b.4 i
(Cont'd) 1 TABLE 1 Sununary of Separation Violations Identified in the Control Room Control Boards and Vertical Ventilation Panels by the CPRT l
Third-Party Inspectors and TUGC0 QC Inspectors.
j CPRT l
Category Third-Party TUGC0 Total i
l Vo*
Vn*
Vo Vn Vo Vn i
- 1) Cable-to-SERVICAIR Flex (I.b.2) 14 7
8 22 7
- 2) Missing or Inadequate i
Barrier 2
4 1
1 3
3 4
- 3) Cable-to-Device 10 4
1 11 4
4
- 4) Cable-to-Cable 9
22 31
- 5) Cable-to-Wireway 9
14 10 19 14
- 6) Cable-to-Conduit 3
3
- 7) Cable-to-Barrier 1
6 7
I i
- 8) SERVICAIR flex-to-Conduit 1
1 i
- 9) Separation Not i
Maintainable 7
2 9
1 I
- 10) Panel Design 46 45 46 45 j
TT T
49 T ~1T Vo are violations of both the original (pre-CPRT) criteria and the final separation criteria. Vn are violations of the final separation criteria only; they do not represent violations of the i
original separation criteria that were in effect when the cables were installed.
i
__.__g.
tk
' O COMANCHE PEAK RESPONSE TEAM RESULTS.4EPORT ISAP:
II.c
Title:
Maintenance of Air Gap Between Concrete Structures REVISION 1 l
- O
/
/
- A,f.u
/2/u/24, Ishue Coordinator Dataf /
// !b Reflew Team Lea %r'U
_ l
/
w Date' E 6-M. /
_t>-
/ 2.[/ 7 /JL JohyW. Beck,ChairmanCPRT-SRT Date O
a.,.--
Q f y.A=
P 6=
{*#
F F
n-R vision:
1 0
Pcgo 1 of 56 4
RESULTS REPORT ISAP II.c Maintenance of Air Cap Between Concrete Structures
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC Issue II.c was identified in SSER 8 (Reference 9.1, pages K-159 and' K-160) as follows:
"The TRT investigated the requirements to maintain an air gap between concrete structures.
Based on the review of available inspection reports and related documents, on field observations, and on discussions with TUEC engineers, the TRT cannot determine whether an adequate air gap has been provided between concrete structures.
Field investigations by B & R QC inspectors indicated unsatisfactory conditions due to the presence of debris in the air gap, such as wood wedges, rocks, clumps of concrete and rotofoam. The disposition of the NCR relating to this matter states that the " field investigation reveals that most of the material has been removed." However, the TRT cannoc determine from this report (NCR C-83-01067) the extent and location of the debris remaining between the structures.
Based on discussions with TUEC engineers, it is the TRT's understanding that field investigations were made but that no permanent records were maintained. In addition, it is not apparent that the permanent installation of elastic joint filler material ("rotofoam") between the Safeguards Building and the Reactor Building, and below grade for the other concrete structures, is consistent with the seismic analysis assumptions and dynamic models used to analyze the buildings, as these analyses are delineated in the Final Safety Analysis Report (FSAR). The TRT, therefore, concludes that TUEC had not adequately demonstrated compliance with FSAR Section 3.8.1.1.1 [*], 3.8.4.5.1, and 3.7.B.2.8, which require separation of Seismic Category I buildings to prevent seismic interaction during an earthquake."
Cited in Reference 9.1, page K-160, as 3.4.1.1.1; corrected to 3.8.1.1.1 in accordance with Reference 9.1, page K-168.
2.0 ACTION IDENTIFIED BY T3E NRC The actions to be taken regarding Issue II.c were identified in SSER 8 (Reference 9.1, page K-160) as follows:
o -
- - - -,~
~'e
(
Rsvision:
1 Pega 2 of 56 g
RESULTS REPORT ISAP II.c (Cont'd) 2.0 ACTION IDENTIFIED BY THE NRC (Cont'd)
"Accordingly, TUEC shall:
1.
Perform an inspection of the as-built condition to confirm that adequate separation for all seismic category I structures has been provided.
2.
Providetheresultsofanalyseswhickt det:onstrate that the presence of rotofoam and other debris between all concrete structures (as determined by inspections of the as-built conditions) does not result in any significant increase in seismic response or alter the dynamic response characteristics of the Category I structures, components and piping when compared with the results of the original analyses".
3.0 BACKGROUND
TUGC0 has committed in the FSAR to provide separation between O
buildings to prevent unacceptable seismic interaction during an earthquake (see FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and 3.78.2.8).
To meet this couaiteene, CPSES has been designed in a fashion similar to other nuclear plants by providing an air space between buildings wide enough to allow for building movement (sway) during seismic activity.
Structural drawings call out a " gap" of 2",
3", or more depending upon the buildings involved. The air space is also referred to as a " gap", " seismic s'ap", " separation gap" or " air gap".
Certain components (e.g., fire or environmental seals) are by design allowed to span this gap. Elastic foam forming material is also allowed in the gap below waterstops (below grada) in the design.
As construction consenced, an elastic foam
- was used by Brown &
Root as the concrete forming material. After pouring, the foam forming asterial was left in place. This practice' continued until 1977, when it came to the attention of Gibbs & Hill. Ccnstruction had been given Engineering approval to leave fosa in place for pours below waterstops due to inaccessibility for The use of the term " elastic foam" in this report is equivalent to the term "rotofoan" cited in NRC references (see Section 1.0 and 2.0).
"Rotofoaa" is a particular brand of foes. CPSES has in fact O
used a different brand of foaa such that the term " clastic fosa" as used in this report is appropriate.
g R: vision:
l' Pags 3 of 56 RESULTS REPORT ISAP II.c (Cont'd)
3.0 BACKGROUND
(Cont'd) removal attempts [ documented in Request for Information'or Clacification (RFIC) number C-029, January 29, 1976]. The approval was provided in Field Problem Action Request (FPAR) 110 (February 13, 1976). Apparently, Construction interpreted the Eng'.neering response as a generic approval (i.e., for all elevations) and continued the practice of leaving foam in place. Gibbs & Hill learned of this practice in September 1977 and informed the Project that this deviated from the design concept.
TUSI meno TUS-5019 (November 2,1977) instructed the Construction organization to remove the foam forming material so as to maintain the design air gap between the buildings in most locations. As a result of this memorandum, slip-forming was subsequently used in i
nost locations.
Because most base sats and lower walls were already poured, this change primarily affected walls more than 10 feet above grade. Elevations at which fosa was required to be removed were identified and Halliburton was contracted to effect remov11. The inspection and documentation of this activity was O
assigned to Brown & Root QC. Brown & Root QC developed a temporary procedure CP-QCI-2.4-9, " Inspection of Elastic Joint Filler Material Removal," which was limited to delineating the inspection and documentation requirements for verifying the Halliburton work effort (removal of the elastic fosa). This procedure referred to TUSI meno TUS-5019 as defining the guidelines and scope of the removal effort and, hence, the scope for this one-time inspection.
A checklist was attached to this procedure (Inspection of Elastic Joint Filler Material Removal Checklist) to document the inspections performed. To date, only two checklists that relate to the inspection scope have been identified. Both' checklists were signed on January 3, 1978.
A Gibbs & Hill meno was issued on January 30, 1978, stating that the gap areas identified in TUS-5019 were inspected by a TUSI Civil Engineer and a Gibbs & Hill Field Engineer, with the conclusion that the removal of foam for the identified areas was acceptable.
The Brown & Root Site Quality Control Manager issued a meno on February 19,1978 (IM-12939), to the Construction Manager stating that inspections of the seismic gap between the' Auxiliary Building and Containment Building #1 (part of TUS-5019 scope) were conducted to determine the effectiveness of the foam removal effort by Halliburton. This meno concluded that, based on the Brown & Root QC inspections, the fosa removal efforts were incomplete and that further removal or engineering evaluation was required. A written reply to this meno was requested to define actions and schedule. A O
.-(
Revision:
1 Page 4 of 56 j:
s 1
RESULTS REPORT O
l i
ISAP II.c j
(Cont'd) 3
3.0 BACKGROUND
(Cont'd)
}
response from Construction management was apparently not provided.
j It is not clear from IM-12939 whether the inspections referred to within the meno are the same as those done by QC inspection procedure CP-QCI-2.4-9.
The locations referenced in IM-12939 are different from those addressed in the two checkiiste discussed above that are identified with CP-QCI-2.4-9, although all. locations are part of the scope defined in TUS-5019.
t Subsequent to this activity, the QC procedures were revised to ensure that the seismic gap was in accordance with the design 4
l drawings at the time of concrete pouring. However, inspection
]
reports subsequent to the removal effort have identified foan forming material and other types of debris in areas where th:e j
design drawings require air gaps. One of these reports indicated that the as-built gap was less than the design requirement. These 4
reports (written in 1978) were attached to an NCR (NCR C-83-01067) j in April 1983 and sent to civil Engineering for disposition. Civil j
Engineering closed cut the NCR with a technical analysis which did l
not address the applicable FSAR load case combination. The NCR has since been re-opened as Revision 1 as a result of the TRT 1
investigation.
4.0 CPRT ACTION PLAN i
l 4.1 Scope and Methodology The objective of this action plan was to assure that the l
1 condition of the air gaps between concrete structures is
-7 adequate to prevent significant interaction during a seismic i
j event.
i i
j The CPRT tasks that were implemented to achieve this objective are:
Provide initial as-built inspection of the condition of the seimaic gaps to identify those areas which are not in compliance with the design drawings.
For all areas which do not comply with the design drawings, correct the condition and, where necessary, conduct an evaluation which demonstrates that the condition meets the FSAR comunitments.
Provide e. final as-built inspection for all areas which required correction.
. h
g Rsvision:
1 i
Pegs 5 of 56 1
s f' -
RESULTS REPORT t
ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) s Provide an analysis which demonstrates that any elastic material or debris remaining in the gaps does not result in a significant adverse effect on the seismic response of Category I structures, components or piping.
The following general sequence was used to resolve the issue:
Project QC inspections of the seismic gaps between Cat,4 gory I structures and between Category I and non-Category I structures for both Unit 1 and Unit 2 were reperformed and documented. With the aid of special video recording equipment, Project QC inspected the existing conditions of the double-walled building separation gaps.* These inspections verified the separation gap width and located and identified the size.and type of materials in the separation gap.
A.
sufficient level of detail was provided from initial O
as-built inspections to support a dacision to either remove existing debris or analyze its acceptability.
Inspections were also performed on single-walled building separation gaps ** which identified the as-built conditions, i.e. existence of 21astic joint fillers, fire protection seals, flashing, etc.
These activities were overviewed by Southwest Research Institute (SwRI), a third-party organization.
The resulting as-built conditions were reviewed to ensure acceptability with design requirements.
Unacceptable conditions were noted to be corrected or analyzed to support the acceptability of the conditions.
i Double-walled building separation gaps are separation gaps between two buildings that have a solid wall (except for openings from one building to the other) on each building face for the full height of a specific separation gap.
Single-walled building separation gaps are separation gaps between
()s two buildings where one building has a solid wall (except for
' (,,
openings) for full height of a specific gap and the opposite building provides gap walls only at slab, beam, column, or wall ends.
E
y.
4 Revision:
1 i
Pege 6 of 56 1
RESULTS REFORT ISAP II.c (Cont'd) i 4.0 CPRT ACTION PLAN (Cont'd) 4 The resulting as-built inspection documentation was reviewed with availabla construction documentation and past inspection records to assess the sequence of events leading to the existing condition and the'cause.
4 j.
Based upon the initial as-built inspection, a decision was made to either remove any debris encountered in the separation space through vacuuming or other methods or evaluate the significance of the as-built condition to the design basis.
[To date, corrective actions have removed all debris encountered. Evaluations.have been j
.made as to the significance of material in the gaps required by design (e.g., fire seals) to the design basis. Also, the Project has evaluated certain areas where inspection and corrective actions were considered 4
j impractical. The third-party has reviewed these i
evaluations and will review all subsequent Project evaluations which justify excluding areas from corrective actions].
QC has documented and will continue to document the j
final as-built conditions and SwRI has overviewed and will continue to overview this process.
Engineering and QA/QC revised project procedures for i
establishment of requirements for maintenance of adequate separation condit$ons. The third-party reviewed the revised procedures.
Engineering evaluated the need to update the FSAR to.
reflect the as-built condition. The third-party reviewed this evaluation and the ensuing FSAR change request and will overview any subsequent FSAR change requests or change request modifications that relate to i
the seismic gaps.
Engineering evaluated the cause of.the existing j
condition and its applicability to other areas of the plant. Based upon these findings, a decision was made to expand the evaluation to include all seismic gaps -
and implement appropriate actions.
j Issues relevant to construction housekeeping methods have been addressed as part of the response to NRC,
!O January 8, 1985 letter on construction QA/QC issues (See CPRT Action Plan Number VII.a.7, " Housekeeping and System Cleanliness").
i Ii
Rsvision:
1 Pogs 7 of 56 i
RESULTS REPORT ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The third-party reviewed conclusions reached on cause and applicability to other areas.
The acceptability of the final as-built condition has been evaluated and will continue to be evaluated by the third-party.
The following action items were incorporated into the ISAP for this issue but their completion has not been necessary so far to close this issue, for the reasons stated.
As necessitated by the results of the gap inspections, an analysis was to be performed using revised stiffnesses (or spring values) based on the actual characteristics and locations of the id$ntified debris.
The re-evaluation was to determine the change in frequency from the original fundamental mode and to evaluate structural interaction effects. The significance of any change in frequency or interaction was to be determined as it applies to components and O
piping as defined in the decision criteria Section 4.6.
(To date, only two areas have been identified where it was considered impractical to search for and remove debris. The Project has justified the exclusion of these two areas from the corrective actions program based on engineering evaluations, without the need of performing analyses - see Section 5.6.
These 1
evaluations have been reviewed by the third-party.
Aside from these two areas, all debris encountered has been, or is being, removed. Accordingly, nc analysis involving debris and its potential effect on building response has been necessary.)
The original analyses were based on clear gaps between the buildings; subsequently, Gibbs & Hill evaluated portions of the separation areas for the effects of the presence of elastic foam debris. These earlier evaluations (prior to CPRT), as well as any determined necessary as part of the effort described above, were to be subject to review by a third-party.
(The current corrective action plan calls for temoval of all material in the seismic gap, both debris and seal material required by design, so that the gap condition can be verified to meet design requirements.
Following this verification, seal material required by design will be reinstalled. Accordingly, previous Gibbs &
O
- h
._g, J
l Ravision:
1 Page 8 of 56 RESULTS REPORT
(::)
4 ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Hill evaluations no longer reflect the as-b'uilt conditions, making third-party review unnecessary.
However, Project evaluations regarding material existing in the gaps by design will be reviewed by the third-party.)
1 f
Engineering issued necessary instructions for removal of Jebris which significantly impact the original design calculations or removal of debris where this
)
course of action is determined to be more expedient
]
than analytical investigation.
(The significance of identified debris has not been analytically determined j
because of the Project decision to remove debris.)
After receipt of QC documentation verifying removal and the final as-built condition, the engineering calculations performed as part of this action plan will i
be revised as necessary to reflect the final as-built O
conditions.
(To date,;no calculation revisions have been required based on final as-built conditions.)
1 j
4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective scopes of work.
4.2.1 TUGC0 Nuclear Engineering (TNE) - Civil / Structural Discipline 4.2.1.1 Scope Coordinated as-built inspections and performed evaluations to determine removal requirements t
Assisted design engineer in final analysis and conclusions Issued design changes as required to document permanent items remaining in gaps; dispositioned Non-conformance Reports (NCR) relating to this matter O
i I
i
. ~. - -..
9 Revision:
1 Pags 9 of 56 RESULTS REPORT ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.2 Personnel Mr. C. R. Hooton TNE Civil / Structural Discipline Supervisor _
Mr. M. Wells Engineering Specialist Mr. R. Orr Project Consultant 4.2.2 Gibbs & Hill, Inc., New York, N.Y.
4.2.2.1 Scope Performed calculations for effect of the as-built conditions on the seismic response and structural behavior 4.2.2.2 Personnel Mr. E. L. Bezkor Structural Job Engineer Mr. A. M. Kenkre Structural Squad Leader 4.2.3 TUGC0 Quality Assurance 4.2.3.1 Scope Inspected seismic gaps for compliance with design requirements and documented findings Documented general debris Iceation and type before or during debris removal Documented final as-built condition 4.2.3.2 Personnel Mr. P. Hals:asd Quality Control O
Manager h.
Rsvision:
1 Page 10 of 56 RESULTS REPORT ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.4 Brown & Root. Inc.
4.2.4.1 Scope Prepared areas for QC Inspections
~
and provided Craft support as required for implementation and completion of CPRT Action Plan for this issue Removed debris as directed by engineering,
Installed required seals upon completion of verification activities 4.2.4.2 Personnel O
1 Craft personnel as required.
Protopower-Bisco 4.2.5 Third-Party Overview 4.2.5.1 Scope Performed review of Project calculations prepared in support of this ISAP Overviewed inspection activities Reviewed inspection documentation Evaluated overall conclusions Prepared Results Report 4.2.5.2 Personnel Mr. H. A. Levin TERA, CPRT Civil / Structural O
Review Team Leader
+w--
--m
- - = - -
Revision:
1 Pega 11 of 56 RESULTS REPORT ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Dr. J. R. Honekamp TERA, TRT Technical Manager Mr. J. C. Miller TERA, TRT Issues Manager Mr. P. L. Turi TERA, Issue Coordinator Mr. G. Lagleder Southwest Research Mr. W. Weis Instituto (SwRI) 4.3 Personnel Qualification Requirements Third-party participants in the implementation of this Action Plan meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its. implementing procedures.
The Brown & Root QC inspectors performing the separation verifications were trained in the applicable requirements of procedure QI-QP-11.0-3, " Concrete or Mortar Placement Inspection". The minimum QC certification level necessary for this activity was Level I.
The inspectors used to implement this Action plan were not involved in previous separation verifications (i.e., verification of Halliburton foam removal effort in late 1977/early 1978).
Southwest Research Institute (SwRI) conducted a third-party overview of the Project QC inspection effort. The SwRI personnel were certified enrough SwRI's QA program,' and were indoctrinated to the SwRI surveillance procedure (Reference 9.2).
Other participants have been qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed
)
by other than third-party personnel were governed by the l
applicable principles of Section III.K. " Assurance of CPRT
)
Program Quality", of the CPRT Program Plan.
4.4 Procedures QC inspections were performed in accordance with procedure (j
QI-QP-11.0-3 and associated operational travelers for Unit 1 and Unit 2 areas. This procedure provided criteria for h
Revision:
1 Page 12 of 56 RESULTS REPORT ISAP II.c
-(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) inspecting separation dimensions, documenting material remaining in the gap, and maintenance of the inspected conditions. Results were documented on Inspection Reports.
Craft prepared areas for inspection and subsequent removal of debris. Existing site procedures were used for these activities, primarily issuance of inspected Item Removal Notices (IRN) for, removal of permanent seals.
SwRI conducted an overview of the inspections performed per QI-QP-11.0-3.
The overview scope and methodology was defined in SwRI surveillance procedure (Reference 9.2),
i 4.5 Standards / Acceptance Criteria 4.5.1 All air spaces are acceptable per the FSAR provided that there is sufficient space to prevent contact when structures experience deflections as a result of a O'
seismic event (FSAR Section 3.7B.2.8).
The minimum gap required is defined in design calculations that meet the FSAR commitments.
4.5.2 Certain components (e.g., fire or environmental seals and elastic foam below waterstops) are by design allowed to remain in the gap provided it is demonstrated that the component's functionality is not adversely compromised and that the component does not adversely affect the structures forming the gap.
4.5.3 For any areas of gaps identified to contain debris that is not accessible for removal, the existing condition will be considered acceptable only if an engineering evaluation determines, based on the type, size and location indicated on the inspection reports, that seismic separation is not compromised.
(There have been no situations to date where debris that has been identified could not be removed.)
4.6 Decision Criteria The engineering analysis for the final as-built condition will i
j document the degree to which materials remaining in the seismic gap (e.g., fire and environmental seals) may affect dynamic response characteristics of the structures. If the s
engineering analysis reveals a significant modification of response, the response will be quantified by analysis and 4
w.
davision:
1 Page 13 of 56 RESULTS REPORT ISAP II.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) response values will be compared to the original response values for determining separation acceptability. Upon evaluation of any significant change in frequency and structural behavior as compared to the original values, the necessity for further evaluation of components and piping will l
be considered.
(Corrective actions performed to date have caused removal of all debris encountered. Accordingly, no engineering analysis such as described above has been i
necessary. Analysis has been performed with respect to.
material in the gaps that is required by design.' The above decision criteria have been applied to these analyses.)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS.
An index to the action items identified for this issue and the subsections in which they are discussed is presented in Table 1.
The chronology of events related to the gap issue up to the TRT investigation is presented in Table 2.
5.1 Development of Seismic Gap Inspection and Maintenance Procedures The first step in implementing the action plan was development of procedures for the inspection of all seismic building gaps. The location and identification of the major buildings is shown on the plan view presented in Figure 1.
An existing TUGC0 QC procedure " Concrete or Mortar Placement i
Inspection" (QI-QP-11.0-3, Revision 4), was revised to add a listing of the seismic gap boundaries, inspection requirements, and guidelines for maintenance of the required gap during and after cleaning and verification.
The gap boundaries to be inspected using QI-QP-11.0-3 were initially identified from the listing of seismic Category I structures provided in FSAR Section 3.2 and by noting from arrangement drawings the interfacing seismic gaps between these structures. Also included were interfaces between 4
seismic Category I structures and non-Category I structures (e.g.; Control Building / Turbine Building). Two additional seismic gaps were incorporated into the scope of this action plan as a result of the Critical Spaces Program, a task that i'
is part of the VI.a Action Plan (see ISAP VI.a. " Gap Between~
the Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall" Section 4.1).
These are:
I l
i 0 _ _.
Revision:
1 Page 14 of'56 RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the gap between the Containment shell and its internal structure, and the top of secondary walls (non-load bearing walls which have a gap to prevent load transfer from the slab above.)
These items have been transferred to this ISAP due to the similarity in the inspections required.
Th's decision was made to expand the scope of the Action Plan to include all seismic separation gaps. This decision.was made based on findings from some of the initial inspections that confirmed the presence of debris between buildings (see Section 5.3).
Added to the scope of the Action Plan were the gaps between adjacent base mats; and, gaps between base mats and adjacent walls. Although the design drawings permit the presence of foam in the base mat gaps, concrete seepage at O
foam joints was observed in single and double wall cases, thereby making a confirmatory inspection of all base mat gaps.
i necessary. However, to date, two instances have been identified as being inaccessible. The Project developed-justifications to exclude these areas from the corrective action program. These justifications were reviewed by the third-party (see Section 5.6).
Inspection requirements were added in Revision 5 of l
QI-QP-11.0-3 to address the TRT request for an as-built inspection of seismic gaps. These additions were included as a separate section within the procedure. As part of this revision, new inspection report forms were developed for
-i as-built inspections of the gaps which required detailed documentation. The procedure was modified in a fashion that anticipated some degree of debris removal by providing instructions for dccumenting the initial condition as well as the final (after removal of debris) condition.
. Revision 5 of procedure QI-QP-11.0-3 also included provisions designed to preclude intrusion of debris into gaps. These provisions, which were retained in all subsequent revisions, require continuous QC witness whenever gaps are opened by removal of permanent seals or flashing.
If the activity extends over a long period of time, installation of temporary barriers is required when work is not actively conducted and O-when there is no QC witness. Upon completion of the activity and prior to reinstallation of the permanent seals and
Rsvision:
1 Pcgs 15 of 56 q
RESULTS REPORT U
ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) flashing, a final QC inspection is required. These provisions apply to all activities conducted by the Construction organization. Upon transference of responsibility to the Operations organization, the seismic gaps defined in this ISAP will be controlled by an Operations procedure. A third-party review of the Operations procedure will be conducted and documented as part of the VI.a ISAP (the seismic gaps will be grouped with other " Critical Space" items identified as part l
of the VI.a Action Plan task related to debris in critical spaces and addressed through one, or a cohesive set of, Operations procedures - see Section'7.0).
