ML20214J690

Forwards Comanche Peak Response Team Issue-Specific Action Plan III.a.5, Preoperational Test Review & Approval of Results & Results Repts I.a.4,I.a.5 & VII.a.5.Related Correspondence

ML20214J690
Person / Time
Site:	Comanche Peak
Issue date:	08/11/1986
From:	Wooldridge R, Woolridge 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-#386-312 OL, NUDOCS 8608150133
Download: ML20214J690 (49)

Text

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CECE Lia J. SRUNER August 11,1986 JOE A. DavtS ERIC M. PETERSON WALTER w W HITE 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 Elizabeth B. Johnson Dr. Walter H. Jordan Oak Ridge National Laboratory Administrative Judge P. O. Box X, Building 3500 881 West Outer Drive Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al

! (Comanche Peak Steam Electric Station,

Units 1 & 2); Docket Nos. 50-445 and 50 446 0/

Dear Administrative,

Judges:

1 Applicants have this date delivered to Mr. Vincent S. Noonan the Comanche Paak Response Team Issue-Specific Action Plan (ISAP) III.a.5 "Preoperational Test Review and Approval of Results" developed by the Comanche Peak Response Team and the SRT approved Results Reports listed below:

I.a.4 Agreement Between Drawings and Field Terminations, Revision 2 I.a.5 NCR's on Vendor Installed Amp Terminal Lugs, Revision i VII.a.5 Periodic Review of QA Program, Revision 1 As a part of our continuing effort to keep the Board apprised of matters which relate to the licensing of Comanche Peak, we are enclosing four copies of each ISAP and Results Report. This material is not being offered into evidence at this time, and is provided for information only.

Res fully, O

06081 $ h $IO PDR P ,

G Robert A. Wooldricjge l RAW /kiw Enclosures cc: Service List 8

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7 CPRT-598 Log # TXX-4952 i File # 10068 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 400 NORTH OLIVE STREET. L.B. SI . DALLAS, TEXA5 75201 August 11, 1986 Uns"ASUn'A Director of Nuclear Reactor Regulation Attn: Mr. Vince S. Noonan, Director Coman*che Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 SUBMITTAL OF ISSUE-SPECIFIC ACTION PLAN OF THE COMANCHE PEAK RESPONSE TEAM (CPRT) PROGRAM PLAN

Dear Mr. Noonan:

In our May 13, 1986 letter TXX-4797 it was indicated that Revision 3 of the CPRT Program Plan was complete. However, an additional ISAP has been developed by the CPRT to further address ASLB concerns as described in Board Memorandum dated December 21, 1984.

As such, transmitted herewith is Comanche Peak Response Team Issue-Specific Action Plan (ISAP) III.a.5 "Preoperational Test Review and Approval of Results" (Revision 0). ISAP III.a.5 should be placed behind the " Appendix C, Testing" tab in Revision 3 of the Program Plan. Also enclosed is a replacement page for the list of Testing ISAPs. This page should be placed immediately behind the " Appendix C, Testing" tab in the Revision 3 Program Plan. .

Should you have any questions please do not hesitate to call either John Beck or myself.

Very truly yours, W. G. Counsil By: b F d . S J(/W. Beck Vice President WGC/arh l Enclosures A DIVISION OF TEXAS U1TLETIES ELECTRIC COMPANY

6 Ok . l 4

l Testing ISAPs III.a.1 Hot Functional Testing (HFT) Data Packages III.a.2 JTG Approval of Test Data III.a.3 Technical Specification For Deferred Tests III.a.4 Traceability of Test Equipment III.a.5 Preoperational Test Review and Approval of Results III.b Conduct of the CILRT III.c Prerequisite Testing III.d Preoperational Testing IV. Reserved for Protection Coatings, however, SSER-9 declassified protective coatings and negated the need for a protective coatings ISAP. Paint quality concerns are being addressed under the Quality of Construction Program.