Beginning with Revision 6, procedure QI-QP-11.0-3 incorporated new boundaries for inspection as well as additional instructions / clarifications for how the inspections were to be performed. Nearly all of the initial as-built inspections performed under this ISAP were conducted using Revision 6 of the procedure. Revision 7 added the Containment / Internal O'
structure interface to the list of boundaries to be inspected.
Revision 8 added considerations for inspection of separation gaps at the top of secondary walls and base mats.
Each revision (beginning with Revision 5) was reviewed by the third-party (Reference 9.3) with concurrence given in matters regarding this issue (i.e., inspection scope, methodology and maintenance requirements).
It should be emphasized that each revision was made to add a seismic gap type (e.g.,
Containment / Internal structure) to the scope of the procedure along with inspection requirements unique to the new areas.
5.2 Initial As-Built Seismic Gap Inspections Following the issuance of Revision 5 of QI-QP-11.0-3, the i
Project began developing tools and techniques for conducting the gap inspections. An inspection approach was adopted that included the use of a video camera with~ voice recording, special lighting to facilitate video taping, and probes of known dimensions.
A third-party overview of the initial inspections was conducted by SwRI (Reference 9.4).
Implementation of the inspection procedure (QI-QP-11.0-3) and the overall documentation process was included as part of the overview.
The scope and methodology of this overview is defined in the SwRI surveillance procedure (Reference 9.2).
This procedure d
applied to the initial as-built inspection overview as well as the final as-built effort (see Section 5.4).
'6
~
Revision:
1 Paga 16 of 56
%)
RESULTS REPORT G
ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3 Evaluation of Initial As-Built Inspection Findings and Ensuing Corrective Actions The initial inspections performed under this ISAP confirmed the existence of debris in many areas of the seismic gaps
[ Discrepancy / Issue Report (DIR) E-1052*].
Figures 2 and 3 present an example (for the containment #1 gap) that shows the approximate distribution of the debris found during the inspection process. The original scope of gap inspections in,cluded single wall and double wall gaps. After a number of initial inspections, it became apparent that there was a significant amount of debris in these areas. Therefore, a decision was made to expand the inspection scope to include all seismic gaps so that the effort would include base mats.
the containment / internal structure interface and the tops of secondary walls. Accordingly, the overview scope by third-party was expanded to include these areas.
O The types of debris encountered included elastic joint filler material Bisco fire sealant and damming material, concrete, wood scraps, rebar tailings, and dirt. Pockets of various types of debris were sparsely located throughout the full i
height of deuble-walled gaps, with a higher concentration in j
the lower regions. In the case of single wall, base mat, and secondary wall gaps, the " debris" primarily consisted of elastic foam left in place after pouring and concrete fragments.
In viewing the video tapes made for double wall gaps as part of the inspections, many pockets of debris appeared to be a mixture of the various types listed above.
In some cases, two adjacent walls were found to be joined through a concrete " bridge" across the gap. Occurrences of this type were found for both single and double-walled gaps.
The Discrepancy / Issue Resolution Report (DIR) is a form used to track the status, classification and resolution of all open issues and of all discrepancies identified during the implementation of this Action Plan as well as the Design Adequacy Program (DAP).
DIRs written in the course of implementing this Action Plan are O
identified in the related text of this report. All DIRs associated with this issue are summarized in Section 5.9 and tabulated in Table 3.
4 J
Ravision:
1 Paga 17 of 56 g
RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Also observed in the inspections were seal materials (e.g.,
foam, fire sealant) that were intended by design. Although these materials are specified in the design, no calculations could be identified that demonstrate that the existence of these materials does not result in a significant increase in seismic response characteristics of the Category I structures, components and piping when compared with the results of the l
original analyses (DIR D-0166). Accordingly, the Project has
{
prepared calculations in this regard for both building-to-building and secondary wall gaps. These calculations have been reviewed by third-party (see Section 5.6).
The initial as-built inspections also revealed that in some locations the seismic gap was less than specified by the original design drawings (DIR D-0004). The gap widths specified on these drawings indicate a single dimension for each building-to-building interface which exceeds the largest
(~')
displacement calculated anywhere along the interface. Thus, s,s) the design basis building displacements calculated for the limiting load combination are less than or equal to the dimension specified on the drawings issued for construction.
To evaluate the significancesof the areas where the as-built gap was less than specified on the drawings, Gibbs & Hill prepared calculations which provide the design basis building-to-building displacements for each seismic gap as a function of elevation.
Also, calculations were prepared to establish displacements / gap requirements for the Containment / Internal Structure interface as well as for the tops of secondary walls (see Section 5.6).
These calculations were used to identify all areas where it was necessary to increase the width of the seismic gap to ensure that the FSAR statements regarding structural independence during abnormal conditions are satisfied.
Before the completion of the initial inspections for single and double wall gaps, an evaluation of the findings caused the Project to move directly to a corrective actions phase. These corrective actions began with debris removal from single wall gaps. After the minimum required gap calculations were completed and reviewed, the Project commenced work on single wall gaps with less-than-design separation width. " Initial" inspections continued to be performed but were for the purpose of assisting Engineering in defining the appropriate O
corrective action.
l j
l
- 4
-__7.
Revision:
1 Page 18 of 56 RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Protopower-Bisco was contracted to effect debris removal from double. wall gaps. The initial phase of their effort focused' on developing the tools aad techniques to dislodge _and remove the various types of debris from the gap.
The current scope F
of this effort now includes base mat and secondary wall gaps.
It is the Project's intent that all foreign material be removed from the gaps.
If there are areas where removal is not possible or practical, a technical justification and/or analysis will be developed to demonstrate that seismic separation is not compromised.
In this event, a review of this work will be conducted by third-party and summarized in a supplement to this report. These third-party activities will be conducted in accordance with Appendix H of the CPRT Program 1
Plan.
Another aspect of the corrective actions undertaken as a result of initial inspection findings involves adjustments to concrete walls in order to provide the minimum required gap width. The inspections identified some locations where the existing gap condition required videning. Figures 4 and 5 present an example (for the containment #1 gap) that shows the locations where gap widening was required. In order to 3
provide adequate gap, some areas may require concrete to be
" shaved" from the surface to allow building movements predicted by the calculations. Although the amount of i
concrete removed is very small relative to thickness of the wall, the third-party will review the Project's assessment of -
significance of these removal activities as they relate to design requirements such as structural integrity and rebar coverage (see Section 5.6).
In the course of performing the inspections, three out-of-scope findings were made. These findings and resolutions are discussed in Section 5.10.
5.4 Final As-Built Seismic Gap Inspections I
Corrective actions are completed for the containment / internal structure interface (excluding internal base sats and certain areas under construction in Unit 2) and partially completed for the double wall, single wall, and base mat areas (i.e.,
debris removal and gap width adjustments).
As part of these corrective actions, all installed seals have been or will be i
i O
removed, the gaps examined and corrective actions undertaken as needed. Final QC inspections (per QI-QP-11.0-3) have been
~. _.. -.,
Rsvision:
1 Pegs 19 of 56 7-~~
RESULTS REPORT b
ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) completed for areas as corrective measures have been implemented. Following satisfactory results from QC inspection, all seals will be reinstalled per design requirements. SwRI conducted an overview (Reference 9.5) of the earliest final as-built inspections and documentation of the as-built condition which involved the Containment / Internal structure interface. This overview determined that the corrective actions are effective in insuring that the design requirements are met.
Additionally, the inspection procedure (QI-QP-11.0-3), and the effectiveness of QC personnel in implementing the procedure, were determined to be acceptable.
5.5 Documentation Review In an effort to determine root cause and assess the possibility of generic implications stemming from this issue, a documentation review was performed (References 9.6 and 9.7).
Of interest were correspondence between the engineering and O
construction organizations, the procedures used to monitor concrete pours. Inspection Reports, and NCRs related to seismic gap debris and width.
5.5.1 Correspondence Review The initial question regarding placement of elastic foam material arose in 1976 when the field requested permission to install and leave in place the foam below waterstops (Request for Information or Clarification number C-029, January 29, 1976). This request was'made because the design called for an air gap but the placement of the waterstop made foam removal difficult.
TUGC0 Engineering responded in FPAR 110, (February 13, 1976) by stating that the foam could be left in place "both below and above waterstops". A Gibbs & Hill telex (GTT-1543) was issued in September of 1977 which stated that construction was proceeding on an erroneous interpretation of the FPAR response. Gibbs & Hill explained that the FPAR allowed leaving in place the foam above and below the waterstop but only up to the grade line. Although this latter point was not explicitly stated in the FPAR reply, the structural drawing (2323-S-0786) revised at that time clearly shows foam between base mats below grade and an air gap above grade. The Project issued a memo (TUS-5019, O
November 2, 1977) which defined the extent to which elastic foam material was to be removed. This memo "b
, ~ -.
I Rsvision:
1 Paga 20 of 56 RESULTS REPORT O
ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) allowed foam to remain in place for specific areas already constructed, required a one inch air gap for i
other specific areas already constructed and required a
{
two inch air gap for future construction. No technical j
justification was provided in the memo for this design change and no engineering evaluations have been identified that support these decisions (DIR D-0166,_
Reference 9.8 and 9.9).
[ Subsequently, new design calculations performed under this Action Plan (see Section 5.6) did justify the design change implied by this meno.]
Beginning in November of 1977, discussions between
'TUGCO, Brown & Root, and Gibbs & Hill ccamenced regarding the need to protect the seismic gaps from the intrusion of debris. The result of these communications was a mutual agreement that a strip of elastic foam filler material could be installed at the construction joint such that, following the pour of the 3
next portion of the well, debris that collected at the foam strip could be readily removed. This approach included the restriction that the foam strip could not remain and eventually was to be removed. No evidence exists that this methodology for gap protection was 4
)
ever proceduralized. The results of the gap inspections conducted under this Action Plan confirm the use of foam strips as a means of protection by having identified a few strips that had not been removed.
Halliburton was contracted to remove foam in late 1977.
Following Halliburton's efforts, a Gibbs & Hill meno was issued (GHF-2390, January 30, 1978) to Construction Management stating that a Gibbs & Hill Field Engineer
~
and a TUSI Civil Engineer had inspected the areas identified for repair in TUS-5019,'and found these j
areas acceptable. No information exists as to the rigor employed in these inspections. However, a Brown
& Root memo was issued two weeks later (IM-12939, February 19, 1978) to Construction Management from the Site Quality Control Manager, stating that removal efforts were not complete based on observations made by
^
QC inspectors and that further removal and/or engineering evaluation was required. Also, this memo specifically requested a written response defining actions and schedule. No documentation was located 1
.g
i R* vision:
1 Page 21 of 56 RESULTS REPORT
( ~s
~
ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) which indicated that Construction Management responded to this memo or that the Site Quality Control Manager followed up on his memo. The third-party interviewed the individual responsible for initiating the memo.
This individual stated that the TUGC0 QC Supervisor informed him that, since TUGC0 was assuming QC responsibility (which occurred officially in July 1978), he (the B&R QC Manager) did not need to pursue the seismic gap issue (Reference 9.10).
Although TUGC0 assumed QC responsibility, there is no evidence that TUGC0 QC documented the concern on a QC record (NCR or Corrective Action Report) or that there was any follow-up to the identified concern (DIR D-2141).
No record of further Halliburton activity or engineering evaluation addressing the identified condition has been located.
O The conflicting reports (i.e., the Gibbs & Hill and B&R memos) and the absence of a full set of inspection
_l reports related to the B&R QC inspection (see Section 5.5.3) raise questions about the quality and effectiveness of implementation of the task assigned to Halliburton. Although the B&R memo (IM-12939) clearly defines a quality concern, appropriate action was aprarently not taken..Aside from the meno, no open inspection reports or NCRs existed to document the unsatisfactory condition (i.e., presence of debris and less-than-design gap width) that would require a closure.
5.5.2 Procedure Review Procedures that relate to the construction and inspection of concrete walls were identified and reviewed by the third-party (Reference 9.11).
The following cummarizes this review.
Concrete placement control was initially the responsibility of Brown & Root (B&R). Brown & Root QC Procedure CP-QCP-2.4, " Concrete Inspection and Testing", was issued in July 1975, and was in effect until July 1978. This procedure addressed concrete qualification test adequacy, documentation requirements, as well as placement inspections prior-to, during, and after pours.
In all revisions of this i
-~~~ - -~~
s Rsvision:
1 Page 22 of 56 i
l RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) procedure, there was no explicit requirement to check the as-built seismic gap width against the design documents. Also, the procedure did not require a check of whether debris had fallen into the air space in the process of pouring or after a pour had been completed.
As part of the late 1977 Halliburton effort to remove foam inadvertently left in place during pours above grade, Brown & Root QC developed a temporary procedure.
to verify the effectiveness of this effort. The procedure, CP-QCI-2.4-9 " Inspection of Elastic Joint Filler Material Removal", required a one-time inspection of the areas identified in TUSI memo TUS-5019 to verify that foam had been removed and that the minimum air gap had been maintained as required by design drawings.
1 In July 1978, CP-QCP-2.4 was replaced by TUGC0 Procedure QI-QP-11.0-3,- " Concrete Placement Inspection". The scope of this procedure addressed pre-pour planning verification and inspection prior to and during the concrete placement. Present in Revision 0 of this procedure was the requirement for QC inspectors to verify that dimensions of the seismic air gap complied with design drawings and that the gap was protected from the intrusion of foreign objects prior to placement.
It is not apparent from the text of the procedure whether the check for adequate protection was related to the plan to use foam strips at construction joints to capture debris (see Section 5.5.1).
Discussions with QC personnel who were onsite during the late 1977 to mid-1978 timeframe indicated that the use of foam strips as a means of protection was not communicated to QC personnel as an item which'should be i
specifically inspected prior to a pour.(Reference 9.12 and 9.13).
There was no requirement to verify that foreign material had not entered the gap during or following the pour or that the dimensions of the gap following the pour still complied with the design drawings.
t
' C' s
---.w
B Revision:
1 Pags 23 of 56 RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The only procedure identified that containe'd post-pour inspection requirements was QI-QP-11.0-5, " Inspection of Concrete Repair". Early revisions of this procedure did not contain any provisions for gap inspections (up to and including Revision 4).
Gap inspection requirements (post-pour) have been added in the Revision 5 (issued 5/28/86) version of this procedure.
It should be noted that by the time QI-QP-11.0-3 was instituted, many of the major concrete pours had been completed (mid 1978). This procedure (now called
" Concrete or Mortar Placement Inspection") is still in effect and has been modified considerably so as to prevent debris and gap width problems.
5.5.3 Inspection Records Review The presence of foam in the seismic gap was initially p
identified without the use of an inspection report.
U The condition was discovered and disposed of through Engineering correspondence between Gibbs & Hill and the Project (see Section 5.5.1).
During the foam removal operation performed by Halliburton in 1977-78, a Brown & Root QC procedure was written to verify removal efforts. This procedure, CP-QCI-2.4-9, " Inspection of Elastic Joint Filler Materiel Removal", provided instructions for QC personnel to verify foam removal and minimum air gap dimensions. Only two checklists that relate to this procedure have been located (DIR D-2143). These two checklists (Reference 9.6) address a small portion of the overall scope defined in TUSI memo TUS-5019. One checklist mentions the use of a tape measure to perform gap measurement whereas the inspection procedure specifies the use of gage blocks as the appropriate technique (DIR D-2144), No indication of inadequacy is present in the reports; yet, Brown & Root memo IM-12939 (see Section 5.5.1) indicated that the removal effort was incomplete for a specific area inspected by B&R QC personnel (the areas covered by the two inspection reports mentioned above
- O i
Revision:
1
[
Pags 24 of 56 8
l RESULTS REPORT i
j ISAP II.c l
(Cont'd) 4 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) are different from the area discussed in IM-12939).
It i
is not clear whether the inspections referred to in the Brown & Root memo were part of the same effort conducted under CP-QCI-2.4-9.
It should be noted that these inspections and corrective actions (TUSI Memo l
TUS-5019, November 2,1977) could only address those i
areas completed at that time. Hence, their scope did not include all the air gaps that are presently of concern.
In late 1978, QC inspections were conducted for gap cleanliness and minimum width. The new Project procedure (QI-QP-11.0-3) was utilized as a guide for the inspection although it contained no explicit l
inst-uctions for a post-pour inspection. The scope of l
these inspections was greater than those performed under CP-QCI-2.4-9 since concrete pouring had continued. Five inspection reports were written that
[
identified various types of construction debris in the
,\\
seismic gap. One report identified a gap width less than the specified design value (1 3/4" as opposed to 2").
As was the practice, these reports were brought to the attention of construction management for scheduling craft support in correcting the condition.
Based on third-party observation of the gap condition during implementation of this Action Plan, it appears that an attempt had been made by Construction to remove the material from the gaps, but thic effort was not completely successful (star drill holes were observed j
by the third-party in_the concrete between the Fuel and Auxiliary Buildings).
Subsequently, in 1983, the.:n 4
open inspection reports were grouped together, attached to NCR C-83-01067, and routed to TUGC0 Engineering for disposition (see Section 5.5.4).
There are no procedural requirements for resolution of open inspection reports in a reasonable timeframe (Reference 9.14) (DIR D-2145). No other irs involving seismic gap width or debris have been identified.
5.5.4 NCR Review 1
The NCR referred to by the TRT in Reference 9.1 (C-83-01067) was written to identify two unsatisfactory situations recorded on inspection reports. The first had to do with the presence of debris in a few areas between buildings. The second involved the measured gap width being less than design requirements. The h-. -
Ravision:
1 Page 25 of 56
)
RESULTS REPORT ISAP II.c 1
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) related inspection reports date back to late 1978.
However, the NCR itself was not written and closed until 1983. The NCR has since been re-opened (as Revision 1) to address TRT concerns.
The disposition of the original NCR (Revision 0) justified accepting the debris in the gap, and the areas of less-than-design gap width, on the basis that the seismic displacements for the area in question were less than the pressurization displacements observed during the containment Structural Integrity Test (SIT, Reference 9.15)*.
Thus, the SIT was. considered as a proof test which demonstrated that the conditions described in NCR C-83-01067 were acceptable. TUGC0 Licensing reviewed the disposition of this NCR and determined that it would satisfy FSAR commitments (Reference 9.7).
The review conducted by Licensing was not for technical adequacy, but only verified that the disposition to the NCR addressed the separation
\\
requirements stated in the FSAR.
The disposition of this NCR has been reviewed by the third-party and found to be technically incorrect in that the limiting load case from FSAR Section 3.8.1.3.2 includes the factored sum of seismic, pressure, and temperature effects for the Containment (DIR D-0004).
A more complete treatment of the discrepancy related to this NCR is presented in Section 5.7.
5.6 Review of Engineering Requirements for Seismic Caps The TRT had requested that analyses be prepared to demonstrate that foam and any other debris identified in the seismic gap does not result in any significant increase in seismic response. This request presumed that foreign material would be left in place. However, the Project has decided to remove all material from the seismic gaps, such that only seal material required by design was to remain in place. For this reason, calculations considering the effect of debris found during the gap inspections were not required.
The NCR specifically cites the Structural Acceptance Test (SAT) as O
the source for pressurization data. The report (Reference 9.15) refers to this as the Structural Integrity Test (SIT). Both refer to the same test.
.h.
Rsvision:
1 Paga 26 of 56 O
RESULTS REPORT ISAP II.c j
(Cont'd) 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The Project did prepara calculations to support various aspects of activities related to the implementation of this Action Plan. Gibbs & Hill completed calculations that determined the relative building displacements to be used as inspection criteria for gap width verification / correction.
The building-to-building relative displacements were prepared i
utilizing the most conservative load case combination equations out of the FSAR and included adjustment for thermal s
expansion effects. Displacement calculations were done for each of the buildings in addition to the Containment Internal Structure gap and secondary wall gaps. The third-party has reviewed these calculations and concurs that they correctly reflect the FSAR commitment for seismic separation.
Although there was no need to assess the effect on building response due to debris identified in the seismic gaps (since it was to be removed), the Project did this assessment to account for the effect of seal material in the gap by design.
O Two types of calculations were prepared, the first demonstrating that the presence of seal material between buildings did not have a significant impact on building response. The second type of calculations demonstrated that seal material at the tops of secondary walls did not have a significant effect on the supporting slabs.- The third-party also reviewed these Gibbs & Hill calculations and found them to be adequate in demonstrating that the presence of these materials does not have a significant effect on the seismic response of the buildings.
In order to completely verify the adequacy of the gap condition, the Project has committed to remove all seal material in seismic gaps where practical. After removal and verification of the absence of debris and adequate gap width, the seal material will be reinstalled.
The Project is preparing calculations to demonstrate the adequacy of the seal design in accounting for relative motion. Vendor restrictions on the degree to which the seal material can be compressed are being considered on a case-by-case basis to ensure the adequacy of seal behavior as well as the validity of seal _ load transfer assumptions used in the response calculations mEEcioned above. The third-party will overview the completion of these calculations, as described below.
O
Ravision:
1 7
Pags 27 of 56 RESULTS REPORT i
ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The Project is also preparing calculations to support the decision to leave certain commodities (designed items) in the 1
gap. There are few instances of this type and usually involve l
a run of conduit. Gibbs & Hill has completed one calculation which demonstrates that an in-gap commodity (i.e., conduit containing non-safety grade lightning grounding cable) is not adversely affected by relative building movenent, as well as showing that the presence of the commodity does not adversely affect the structures forming the gap (i.e., no significant local damage and no significant effect with respect to building response). The third-party will overview this calculation and other calculations of this type as part of the overview activities discussed below.
It was anticipated at the onset of the gap inspection effort that some areas may not be accessible. To date, only two areas have proven to be such. The Project has defined the areas and developed a technical justification for excluding the areas from the program (References 9.16 and 9.17).
Both O
areas are located at base mats with configurations that l
prohibit examination unless pcreions of walls and floors are removed. Instead, the Project has excluded these areas from the corrective action program on the basis that the relative displacements at these locations are essentially non-existent (the base mat locations in question are either in contact with the underlying rock or show a common foundation). The j
third-party has reviewed the Project evaluation and has agreed
_i with the Projects' conclusion to exclude these areas from the 1
corrective action program (References 9.18 and 9.19).
1 Five DIRs have been written in the course of ' reviewing Gibbs &
Hill calculations related to the gap. One of these, DIR D-1346, has been found to be unsubstantiated. Another, DIR l
D-1347, identified a discrepancy related to slab design and has been transferred to DAP for consideration. The other three DIRs (D-0258, D-0259, D-0260) have.been closed'as 4
j
_ observations, the identified discrepancies having been resolved through the issuance of new or revised Gibbs & Hill calculations.
The Project made the decision in October 1986, to replace i
Gibbs & Hill as the engineering organization responsible for all Civil / Structural design work with Stone & Webster
]
Engineering Corporation (SWEC).
SWEC is conducting a complete 1
verification of the design work in the Civil / Structural area under the SWEC Corrective Action Program, which includes all I
~ b
i Ravicion:
1 s
Pass 28 of 56 l
RESULTS REPORT I
ISAP II.c l
(Cont'd)
{
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) calculations performed by Gibbs & Hill related to separation j
gaps. The third-party reviews of,the Gibbs & Hill gap
^
calculations completed to date have each concluded that the calculations examined were adequate. However, these revic'is were limited in scope to the gap calculations themselves, i.e.,
the results of previous Gibbs & Hill work used as input to the gap calculations (e.g., seismic building models) were assumed to be correct. Because the verification effort has the potential to alter results used as input to the gap.
a 4
calculations, and because DAP will be conducting an overview
{
of the SWEC verification program, a final determination of the I
adequacy of separation gap-related engineering. requirements will be reached by DAP.
In particular, DAP will review the j
calculations related to the seismic gap (including those j
l already reviewed as part of work done for this Action Plan should they be retained by SWEC).
}
5.7 Evaluation of NCR C-83-01067 lO As described in Section 5.5.4, the subject NCR accepted "as-is" both the presence of debris in the seismic gap and the less-than-design gap width, based on a technical analysis l
which is inconsistent with the applicable FSAR load case combination. The NCR analysis is based on a comparison l
between predicted combined seismic displacements for the containment and adjacent buildings, and the observed displacements recorded during the Structural Integrity Test 1
(SIT, Reference 9.15) perfo-n:ed for Unit-1.
The SIT I
pressurized the containment to 115% of the design value (design is 50 psi) to establish the adequacy of the structure l
in withstanding loss of coolant accident effects. The NCR concludes that the expected seismic displacements are less i
than the observed radial growth experienced during the SIT I
and, therefore, "... remaining materials in the gaps are j
acceptable 'as is' without further-rework."
i Section 3.8.1.3.2 of the FSAR iefines a load case which
)
includes the factored sua of seismic response as well as
~
pressure and temperature effects. This load case would l
produce the governing situation in terms of relative building displacements. The NCR disposition did not address this load case but, instead, considered building growth due to i
pressurization alone.
lO i
'4
Ravision:
1 Paga 29 of 56 RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l The conclusion regarding the inadequacy of the NCR disposition led to an investigation of other NCRs signed by the engineer responsible for the subject NCR. All NCRs in a six month timefrace (three months on either side of the subject case.
2 dated April 17, 1983) were examined by the Project to identify those with this individual's signature.as the engineering representative approving the disposition. The third-party 1
reviewed each of these NCRs to identify those where a i
technical justification for altering the design was provided (according to ANSI N45.2, Criterion 16. dispositions where j
"use-as-is" or " repair" are proposed require a technical justification for allowing an alteration of the design). The I
resulting collection of twenty-two NCRs was then reviewed for technical adequacy by the third-party. This review identified
)
no other instances where an incorrect technical analysis was-provided within an NCR disposition (Reference 9.20).
This i
investigation of NCRs over a six month period supports the conclusion that there was no adverse trend associated with the-individual who signed the subject NCR.
5.8 FSAR Update Assessment The Project conducted a review to determine the need to update the FSAR based on inspection findings. The results of the i
Project review revealed that a revision to Section 3.8.5.1.3 was required to reflect the as-built condition more accurately. The proposed change has been submitted for-incorporation into the next update of the FSAR (Reference 9.21).
The third-party has reviewed the Project's FSAR impact assessment and concurs with the conclusions drawn (Reference 9.22).
Any subsequent action to this particular change request or any new change requests will be reviewed by the third-party (see Section 7.0).
j 5.9 Summary of DIRs Seventeen DIRs were written durir.g the course of implementing the II.c Action Plan. They are summarized in Table 3.
Six of these DIRs (D-0166, D-0258, D-0259, D-0260, E-1220, D-2133) have been closed with a classification of " observation",
i.e.,
the identified discrepancy has been determined not to be a violation of a design criterion, commitment or specification.
Each of the six observations has been completely resolved such that no further action is required.
i g
n R3 vision:
1 Paga 30 of 56 RESULTS REPORT ISAP II.c (Cont'd) j 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Seven of the seventeen DIRs have been transferred from this Action Plan. Five of these seven DIRs (D-2141, D-2142, D-2143, D-2144, D-2145) have been transferred to the QA/QC Review Team because the discrepancies relate to QC issues (Reference 9.23).
Of the remaining two DIR D-2132 has been transferred to ISAP II.d (" Seismic Design of Control Room Ceiling Elements") and DIR D-1347 has been transferred to DSAP VIII (" Civil / Structural Discipline Specific Action Plan").
One of the remaining four DIRs (DIR D-1346) has been closed as
" unsubstantiated",
i.e.,
the originally-identified discrepancy has been found to have no substance after additional information had been obtained. The remaining three DIRs (D-0004, E-0987, E-1052) have been closed and assigned the category " unclassified deviation",
i.e., a violation of a design criterion, commitment, or specification had occurred but it had been determined that it was more practical to proceed directly to analyzing root cause and generic implications and specifying of cor ective actions. No safety significance evaluation is required in this situation (see Section 5.11).
Root cause and generic implications relating to these three discrepancies are addressed in Section 5.12.
The corrective actions associated with these discrepancies have been defined in Section 5.3.
All of the above DIRs, except for those transferred to the QA/QC Review Team and the one determined to be unsubstantiated, remain a part of the DAP Tracking System and will be included in the DAP trending evaluations.
5.10 Out-of-Scope Observations 5.10.1. Fuel Building Wall Damage In preparing an area for removal of debris and widening of the air gap, craft personnel discovered that a piece of the corner of the Fuel Building east wall adjacent to the Unit I containment between elevations 860 and 870 was broken. The broken piece (approximately 1.5 ft. long and about 1 foot in width and depth) included a well-consolidated concrete bridge in the seismic air gap between the Unit I containment and the end of the fuel building wall (see. Figure 6).
O
Rsvision:
1 Page 31 of 56 RESULTS REPORT O
ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The procedure used for concrete repairs (CCP-12) required that the area to be repaired be chipped to sound concrete and, if reinforcement bars are exposed, that the concrete be removed around the exposed bars to a distance of 1-inch on all sides. While preparing this area for repair, cracks running parallhi to the outer row of reinforcement bars were encountered.
These observations were documented by the Project in subsequent revisions to NCR C-85-101778S (Revision 0 was written following discovery of the dislodged block of concrete) and discussed with the third-party.
In addition, in chipping out concrete to effect repair, a
- 4 cap bar (face-forming rebar) was observed to be misplaced. This was documented and resolved on the above NCR. Further consideration of this aspect (i.e.,
misplaced rebar) will be addressed within ISAP II.a.
" Reinforcing Steel in the Rear. tor Cavity".
O Inspection of the repair area and subsequent evaluations (part of NCR disposition) led to the conclusions that the probable cause of the cracking and the breaking loose of a piece of the corner of the wall was a mechanical interaction between the containment wall and the end of the Fuel Building wall in the area of the concrete bridge during the Structural Integrity Test (SIT).
In this location, the radial displacement of the containment wall during the SIT was measured to be of the order of 3/4" (Reference 9.15).
The corrective action plan for this NCR included the following:
Repair of the cracked corner of the Fuel Building wall per Project procedures.
Examination of all other areas where concrete bridges existed in the gaps between the Unit I containment and adjacent buildings (because all debris will be removed prior to the Unit 2 SIT, it will not be necessary to examine areas surrounding the Unit 2 containment for mechanical interaction).
O
4 Rsvision:
1 Page 32 of 56
/
RESULTS REPORT ISAP II.c (Cont'd)
I' 5.0 ' IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The examination identified above has been conducted by j
the Project-with assistance from Mr. Richard Orr, a
. recognized expert in evaluating concrete for structural integrity, who was employed by the Project as a consultant.
The investigation showed that no other instances of wall breakage had occurred as a result of the SIT. Three areas of contact with the Safeguards Building were identified where, because of their locations and the sizes of their areas, it would be reasonable to expect potentially large contact forces.
+
Under the direction of Mr. Orr, an analysis was j.
performed to determine the magnitude of the maximum concentraced force between the Safeguards Building and~
the Unit 1 Containment Building which may have l
developed during the SIT, and the effect of this force on the two buildings. The results of this analysis, as well as a summary of the investigation conducted'to identify local damage, have been documented in i
Reference 9.24.
The third-party reviewed the Projects' investigation and analysis results and concluded that the question of potential damage due to building-to-building contset during the SIT has been 4
satisfactorily resolved ~(Reference 9.25).
5.10.2 Concrete Voids In the process of chipping an access hole through a l
concrete wall to effect debris removal in a double wall 1
gap, a concrete void was-discovered. The situation was
. documented in NCR C-86-101455. The void was located at a ecnstruction joint (the line of separation between sequentially poured concrete lifts) in the 8S wall (north wall) of the Safeguards building at elevation
~
797'.
This void is being considered by the Project in an investigation program for concrete voids described in Reference 9.26.
The third-party will overview the Project investigation as part of the DAP overview 1
effort (see Section 7.0).
5.10.3 Commodities Bridging Seismic Gaps s
The gap inspections have identified instances where plant equipment span the seismic' gap (DIR D-2132). One Or example of this situation involves rigid conduit that is attach 3d to a secondary wall and runs vertically to an attachment point on the ceiling. The conduit does I
i
..?
3 Rsvision:
1 Peg 2 33 of 56
(}
RESULTS REPORT
'w/
ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) not intrude into the seismic gap at the top of the secondary wall, but does rigidly bridge the wall and ceiling which are expected to respond differently during a seismic event. This situation in itself does not violate any existing design criteria. The subject of relative building motion for plant equipment near, or bridging, seismic gaps has been included in the scope of ISAP II.d, " Seismic Design of Control Room Ceiling Elements", as part of the task for Damage Study Verification (see Section 7.0).
5.11 Safety Significance Assessment The presence of debris in the gap, the existence of less-than-design gap width, and :he error associated with the disposition of NCR C-83-01067 have been categorized as
" unclassified deviations". No safety significance assessment was performed because a determination of safety significance-O in each case would require extensive analyses to establish
\\w/
whether the direct result would have been the loss of functionality of a safety-related structure, system, or component, if the discrepancy went undetected. Consistent with the Project Plan, root cause and generic implication.
assessments were performed and are provided in the following section.
5.12 Root Cause and Generic Implication Assessments 5.12.1 Debris in Seismic Gap The circumstances that led to debris in the seismic gap were examined from two perspectives:
(1) why was debris allowed to enter the gap and (2) why was the debris not detected and removed prior to the TRT investigation? This section summarizes tne potential causes that were evaluated and the conclusions reached.
Initially, a misunderstanding between the Construction and Engineering organizations allowed foam forming material to be left in place above the base mats following concrete pours. Although it was later made clear that the design required open gaps (i.e., foam removed following a pour), the 1977 corrective actions
(~N to remove foam do not appear to have been fully
\\
effective based on inspection results from 1978 an well as the results of the inspections performed under this action plan. The lack of ef.fectiveness of the 1977 k
Ravision:
1 Page 34 of 56 4
4 RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) corrective action to remove foam is not by itself considered to represent a root cause of debris in the gap since significant quantities of other types of
' debris (i.e., dirt, concrete and construction scraps) entered the gap _during subsequent pours, primarily because of the change in forming practice to a slip form method (since the gap was no longer filled with foam, other types of debris were no longer restrained from entering).
Yet, these actions give an indication of a lack of adequate attention by QC, Engineering, and Construction Management, to ensuring that the seismic gap was maintained in accordance with design requirements. All three organizations were aware of the inadequate gap condition, but a combined lack of action allowed the condition to go uncorrected.
It is possible that this apparent absence of concern regarding the seismic gap allowed subsequent incidents f
involving debris intrusion (e.g., concrete spillage, O
construction scraps, etc.) to not only go uncorrected but unidentified.
The cause of construction scraps and dirt in the air gaps is clearly related to inadequate protection of thesa gaps during or after construction of the adjacent walls. The concrete found in the gaps is probably related to form leakage or spillage. No matter which l
forming technique is used (e.g., foam, slip-forming),
the potential exists for concrete intrusion or spillage and for other debris to enter the gap. Therefore, the-forming technique by itself cannot be a cause of this problem because standard construction practices may be assumed to allow debris to enter the' gap and to require remedial action.
Pre-pour inspections by both craft-supervision and QC for form tightness were called for l
by the first procedures used for concrete pours.
However, explicit instructions for protection of the gap were not includ64 prior to mid-1978 (as stated in Sections 5.5.1 and 5.5.2, a me,thodology for gap protection was developed but was not proceduralized or communicated to QC for verification purposes). Until i
recently these checks for gap protection were limited to pre-pour inspections (QI-QP-11.0-5, " Inspection of Concrete Repair", was revised in May of 1986 to include O
these new requirements). While post-pour inspections were performed for concrete defects, no procedure has been identified that required _a post-pour check for gap cleanliness, protection of the gap from debris i
e a
i
B Revision:
1 Page 35 of 56 RESULTS REPORT v
IFAP.II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) intrusion, or verification of the as-built gap width.
The lack of an effective construction procedure requirement to protect the gap and the lack of a QC procedure requirement to verify that the gaps were free of debris and protected (especially after a pour) are concidered to be major causes of debris in the seismic air gaps.
The question of why debris were not detected and removed prior to the TRT investigation led to an examination of the role of QC in this area. As discussed previously, QC procedures did not require a post-pour inspection to verify that the seismic air gaps were free of debris and protected from debris intrusion (DIR D-2142). Had these steps been included in the inspection procedures, it is likely that significant debris intrusion vould have been prevented or detected.
O The lack of timely processing of the inspection reports from the 1978 inspection (see Section 5.5.3) and the subsequent erroneous disposition of NCR C-83-1067, while clearly a missed opportunity to correct the problem, are not considered to be the cause of the current conditions remaining undetected and uncorrected.
This conclusion is based on the observations that debris was found in areas not covered by the 1978 inspections and that without protection of the gaps debris could have entered after the 1978 inspections.
Accordingly, the root cause for the presence of debris in the seismic gap is inadequate construction and QC procedures for the in-process protection and post-pour inspection of the seismic gaps. The significance of these procedural inadequacies, in addition to the possible determination of a higher level root cause, will be considered by the QA/QC Review Team in their Collective Evaluation.
The implication of inadequate procedures for protection and inspection of seismic gaps is that it is unknown whether or not and the degree to which other critical O
air spaces required by design have been maintained as such. This prasibility has been addressed within the Critical Spaces Program established by ISAP VI.a.
The purpose of that program is to identify all spaces in which the existence of debris, equipment, or structures may adversely affect a safety-related system, structure, or component.
5 Rsvision:
1 Pega 36 of 56 f
RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCU.9310N OF RESULTS (Cont'd) 5.12.2 Less-Than-Design Cap Width The circumstances that led to less-than-design gap width were also examined from two perspectives, namely:
what caused the condition and why was it not detected and corrected earlier?
The two forming techniques (foam and slip form) used in constructing the structures related to the seismic gaps have been employed in constructing similar structures in other power plants, and, as is evident at CPSES, can provide suitable results. However, both techniques inherently produce small variations in the plane of the concrete surface. These variations may result from such causes as variation in forming material thickness and compression (in the case of foam) or form positioning and bulge (in the case of slip forms).
Variations in concrete forming are accounted for in American Concrete Institute (Ar,I) Standard 301-72 which provides recommended tolerances for cencrete construction.
Construction at CPSES was and still is controlled by structural drawings which specify the design gap width and Gibbs & Hill specification 2323-SS-9 which references ACI 301-72 as the guideline for construction tolerances. Lacking any instruction for alternative application of those tolerances, it is implicit that they would be applied as a positive and negative variance relative to the design dimension [e.g., 2" !
(tolerance per ACI 301-72)].. Therefore, less than design gap dimension (e.g., 2" - (tolerance per ACI 301-72)] would be considered to be within tolerance. It appears that the construction organization made an effort to construct the gap so that the design gap was achieved; nevertheless, there J
were some areas where less than design gap width resulted. Even if a rigorous QC inspections program had been empipyed te verify the seismic gap dimension, it is inevitable that some degree of less than design gap dimension would have been accepted as satisfactory (i.e., within tolerance).
w
Revision:
1 Page 37 of 56 i
RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
It is evident that the intention of the design'in satisfying the FSAR commitment was that the seismic gaps are a minimum value. There is no evidence in the original design that a tolerance value was incorporated to allow for the ACI tolerances. Accordingly, to provide an acceptable result, any tolerances could only i
be of a positive _ sign (e.g., 2" - 0" + (tolerance per i
ACI 301-72)].
In this case, an errer in application of tolerance is particularly important because of the small absolute value of the seismic gap dimension.
i Thus, it is concluded that a cause of the less-than-design gap width condition is that the design did not correctly define how construction tolerances were to be included (DIR D-2133).
f As discussed in Section 5.12.1, QC procedures did iot i
require a post-pour verification of the cleanliness, O
protection, or the as-built dimensions of the air gaps.
V While the 1978 inspection did identify one area of les:
than gap width, such inspections were not required by 1
the QC program to be performed on a regular, comprehensive basis.- Thus, it was concluded that the primary reason that the less than design gap width l
condition was not detected and corrected earlier was that.rtgular post-pour inspections of the as-built gap width were not required by the QC program.
Accordingly, the direct cause is considered to be a combination of two factors:
(1) the design did not clearly define how construction tolerances affecting the gap width were to be-included (this represents an j
interface problem between the design and construction organizations) and (2) post-pour verification of the as-built gap width on a regular basis was not required by the QC program.
The implication of not adequately defining construction tolerances in the controlling design documents would, l
of course, extend to all seismic gaps. As part of the corrective actions under this Action Plan, all seismic gcps will be inspected (unless otherwise justified) and i
in instances where gap widths are found to be
{
inadequate, corrected. The root cause regarding construction tolerances not being clearly defined l
within the design will be considered within DAP as part j
4 of its evaluation of potential adverse design trends,-
and within the QA/QC Review Team as a result of its hardware inspection effort.
1 I
li.
l
7 4
Revision:
I Pogs 38 of 56 RESULTS REPORT ISAP II.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i i
The implications of the second direct cause, i.e.,
lack l
of post-pour verification (design conformance) on the
.part of the Project QC organization, are similar to those stated in Section 5.12.1.
i 5.12.3 Technically Incorrect Disposition of NCR C-83-1067 Inspection reports completed in late 1978 identified instances of less than design gap width and debris in the seismic gaps. These reports remained open until 1983 when, during the building turnover process, they were found to be unresolved. Construction attached these inspection reports to NCR C-83-1057 and sent them -
to Civil / Structural Engineering for disposition. As discussed in Section 5.7, the disposition provided by Engineering accepted as-is the identified non-conformances using an analysis that was technically.
incorrect.
O The root cause related to this matter is a technical error on the part of the responsible engineer within-the Civil / Structural Engineering. group. An investigation of other NCRs approved by the same engineer in a six-month timeframe identified no other i
technically incorrect dispositions, thereby dispelling any generic concerns related to this individual. A more comprehensive invest'igation of the technical adequacy of NCR dispositions is being performed by the i
Project with a third-party overview being conducted by I
DAP.
6.0 CONCLUSION
S 1
i Based.on the third-party's investigations, all seismic gaps have been identified and have been or will be inspected, with two exceptions identified to date. For these two cases, acceptable 4
justifications were developed that demonstrate seismic separation is maintained. The reinspections identified areas of significant-i debris accumulation and less-than-design gap width, thus confirming the TRT concern that the FSAR commitment for seismic separation had I
not been achieved. The Project is continuing to inspect all 1
seismic air gaps. In-process overview by the third-party has j
confirmed that the procedure's used and their implementation are effective in identifying the areas requiring corrective action.
i 4
Revision:
1
_Pags 39 of 56 i
fg RESUi.TS REPORT 4
IiAP II.c (dont'd) 1
6.0 CONCLUSION
S (Cont'd) i The Project is in the process of removing debris, widening the gaps where necessary and performing a final verification that the gaps meet the FSAR commitment for seismic separation. The third-party has performed in-process overviews of the final inspection for those areas where the Project corrective action is complete. Based on these overviews, it is concluded that the procedures used and their implementation have been effective in assuring that the design gap width is achieved, that the gaps are free of debris and that they are protected from future debris intrusion.
Gibbs 5 Hill has prepared calculations to establish the design basis building displacements and to confirm that t.he (elastic foam) materials designed to be present in the seismic gaps (e.g.,
environmental and fire seals) do not invalidate the assumptions or dynamic models used to analyze the seismic response of the building. The third-party has reviewed these calculations and concurs that they correctly reflect the FSAR commitment for seismic separation, and demonstrate that the presence of these materials do not have a significant effect on the seismic response of the buildings. However, due to the verification effort being conducted by SWEC in the Civil / Structural design area and the potential ier this verification effort to affect engineering results used as input to the Gibbs & Hill separation gap calculations, a final determination of adequacy for the engineering requirements related 1
to the seismic gap will be made by DAP in their overview of the SWEC verification effort.
One of the Out-of-Scope Observations made during the implementation of this Action Plan (Section 5.10.1) involved the discovery of damage to the Fuel Building wall. The concrete bridge between the Fuel Building and Containment Unit I walls transferred forces to i
the Fuel Building as a result of the radial expansion of the Containment structure during the Structural Integrity Test (SIT).
The affected area was repaired in accordance.with procedure. The Project then conducted an investigation of other locations along the Containment Unit I wall where concrete bridging had been observed, to determine if the expansion of the Containment caused by the SIT gave rise to adverse structural effects. The results.of the field survey and the analysis performed by the Project were reviewed by the third-party.
It was concluded that the question of 1
potential damage due to building-to-building contact during the SIT had buen satisfactorily resolved.
OV I
b M _,,, _.,.
t Rcvision:
1 Page 40 of 56 RESULTS REPORT l
ISAP II.c j
(Cont'd)
6.0 CONCLUSION
S (Cont'd)
The third-party has evaluated the root cause and generic implications of the three unclassified deviations identified by the j-investigations performed under this action plan. Based on this i
evaluation, it was concluded that this action plan has fully addressed the generic implications relative to paismic separation gaps and that similar deficiencies, if they existed in other areas, i
would be detected by the investigations being conducted under ISAPs II.a. II.d, VI.a and the DAP and Quality of Construction programs.
7.0 ONGOING ACTIVITIES Corrective actions are still in progress for secondary walls, base i
mats (including Contain ent Units 1 and 2 internal base mats),
. single wall gaps (including certain areas in Containment Unit 2 that are still under construction) and double wall gaps.- In order to facilitate QC inspector training, the gap inspection L
requirements have been consolidated in a new procedure.
QI-QP-11.0-16 " Building Separation Gap and Condition Inspection".
The methodology to be used for the remaining final inspections is j
the same as used for the inspections already completed and j
confirmed by the third-party to be effective. A third-party overview of-these corrective actions continuer as an addea t
assurance that the QC process (utilizing the new procedure) will-
{
continue to be effective in verifying the acceptability of the j
final condition. Corrective actions associated with this effort will be completed prior to fuel load.
Should the situag{on arise where the Projnct is unable to completely remove debris in some location (s), an analytical evaluation will be completed to assess the acceptability of the condition.
In such cases, the third-party will review the analysis, with the results included in a supplement to this report.
j The ne_ed to revise the FSAR has been assessed based on inspection i
findings. Section 3.8.5.1.3 has been submitted for revision in a l
subsequent FSAR update (Reference 9.21). These changes are
{
primarily in descriptive text and now reflect the as-built condition. This particular change request is subject to approval by SWEC as part of the verification effort being conducted for Civil / Structural design work. Accordingly, any modifications to this change request, or any new FSAR change requests related to I
seismic separation gaps, will be overviewed by the third-party.
O f
i l
i
- 4
f Rsvision:
1 Pags 41 of 56 l
RESitLTS REPORT ISAP II.c (Cont'd) t 7.0 ONGOING ACTIVITIES (Cont'd) l Ongoing maintenance of the seismic gaps (following completion of corrective actions and final inspection) is to be addressed through Operations procedures. Third-party overview of the critical spaces program, including review of Operations procedures, will be undertaken as part of ISAP VI.a.
Engineering requirements related to the seismic gap are subject to verification under the SWEC Corrective Action Program in the Civil / Structural area. DAP will conduct an overview of'the SWEC effort.and will, in particular, review calculations related to the seismic gap.
Section 5.7 summarized the results of a focused NCR technical adequacy review. A comprehensive investigation of the adequacy of NCR dispositions is being conducted by the Project in a self-initiated effort. The Project activities in this area will be
{
overviewed by DAP.
i Two of the Out-of-Scope Observations discussed in Section 5.9 (Concrete Voids and Commodities Bridging Seismic Gaps) are being addressed by other Action Plans.
The Project investigation of concrete voids will be overviewed by DAP (DSAP VII).
ISAP II.d j
will consider the significance of commodities bridging seismic gaps as part of its study of relative motion.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE To ensure against debris intrusion in seismic gaps, measures were added to QC procedure QI-QP-11.0-3, " Concrete and Mortar Placement l
Inspection", and now exist in QC procedure QI-QP-11.0-16, " Seismic l
Separation Gap and Condition Inspections". Primarily, these i
measures involve maintenance of flashing and/or seals with i
requirements for QC witness in instances where flashing or seal removal is necessary as part of some inspection or work activity.
+
To incorporate more definitive measures in conducting post-pour inspections for future concrete placement, QC procedure QI-QP-11.0-5, " Inspection of Concrete Repair", has been revised I
(Revisions 5 and 6).
These changes were reviewed by third-parte and found to adequately address the concerns identified as a rebult of the root cause assessment presented in Section 5.11 (References 9.11 and 9.27).
To insure that the seismic gaps are maintained and inspected satisfactorily, Operations procedures have been developed. The l
third-party will review these procedures as a task in ISAP VI.a.
g a.
Rsvision:
1 Page 42 of 56 4
RESULTS REPORT i
ISAP II.c (Cont'd) i
9.0 REFERENCES
9.1 Safety Evaluation Report, Supplement 8, NUREG 0797, Related to the Operation of Comanche Peak Steam Electric Station Units 1 and 2, Docket Number 50-445 and 50-446, February, 1985.
9.2 SwRI Surveillance Procedure, "SwRI QA Overview Plan for Verification of the TUGC0 Inspection of the Seismic Gap Between Category I Structures and Non-Category I Structures",
i CPRT File Number II.c.3 (file includes Revisions 1, 2, 3, and 4).
4 9.3 TUGC0 Quality Instruction QI-QP-11.0-3, " Concrete or Mortar Placement Inspection", CPRT File Number II.c.5a (file includes Revisions 5, 6, 7, and 8).
4 9.4 SwRI Report, " Surveillance Report for the Investigation of As-Built Building Separation Gaps at Comanche Peak Steam Electric Station, Units 1 and 2", SwRI Project 8478, January 1986, CPRT File Number II.c.5c.
O 9.5 SwRI Report, " Interim Report on the Overview of the Final As-Built Seismic Gap Inspection at-Comanche Peak Steam Electric Station, Units 1 and 2", SwRI Project 8478 July 1986, CPRT File Number II.c.5c.
9.6 TENERA Memorandum, 6/18/86, from Peter Turi to File II.c.4f,
" Review of Historical Documents Related to Seismic Gap", CPRT File Number II.c.4f.>
9.7 TENERA Memorandum, 8/28/86, from Peter Turi to File, "Reviev 4
of Additional Historical Documents Related to the Seismic Gap", CPRT File Number II.c.4f.
9.8 Gibbs & Hill Letter, Number GTN-71282, 3/6/86, "TRT Item II.c
- Seismic Gap".
9.9 Contact Log Sheet, 3/6/86, telecon between Peter Turi (TERA) and Anil Kenkre (Gibbs & Hill), " Clarification on GTN-71282".
l 9.10 Contact Log Sheet, 7/9/86, telecon between Peter Turi (TERA) and Pat Clarke (former B&R QC Manager), " Seismic Gap History".
O 1
[
- 5
9 Revision:
1 Pags 43 of 56 RESULTS REPORT ISAP II.c (Cont'd)
9.0 REFERENCES
9.11 Memo to file, 6/25/86, " Review of Project Procedures", CPRT File Number II.c.4f..
9.12 contact Log Sheet, 9/3/86, telecon between Peter Turi (TERA) and Neil Britton (Quality Engineer), " Seismic Cap Protection".
9.13 Contact Log Sheet, 9/3/86, telecon between Peter Turi (TERA) and Dennis Murcer (Quality Engineer), " Seismic Gap Protection".
9.14 Contact Log Sheet, 6/9/86, telecon between Peter Turi (TERA) and Tom Brandt (QC Supervisor), "QC Inspection Procedures".
9.15 Wiss, Janney Elstner and~ Associates, Inc., Report. Number 79656Q, 3/21/83, " Structural Response of Containment Vessel, Unit No. 1. During Structural Integrity Test at Comanche Peak-Steam Electric Station".
O 9.16 Gibbs & Hill Letter, Number GHCP-1362, 9/8/86, re:
inaccessible areas.
9.17 Gibbs & Hill Letter, Number GHCP-1775, 9/30/86, re: Type "C" inaccessible area.
9.18 Hansen, Holley, and Biggs Inc. Letter, 11/12/86, from M le f
Holley to Peter Turi, "G6H Position re Type C Caps (GHCP-1775)"
9.19 Hansen, Holley, and Biggs Inc. Letter, 11/18/86, from Myle Holley to Peter Turi, "C&H Position re Type A Gaps (GHCP-1362)"
9.20 Memo to file, 6/24/86, "II.c NCR Review",-CPRT File Number II.c.4c.
i 9.21 CPSES FSAR Change Request, 5/30/86, GHCP-080.
9.22 Memo to file, 6/18/86, "FSAR Update Review" 9.23 TENERA Memorandum, Number DAP-L-159, 10/3/86, from John Miller to John Hansel, "ISAP II.c".
9.24 Gibbs & Hill Letter, Number GHCP-1678, 9/25/86, " Report:
O Effect of Bridged Concrete as'a Result of Unit 1 SIT".
I
. _.. _ =
l Rsvision:
1 Pags 44 of 56 RESULTS REPORT ISAP II.c 4
(Cont'd) i
9.0 REFERENCES
(Cont'd)
J 9.25 Hansen, Holley, and Biggs Inc. Letter, 11/12/86, "Gibbs & Hill Report 'Effect of Concrete Bridging in Gap Locations at Containment U1 and Surroundinf. Interfaces as a Result of Unit
{
1 SIT' GHCP-1678".
9.26 SWEC Letter, Number SWTU-056,10/22/8%, re:
Issues Concerning l
Concrete Voids / Inadequate Consolidation.
9.27 Memo to file, 9/10/86, " Revision to QI-QP-11.0-5 (Rev. 6)".
1 i
i a
l I
J i
i i
)
I i
I l
-. -...,,..... -. _,..... - -. - - - -, - - ~.. _.
B Rsvision:
1 Page 45 of 56 RESULTS REPORT ISAP II.c (Cont'd)
Figure 1 Site Plan Viev 1
NFELING WATER STORAG TANK MFWLING WATER rwt STORAE TAPE (
REACTOR MAE.LP M ACTORe4AE.4.7 WATER STORAE TAreC WATER STORAE TAtet CONTANMENT CONTANENT
]
LHT NO. 2 f
/
( UPeT NO. I l
AUXu.lARY SAFECUAROS BulLDING
$AFECUAROS suiLowc sum _w g
UNIT Pc. 2 LDST NO. I COPCEWTE O
I I
CONTROL
$WITCHEAR R00as SWITCHEAR N NO. 2 m
Mml COPCEPSATE STORAE TAret t
ouu.Nc ouu.c LMIT NO. 2 UNIT NO. I i
- O
Revision:
1 Page 46 of 56 RESULTS REPORT ISAP II.c (Cont'd)
Figure 2 Representative Mapping of Debris Size and Location for Area Along Containment Unit 1 Outer Wall EL 918 ' - 4' EL 916' - 10' O
.8 g See Figure 3 j
j F\\
I n
\\9,,t
\\
e w
e553tg- ^
=
O e
f
Revision:
I Page 47 of 36 RESULTS REPORT ISAP II.c (Cont'd) l Figure 3 Detail of Debris Size and Location (Use in conjunction with Figure 2) l l
l i
O lb o
O bf O
O O
0 1
2 3
4 5 FEET O
O o
9 i
i
~ - - - - - ~ ~ - - ' - - - - - - - - - - ~ - ~ " ' - ' ~ ~ ~ ~ ' ' - ~ ~ ~ ~ ~ ' ~ ~ ' ~ ' ~
Revision:
1 Page 48 of 56 p
RESULTS REPORT ISAP II.c (Cont'd)
Figure 4 Representative Mapping of Locations Requiring Gap Widening for Area Along Containment Unit 1 Outer Wall EL. fisVy W
i 3.mv l
g u
j
_m.
I
!!E t
p
{
c I
c h
R
[((
2Ji l
See Figure 5
~
q ggg E
.\\
A i
3
~ %9 w%
n O
Revision:
1
'9 of 56 Page
+
RESULTS REPORT ISAP II.c
)
(Cont'd)
Figure 5 Detail of Gap Widening Locations (Use in conjunction with Figure 4) s' - 9 7/e*
6* - 10 3/4*
h 1
v/
/
EL We* - 10' 2
% /A
//mM8::::
J l
LSEMk Areas requirin0 Osp width edjusteent with associated nexteus concrete reenval requirements.
Besed on as-tuilt inspection seasurseontal i
_. W
.zw No Adjustment Required NOTE Winisue gas width requirement ebeve elevation E82' - 0* 1e 1.075*.
This restrement is sejact te verification by SEE.
b.
Revision:
I Page 50 of 56 f
RESULTS REPORT k
ISAP II.c (Cont'd)
Figure 6 Diagram Showing Concrete Bridge and Broken Cencrete of Fuel Building Wall Near Containment Unit 1 NORTN CONTAINNENT (UNIT U
'.;h fJ. k%
' rj ',g ig$y-l
. :6 g F:.
2' OESIGN GAP
~
4,. ' ':' %.$f
- i
.h?w,l4) 3 '.\\
~'
ff
% K D*
s 6.g?YS..
!s *
.. 2..
Mp?.de:
f.:,p
. *:ey.i.
.;.4.; j.kkskT$d.,fh
, h[.
REaAn a -%s:m r.;?
p, ;F e.w-et.
gj
- t..
~
l{ T.E*' $b U
p
.. r:,..
. n*?gky
@ ") k.,
- !sW.
.iy.e.n.i
,p.
y g4..
- g;.y.5,;, s.:.. :..
..:eQ.,;.
,;g;.. _p
....,.n.
u?* b.'
f 'kI d,",4. Mt my CONCRETE SAIOGE LEGEN0;
- -- Outline of Intended Design Configuration
[Eh.pN Concrete I$fN.%
Dislodged Concrete 6
~
. - ~.
i i
Ravision:
1 Paga 51 of 56 RESULTS REPORT ISAP II.c (Cont'd)
Table 1 Location in Section 5 of Action Item Resolution
, ACTION ITEM SUBSECTION LOCATION 1
CPRT Tasks
- i 1.
Inspect air gaps and identify 5.2 those that are out of compliance 1
2.
Correct out-of-compliance condition 5.3, 5.8 or demonstrate FSAR compliance 1
3.
Provide final as-built inspection 5.4 1
for corrected areas 4
4.
Provide analysis demonstrating no 5.6 effect of material in gap on seismic response Issue Resolution 5.
Reperform and document QC inspections 5.2 of air gaps 6.
Ensure that as-built conditions meet 5.3, 5.6, 5.8 design requirements 7.
Assess events leading to existing 5.5 condition and cause 8.
Remove debris or evaluate significance 5.3, 5.6, 5.11 to design basis 9.
Perform analysis using revised N/A (5.6) i stiffness, as necessary 10.
Review design evaluations on presence 5.6 of foam 11.
Issue instructions for removal of 5.3 i
debris
- O I
W
..--n.-
-~ - - - - - --
Rsvision:
1 Pags 52 of 56 1
RESULTS REPORT ISAP II.c (Cont'd)
Table 1 l
(Cont'd)
ACTION ITEM SUBSECTION LOCATION Issue Resolution (Cont'd) r 12.
QC verification of the final as-built 5.4 condition i
13.
Revise engineering calculations N/A 14.
Review project procedures on 5.1 requirements for separation conditions i
15.
Evaluate need to update FSAR 5.8 l
- 16. Evaluate cause and decide on 5.12
()
further actions t
- 17. Address construction housekeeping (see ISAP VII.a.7)
'l t
methods 18.
Review conclusions on cause, 5.12 i
applicability to other areas, and acceptability of final as-built j
condition.
1 1
1 i
i l
4 l
i i
1 Rsvision:
1 P gs 53 of 56 RESULTS REPORT ISAP II.c (Cont'd)
Table 2 Chronology of Events Date Document Comments FSAR Seismic load case defined by Sections 3.8.1.1.1, 3.8.4.5.1, and 3.7.b.2.8.
07/14/75 CP-QCP-2.4 Concrete pre-pour inspection procedure issued (no gap dimension check included).
01/29/76 RFIC~029 Field request to leave foam in place below waterstops due to difficulty in removal.
02/13/76 FPAR 110 Engineering approves RFIC-029 request saying foam may be left both below and above waterstop. FPAR apparently misinterpreted by Construction to mean all foam may be left in place. Engineering had O-apparently intended "above waterstops" to mean up to grade level only.
09/06/77 Telex GTT-1543 Gibbs & Hill notiffes TUSI that practice of leaving foam in place above grade deviates from design intent and is unacceptable.
10/07/77 TUS-5012 TUSI instructs Construction management to 11/01/77 Halliburton Contract remove foam from specific areas (defined on 11/02/77 TUS-5019 sketch attached to T"S-5019), allows foam to remain for certain areas and allows a minimum of 1" air, gap for certain areas (no technical justification was documented for this " design change") already constructed.
TUS-5019 states explicitly that a 2" gap must be maintained in subsequent work.
12/05/77 CP-QCI-2.4-9 B&R procedure (temporary) to verify Halliburton removal effort and check minimum gap dimension. Only two checklists have been identified to date that relate to this inspection.
i O
1 1
h
I Rsvision:
1 Pago 54 of 56 RESULTS REPORT ISAP II.c (Cont'd)
Table 2 j
(Cont'd) t Date Document Comments 02/19/78 IM-12939 Memo from Site QC Manager to Construction Management saying that, as a result of QC inspections, it is apparent that the Halliburton effort was not complete; both foam debris and less than design gap width are identified for a specific area; requests written response detailing actions
- ~
and schedule to correct areas. No response from Construction has been identified to date.
07/12/78 QI-QP-11.0-3 Replaces CP-QCP-2.4, adds pre-pour
. verification of gap dimension, protection from debris intrusion.
t
~
09/14/78 Inspection Reports Six. reports were writtan, five "unsat" 10/17/78 reports identified debris in gaps, one of the five identified less than design gap width.
04/13/83 NCR-C-83-01067 Open inspection reports were identified during building turn-over, were attached to NCR and routed to C/S Engineering.
04/17/83 NCR-C-83-01067 NCR closed using technically incorrect i
analysis.
04/26/83 TUS-4106 TUGC0 Dallas Licensind response to TUQ-1622 (TUGC0 QC meno to licensing group requesting review of NCR disposition) j stating that disposition will satisfy FSAR commitments.
.i i
l i
! O i
[ h
~.
j-Ravision:
1 l
Paga 55 of.56 RESULTS REPORT l
ISAP II.c (Cont'd)
Table 3 Summary of Related DIRs il' i
Related Report DIRf Title Classification Sections 1
j D-0166 No Design Basis Calculations-Observation 5.3, 5.7 i
j D-0258 Effect of Gap Condition on Seismic Response Observation 5.6 i
D-0259 Effect of' Gap Condition on Seismic Response Observation 5.6 j
D-0260 Local Seismic Displacements j
of Floors at Secondary Walls Observation, 5.6 j
D-1346 Inadequate Built'.ing Gap Unsubstantiated 5.6 r
4 1
D-1347**** Frequency Calculations Lack Wall Discrepancy 5.6 i
j and Equipment Weights i
D-0004 Building Air Gap Dimension Unclassified 5.3, 5.11, 3
Deviation 5.12.2, 5.12.3 1
j E-0987*
Air Gap Between Concrete Structures Unclassified 5.11, 5.12.1, Deviation 5.12.2 1
E-1052*
Poor Workmanship Using "Rotofoam" Unclassified 5.11, 5.12.1, Deviation 5.12.2 E-1220*
Elastic Joint Filler Between Observation 5.6 Category I Buildings D-2141** Unsat Condition Not Documented Discrepancy 5.5.1 by QC Record D-2142**
No Procedural Requirements for Discrepancy 5.5.3 Post-Pour Gap Inspections i
I
'D-2143**
Misplaced or Lost QC Checklists Discrepancy 5.5.3 1
D-2144**
Inspections Conducted Contrary to Discrepancy 5.5.3 j
Procedural Requirements
- O t
1 1
J Ravision:
1 Page 56 of 56 i
RESULTS REPORT I
ISAP II.c (Cont'd) i i
Table 3 Related Report DIRf Title Classification Sections i
D-2145**
Unresolved Inspection Reports Discrepancy 5.5.3 Remained Open for 5 Years l
D-2132*** Commodities Bridging Seismic Gap Discrepancy 5.10.3 D-2133 Tolerance Allowables Not Specified Observation 5.12.2 on Drawing These DIRs were extracted durtrg a review of external source documentation and represent discrepancies identified by individuals outside of the CPRT.
Transferred to QA/QC Review Team.
)
Transferred to ISAP II.d.
- Transferred to DAP.
O O
b
\\
-\\
u i
- j COMANC
- IE PEAK RESPONSE TEAM i
RESULTS REPORT ISAP:
V,d Titic: Plug Welds REVISION 1 i
O I2-l lI/ c?$
gwa r
k mM Issue Co rdinator Date I
b -w nInis i
rem 1le"an Leader
'U Date u./ b
/ L// r/ft JohnW. Beck, Chairman CPRT-SRT Date O
p f fh W 6 f d B J j
l 9
~ - -.
Rsvision:
1 Page 1 of 57
()
RESULTS REPORT ISAP V.d Flug Welds
1.0 DESCRIPTION
OF ISSUE Issue V.d was identified in SSER-10 (Reference 9.1, pages N-329 and N-330) as follows:
"The TRT investigated alleged generic problems regarding uncontrolled repairs to holes existing in pipe supports, cable tray supports and base plates in Units 1 and 2.
These holes, which had been misdrilled during fabrication, were repaired by plug welds. Since these supports are Seismic Category I supports and the effects of the velds have not been evaluated, this constitutes a violation of Criteria IX and XVI of Appendix B to 10 CFR 50. Region IV inspections have confirmed the existence of such welds in cable tray supports located in the Unit 2 Cable Spreading Room.
Although the effects of unauthorized, undocumented and uninspected plug welds in some locations (e.g., the webs of I-beam or in structural members in compression) will be
- O inconsequential, their effects in critical locations (e.g.,
flanges of I-beams in flexure or in structural members in tension) in critically loaded supports or base plates could affect their structural integrity and intended function."
2.0 ACTION IDENTIFIED The actions to be taken regarding Issue V.d were identified in SSER-10 (Reference 9.1, page N-330) as follows:
"Accordingly, TUEC shall perform one of the following:
(1) Modify its proposed plan to Region IV (TXX-4183 and TXX-4259) to include a sampling inspection of all areas of the plant having plug welds, to include cable tray supports, pipe supports and base plates. Propose alternate methods of inspection where the oblique lighting method is not viable (e.g., locations covered by heavy coats of paint). Perform an assessment of the effects on quality.due to uncontrolled plug welds found during the proposed inspection, as modified above.
Submit a report documenting the results of the inspection and assessment to the NRC for review.
4 O
I I
k
- b
I
\\
Rsvision:
1 Page 2 of 57 RESULTS REPORT ISAP V.d (Cont'd) 2.0 ACTION IDENTIFIED (Cont'd)
(2) Perform bounding analysis to assess the generic effects of uncontrolled plug welds on the ability of pipe supports, cable tray supports and base plates to serve their intended function. Submit a report documenting the results of the assessment to the NRC for review."
3.0 BACKGROUND
The issue of uncontrolled plug welds was first raised during the ASLB Hearings (Reference 9.2).
At these hearings it was alleged that mislocated holes in cable tray and pipe supports were welded closed without enginee' ring authorization using weld rods withdrawn for other authorized we'lds and that these plug welds were not inspected by Quality Control (QC). The allegers also stated that they were directed by their supervisor to make these unauthorized l
welds, that they were made without adequate cleaning of the back side of the weld and thus may have left slag in the welds.
It should be noted that the term " plug veld" as used in this results i
report and other documents related to this issue refers to the i
repair of mislocated holes by welding and not a plug weld as
)
defined by the American Welding Society (Reference 9.3).
In the addendum to the NRC staff testimony at the ASLB Hearings (Reference 9.4) Region IV staff reported the results of their inspection of several areas of the plant for plug welds. No indications of plug welds were found in the pipe supports examined in the south yard tunnel. However, three horizones.1 I-beam members of cable tray supports in the north cable spreading reos were each found to contain indications of two plus welds that were not documented in the construction and inspection records for these supports. Subsequent examination of these sospect areas confirmed the presence of two undocumented weld repairs in each of these three support members. The TRT concluded (Reference 9.1, page N-64) that the existence of these welds and the difficulty in detecting them raised a generic concern regarding the potential existence of an unknown number of unauthorized plug weld repairs of questionable quality in base plates, pipe supports and cable tray supports throughout Units 1 and 2.
1 l
The repair of taislocated holes in cable tray supports was generically authorized by engineering in Design Change Authorization DCA-5347. No similar generic authorization for repair of mislocated holes in pipe supports was issued by
,jO engineering.
Instead, the practice at CPSES (Reference 9.5) was to reject pipe supports with mislocated holen rather than repair them.
However, as described during the ASLB Hearings (Reference 9.6), an 1
Revision:
1 Page ?of$7 m
RESULTS REPORT ISAP V.d (Cont'd) 3.0 BACKCROUND (Cont'd) instance of unauthorized welding on pipe supports did occur.
In this instance, the resolution of the unauthorized welding was addressed at the time it occurred. The pipe supports in question were scrapped and the responsible foreman was denoted to a nonsupervisory position.
In addition, for reasons unrelated to repair welding, all pipe supports of the type involved in this case of unauthorized welding were removed from the plant, providing assurance that this specific case did not represent a concern.
The construction and inspection procedures applicable to the repair welding of mislocated holes at CPSES evolved with time and were dif ferent for ASME components *(e.g., pipe supports) and AISC components **(e.g., cable tray supports). For ASME components, base metal repairs required the issuance of a Repair Process Sheet
{
(RPS) by the Project Welding Engineer (PWE). An equivalent
~
document (Resolution of Defects form and later the RPS) vas urad l
for base metal repairs of AISC components except for the repair of mislocated holes that were welded using pre-specified techniques
- O (Reference 9.7).
In addition, the construction and inspection procedures applicable to cable tray supports did not require documentation specific to the repair of mislocated holes prior to
)
November of 1980.
Instead, the inspectien of these welds was temporarily docusated using a QC cceeptance sti:ker on the q
support. Thus, while the repair of mislocated holes in cable tray supports was authorized, the inspection records prior to November 1960 do not provide a basis to confirm or refute the allegation that some mislocated holes were repaired without OC inspection.
4 The second area questioned during the tearing was the adequacy of the QC inspections performed. The contention was made that it was difficult to remove the slag from inside the hole prior to welding the second~ side without using a pencil grinder. It was alleged that. pencil grinders were not always available and that QC should have been required to inspect the hole cleanliness prior to welding the second side. However, several welders and foremen from the same work crew as the alleger testified that they never directed, nor were directed by others, to make questionable repairs. Other welders also testified that there was no shortage of pencil grinders.
Components governed by American Society of Mechanical Engineers Codes.
Components governed by American Institute of Steel Construction Codes.
..,. -. In -... -, -
Revision:
1 Page 4 of 57 f ~s RESULTS REPORT U
ISAP V.d (Cont'd) 3.0 BACKGPOUND (Cont'd)
TUCCO presented test data at the hearing (Reference 9.8) which addressed the issue of slag entrapment in plug welds. The tests showed that, using normal velding techniques, significant amounts of slag could not be entrapped within the weld. Further tests, in which deliberate attempts were made to entrap slag, showed that even with large amounts of slag in the weld, the welded specimens exceeded the tensile strength requirements of the base metal. The results of these tests were consistent with the NRC Staff testimony (Reference 9.9) which concluded that if the plug weld were made well enoegh not to be readily discernable af ter surface grinding, the weld and the surrounding base metal are at least as strong as the original base metal before it was drilled.
The ASLB, in its opinion concerning welding issues (Reference 9.10) concluded that the allegations related to the repair of mislocated holes were found to be without merit except to the extent indicated in the Board's written opinion, primarily with respect to the implementation of repair welding procedures; and even if some weld Os repairs of misiccated holes were not properly inspected and contained defects as alleged, based on the TUGC0 tests and NRC Staff testicony it is unlikely they would have an adverse impact on the safety of the plant.
With respect to the documentation of thesa repair welds, the ASLB concluded that there was a practice of indeterminate extent in which the repair of mislocated holes was not properly documented and that this was a significant violation of Appendix B of 10CFR50.
With respect to the pipe supports that were velded without proper authorization, the ASLB concluded that most, if not all, of these supports were removed. However, the failure to issue a deficiency document for this violation of welding procedures and to perform an adequate contemporaneous investigation of the extent of the practice was considered to be a violation of Appendix B.
This report presents the results of the investigations performed in response to the actions identified by the NRC in Section 2.0 and the concern raised by the ASLB related to the practices for documenting the repair welds of mislocated holes. Investigation of the generic ASLB concerns typified by the concern for the adequacy of the corrective action for the pipe supports that were welded without proper authorization will be addressed by ISAP VII.a.2, "Non-conformance and Corrective Action System".
+.-
r Revision:
1 Page 5 of 57 RESULTS REPORT ISAP V.d (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objectives of this action plan were to:
Provide additional evidence to confirm the absence or presence of unauthorized or undocumented plus welds in ASME pipe supports and base plates and assess the significance of any plug welds found.
Assess the significance of undocumented plug velds on the quality of cable tray supports.
The plan was based on a combination of sample inspections and engineering evaluations. Sample inspections were used to characterize the number and locations of plug welds to be evaluated. Engineering evaluations were used to ass (ss the significance of specific plug welds identified and the limitations of the inspection technique. The sample O
inspections utilized a combination of paint thickness measurements to identify areas of excessive print thickness requiring removal and oblique lighting to detect suspect weld areas. This technique detected about 84% of the plug welds known to be present.
4.1.1 Pipe Supports and Base Plates 4.1.1.1 ASME pipe supports and base plates required specific engineering authorization to perform plug welds. Accordingly, it was anticipated that neither unauthorized nor undocumented plug welds exist in ASME pipe supports and their base plates. Therefore, the primary purpose of the sample inspection of pipe supports and their base plates was to assess whither unauthorized or undocumented plug welds exist.
Two random samples of ASME pipe supports and their base plates were selected for inspection. One sample was drawn from the population representing Unit I and Common and the second sample from the population representing Unit 2.,
The use of separate O
samples was not based on any expected
(
- b
Revision:
1 Page 6 of 57 RESULTS REPORT ISAP V.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l difference in the frequency of occurrence of plug welds between the two units, but was intended simply to increase the inspection coverage because of the expected low frequency of occurrence.
The sample plan was based on Appendix D of the CPRT Program Plan using the minimum sample size of 60 with a detection number of zero. However, the confidence level achievable in this case is less than indicated in Appendix D due to the limitations of the inspection technique. To maximize the probability of detecting plug welds, mockup supports with a variety of plug welds were used to ref fne inspection techniques and select inspectors based on their proficiency in detecting plug welds.
O In addition, the use of two samples of 60 pipe supports provided additional opportunities to detect plug welds if they were present.
4.1.1.2 When a support was identified as containing a suspected weld repair of a hole, the paint was removed and the suspect area etched to determine if a plug veld was present. If any plug welds were found, they were to be inspected and documented, and these documents were to be compared to the original fabrication and inspection records to determine if they had been authorized and properly documented. While a number of suspect areas were examined in detail, no plug welds were found. Thus, it was not necessary to perform the comparison with the original records or to perform steps 4.1.1.3, 4.1.1.4, and 4.1.1.6 as described below.
4.1.1.3 If the inspection and document review indicates that one or more of the sampled supports or base plates have unauthorized /
undocumented plug welds, an NCR (Nonconformance Report) will be issued and an 6
Revision:
1 Page 7 of 57 RESULTS REPORT ISAP V.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) engineering evaluation will be performed to determine the effect of such velds on the structural integrity of the affected support or base plate.
4.1.1.4 If one or more supports or base plates are found to lack structural integrity due to unauthorized or undocumented plug welds, a decision will be made to either expand the sample, utilize stratified sampling or go to 100% inspection.
4.1.1.5 If no undocumented plug welds are found in the random sample of ASME pipe supports and base plates, it will be concluded that there is reasonable assurance that the structural integrity of ASME pipe supports has not been degraded by the presence of unauthorized plug O
If unauthorized or undocumenced plug velds are found, but determined, either by inspection or engineering evaluation, not to affect the quality of the supports or base plates, an evaluation of the need for additional inspection will be performed based on the observed trends in the inspection results.
4.1.1.6 All supports found with unauthorized /
undocumented plug welds will be identified via an NCR and modifications will be implemented if required.
4.1.1.7 As part of this investigation, the existing QC inspection and documentation procedures were reviewed and the results are discussed in Section 5.0.
l 4.1.1.8 The third-party conducted the reinspection and provided an overviaw of the full scope of the effort.
O l
[
_j
Revision:
1 Page 8 of 57
()
RESULTS REPORT ISAP V.d (Cont'd) i 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Cable Tray Supports It was recognized that cable tray supports do exist for which the documentation specific to the inspection of individual plug velds is not available. Therefore, the primary purpose of the sample inspection of cable tray supports was to determine the number and location of such welds in order to determine the effects on the quality of the supports.
Random samples of cable tray supports in both Units 1 and 2 were selected for inspection. The steps involved in this investigation parallel those for the pipe supports and base plates as described in Sections 4
4.1.1.2 and 4.1.1.4 th, rough 4.1.1.6.
4.1.3 Engineering Authorization of Cable Tray Support Plug Welds l
The third-party reviewed Design Change Authorization DCA-5347 which generically approved plug welding in cable tray supports to ascertain whether a sufficient 1
technical justification existed at the time of issuance. That technical detail could include structural calculations, tests, or justification based on applicable industry codes and standards which are part of the licencing basis.
4.1.4 Documentation of QC Weld Inspections
.i The history of programmatic requirements and implementing procedures for QC documentation, as applicable to plug welds, was reviewed by the third-party. This review was undertaken with the knowledge that, prior to November 10, 1980, weld-specific documentation was not required by procedure. The review assessed compliance with the QA program and licensing commitments as documented in the FSAR.
4.1.5 Evaluation of Root Cause and Applicability to Other Areas The action plan also contained provisions for the O
evaluation of root cause and generic implications in accordance with Appendix E of the CPRT Program Plan.
.-.v-7
.m.
,_m,.
,,y m.,,,,,,,,,,,_,,,wy
s Pavision:
1 Page 9 of 57 RESULTS REPORT ISAP V.d (Cont'd) 4.0 CPRT ACTION P1h(Cont'd) 4.2 Participants Roles and Pesponsibilities The organizations that participated in this effort are listed below with their respective scopes of work.
4.2.1 CPSES Project 4.2.1.1
/ Scope Define population and select sample Prepare mockup supports and assf.at in the development of the inspection procedure Assist in the'rtview of'the hist'ory
-~
of procedures / program requirements for inspection and documentation of plug welds Assist in the evaluation of inspection results Provide the basis for the generic authorization to repair mislocated holes 4.2.1.2 Personnel Mr. C. Moehlman Project Mechanical Engineer Mr. W. Baker Senior Project Welding Engineer Mr. W. Wright Project Welding Engineer 4.2.2 Third-Parry Activities 4.2.2.1 Scope Review population definition and sample selection O
\\
Revision:
I Page 10 of 57 RESULTS REPORT O
ISAP V.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l Inspect pipe and calle traf supports QA/QC Review Team (ERC)
Evaluate QC inspection methods and.
documentation requirements Review TUGC0 engineering evaluations Recommend procedure changes if applicable Prepare Results Report 4.2.2.2 Personnel Mr. H. A. Levin TERA Corporation - CPRT Mechanical Review Team Leader Mr. J. C. Miller TERA Corporation - CPRT TRT Issues Manager Dr. J. R. Honekamp TERA Corporation - CPRT TRT Techni al Manager Mr. C. Spinks QA/QC Review Team (ERC)
Inspection Supert'1sor Dr. F. A. Webster Jack Benjamin &
Associates (JBA), - CPRT Statistics Advisor Mr. R. L. Shipp TERA Corporation - Senior Materials and Welding Engineer l
Mr. R. Sanan TERA Corporation - Issue Coordinator Dr. C. D. Lundin Material and Welding Consultant
'h,
Revision:
1 Page 11 of 57 RESULTS REPORT ISAP V.d
}
(Cont'd) l l
4.0 CPRT ACTION PLAN (Cont'd) 4.3 Qualification of Personnel The QA/QC Review Team inspectors were certified to the requirements of the ERC Quality Assurance Program and met the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants".
The' inspectors were also trained in the requirements of the QA/0C Review Team plug weld inspection procedure (Reference 9.11) and tested using the mockup supports to determine their proficiency in detecting plug welds.
Third-party participants'in the implementation of this Action Plan met the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.
Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific O
requirements of the CPRT Program Plan. Activities performed by other than third-party personnel were governed by the applicable principles of Section III.K " Assurance of CPRT Program Quality", of the CPRT Program Plan.
4.4 Procedures l
4.4.1 A procedure (Reference 9.11) was developed for the inspection of cable tray supports, pipe supports and their associated base plates to identify misdrilled holes that have been welded. This procedure contained criteria for limits on paint thickness and methods for paint measurement. These criteria were developed based upon a test program that established limits on paint thickness at which plug welds can be detected via visual inspection.
Inspectors were specifically trained and qualified for this task.
4.4.2 Inspection of all identified plug welds was performed utilizing the criteria for visual inspection as delineated in AWS D1.1.
' O
. (.
Revision:
1 Page 12 of 57
()
RESULTS REPORT ISAP V.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Decision Criteria / Acceptance Criteria The decision criteria and acceptance criteria for pipe supports and base plates are described in Sections 4.1.1.3 through 4.1.1.6.
The decision criteria and acceptance criteria for cable tray supports are outlined in Sections 4.1.2 and 4.1.3.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS This section describes the results of third-party investigations and reviews related to:
inspections of pipe and cable tray supports and their associated base plates and reviews of construction and inspection records (Section 5.1); review of the
- engineering basis for generic' auth'orization of plug welds in cable tray supports (Section 5.2); reviews of plug weld inspection and documentation requirements (Section 5.3); bounding evaluation of O
the effects of plug welding on the structural integrity of the components involved (Section 5.4);
safety significance of identified construction deviations (Section 5.5); a statement about generic implications (Section 5.6); and out-of-scope findings identified during the above investigations (Section 5.7).
5.1 Inspection of the Sample of Pipe and Cable Tray Supports and Comparison with Construction and Inspection Rtcords The initial step in determining the presence of unauthorized or undocumented plug welds was to establish an inspection procedure that would detect plug welds and to train the inspectors in using the procedure. The second step in the investigation was to identify the populations of potentially affected pipe and cable tray supports and to obtain representative samples of the populations. These samples were then inspected. The final step was to compare the results of the inspections with existing project documentation to determine whether or not unauthorized or undocumented plug welds exist.
5.1.1 Development of Inspection Technique and Inspection Procedure There are two basic methods for locating a weld in a carbon steel member. These are:
h
i l
l Revision:
1 Page 13 of 57
)
RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i Visual inspection, which relies on changes in
~
the surface contour or roughness between the weld metal and the base metal as the basis for detection, and Removal of paint and/or cleaning of the surface to be examined followed by etching of the surface with a nitric acid solution, which produces a discoloration of the heat-affected zone.
To provide a basis for evaluating the effectiveness of the visual inspection technique and the proficiency of individual inspectors in detecting plug welds, sixteen j
(16) mockup supports containing fifty-three (53) plug welds were fabricated. -These mockup supports were duplicates of supports used in the plant. Most of the plug welds in the mockups were located in areas where a O
bolted connection was intended by the design. However, some were arbitrarily located in areas where bolted connections were possible, but none was intended by the design. The plug welds were made and ground, using the same techniques as are used in the field, and the supports were painted to maximum thickness permitted by the specification..The mockup supports were then installed on the floor and ceiling of the welding shop to simulate field conditions.
Based on examination of the mockup supports by Project and third-party personnel, it was apparent.that plug welds located in base metal that had a textured surface (i.e., slight roughness) were easily detected through the maximum paint thickness because of the difference in texture between the ground surface of the veld and the unground base metal. For plug welds located in base metal that had no visible surface texture, detection depended on changes in the surface contour in the welded region. Low-angle reflected light was found to be an effective method to detect these irregularities on a smooth surface.
O 6
Favision:
1 Page 14 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The inspection technique selected utilized a combination of the visual examination and acid etch methods together with paint thickness measurements.
l For each support in the sample the paint thickness was measured to determine if it was greater than 0.015 inches which was the paint thickness used for mockup inspections. The inspection procedure required the paint to be removed prior to visual examination in all areas where it was thicker than 0.015 inches. Each support was visually examined for indications of plug welds. All suspect areas were marked and the surface cleaned and etched to determine if a plug weld was present.
l After development of the inspection technique, inspectors were trained and testad using the mockups.
The initial training and testing involved ten candidate inspectors.
In the inspection of the mockups, each O
inspector worked independently and was not told befora or af ter his inspections how many plug _ welds were present in the mockup supports, where they were located, or which plug welds were missed in their inspections. These inspections (Reference 9.12) produced an average detection rate of 76.7%.
Three plug welds (5.7%) were not detected by any of the ten inspectors. Of the ten candidates, four were selected for the in-plant inspections. The average detection rate of plug welds in the mockups for this group of four individual inspectors was 82%.
Initial inspections of pipe and cable tray supports in the plant were performed individually by the four inspectors. The results of these inspections showed that the inspectors had detected only 42% of the plug welds documented in the original inspection records for the sample of 120 cable tray supports.
In order to improve the detection rate, all the pipe and cable tray supports in the sample were reinspected using two inspection teams, each consisting of two inspectors. In this approach the first inspector examined'the support, documented his findings and provided them to the second (the checker) inspector.
The checker then reinspected the support for additional 3
Revision:
1 Page 15 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) suspect areas. The average detection rate for the two teams, based on their performance on the mockup inspections, was 87.5%. Mere importantly, these inspection teams detected 83.9% of the documented plug welds in cable tray supports in the plant.
5.1.2 Population Determination and Sample Selection The populations of pipe and cable tray supports were established as described in Reference 9.13.
The Hanger Information Tracking System (HITS) was used as the source document for.the population of pipe supports.
The accuracy of the HITS data base has been verified by the OA/QC Review Team, a third-party organization (Reference 9.14).
~
The population of cable tray supports was based on the list of Field Sketch Electrical for Cable Tray Hangers O,
(FSE-159) drawings in the Document Control Center. A list of cable tray supports obtained from the Unit 2 Package Flow Group was used to separate the Unit 2 supports from the total list.
(The Unit 2 Package Flow Group is the site organization that assembles and controls the Construction Work Packages). The accuracy of the resulting Unit 1 population was verified by checking it against a list of Unit I supports compiled by Engineering from a review of " map" drawings.
Electrical Drawings that are marked to identify hanger locations, types, and hanger numbers. The accuracy of the Unit 2 population was verified by comparison with 200 supports arbitrarily selected in the plant. All the supports selected in the plant were on the list.
The populations of pipe and cable tray supports were sampled randomly in accordance with the guidelines in Appendix D of the CPRT Program Plan to obtain a sample of 60 supports from each of the four populations of supports ar.d their associated base plates. The random selection process was checked by the third-party (Reference 9.15 and 9.16).
The initial sampling of pipe supports included Class 5 (non-ASME) supports on the basis that they were welded O
using the same procedures that were used for ASME supports.
Fifty-one (51) Class 5 supports were
- 4
Revision:
1 Page 16 of 57
(
RESULTS REPORT V}
ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) obtained by the random sampling process and inspected.
However, since the concerns raised in the ASLB hearing relative to pipe supports were focused on ASME supports, additional ASME pipe supports were drawn at random to obtain two samples of 60 ASME pipe supports for inspection (one cample from Unit 1 and one from Unit 2).
An error was detected during a third-party audit of the random sample selection. The impact of this error was evaluated by the third-party and the statistical consultant and was found to have no effect on the final inspection results (Reference 9.16), even though it affected the randomness of 14 out of the 250 samples.
5.1.3 Results of Pipe Support Inspections A total of 130 ASME and 51 non-ASME pipe supports and O
their associated base plates was initially examined using single inspectors. Eight (8) supports were identified as having suspect areas (i.e., areas with indications of surface imperfections that might indicate a repair). Each suspect area was stripped of paint and etched. No plug welds were present in any of the suspect areas. The same sample of 130 ASME pipe supports and base plates was reinspected using two-inspector teams as described in Section 5.1.1.
One (1) additional suspect area was identified during this reinspection. Again, when the paint was removed and the suspect area etched, no plug welds were found. The records for both, inspections are contained in Reference 9.17.
As a check on the effectiveneas of the reinspection, the document packages for the 130 ASME supports in the sample were reviewed by the third-party to determine if any plug welds were authorized. This review (Reference 9.18) confirmed that no plug welds were authorized.
Since no plug welds were found in either inspection, i
the record reviens indicate that no plug welds were authorized, and the pipe supports involved in the incident of unauthorized welding were removed frca the plant, it was concluded that there is reasonable assurance that the ASME pipe supports and base plates in the plant do not contain plug welds.
?
I Revision:
1 Page 17 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.1.4 Fesults of Cable Tray Support Inspections Table 1 summarizes the results of the inspections and document reviews for the 120 cable tray supports in the sample. More specific information on the 26 cable tray supports in which plug welds were found is provided in Table 2.
As discussed in Section 5.1.1 all 120 cable tray supports were examined by individual QA/QC Review Team inspectors and then reinspected by the two inspection teams. The information provided in Tables 1 and 2 are the combined results of both inspections.
A total of 57 plug welds was found, all of which passed the visual examination criteria of AWS D1.1.
Forty-seven (47) of these plug welds (82.5%) were documented in the original inspection records for the s'upports. The Project has issued NCRs (Nos.
M-86-104369X through M-86-104374X) for the six (6)
O' supports which contained the ten (10) undocumented plug welds. For these six supports the QA/QC Review Team inspectors found the welds to be satisfactory.
However, since the inspections performed under this action plan were based on a random sample, the results imply that additional undocumented plug welds exist.
This was documented in a DIR, as discussed in 5.3.2.
The fraction of supports containing one or more undocumented plug welds can be estimated from the inspection results. From Table 1 it can be seen that 6 of the 120 supports inspected, or 5%, contained one or more undocumented plug weld. If this observation is adjusted for the fraction of plug welds that were inaccessible and the fraction of plug weld not detected by the inspectors, the estimate of the number of supports with one or more undocumented plug weld becomes 6.9%.
The results of the inspections and document reviews were also examined for trends related to the occurrence of undocumented plug welds. Two trends were observed.
First, no undocumented plug welds were found on supports that were initially accepted by QC after December 1979 (see Table 2). As discussed in Section O
5.3, the December 1979 date correlates with a change in l
the method of documenting the inspection of plug welds.
l The second trend that can be seen in Table 2 is that I
all the undocumented plug welds were found on supports
- 21
Revision:
1 Page 18 of 57 RESULh5 REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) in Unit 1 and Common. However, it is known from the inspections performed by NRC Region IV (Reference 9.4) that some undocumented plug welds are present in cable tray supports in the Unit 2 cable spreading room.
Review of the installation records for the three cable tray supports with plug welds identified by NRC Region IV indicates that these supports were installed in December of 1979 although they were not accepted by QC until April to July 1980. Thus, it was concluded that the correlation with the date of installation is the underlying trend and that the observation of no undocumented plug welds in the sample from Unit 2 is the result cf the fact that most Unit 2 cable tray supports were installed at a later date than those in Unit 1 and Common.
It should be noted that correlation with the date of installation does not imply that all plug welds in O-supports initially accepted by QC prior to December 1979 are undocumented since some of these plug welds could have been made after the method of documenting plug weld inspections was changed. This is supported by the information in Table 2 which indicates that of the fourteen (14) supports with plug welds that were initially accepted prior to December 1979, eight (8) supports or 57% contained documented plug welds.
5.2 Review of the Engineering Authorization for Plug Welding 5.2.1 Cable Tray Supports The third-party reviewed the technical justification for DCA-5347, which provided the gencric authorization to repair mislocated holes in cable tray supports. The i
purpose of this DCA was to specify which holes in the cable tray supports must be welded in terms of the hole size and hole spacing. The welding process and the inspection and documentation requirements for these velds were defined by the specifications and procedures that control the fabrication, installation and inspection of cable tray supports. As discussed in the ASLB testimony and the TRT review (Reference 9.1 page N-62) and (Reference 9.9), the weld procedure specified Og meets the requirements of the AWS DI.1 code and, if properly implemented, results in a weld that is stronger than the base metal.
- 6 -
Revision:
1 Page 19 of 57
~)
RESULTS REPORT
[O ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Review of DCA-5347 (Reference 9.19) revealed two discrepancies: criteria specifying which holes could be left unwelded were not clearly stated and justification for allowing holes up to 3/4" in diameter to remain unwelded was not adequate. These discrepancies were documented in DIR-D-0018 and classified as a deviation. As part of this effort, Ebasco provided a reanalysis oddressing DCA-5347. This reanalysis was conducted to establish justification supporting the criteria specified in the DCA.
The DCA criteria have been incorporated into the Ebasco cable tray support as-built inspection program, and the effect of the presence of unused holes up to 3/4" diameter continues to be considered in the Ebasco cable tray requalification program.
Implementation of these programs is being overviewed by the third-party under DSAP VIII, " Civil / Structural".
5.2.2 Other Components Welding of mislocated holes was authorized in other components designed and fabricated to the AISC/AWS codes (non-ASME). The specific component types and the documents which authorized the repair of mislocated holes are listed in Table 3.
The base metal velded in the components identified in Table 3 was principally A-36 steel and carbon steel sheet, e.g., A569. The repair welds were made primarily using two welding procedures (WPS-10046 and (WPS-10082) and appropriate filler metals (E7018 and E70S-2). For these repairs, the combination of the matching filler metal and welding technique yields a welded region that is stronger than the base metal.
The fabrication and inspection of these components were, in many cases, controlled by different procedures from those used for cable tray supports (see Table 3).
However, as for cable tray supports, a qualified weld procedure specification was used and visual weld inspections were performed in accordance with AWS DI.1.
The third-party has reviewed the construction and 9
s Revision:
1 Page 20 of 57
~'%
RESULTS REPORT
[G ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) inspection procedures for these components and a sample of their inspection records and found them to be comparable to the procedures and inspection records used for the repair of mislocated holes in cable tray supports (see Section 5.3.3).
5.3 Review of Plug Weld Inspection and Documentation Requirements The third-party has reviewed historical and current procedures for the inspection and documentation requirements associated with the repcir of mislocated holes. The purpose of this review was to assess the ad.quacy of the procedures regarding weld repairs of mislocated holes and to determine their compliance with the QA program and licensing commitments. The results of this review are described in the following
_ sections.
5.3.1 ASME Pipe Supports The current procedure that controls the fabrication of ASME pipe supports and their base plates is CP-CPM-9.10 (Revision 15).
(A list of procedure titles is given in Table 4.)
This procedure requires that welding be performed in accordance with weld procedures qualified per the requirements of ASME..ler and Pressure Vessel Code Sections III and IX and that the welders be qualified for the weld procedures used. The procedure further requires the preparation of a Repair Process Sheet (RPS) for the weld repair of base metal defects (mislocated holes), and references procedure 5
CP-CPM-6.9G for weld documentation requirements.
CP-CPM-6.9G provides instructions for the preparation and approval of the RPS and requires that the RPS include the inspection requirements and any necessary QC hold points for the repair weld.
Procedure CP-CPM-9.10 was first issued in September 1980. Prior to that time the fabrication of ASME pipe supports was included in CP-CPM-6.9 and its associated appendices. These earlier procedures also required the use of the RPS to authorize and document the weld repair of base metal defects. Based on this review, it was concluded that the requirements for inspection and O-documentation of such, repairs in ASME pipe supports and their base plates are adequate and have complied with QA program and licensing commitments.
- s
Revision:
1 Page 21 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCt'SSION OF RESULTS (Cont'd) 5.3.2 Cable Tray Supports The current procedures that control the fabrication and installation of cable tray supports are ECP-10 (Revision 8) for Unit 1 and ECP-10A (Revision 4) and ECP-10B (Revision 1) for Unit 2 and other areas not included in ECP-10. The corresponding inspection procedures are QI-QP-11.10-2 (Revision 29) and QI-QP-11.10-2A (Revision 9).
The procedures for fabrication and installation require that all welding and related inspection be performed in accordance with AWS D1.1 and B&R welding specification WES-029. The welding process specified for general velding, which includes plug welds, is specified in WPS-10046.
The inspection procedures require a visual examination of all welds in accordance with procedure QI-QP-11.21-1 which includes the AWS D1.1 acceptance criteria. Both O,
the inspection procedures and QI-QP-11.21-) refer to procedure QI-QP-16.0-5 for the repair of mislocated holes. Procedure QI-QP-16.0-5 is a general procedure for reporting base metal defects in non-ASME items.
Section 3.1 of this procedure contains the following requirements for the welding of mislocated holes in cable tray supports:
Document the hole as unsatisfactory on an inspection report.
1 Prior to welding obtain engineering approval via an engineering design document or by engineering approval on an RPS.
For repair of holes in cable tray supports or conduit supports that are accessible from both sides, a construction operation traveler can be used to document the repair in lieu of an RPS.
Document the results of the visual weld inspection and the RPS, design document, or traveler number on the inspection report.
(
These requirements and other information provided in
\\
this procedure related to the repair of mislocated holes are consistent with the more detailed requirements provided in WES-029 for the repair of base metal defects in non-ASME components.
h
Revision:
I Page 22 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
In addition to the above procedures that control the normal construction and inspection activities for cable tray supports, the cable tray support requalification program also addresses mislocated holes as part of the as-built inspections. These inspections are controlled by QI-QP-11.10-9 and QI-QP-11.10-2A, which primarily address the support configuration. However, they do contain the acceptance criteria for unused holes and instructions for the documentation of holes that do not meet the acceptance criteria and the inspection of their repair. These inspection and documentation requirements are the same as described above for mislocated holes encountered in the normal construction and inspection process.
The evolution of the inspect. ion,and documentation
~
requirements for plug welds in cable tray supports is summarized in Table 5.
As indicated in Table 5, the O'
applicable procedures and specifications did not provide explicit instructions for the inspection and documentation of plug velds prior to November 1980.
However, the Brown &_ Root welding specification (S-52.01-106B) and the applicable inspection procedures (QI-QP-11.3-2 and QI-QP-11.10-2) clearly require all
{
welds to be inspected in accordance with AWS D1.1.
In addition, these inspection procedures provided for the use of an inspection report, a construction operation traveler or, in the earlier versions, an Electrical Hanger Inspection Checklist to document the results of weld inspections.
Further, the Resolution of Defects (ROD) and later the RPS was provided to authorize and document the weld repair of bass metal defects (unused holes). Both the ROD and the RPS included the instructions for making and inspecting the repair weld and documenting the results of the inspection.
Since the procedures in effect prior to November 1980 provided several methods to document weld inspection on cable tray supports, interviews were conducted with Welding Engineering and inspection personnel who were involved in the repair of mislocated holes in cable tray supports at that time. The interviews with Welding Engineering personnel (Reference 9.20) indicated that there was a question at the time as to O
whether mislocated holes must be considered base metal defects requiring the preparation of an ROD /RPS. The j
A
i Revision:
1 Page 23 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) interpretation provided by Welding Engineering was that since the repair of mislocated holes in cable tray supports had been authorized by DCA-5347, and the weld was an AWS D1.1 pre-qualified joint configuration, an ROD /RPS was not required. An ROD /RPS would be required for those cases where special preparation, welding or inspection methods were necessary, or where engineering authorizati~n was not provided via other mechanisms o
such as a DCA or CMC.
This interpretation was included in Revision 2 of WES-029 (January 14, 1983).
The interviews with inspection personnel (Reference 9.21) indicated that before November 1980 several methods had been used to document the inspection of plug velda in cable tray supports. Prior to the reassignment of responsibility for cable tray support,,
inspection in December 1979, most plug weld inspections were documented using a QC accept sticker attached to O
the support or by the inspector marking his initials and date on the support near the weld. After December 1979 and prior to November 1980, plug weld inspections were documented using an inspection report. Use of the inspection report was in compliance with the procedures in effect at that time. However, the third-party has not been able to identify any procedure which authorized the use of QC accept stickers or inspector initials on the support as the only record of inspection. The use of QC accept stickers was required by procedure QI-QP-11.3-24 (Revision 0).
However, it does not appear that this procedure applied to cable tray support weld inspections. Furthermore, this procedure also required that Class 1E cable tray raceway inspections be documented on an inspection report in accordance with, procedure CP-QP-18.0.
l The information provided by these interviews is consistent with the results of the reinspections and document reviews performed by the third-party under this action plan. All the plug welds found in the records of the 120 supports in the random sample were documented on construction operation travelers and/or inspection reports. Thus, the ROD /RPS, if used, was a very infrequent method of documenting the repair of mislocated holes in cable tray supports.
In addition, O
no undocumented plug welds were found in supports for which the construction operation traveler was signed by
'b
Revision:
1 Page 24 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
QC af ter December 1979. This corresponds to the date when the responsibility for cable tray supports was assigned to a new inspection group and the interviews indicate that inspection reports, rather than QC accept stickers, were used to document plug weld inspections.
Based on this review, the third-party concluded that the current procedural requirements for the inspection and documentation of the repair of mislocated holes in cable tray supports are adequate and in compliance with QA program and licensing commitments. Wi,th respect to the previous procedural requirements, the third-party concluded that the fact that an ROD or RPS was not generally issued for the repair of mislocated holes in cable tray supports is not a deviation from QA program or licensing commitments. Since these welds were authorized by DCA-5347, documenting their inspection in the same manner as all other cable trcy support welds (i.e., on a construction operation traveler or inspection report) was in compliance with the QA program. However, the 3ractice of using QC accept stickers or initials marked on the support as the only method of documenting the inspection of some plug welds prior to December 1979 is considered to be a violation of 10CFR50, Appendix B, Criterion XVII (Quality Assurance Records) in that it resulted in a condition where no retrievable inspection record exists for some plug welds in cable tray supports. This discrepancy was documented in DIR-D-2177 and classified as a deviation. This DIR was determined to be not safety-significant on the basis that all of the plug welds found during the reinspection met AWS DI.1 visual acceptance criteria, and, as discussed in Section 5.4, it is unlikely that the undocumented plug welds have adversely affected the structural integrity of the supports. This DIR has been transmitted to the QA/QC l
Program Adequacy Review Team for trending under that program (Reference 9.22).
)
5.3.3 Other Components 1
j Table 3 lists the component types, or commodities, other than cable tray supports where the repair of i
mislocated holes was authorized. With the exception of HVAC supports these commodities were fabricated and/or
- 6
.(
4 Revision:
1 Page 25 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Installed and inspected by Brown & *.oot.
The HVAC I
supports, which are addressed later in this section, j
were fabricated, installed and inspected by the Bahnson Service Co.
The primary construction and inspection procedures involved are also listed in Table 3.
The third-party has reviewed over seventy procedures, excluding revisions, which over time have addressed some aspects related to the repair of mislocated holes (Reference 9.23).
In general the CP-QCI and CP-QCP series of inspection procedures were originated in 1976 and were superseded by the existing CP-QP and QI-QP series in 1978. The corresponding Brown & Root construction j
procedures began in 1975 and evolved to their current l
revisions. Both the construction and inspection procedures reference construction specifications and Brown & Root welding standards for the general requirements related to velding. While there have been changes to these procedures, specifications and standards related to the authorization for the repair of mislocated holes and the methods of documenting these repairs, the basic requirements for making and inspecting plug welds have consistently included the
{
following:
Visual inspection of all welds in accordance with the requirements of AWS DI.1 (either by i
reference or by inclusion of the inspection j
criteria in the procedure).
Use of qualified welding procedures.
a 1
Use of qualified welders.
l Fabrication, welding and installation to approved drawings and other documents 1
including design change documents.
Documentation of weld inspections via Construction Operation Travelers (C0Ts),
Inspection Reports (irs), Weld Inspection Documentation Cards, Repair Process Sheet (RPSs) or checklists.
l 1
A
7 Revision:
1 Page 26 of 57
"'g RESULTS REPORT J
ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Before 1978, various component checklists were used to document weld inspections. Since 1978 the IR, the C0r and the RPS have been the principal records for documenting weld inspections by Brown & Root.
It was noted that several of the cable tray and conduit raceway inspect'on procedures in effect prior to January 1984 address the use of QC acceptance stickers.
While these procedures required the use of an IR to document inspections discussions with a Brown & Root inspector (Reference 9.24) who performed plug weld inspections on cable trays indicated that in the late 1979, early 1980 time period the practice of using QC acceptance stickers to document plug weld inspections also extended to cable trays.
The welding of mislocated holes and the associated inspections have been addressed by both 'cosmodity specific procedures e.g., QI-QP-11.10-1A (Inspection of O
Class 1E Conduit Raceway System) and generic procedures e.g., QI-QP-11.21-1 (Requirements for Visual Weld Inspection).
In addition, the repair cf mislocated holes has been described in various procedures as the repair of base metal defects, repair welding or its own unique activity, i.e., plug welding of mislocated 4
holes. However, the general treatment regarding visual inspection, qualified welding procedures and welders and fabrication and inspection in accordance with the design documents has remained the same.
Furthermore, since August 1975, the Project has had procedures (WCP-5) in place to control weld filler material and its proper selection and use with the various base materials. As can be seen from Table 3 the principal base metals in which plug welds were made have been A-36 and other Group 1 & 2 carbon steels.
The filler metals used for these welds have been E7018 and E705-2.
As of October 1986, the Bahnson procedures do not explicitly address repair welding of mislocated holes.
This subject is being incorporated in Revision 6 of their general repair procedure, GRP-TUSI-001. However, as with other commodities the key elements were included in the Bahnson procedures which govern the O
fabrication, installation and inspection of HVAC supports. Specifically, the following requirements related to welding have been included in the Bahnson procedures since 1978:
Revision:
1 Page 27 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Visual inspection in accordance with AWS D1.1.
Use of qualified welding procedures.
Use of qualified welders.
Fabrication, welding and installation in accordance with design documents.
Use of proper weld filler metal for the base metal being welded.
Documentation of veld inspections on duct I
support inspection checklists.
Surveillance of weld filler metal cont [o j
practices by a Quality Representative.
Based on the results of these reviews, it was concluded that the procedural requirements associated with the repair of mislocated holes and their inspection and documentation are adequate. The review did identify inconsistencies in several procedures relative to the criteria for allowing unused holes to remain unwalded.
These inconsistencies were documented and are discussed further in Section 5.7.
The third-party also reviewed the construction and inspection records for selected components as indicated in Table 3 (Reference 9.25).
The results of this review indicated that the repair of mislocated holes in 4
these components was properly authorized, utilized qualified welders and welding procedures, and the welds were inspected and documented in accordance with applicable procedures. However, as noted previously, the practice of using QC acceptance stickers to document plug weld inspections (see Section 5.3.2) also extended to plus welds in cable trays during the same tima period (i.e., late 1978 to early 1980). Thus, some undocumented plug welds exite in cable trays. The frequency of undocumented plug welds in cable trays is expected to be less than observed in cable tray supports on the basis that cable tray is installed O
after the cable tray supports and the use of QC acceptance stickers to document plug weld inspections was discontinued early in the process of accepting cable tray supports.
i
--4
- ' " " ~ ' " ' " ' ~ " " ' " ~ '
Revision:
1 Page 28 of 57 PESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Based on the above reviews, it was concluded that the repair of mislocated holes in commodities listed in Table 3 was treated in a manner comparable to the repair of mislocated holes in cable tray supports.
Thus, the results of the evaluation of plug welding in cable tray supports are coneidered to be applicable to these commodities and no reinspection of the plug welds in these commodities is necessary.
5.4 Bounding Evaluations The TRT requested that TUGC0 perform sample inspections of 1
cable tray supports, pipe supports and base plates for plug j
weld quality or perform bounding analyses of the generic effects of uncontrolled plug welds on the structural integrity of these components. As discussed in Section 4.0, this action plan utilized a combination of both approaches, in order to provide additional assurance that plug welding practices at i
CPSES did not adversely affect the structural integrity of support members.
5.4.1 Evaluation of the Effect of Weld Quality on Wald Strength As discussed in Section 3.0, TUGC0 presented test data during the ASLB Hearings that indicated'that, using normal welding techniques, significant amounts of slag would not be entrapped in the weld, and that even with large amounts of slag in the weld, the test specimens exceeded the tensile strength requirements of the base metal.
In the interest of further exploring the possibilities of slag entrapment, it was decided that additional i
tests using CPSES welders, selected at randon, would add confidence to conclusions drawn from earlier tests.
Three welders were selected at random from the list of 138 welders at CPSES who were currently qualified for the welding procedure used to make plug welds (WPS-10046). Each welder made eight 3/4-inch-diameter i
plug welds in 3/8 inch thick A36 plate coupons using the welding parameters specified in WPS 10046.
Four of these plug welds were made with the aid of a pencil grinder to remove slag and four were made using only a 0
i Rsvision:
1 Page 29 of 57 RESULTS REPORT ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) chipping hammer and wire brush. One veld coupon of each type was selected for metallographic examination and the other three of each type of weld coupons were subjected to tensile tests. This provided a total of six metallography coupons and 18 tensile test coupons.
The results of these tests Reference. 9.26, confirmed the basic original conclusions in that all 18 specimens tested exceeded the minimum yield and tensile strength of the base metal. The tests did indicate that grinding is more effective than chipping and wire brushing alone in preventing slag entrapaent. However, wich both weld cleaning techniques the required strengths were obtained.
. Based.on.the above, it-een be-concluded that for the geometry of a typical plug weld, using a suitable welding procedure, sufficient slag will not be entrapped to reduce the strength of the welded section to less than the minimum required of the base metal.
Visual inspection aad acceptance of plug welds in the ground condition also provides evidence that the weld will meet the applicable strength requirements.
5.4.2 Evaluation of the Structural Significance of Holes in Cable Tray and Cable Tray Supports Cable Tray Supports Since plug welds in cable tray supports were made to repair mislocated holes, an assessment of the structural significance of a poor quality plug weld can be obtained by concidering the significance of an unwelded hole at the same location.
As part of the cable tray support requalification program Ebasco has performed a sample inspection of the size of used and unused holes in cable tray supports and their base plates (Reference 9.27).
The results of this inspection were evalueted by the third-party to estimate the size of holes that may have been plug welded (Reference 9.28).. Table 6 summarizes the reaults of this evaluation. As can be seen from 7
Table 6 most (96%) of the anchor bolts are 1" or 1-1/4" in diameter and all of the member bolts are 5/8" or 3/4" in diameter. The size of the plug welds are equal
'. d
Revision:
1 Page 30 of 57 RESULTS REPORT
/
ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) to the bolt size plus the normal bolt hole clearance and any fabrication variation. Thus, for base plates most plug welds are expected to be in the range of 1-3/16" to 1-7/16" in diameter with'a maximum diameter slightly more than 1-5/8".
For the support members most of the plug welds are expected to be 11/16" to 13/16" in diameter with a maximum size slightly more than 13/16".
The inspections performed by Eh?sco determined the actual size of each used and unused hole in the scmple.
Thus these data can be used to estimate the largest hole that may have been welded. As shown in Table 6 the largest anchor bolt hole found was 1-11/16". The statistical evaluation of the anchor hole size data
.(Reference.9.28). indicated that at the-95% confidence level less than 1.32% of the supports have anchor holes larger than 1-11/16". The largest support member hole found was 29/32". The statistical evaluation of the support member hole size data indicated that at the 95%
confidence level less than 1.32% of the supports have holes in the support members larger than 29/32".
The design basis provided in DCA-5347 and substantiated by Ebasco (See Section 5.2.1) for cable tray supports allows for unused holes up to 3/4" in diameter in the support members that meet the spacing criteria from other used or unused holes as shown in Figure 1.
Since the plug welds in support members are expected to be 'In the range of 11/16" to 13/16" with an expected maximum size of 15/16", it is considered extremely unlikely that a poor quality plug weld would be more limiting than a 3/4" hole which is permitted in most regions of the member (see Figure 1).
In those cases where the plug weld is located close to another used or unused hole, a poor quality plug weld would be more critical.
However, based on the results of the weld tests discussed in Section 5.4.1, even plug welds with significant slag inclusions are expected to exhibit strengths comparable to the base metal. Therefore, it was concluded that the presence of a poor quality plug weld in a cable tray support member was very unlikely to compromise the structural integrity of the support.
O
- b
Revision:
1 Page 31 of 57 RESULTS REPORT ISAP V.d l
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
To assess the potential effects of a poor quality plug weld in a cable tray support base plate, Ebasco j
evaluated the effect of a 1-11/16" hole located in the region of maximum bending stress (Reference 9.29).
The results of this evaluation indicate that the hole will not cause any significant increase in the stress levels in the plate.
Cable Trays Misdrilled holes in cable trays are repaired by depositing weld material by the Gas Tungsten Arc Welding (GTAW) process, with E70S-2 (electrode material) cold wire feed. The weld metal so deposited will have a nominal yield of 60 KSI and a tensile strength of 72 KSI (stronger than the base metal).
GTAW is an inert gas shield process in which slag is not produced. Porosity is the major discontinuity O
which can occur and its presence will cause cross sectional' reduction proportional to its size. Because cable trays are fabricated from thin material (sheet metal), significant porosity will be visible in the welded surface and corrective action can be taken if the surface fails to pass the visual examination criteria for AWS D1.1.
4 To assess the effect of an unplugged hole on the structural integrity of the cable trays, Ebasco performed an analysis. The result of the analysis indicates that an unplugged hole would have no effect on the integrity of the cable tray provided 1) the hole is not larger in diameter than that required for a S/8 inch bolt, and 2) the edge-to-edge distance to the nearest used or unused hole is not less than the 4
diameter of the unplugged hole.
i The analyses discussed in this section have been
~
incorporated into the Ebasco cable tray requalification
~
program and are being evaluated by third-party as part of the implementation of DSAP VIII overview activities of that program.
O l
1 Revision:
1 Page 32 of 57 i
I RESULTS REPORT ISAP V.d (Cont'd)
I 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.4.3 Implication of Bounding Evaluations The results of the document reviews and procedure reviews indicated that the repair of mislocated holes was authorized, that the welds were made with the proper filler metal using qualificd welders and welding procedures, and that they were inspected in accordance with the requirements of AWS D1.1.
However, as discussed in Section 5.3.2 and 5.3.3 there was a practice early in the Project of using QC acc'eptance i
stickers to document plug weld inspections in cable tray and cable tray supports which resulted in no permanent inspection record for some plug welds.
The extent of this practice was quantified by the cable tray support inspections which indicated that 6.9% of the cable tray supports have one or more plug welds for which weld inspection records are no longer available.
O plug welds were found on supports initially accepted by These inspections also indicated that no undocumented QC after December 1979 and that all plug welds found, both documented and undocumented, meet AWS D1.1 visual inspection criteria. Thus, the lack of permanent plug-weld inspection records 4.
ears to be limited to a small portion of the pop uation and did not adversely reflect on the quality of the plug welds.
The bounding evaluations described in Sections 5.4.1 and 5.4.2 provide additional confidence that the undocumented plug welds not reinspected under this action plan are very unlikely to compromise the structural integrity of the components involved. Thus, based on the results of the investigations performed under this action plan, it is concluded that there is reasonable assurance that the existence of undocumented plug welds is not safety-significant.
5.5 Safety Significance Evaluation The original concern identified by the NRC (DIR-E-0348) related to the possible existence of unauthorized, undocumented and uninspected plug welds in pipe supports, I
cable tray supports and their base plates.. The investigations l
performed under this action plan determined that the repair of O
mislocated holes was not authorized in ASME pipe supports or their base plates 'and no plug welds were found. The repair of mislocated/ unused holes was authorized by Engineering for
. l A -
-- --- -- - - - - --~ ~ ~'
~
Revision:
1 Page 33 of 57 RESULTS REPORT
~~'
ISAP V.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) cable tray supports and a number of other AISC components.
The applicable construction and inspection procedures have consistently required that these welds be made using qualified welders and weld procedures and inspected in accordance with the AWS D1.1 visual examination criteria.
l The investigations performed under this action plan also determined that prior to December 1979 there was a practice of using QC acceptance stickers or inspector initials marked on the support as the only record of plug weld inspections of cable tray supports and that this practice also extended to the inspection of plug welds in cable trays. Thus, the NRC concern is partially substantiated in that some plug velds exist for which the record of inspection is no longer available.
All undocumented plug welds found during the cable tray support inspections met the visual examination criteria of O
AWS D1.1.
Thus, the lack of permanent inspection records for the six (6) supports which were found to contain undocumented plug welds (DIR-D-2177) was determined to be not safety-significant. Further, the evaluations performed under l
this action plan indicate it is very unlikely that the undocumented plug welds that were not reinspected under this action plan could compromise the structural integrity of the components (see Section 5.4.3).
Therefore, it was concluded that the practice of using QC acceptance stickers or inspector initials marked on the support as the only record of inspections for some plug welds in cable tray and cable tray supports is not safety-significant.
Since the only aspect of the original concern identified by the NRC that has been substantiated relates to the existence of undocumented plug welds, DIR-E-0348 was transferred to DIR-D-2177 which addresses this issue. DIR-D-2177, which is classified as a deviation, has been transmitted to the QA/QC
~
Review Team for trending under that program (Reference 9.22).
5.6 Root Cause and Generic Implications The investigations performed under this action plan did not identify any deficiencies or adverse trends. Thus, an evaluation of roo cause and generic implications is not required by the CPRT Program Plan.
'E
7 t
Revision:
I
{
4 Page 34 of 57 RESULTS REPORT i
ISAP V.d 1
(Cont'd)
[
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 1 5.7 Out-of-Scope Findings t
The purpose of the investigations performed under this action i
plan was to evaluate concerns'related to the adequacy of welds 4
made to repair mislocated or unuse'd holes.
In the process of l
these investigations, the following discrepancies associated with the criteria that specify which unused holes can remain i
unwalded were identified:
1
)
DIR-D-0018 As discussed in Section 5.2.1, this DIR was issued to document j
the fact that criteria in DCA-5347 (Revision 0 and 1) i specifying which holes could remain unwelded were not clearly stated, and the justification was not adequate for allowing holes up to 3/4" in diameter to remain unwelded. This DIR was l
classified as a deviation and determined to be not safety-significant. A new DCA (No. 25028) has been issued to clarify the criteria for the repair of mislocated/ unused s
holes. Further, the presence of unused holes up to 3/4" diameter is being addressed by Ebasco in the reanalysis of the cable tray support system.
Sinca the lack of clarity in DCA-5347 has been corrected and the implementation of the cable tray requalificatica program is being overviewed by the third-party under DSAP VIII, no further action under this ISAP is necessary. DIR-D-0018 has been revised to transfer the responsibility for closure to DSAP VIII.
DIR-D-2201 and DIR-D-2202 These DIRs were issued to document the fact that unused bolt holes in instrument tube supperts and conduit supports were not included in the evaluation of the individual supports and no generic justification was provided. The Project is currently evaluating the significance of unused bolt holes in these supporte. Third-party overview of these Project evaluations has baen included under the Design Adequacy 4
Program. Therefore, DIR-D-2201-(Unused Holes in Instrument Tube Supports) has been transferred to DSAP IX (Piping and Supports) and DIR-D-2202 (Unused Holes in Conduit Supports) has been transferred to the DSAP VIII (Civil / Structural) for classification and closure.
.O l
i
Revision:
1 Page 35 of 57 RESULTS REPORT ISAP V.d (Cont'd) i l
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
DIR-C-0097 The criteria specifying which unused holes can remain unwelded in cable tray, cable tray supports and conduit supports evolved with time and several inconsistencies in incorporating these criteria in the construction and inspection procedures were encountered in the procedure reviews performed under this action plan. In all three areas the Project was aware of such concerns and is in the process of initiating corrective actions which should assure that the proper criteria have been applied. Third-party overview cf these corrective actions will be tracked under DIR-C-0097.
6.0 CONCLUSION
S The investigations performed under this action plan determined that the repair of mislocated holes was not authorized in ASME pipe p
supports and their base plates and there is reasonable assurance L
that no plug welds are present. The repair of mislocated/ unused holes was authorized for cable tray supports and a number of other AISC components. The applicable construction and inspection procedures have consistently required that these welds be made using qualified welders and weld procedures and inspected in accordance with the AWS DI.1 visual examination criteria.
The investigations performed under this action plan also derarmined that prior to December 1979 there was a practice of using QC acceptance stickers or inspector initials marked on the support as the only record of plug weld inspections of cable tray supports and that this practice also extended to the inspection of plug welds in cable tray. Thus, some plug welds exist for which the record of inspection is no longer available. Thir discrepancy was considered to be a violation of 10CFR50, Appendix B, Criterion 16 (Quality Assurance Records).
It has been classified as a deviation and transmitted to the QA/QC Review Team for trending under that program.
Based on the results of the inspections, procedure reviews and bounding evaluations performed under this action plan, it was concluded that there is reasonable assurance chas undocumented plug welds not reinspected under this action plan will not compromise the structural integrity of the components.
O~
_4
Revision:
1 Page 36 of 57 RESULTS REPORT
\\
ISAP V.d (Cont'd)
6.0 CONCLUSION
S (Cont'd)
The investigations performed under this action plan also concluded that adequate justification was not provided for the criteria which permit unused bolt holes to remain unwelded in cable tray supports, conduit supports and instrument tube supports. The cable tray support requalification program has already included the evaluation of unused bolt holes and the Project is assessing the significance of unused holes in instrument tubing and conduit supports. These discrepancies have been transferred to the Design Adequacy Program i
for follow-up.
7.0 ONGOING ACTIVITIES There are no ongoing activities related to the welding of mislocated holes. However, three discrepancies related to the justification for allowing unused holes to remain unwelded (DIR-D-0018, DIR-D-2201 and DIR-D-2202) have been transferred to the Design Adequacy program for follow-up and closure. In addition, DIR-C-0097 was issued to track the third-patcy overview of the Project corrective actions related to the implementation of the unused hole criteria in the inspection procedures for cable tray, cable tray supports and conduit supports.
8.0 ACTION TO PRECLUDE RECURRENCE The current procedures and practices for the repair of mislocated holes, including their inspection and documentation are adequate to preclude the recurrence of undocumented plug welds.
9.0 REFERENCES
9.1 NUREG-0797 Supplement 10, April 1985 (SSER-10), " Safety Evaluation related to the Operation of the Comanche Peak Steam Electric Station, Units 1 and 2".
9.2 ASLB Hearing Transcript dated February 23, 1984 9.3 ANSI /AWS A3.0-80 " Welding Terms and Definitions" 9.4 Addendum to Page 27 of NRC Staff Testimony on Welding Fabrication Concerns [TR:
12146]
()
9.5 ASLB Hearing Transcript (TR:
11632-33)
+
6 4
Revision:
1 Page 37 of 57 RESULTS REPORT ISAP V.d (Cont'd)
9.0 REFERENCES
(Cont'd) 9.6 ASLB Hearing Transcript [TR:
11781}
9.7 Brown & Root Specification WES-029. Revision 2 (January 14, 1983) " Welding Specification for Field Fabrication and -
Erection of Structural Steel" 9.8 ASLB Hearing Transcript. Applicants' Exhibit 177 pages 42-44 i
9.9 ASLB Hearing Transcript, NRC Staff Testimony page 26 [TR:
12,146]
9.10 ASLB Memorandum Concerning Welding Issues (LBP-84-54),
December 18, 1984 pages 77-78 4
9.11 ERC inspection procedure QI-007 for plug weld inspections 9.12 Memo J.1R. Honekamp to V.d File " Summary of Inspector Testing for the Location of Plug Welds" May 29, 1986 9.13 Memo IM #29082, W. E. Baker to Claude Moehlman " Plug Weld
. Sampling and Inspection" November 20, 1985 9.14 ERC Memo QA/QC-RT-200, " Population Items List: Large Bore Pipe Supports", July 3, 1985 9.15 Memo R. L. Shipp to Harold Porter "Randon Sampling for Plug Welds", July 31, 1985 9.16 TERA Memo Sancn to ISAP File V.d " Methodological Errors in Support Sampling Related to ISAP V.d", November 17, 1986 9.17 ERC inspection records for both the inspections of cable tray and pipe supports.
(File V.d.5.c) 9.18 TERA Memo R. T. Woo 1 heater to R. K. Sanan, " Pipe Support Packages", October 7, 1986.
9.19 TERA Engineering Evaluation V.d.4b.1, Revision 1. " Evaluation of DCA 5347 Revision 1".
9.20 TERA Memo ISAP-L-002, J. R. Honekamp to ISAP V.d File, October 9, 1986.
1 9.21 Memo John R. Honekamp, to V.d File - Plug Welds O
" Interviews with Personnel Involved in the Inspection of Plug Welds in Cable Tray Supports Prior to November of 1980",
October 17, 1986.
. k._,
~~
d Revision:
1 Page 38 of 57
-s RESULTS REPORT ISAP V.d (Cont'd)
9.0 REFERENCES
(Cont'd) 9.22 DAP/QOC Interface Transmittal S-1080, October 1, 1986, 9.23 TERA Memo D. C. Timmins to J. R. Honekamp, "ISAP V.d - Review of Applicable Specifications and Procedures", October 7, 1986.
9.24 CPRT TRT/DAP Contact Log Sheet documenting a telecon between Doug Timmons (TERA) and Mike Uptmore (B&R) relative to plug welding of cable trays, 10/30/86.
9.25 TERA Memo from D. C. Timmons to J. R. Honekamp, "ISAP V.d -
Construction / Inspection Documentation Review", 10/15/86.
9.26 Test Report "The Metallurgical and Structural Significance of
' Plug Welded' Holes in Cable Tray Supports - ISAP V.d (Comanche Peak Steam Electric Station), C. D. Lundin, November 24, 1986.
9.27 Ebasco Memo EB-RCI-0239, R. C. Iotti to C. K. Moehlman,
("'s "Results of Belt Hole Edge Distance Investigation",
\\,
October 20, 1986.
9.28 Memo CPRT-718, F. Webster to J. Miller, dated November 20, 1986 " Statistical Analysis of Bolt-Hole Sizes in Cable-Tray Hangers - Issue V.d".
9.29 Ebasco Memo SAG. TUG 2.2449, R. Alexandru and L. Gorozdi to E. Odar, ' Unused Bolt Holes in 1" Four Bolt Anchor Plate',
February 3,1986.
I
i Revision:
1 Page 39 of 57 i
g--
RESULTS REPORT ISAP V.d (Cont'd)
Table 1 Results of Cable Tray Support Document Reviews and Inspections Number of Cab.le Tray Supports in the Sample 120 Document Review Results:
Number of Supports With Documented Plug Welds 30 Number of Documented Plug Welds 65 Number of Accessible Documented Plug Welds 56
% of Documented Plug Welds Accessible (56/65) 82.6 Inspection Results:
Weld Basis:
Total Number of Plug Welds Detected 57 Number of Documented Plug Welds Detected 47 Number of Undocumented Plug Welds Detected 10
% of Accessible Documented Plug Welds Detected (47/56) 83.9
% of Plug Welds Found That Were Documented (47/57) 82.5 Support Basis:
Total Number of Supports With Plug Welds 26 Number With All Plug Welds Documented 20 Number With One or More Undocumented Plug Weld 6
% of Supports With One or More Undocumented Plug Welds (6/120) 5 O
+
RLvision:
1 Pcgs 40 of 57 RESULTS REPORT ISAP V.d (Cont'd)
Table 2 Summary of Cable Tray Supports With Plug Welds Initial Support Original Plug Plug Weld QC Acceptance Plug Weld Weld Inspection Found by Support Number Unit i On the COT
- Number Record and Date QA/QC Review Team Comments CTH-t-61 1 & COMMON 03/24/80 01 COT
- 10/05/83 NO 02 COT 10/05/83 YES 03 COT 11/02/83 NO FSE-00159-338 1 & COMMON 02/12/79 01 COT 09/01/83 YES 02 COT 09/01/83 YES FSE-00159-1831 1 & COMMON 04/04/79 01 COT & IR*
06/27/83 YES NONE YES NOTE I FSE-00159-2372 1 & COMMON 02/02/79 01 IR 12/04/79 YES 02 NONE YES NOTE I FSE-00159-3785 I & COMMON 02/07/79 01 RCOT*
02/19/84 YES 02 RCOT 0?/19/84 YES 03 RCOT 02/19/84 YES 04 RCOT 02/19/84 YES FSE-00159-4045 1 & COMMON 02/08/79 01 RCOT 02/18/84 YES 02 RCOT 02/18/84 YES FSE-00159-4142 1 & COMMON 02/08/79-01 NONE YES NOTE 1 FSE-00159-4182 I & COMMON 02/19/79 01 NONE YES NOTE 1
-0 O
O O
R; vision:
1 P;g2 41 of 57 RESULTS REPORT ISAP V.d (Cont'd)
Table 2 (Cont'd)
Initial Support Original Plug Plug Weld QC Acceptance Plug Weld Weld Inspection Found by Support Number Unit #
On the COT
- Number Record and Date QA/QC Review Team Comments FSE-00159-4262 1 & COMMON 01/30/79 01 RCOT 02/20/84 YES 02 RCOT 02/28/84 YES 03 RCOT 02/28/84 YES 04 RCOT 02/28/84 YES 05 COTW*
03/18/83 YES 06 YES 07 NO 07 NO FSE-00159-4292 1 & COMMON 02/14/79 01 IE 09/25/79 YES 02 IR 09/25/79 YES FSE-00159-4300 1 & COMMON 02/08/79 01 RCOT 02/20/84 YES 02 RCOT 02/20/84 YES 03 RCOT 02/20/84 YES 04 RC01 02/20/84 YES FSE-00159-4328 i & COMMON 02/08/79 01 COT & IR 07/13/83 YES 02 RCOT 02/24/84 YES 03 RCOT 02/24/84 YES 04 NONE YES NOTE I 05 NONE YES NOTE 1 FSE-00159-5230 1 & COMMON 02/01/79 01 COTW 11/30/83 YES
-es O
O O
R.vicion:
1 Page 42 of 57 RESULTS REPORT ISAP V.d (Cont'd)
Table 2 (Cont'd)
Initial Support Original Plug Plug Weld QC Acceptance Plug Weld Weld Inspection Found by Support Number Unit I On the COT
- Number Record and Date QA/QC Review Team Comments CTil-1-616 7 I & COMMON 03/17/80 01 COT & IR 07/10/83 YES 02 COT & IR 07/10/83 YES 03 COT & IR 07/10/83 NO 04 COT 01/04/79 YES FSE-0159-6485 1 & COMMON 04/30/79 01 COTW 11/10/83 YES 02 COTW 11/10/83 NO CTil-2-7175 2
08/09/82 01 COT & IR I1/11/85 YES FSE-0159-7271 2
03/20/82 01 COT 01/23/84 YES FSE-00159-7271 1 & COMMON 07/19/80 01 COTW 07/06/84 YES 02 COTW 07/06/84 YES FSE-00I59-8322 '
'I & COMMON 11/28/79 01 NONE YES NOTE 1 02 NONE YES NOTE !
03 NONE YES NOTE 1 04 NONE YES NOTE I FSE-00159-8558 I & COMMON 06/25/80 01 COTW 07/27/84 YES 02 COTW 07/27/84 YES 03 COTW 07/27/84 YES 04 COTW 07/27/84 YES
~t FSE-00159-9887 2
08/28/80 01 COTW 03/13/84 YES e
O 9
R; vision:
1 Pzgo 43 of 57 RESULTS REPORT ISAP'V.d (Cont'd)
Table 2 (Cont'd)
Initial Support Original Plug Plug Weld QC Acceptance Plug Weld Weld Inspection Found by Support Number Unit i On the COT
- Number Record and Date QA/QC Review Team Comments FSE-00159-10,760 2
12/15/80 01 COTW 02/07/84 YES FSE-00159-10,161 2
03/19/80 01 COTW 02/14/84 NO 02 COTW 04/17/84 NO 03 COTW 04/17/84 YES FSE-00159-10,789 2
09/04/80 01 COT 10/20/81 YES FSE-00159-II,254 2
01/07/81 01 COTW 02/01/84 YES 02 COTW 02/01/84 YES FSE-00159-II,405 2
10/20/80 01 COTW 02/02/84 YES 02 COTW 02/0F/34 YES NOTES
- COT = Construction Operation Traveler RCOT = Unit I Spreading Room Kework Traveler COTW = Traveler with Weld Inspection Data Card IR
= Inspection Report NOTE I - Undocumented Plug Weld
~0.
O O
O
R; vision:
1 Prga 44 of 57 RFRL1B REmRT ISAP V.d (Cont'd)
Table 3 Stamary of Other Gmpments with Plts Welds 01BNNr F?CIhT7 RING WEIA NC I?SPELTIm FIBRICATION/
BASE FIIUR LNJSFD n m ou2ATTm PEGWRES PR00 TURF 3 UNmECTIm
- HETAI, HETAL h2S IXX1NFNIS PI0GDURES All0WED JtNCTIW Il0XFS ITA 4343 WPS 10082 QI-QP-11.10.-l EXF-19 A36 E70S-2 10 WPS 10046 QI-QP-11.10-7 EIF-19A A569 E7018 GNm0CTIN PAGACE (1)
QI-QP-I I.21-1 A570 REVIEWED (2)
G-QCI-4.3-3 JBS-3617 (3)
OI-QP-16.0-5 CP-QCP-2.13 G-QCI-2.13-1 CP-QCP-2.17 ELECIRICAL PANFL DCA 3273 WPS 10(M6 QT-QP-16.0-5 CP-GM-7.3D A36 E70S-2 70,
0[NmRUTION PKKA2 IYMRIE IN GASS ITA 20986 WPS 10082 QI-QP-11.10.-l AISI-1010 E7018 REVIEWED lE ARFAS DCA 7974 (1)
QI-QP-I I.21-1 A569 G2-EIDPED-01 DCA 6549 (2)
QI-QP-I I.10-7 DCA 3120 (3)
QI-qP-I I.14-12 DCA 7982 0 W 2.13 ira 15619(a) w-QCP-2.17 DCA 22199 CP-QCI-2. lFI O W -2.17-1 (a) R R INE3GMX
- f, BATITRY RMX thTIS e
O O
R;visfon:
1 Pega 45 of 57 REStHIS RFT W T ISAP V.d (Cont'd)
Table 3 (Cnnt'd)
(INITMNT FNGDURDC WFII)DC INSPDCTIm FABRICATION /
BASE FII11R (10 SED MmIDRI7ATION IT0010RES PROGIURES QNSIMLTION PETAL ETAL IRIS DOClNFNIS ITDCFIl0RES AIIIMED DSIRtNFNTATION Inc FSI-00082 WPS 10046 QI-QP-I I.8-5 CP 6 7.3D A36 E7018 YES*
INSNCTION RERRIS
& INSIMNFNr 110 FSI-00071 (1)
QI-QP-11.8-2 T-CFM-9.10 SA-36
- for 100N REVIEWED 11EDC StTEWIS lic 2323-I-001 (2)
QI-QP-11.21-1 SA515m65 10 BE IR-1252, 1457, 1458,
-m02 QI-QP-16.0-5 D&RCISED DIE 1588, 2926 & 2928 WC-73029R0 QI-QP-II.3-14 10 PRACTI 1NE-Il-0071 Q!-QP-11.8-1 0Fa TNE-Il-0078 QI-QP-11.8-9 INSTAIIATION 1NE-II-00B2 G-QCP-2.17 G-QCP-2.13 Q W -2.13-1 CNEI-2.17-1 QI-QP-11.1M CAN E TRAY DCA 4178 WPS 10046 QI V -16.0-5 ELT-10 A570@B E70S-2 TrS (INSIMLTIm PAOWE TA 25066 kTS-10082 QI-QP-il.21-1 EIP-1(R REVIEWED frA 2i244 (a)
(1)
QI-QP-i l.10-2A T-CEM-7.3E 10(a) 123GX2-54 (2) 0 4 I-4.3-4 FIT-10B QI-QP-II.3-5 QI-QP-I I.10-9 FtM EAIL DCA 22425 WPS-10046 QI-QP-I I.21-1 067.3D A36 E7018 ND (INSIRCITON PNKA&S ira 22705 (1)
QI-QP-II.14-1 SA 36 REVIEWED ira 18145 (2)
QI-QP-16.O-5 T2-+efoi-59.
(3)
G-QQ-2.13 CP2-FelDi-30 O
O O
R; vision:
1 Pcg2 46 of 57 RI3tt,TS RITMr ISAP V.d (Cont'd)
Table 3 (Cont'd)
(TM MTNr F20TN17 RING WUDI?C INSPELTION FAIRICATICN/
IMSE FIIIIR UMJSED NmMI7ATION PR0011RES PKXEURFS GESIRtUTION METAL PETAL MXES D00 MENIS Pf0CEIREES AIIIMD 1DRNNU IWFER G-QCP-2.17 TRVf5 & QSSET G-QCl-2,13-1 PIA 1TS (Cont'd)
G-QCl-2.17-1 10RNMD IWFER OCA 20R09 WPS-10046 QI-QP-16.0-5 CP-OW7.3D A36 E7018 YES GMTIRUCTION FRVES & CUSSER DCA 15029 (1)
QI V -II.14-1 PKXAGE REVIBED 11ATTS ILC 2323-S-789(a) (2)
QI-QP-i l.14-3 DCA 15952 (a)
(3)
QI-QP-I I.21-1 K)(a)
CP2-1VSLM)-Ol(a)
(Np-2.13 T-83-324-8904 CNp-2.I7 T-QCl-2.13-1 0 % I-2.17-1 thG 2323-S-0910 WPS-10046 QI-QP-16.0-5 EIP-19 A36 E7018 YES (INSIRUCTICN (IMLTI SFEr G-6a (1)
QI-QP-II.21-1 FIP-19A PNXAGS REVIfMED RTTWIS IMG 2323-S2-0910 (2)
QI-QP-i l.3-23A CP-OW7.3E C22KD7334 SHEER C,-Sa (3)
QI-QP-II.10-1 C26807181 QI-QP-11.10-1A QI-QP-I I. lO-4 G-QCP-2.13 CP-QCP-2.17 G-QCl-2,17-1 CP-QCI-4.3-3
-C QI-QP-II.3-2 O
O O
R; vision:
1 P g2 47 of 57 RFSUl35 REIWr ISAP V.d (Cont'd)
Table 3 (Cont'd)
RNinTNT D CINEERR E WHDING INSPECTION FAIRICATION/
BASE FIIIR 1RISED Mm0RI7ATIm PRDOIIRES Ff00DURES GNillRUITON ETAL ETAL 10115 DOCtMNTS PROCEIIEES AUIMD INY, SUPINIS DD G ND. BSC-127 BSC-12 QCI-GSES-Oll DEP-11SI-001 A526 E70S-2 M)*
BSC-20 A527 E70S-3 A36 E7018 (a) SIRtCI1EAL S1HL DCA 1818 WPS 10046 QI-QP-16.0-5 CP-GM-7.3D A36 E7018 NO GMTUTTON DrA 2087 (1)
QI-QP-il.14-1 CT-22 1 01I
(?)
QI-QP-I I.14-3 MISFIT 10 (3)
QI-QP-i l.21-1 D E RIS QI-QP-I I.14-5 T-QT-2.13 CP-QCP-2.17 T-qcl-2.13-1 CP-qCl-2.17-1 (b) Sint DCA 20999 A36 E7018 NO ONSDRETION PIA 1TURM DCA 20854(a)
YES(a)
PMKAGS REVIEWED DCA22296(b)
YES(b)
OP-2, P@l, P-02 DrA 22193 (c) SIHL GM.TUTION DCA 22171 A36 E7018 NO SIFrlTD 10 TIS DrA 20434
~s.
O O
O
Rc. vision:
1 Psge 48 of 57 RESlE3S RDWT ISAP V.d (Cont'd)
Table 3 (Cont'd) m0TMNr DUINEERitC k'UDI!C INSPILTION FAIRICATIm/
1%SE FIIH R tt0 SED ArmIRIZAHW PIRMIRFS n u m RES M 61RUCTIm PETAL PETAL IIXFS DOCLMNIS IROCDXEES AUIMD (d) IUC WE2DS IN ITA 29771 A36 E7018 to BEAPI bTP OF ITA 22474 17A1RRf DCA 20264 (c) PIA 1RR1 ITA 14664 A36 E7018 10 STU3.
SAFH2iARD BIIG.
(f) D.C.
FG MMTIm ICA 22537 A36 E7018 to NATE (g) PfT)IFICATIm ITA 10357 A36 E7018 NO OF PIATRRf (h) IMSE P! ATE ITA 22455 A36 E7018 NO IUU kT1DS (i) S-1-STAT 1MAY ira 15684 A36 E7018 NO (DEIRUCTim PAGA2S ITA If622 REVIEWED Cfr83-1027-8903 C3-83-1057-8903
-s O
O O
Rcviefon:
1 Prg2 49 of 57 RFSt4115 RFR ET ISAP V.d (Cont'd)
Table 3 (Cont'd)
HMtMAT ENGINFIRING WEIDDE INSPFLTim FAIRICATIm/
PASE 9111R IMlSED n m 0RIZAH m PR UIURES IWXmRFS 00NSIMLTIm HETAL METAL MXIS Il00MNIS IPOCEI1FIS AlliMD Before.hre 4,1986, IWurson Service Co. was not authorized to leave trused holes. !!1storically, no trused holes or related pits welds were associated with anin frme ne+ers anf all trused holes in baseplates were pitg welded to qtalified weldirg procedures. Criteria for trused holes is being placed in the Ibbnson general repair procedure.
(1) Related requirments - WES-029 (2) Relatal requirenents - S52-01-106B (1) Relatal requirements - 232_%SS-16B D
~0!
O O
O
Revision:
1 Page 50 of 57 RESULTS REPORT ISAP V d (Cont'd)
Table 4 Procedures Reviewed in the Course of Preparing Results Report V.b Fabrication Construction Procedures CCP-22 Structural Steel Erection CP-CPM-6.9 General Piping Procedure CP-CPM-6.9G Documentation for ASME Welding and Installation Activities CP-CPM-7.3D Welding and Related Processes CP-CPM-7.3E Cable Tray and Conduit Supports CP-CPM-9.10 Component Support Installation ECP-10 Cable Tray & Hangers
()
Installation ECP-10A Cable Tray & Hangers Installation Unit II ECP-10B Cable Tray & Hangers Unit II Cable Spread Room / Frame Room 134 ECP-19 Exposed Conduit / Junction Box and Hanger Fabrication and Installation Unit II ECP-19A Exposed Conduit / Junction Box and Hanger Fabrication and Installation Unit II GRP-TUSI-001 General Repair Procedure Inspection Procedures CP-QCI-2.13-1 Inspection of Field Fabricated Miscellaneous Steel CP-QCI-2.17-1 Inspection of Installation of Miscellaneous Steel
s Revision:
1 Page 51 of 57 i
RESULTS REPORT ISAP V.d (Cont'd)
Table 4 (Cont'd)
CP-QCI-4.3-3 Exposed Conduit & Hanger Installation CP-QCI-4.3-4 Cable Tray & Hanger Installation CP-QCP-2.13 Inspection of Field Fabricated Miscellaneous and Structural Steel CP-QCP-2.17 inspection of Miscellaneous Steel Installations i
CP-CPSES-011 Visual Inspection of Weld Proceduren CP-QP-18.0 Inspection Report l
QI-QP-11.03-2 Cable Tray Hanger Inspection QI-QP-11.03-5 Cable Tray Inspection QI-QP-11.03-23A Class IE Conduit Receiving Inspection QI-QP-11.03-24 Class IE Cable Tray Raceway i
Inspections QI-QP-11.08-01 Instrument and Tubing Installation Inspection QI-QP-11.08-02 Insp. of the Fab. of j
Instrumentation Supports &
Rack Assemblies QI-QP-11.08-05 Insp. of Instrument Tubing Fabrication, Installation and Instrument Installation QI-QP-11.08-06 Inspection of Instrumentation Tubing Installation J
QI-QP-11.08-09 Insp. of Instal. of Non-Nuclear Safety Instr.
Seismic Supports
i Revision:
1 Page 52 of 57
(~'
RESULTS REPORT ISAP V.d (Cont'd)
Table 4 (Cont'd)
QI-QP-11.10-01 Inspection of Seismic Electrical Support & Restraint Systems QI-QP-11.10-01A Insp. of Class 1E Conduit Raceway Systems QI-QP-11.10-02 Cable Tray Hanger Inspection QI-QP-11.10-02A Inspection of Unit 2 Cable Tray Supports i
QI-QP-11.10-04 Inspection of Seismically Mounted Conduit Supports 4
QI-QP-11.10-07 Inspection of fabrication and Inatallation of Misc.
f Electrical Equipment and
,\\
Related Supports QI-QP-11.10-09 Cable Tray Hanger "As-Built" Inspection / Verification QI-QP-11.14-01 Insp. of Site Fabrication and Inst, of Struct. & Misc. Steel QI-QP-11.14-03 Inspection of Structural / Misc.
Steel Welding i
QI-QP-11.14-05 Insp. of Platforms Installed in Seismic Category I Structures QI-QP-11.14-12 Reverification of Seismic Electrical Equipment Mounting Details QI-QP-11.21-01 Requirements of Visual Wald Inspection QI-QP-16.00-05 Reporting of Base Metal Defects
- O w
s Rcvision:
1 Page 53 of 57 RESULTS REPORT ISAP V.d (Cont'd)
Table 4 (Cont'd')
Welding Procedures & Specifications 2323-SS-16B Structural Steel (Category 1)
BSC-12 Gas Metal Arc Groove Joints.
Carbon l
BSC-20 Shielded Metal Arc Groove &
Fillet, Carbon I
WES-029 Welding Spec. for Field i
Fabrication & Erection of Structural Steel l
WES-021 Welding Engineering Standard WPS-10045 Weld Procedure Specification WPS-10046 Wald Procedure Specification WPS-10082 Weld Procedure Specification WPS-11032 Weld Procedure Specification I
j S-52.01-106B Welding Specification for Field Fabrication and Erection j
of Structural Steel
)
l 1
i O
d
,-..,,,.a
a i
Revision:
1 Page 54 of 57 i
RESULTS REPORT ISAP V.d (Cont'd) 3 Table 5 History of Inspection and Documentation Requirements For the Repair of Mislocated Holes in Cable Tray Supports i
June 3, 1978 Procedure QI-QP-11.3-2 (Revision 0) covering the i
{
inspection of cable tray and conduit supports was issued. By this time B&R welding specification S-52.01-106B (structural steel welding per j
AWS D1.1), B&R welding standard WES-021 (repair of base metal defects) and construction procedure 7
i ECP-10 for cable tray supports had also been i
issued. None of these procedures or i
specifications directly addressed the repair of I
mislocated holes. However, both the welding i
specification and the welding standard provided i
l for the weld repair of base metal defects using the Resolution of Defects (ROD) form to authorize and document the repair.
t l
August 8, 1979 DCA-5347 (Revision 0) was issued requiring the j
weld repair of mislocated holes in cable tray l
i supports that do not meet the stated spacing criteria.
August 13, 1979 B&R specification S-52.01-106B modified to use the RPS instead of the ROD form to authorize and i
document weld repairs of base metal defects.
4 i
December 1979 Inspection procedure QI-QP-11.3-2 (Revision 9) was replrced by procedure QI-QP-11.3-24 (Revision 0).
{
Several weeks later the inspection j
responsibilities for cable tray supports were transferred to a new group. The scope of procedure QI-QP-11.3-24 was modified to cover only l
the inspection of cable tray and a new procedure, l
QI-QP-11.10-2 was issued for the inspection of cable tray supports. Revision 0 of QI-QP-11.10-2 was essentially identical to Revision 9 of QI-QP-11.3-2 which it replaced.
^
January 17, 19o0 86R Senior Project Welding Engineer issued meno IM #18507 dated 01/17/80 clarifying the
{
requirements for welding mislocated holes in cable tray supports and instrument racks.
O
+
Revision:
1 Page 55 of 57 O
RESULTS REPORT 1
ISAP V.d (Cont'd)
Table 5 (Cont'd)
November 10,' 1'980 Revision 2 of QI-QP-11.10-2 was issued which included the criteria from DCA-5347 for plug welding unused holes plus the requirement for documenting these plug welds on the constructfon operation traveler.
August 4,,1981 B&R welding specification WES-021 was replaced by WES-029.
January 14, 1983 Revision 2 of WES-029 provided specific direction for the repair of mislocated holes and stated that preparation of an RPS was not required for holes i
repaired in accordance with the specified technique.
O O
+
s 1
Revision:
1 Pags 56 of 57 RESULTS REPORT ISAP V.d (Cont'd)
Table 6
SUMMARY
OF CABLE TRAY HOLE SIZE EVALUATION Distribution of Bolt Sizes in the Sample Inspected I
Bolt Size (inches) 1/2 5/8 3/4 1
1-1/4 1-1/2 4
Anchor Bolts 1%
0%
0%
19%
77%
3%
Member Bolts 0%
67%
33%
0%
0%
0%
l Results of Hole Size Inspections i
No. of Supports Largest Hole Found i
Used Anchor Bolt Holes 213 1-11/16" Used Member Bolt Holes 133 29/32" i
Unused Holes
- 32 13/16" 4
Total 227 Percent of Supports With Roles Larger Than the Indicated Size "Best" (50% Confidence) 95% Confidence Estimate Estimate Anchor Holes Larger Than 1-11/16" 0.31%
1.32%
j Members Holes Larger Than 29/32" 0.31%
1.32%
l i
l
!O Only one of the 32 supports with unused holes was found to contain a hole larger than the allowed 3/4" size (i.e. 1/16" more than 3/4").
i i
7
,..-m t
Rcvision:
1 Page 57 of 57 RESULTS REPORT ISAP V.d (Cont'd)
FIGURE 1.
UNUSED HOLE CRITERIA FOR CABLE TRAY SUPPORTS 1.
All unused holes greater than 3/4-inch diameter shall be repaired.
2.
Unused holes which are spaced 2 inches or less (measured center to center) from a used or unused hole shall be repaired.
3.
No two holes (used or unused) shall be located in the same cross-sectional plane (see typical examples of acceptable and rejectable bolt / hole configurations).
In summary, when a used hole and an unused hole are in the same cross-sectional plane, the unused hole shall be repaired.
Conversely, when two (2) unused holes are in the same cross-sectional plane, one must be repaired. A cross-section is a section normal to the longitudinal axis of the member.
LONGITucINAL AXI$
7 FLANGES 5
5 i
a\\
CROSS SECTIONAL ALANE NCAuaL SAMALE SfayCTumAL SNapE C'anael useo 'ce enawls.
SECTION A-4 acolt:acle for any saeces xx:
o accrer - o i - m e =
. w e-A ma a i
p %~st,...f 5
n
~
2 I
f f_
f 1
f f
i l
- MwA c:
..s.
- d. - s *6 r II
)
i e
i i
- Holes or bolts are in the same cross-sectional plane.
- - Holes or bolts not in the same cross-sectional plane must also meet the distance criteria (greater than 2 inches) and hole size criteria (Jess than or equal to 3/4-inch diameter).
~"*
y-
[v COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP:
VII.a.3
Title:
Document Control REVISION 1 O
l
/
/2!'7[N I
Coordinstor /
Date
/L 7-
'/d R
ew Team Le'ader Date /
Y.
/2-f/7ll%
JohyW. Beck, Chairman CPRT-SRT Date fr
(
o,-, 1..,,
a-y gp FP f ?O O u
A
Revision:
1 Page 1 of 11
]
RESULTS REPORT ISAP VII.a.3 Document Control
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC The Comanche Peak SSER 11, Appendix P, Section 4.7, pages P-27 and P-28, describes the NRC concerns in the area of document and record control. The concerns pertaining to document control have been extracted and are presented here:
"The TRT assessment of the document control function for the
' period following July 1984 indicates that the preparation, issuance and changes to documents that specify quality requirements or prescribe activities affecting quality are adequately controlled. Documentation packages reviewed at the point of issue, and in the field where prescribed activities were being performed, were found to be complete and current.
Further, a sample of safety-related quality records stored in the permanent plant records vault (PPRV) was reviewed and found to be acceptable.
Included in the documentation packages were completed records for piping, piping supports (hangers), assembled and/or installed components, fabrication and inspection / testing data, including walkdown inspection V
check lists and the applicable N-5 data reports.
In-process and final inspection and acceptances for completed record packages appeared to have been performed to the latest revision of drawings and specifications.
j However, the history of recurring document control deficiencies prior to. July 1984 raises concern about certain aspects of the quality of construction....In procedural j
control, the TRT mechanical and piping group observed that l
uncontrolled and unauthorized procedures were used to perform cold-springing (realign piping) during its installation.
With respect to drawing control prior 'co 1984, the TRT found deficiencies that included: distribution of incomplete or obsolete drawing packages to the craft and QC personnel; inadequate drawing control; high DCC satellite error rates; and procedural non-compliance. The TRT QA/QC Group concludes l
that although many of the document control inadequacies have been corrected, the implications of past inadequacies on construction and inspection have potential generic significance which has not yet een fully analyzed by TUEC."
The NRC letter from D. G. Eisenhut to L D. Spence dated January 8, 1985 stated the following:
O
6 Rsvision:
1 Pags 2 of 11 RESULTS REPORT ISAP VII.a.3 (Cont'd)
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (Cont'd)
"The TRT found that the DCC issued a controlled copy stamp to the QC department to expedite the flow of hanger packages to the Authorized Nuclear Inspector. Methods for this kind of issuance and control of such stamps were not described in TUECs procedures."
2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT."
" Address the root cause of each finding and its generic
)
implications..."
" Address the collective significance of these deficiencies..."
" Propose an action plan..that will ensure that such problems do not occur in the futta s."
~^
3.0 BACKGROUND
Basic problems in the Document Control Program were identified and documented by TUGCO. As a result, appropriate changes were introduced into the program, and as indicated in SSER 11, an acceptable level of implementation was achieved by July 1984.
TUGC0 has, to date, performed activities to ensure that features of the physical plant affected by the CPSES QA/QC program conform to the latest design information. These activities include the following:
Design Change Verification Program - Originated in 1981 to ensure, through document review and/or hardware inspection, that all applicable design changes had been incorporated into l
the plant. The program was implemented in the electrical j
discipline and was essentially completed in late 1984. A current program is being imple'mented whereby all issued design changes will be reviewed to ensure that they have been incorporated.
i
~
l
e Rsvision:
1 Pags 3 of 11 RESULTS REPORT ISAP VII.a.3 (Cont'd)
3.0 BACKGROUND
(Cont'd) i Preparation of ASME Code Data Sheets (N5) - Performed final verification of acceptable ASME component installation or installation processes for component installation certification. This activity was performed in 1983 and 1984 for Unit 1 and is presently ongoing for Unit 2.
- Class V Hanger / Support As-Built Program - This activity was performed from 1981 to 1983 in conjunction with the i
implementation of NRC IE Bulletin 79-14, " Seismic Analysis for As-Built Safety-Related Piping Systems".
The CPRT performed the following activities which provided data to verify that the latest design information has bett incorporated into the plant features that are of interest:
ISAP III.d, "Preoperational Testing" l
- ISAP VII.c. " Construction Reinspection / Documentation Review Plan" Action Plan VII.a.3 was designed to provide reasonable assurance that past DCC problems have not resulted in adverse hardware conditious in the existing plant. This was evaluated by examining the results of other ISAPs which address hardware configuration / status and test programs results.
TUCCO has previously responded to the NRC concerning the issue of the " Controlled Copy" stamp to the QC Department. The response and subsequent correspondence with the NRC were reviewed to determine the status and possible additional actions.
~
4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 The objective of this action plan was to provide confidence that, although problems vare identified over a period of time in the implementation of the Document Control program during the construction phase of CPSES, the hardware has been installed and tested in accordance with the current design requirements. In addition, the current procedures governing the operation of the Document Control Center were reviewed O
for adequacy of control of drawings and revisions thereto.
h
f Rsvision:
1 Page 4 of 11 4
RESULTS REPORT ISAP VII.a.3 (Cont'd) 4 4.0 CPRT ACTION PLAN (Cont'd) t 4.1.2 The specific methodology is described below.
i 4.1.2.1 It was determined by the QA/QC Review Team I
Leader that CPRT Issue Specific Action Plan VII.c, " Construction Reinspection /
Documentation Review Program", would provide sufficient data to provide confidence that i
applicable design changes have been l
incorporated into the physical plant. This determination was based on the extensive i
nature of ISAP VII.c whereby a v'ery large sample of installed hardware would be i
compared to the current design information.
It was also determined that ISAP III.d, "Preoperational Testing", would provide j
pertinent information concerning the possible i
effect of document control problems on the I
prerequisite and preoperational test programs.
I l
4.1.2.2 ISAPs VII.c and III.d specified actions to be i
performed as follows:
ISAP VII.c. " Construction i
Reinspection / Documentation Review l
Plan" included a Reinspection /
1 Documentation Review cf QC-accepted I
safety-related construction work activities performed at CPSES. The implementation of this action plan
]
required that the latest design 1
information he utilized in preparing l
reinspection / documentation review i
checklists, and that the latest applicable design information, including design change authorizations (DCA) and component
)
modification cards (CMC), were 1
included in the reinspection / review package. If equipment differed from checklist requirements or if the associated documentation did not exist or was improperly completed, a
{
deviation report was initiated.
In j
accordance with the requirements of l
I l
2
\\
9 Rivision:
1 Page 5 of 11 O
RESULTS REPORT ISAP VII.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) the ISAP, deviations were evaluated for safety significance, and if required, root cause, generic implications, and appropriate corrective actions were recommended.
All deviations for each population were also evaluated for adverse trends.
These root cause and generic j
implication analyses for safety significant deficiencies and adverse trends were reviewed to compile information that might be relatable to document control concerns.
ISAP III.d. "Preoperational Tescing" actions included an investigation to determine if the problems associated with document control had an adverse effect on either prerequisite or preoperational testing.
In accordance with the requirements of the ISAP, identified deficiencies would be evaluated for root cause and' generic implications, and appropriate corrective action would be taken. Root cause and generic implication analyses would also be reviewed to compile information l
that might be relatable to document control problems.
4.1.2.3 Current procedures governing the operation of the Document Control Center were reviewed to verify that adequate controls are provided to ensure that currer.t design drawings and changes thereto are available for construction and inspection activities.
4.1.2.4 The Issue coordinator compiled and reviewed l
the results of ISAPs VII.c and III.d.
From this evaluation, and the review of the
](
current program, a determination was made for any corrective actions and/or program changes required for the remaining construction phase of' Unit 2 and the operations phase.
4
--- x-
.9 Revision!
1 Pegs 6 of 11
-i i
RESULTS REPORT ISAP VII.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Participants Roles and Responsibilities i
4.2.1 TUGC0 i
4.2.1.1 Scope l
TUGC0 assisted in identifying and locating applicable information and documentation to support the Review Team activities.
4.2.1.2 Personnel Mr. D. Snow TUCCO QC Coordinator i
4.2.2 QA/QC Review Team 4.2.2.1 Scope j
Reviewed ISAPs VII.c and III.d i
results and compile data related to
]
document control problems.
j Analyze / evaluate data for generic implications 1
1 Determine corrective actiona and recommend program changes l.
l 4.2.2.2 Personnel i
j Mr. J. Hansel QA/QC Review Team Leader l
Mr. J. Gelzer Issue Coordinator 4.3 Qualifications of Personnel 1
Participants were qualified to the specific requirements *of
{
the CPRT Program Plan.
1 I
f e
e R: vision:
1 Page 7 of 11
(~3 RESULTS REPORT d
ISAP VII.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Standards / Acceptance Criteria Programs and procedures were evaluated for adequacy against applicable portions of the CPSES FSAR and 10CFR50, Appendix B Criterion VI, including the following:
4.4.1 That procedures are established to assure that documents are available at the location where the activity will be performed prior to commencing the work.
4.4.2 That procedures are established to assure that obsolete or superseded documents are reimoved and repl3ced by applicable revisions in work areas in a timely manner.
4.4.3 A document control system is established to identify the current revision of controlled documents.
h 4.4.4 That the Results Report of Action Plans III.d -
"Preoperational Testing" and VII.c
" Construction Reinspection / Documentation Review" provide reasonable assurance that items of concerns related to document control prior to July 1984 had no adverse impact on either testing cenducted or the quality of installed hardware or if, in fact, anomalies are identified, appropriate corrective measures are indicated in the report.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RES1/LTS As stated in Section 4.0 of this report, the implementation of this ISAP consists of an evaluation of the results of the implementation of ISAPs III.d and VII.c specifically the evalaation of the results of any root cause and generic implications atialyses which were performed as a result of identified deficiencies or adverse trends. The results of this evaluation are discussed below:
I 5.1 ISAP III.d "Preoverational Testing" This ISAP was designed, in part, to determine if past problems with the operation of the DCC had resulted in adverse effects on the prerequisite or preoperational testing program activities.
j
(
\\v
- E
I j
R: vision 1
Pega 8 of 11 1
]
l RESULTS REPORT I
i 1
ISAP VII.a.3 l
(Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i As documented in the CPRT Results Report for ISAP III.d.
I Revision 1, there were no deficiencies or adverse trends l
identified as a result of its implesentation. The report also stated the following in Section 5.4.2:
4 "The CPRT evaluation provided ninety-five percent confidence that at least ninety-five percent of the design changes which could have affected the prerequisite and preoperational testing j
due to document control center problems did not adversely affect these programs."
In addition, the following is stated in Section 6.0:
)
"The results of this evaluation provide reasonable assurance that the document control problems which existed prior to 1984 j
did not adversely affect the testing program".
1
]
5.2 ISAP VII.c
" Construction Reinspection / Documentation Review Plan" l
This ISAP was designed to provide reasonable assurance that j
the safety-related plant features have been installed and 4
inspected in accordance with current design information.
As described in ISAP VII.c. the safety-related plant features 1
were divided into thirty-two (32) populations for purposes of
)
investigation and analysis. During its implementation, over 1
565,000 inspections and document reviews were performed. As a j
result, approximately 16,000 deviations were identified. From i
i the issues raised by these deviations, Construction
]
Deficiencies, adverse trends and unclassified trends have been identified that have resulted in approximately forty (40) root l
cause analyses being performed under ISAP VII.c.
l A review of the results of these root cause analyses 1
identified no case where a Construction Deficiency, an adverse trend or an unclassified trend resulted from inadequate implementation of the docueent control program through the DCC.
i J
Although the reinspection portf.on of ISAP VII.c is essentially j
complete, the final evaluation of all data is incomplete. As 4
a result, there exists a potential for an adjustment in the total number of Construction Deficiencies and trends, and
?
therefore the number of root cause analyses required.
Initial reviews of the remaining data indicate that no new issues i
i t
1 Rsvision!
1 Pass 9 of 11 RESULTS REPORT ISAP VII.a.3 (Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) involving the DCC are being raised and therefore any additional root,cause analyses would not likely identify inadequacies in the implementation of the document control program through the DCC.
5.3 Review of Current Prosras Current operation of the DCC is described in procedure DCP-3, "CPSES Document Control Prograa," Revision 19, dated March 31, 1986. Based on the review of this procedure, it is concluded that it provides adequate controls to ensure compliance with the applicable requirements of 10CFR50, Appendix B, Criterion VI and the CPSES FSAR as described in Sectf ons 4.4.1 through 4.4.3 of this report.
In order to obtain a measure of the effectiveness of the current DCC operation, the following information was obtained relative to the operation of the DCC over the past yeart During the implementation of ISAP VII.c, approximately 23,000 drawings and drawing changes were requested from
(
the DCC and/or satellites. Based on information from the QA/QC Review Team participants, it was determined that the overall error rate of documents received from the DCC was extremely low and did not affect VII.c results.
In an interview with the head of the CPSES Monitors Team, who is responsible for monitoring the performance of the DCC and Satellites, he stated that the incidence of errors in the DCC and Satellites is less than one tenth of one parcent (0.1%). A review of the Executive Summary Reports of monitoring activities for the past
. year siipports this figure.
It is therefore concluded that the controls for, and operation of, the DCC pertaining to the distribution of drawings and drawing changes is satisfactory.
5.4 Closecut of Related External Issues 5.4.1 The issue of'the alleged use of uncontrolled and unauthorized procedures for cold-springing of piping is addressed in the Results Report for ISAP V.e.
This O
report concluded, in Section 6.0, that "... no such misapplication [of a Bechtel procedure] occurred."
4 R;vicion:
1 P:go 10 of 11 s
RESULTS REPORT V($
ISAP VII.a,3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.4.2 TUGC0 responded to the issue concerning the " Controlled Copy" stamp in a letter to the NRC (TXX-4180, dated May 25, 1984) stating that control stamps were used by Brown & Root ASME QA personnel for a short period of time. The stamps were applied to drawf,gs forwarded to the Authorized Nuclear Inspector (ANI) ;or review.
These drawings were not used for construction. TUGC0 determined that this activity had no safety significance or generic implications. No subsequent NRC correspondence (except SSER 11) was noted which applied to this issue.
The NRC concluded in SSER 11 that " Issuance of the stamps to QC had no significant safety implication in the erection, fabrication, or construction of safety-related systems, components, and structures, and the TRT found no evidence that there was a loss of hanger drawing control as a result of the QC
/)N department's stamping of the hanger drawings of
\\--
concern."
5.5 Evaluation of Findings 5.5.1 Because ISAP III.d identified no safety-significant deficiencies or adverse trends, no root cause analyses were required. Therefore no further actions are required in relation to ISAP III.d results.
5.5.2 ISAP VII.c identified safety-significant deficiencies, adverse trends and unclassified trends. Over 40 root cause analyses were performed.
Because no root cause or contributing cause was attributable to document control inadequacies, no further actions are required in relation to ISAP VII.c results.
l
'5.5.3 As a result of the review of the results of ISAPs III.d and VII.c. and the review of the current program, it is determined that no remedial actions are required.
5.5.4 The final evaluation of ISAP VII.c data as well as TSAPs other than III.d and VII.c may identify safety-significant deficiencies and/or adverse trends whose root cause is identified as inadequacy in the 3
document control program. Should this occur, a
)
reassesrment of the results of this ISAP will be
"~'
conducted by the QA/QC Review Team's Collective Evaluation Group af ter the resuler af other ISAPs are issued.
y'
e R vicion:
1 Paga 11 of 11 RESULTS REPORT ISAP VII.a.3 (Cont'd)
6.0 CONCLUSION
S The QA/QC Review Team believes that the actions taken through ISAPs III.d and VII.c respond to the TRT concern contained in SSER-11 that "
iniplications of past [ document contro1} inadequacies on construction and inspection have potential generic significance which has not been fully analyzed by TUEC."
It is concluded, based on the findings of ISAPs VII.c and III.d, that there is reasonable assurance that currently there are no adverse hardware conditions in the plant resulting from past problems with the operation of the DCC.
However, because of on-going work, modifications, and the several verification activities that have been performed throughout the plant life, no statement can be made as to whether or not adverse hardware conditions had ever been caused by DCC problems.
7.0 ONGOING ACTIVITIES No ongoing activities have resulted from implementation of this Action Plan.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE TUTURE No actions to preclude occurrence in the future are required.
O
+
-