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( COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.a.5

Title:

Preoperational Test Review and Approval of Results Revision No. 0 Original Description Issue Prepared and g i Recommended by: . 'pk Review Team -

t Leader d l

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Approved by:

Senior Review Team b d.

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Page 1 of 4 O

ISAP III.a.5 Preoperational Test Review and Approval of Results

1.0 DESCRIPTION

OF ISSUE In a Memorandum , dated December 21, 1984, the Atomic Safety and Licensing Board (ASLB) described the issue as follows:

Testimony indicates that system performance did not meet the acceptance criteria, both because of obvious calculational errors and because the acceptance criteria were exceeded.

2.0 ACTION IDENTIFIED BY THE ASLB The information required by the ASLB is as follows:

We need to know how this occurred and to be assured concerning the frequency of similar errors in startup test results.

3.0 BACKGROUND

, The preoperational test program is conducted according to written procedures approved by a Joint Test Group (JTG), whose membership reflects the major CPSES design, testing, and operating organizations. The preoperational tests are conducted by the Startup organization according to JTG approved procedures. The System Test Engineer responsible for performing a particular test also prepares the final test data package for subsequent review and approval by the JTG.

The ASLB's Memorandum resulted from TUEC's presentation of a JTG approved preoperational test data package, 1-CP-PT-02-02, "118 VAC RPS Inverters," as evidence in the companion ASLB hearings. The test data package contained recorded test data which aid not meet the stated acceptance criteria. The function of this system is to provide an uninterruptable power supply to the Reactor Protection System instrumentation. The first preoperational test of this system was approved by the JTG in January, 1983. During subsequent operation of the system, ferroresonant transformers, a major component of the system, exhibited in-service failures.

Investigation of the failures led to filing a notification to the ASLBP No. 79-430-06 OL, Memorandum (Standards Applicable to Pending Motions)

i 1 Ravicion: 0 i Pags 2 of 4 ISAP III.a.5 (Cont'd)

3.0 BACKGROUND

(Cont'd) i NRC pursuant *o 10CFR50.55(e). The transformers were replaced. l The retest requirement specified for the system was total reperformance of the preoperational test. During preparations for j

^

performing the retest, the responsible System Test Engineer, who did not perform the first test, identified the unacceptable data in the original tear data package. Subsequently, the original test data package was oresented as evidence in the companion ASLB hearing in order to impeach testimony given by others.

4.0 CPRT ACTION PLAN The objective of thia Action Plan is two fold: a) to identify the factors which contrituted to the approval of test data which did not meet specifications; and b) to provide reasonable assurance there are no similar errors in other test data packages.

4.1 Scope and Methodolog The scope of the evaluation includes all 205 preoperational test data packages that have been approved by the JTG to date.

There remain several tests associated with the Unit 1 test program which have not yet been performed. JTG approval of these test data packages is not anticipated before this evaluation is complete.

The evaluation will be conducted by examining the circumstances which led to the approval of test results which did not meet specifications; and reviewing the remaining test data packages to determine the frequency of similar errors.

4.1.1 1-CP-PT-02-02, "118 VAC RPS Inverters," Revision 0.

The original test data package will be reviewed to determine the reason (s) for approval of test results which did not meet the stated acceptance criteria.

4.1.2 Remaining Test Data Packages Test data in the 205 test data packages will be examined to determine if there are any other instances where test data does not meet the stated acceptance criteria. The review will be conducted through a sampling program as discussed in Section 4.5.

l l._. ____ _ . _ _ _ _ _ . - _ _ _ _ __ __ . - _ _ _ - _ _ - - . _ _ _. . _ _ - -

1-R1 vision: 0 I Page 3 of 4 O ISAP III.a.5

'(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 Corrective Action Identified discrepancies, if any, will be processed according to Appendix E, "CPRT Procedure for the Classification and Evaluation of Specific Design or Construction Discrepancies Identified by CPRT."

Corrective action, if required, will be implemented according to Appendix H "CPRT Procedure for the Development, Approval, and Confirmation of Implementation of Corrective Action."

4.2 Procedures .

A checklist will be developed to guide and document the CPRT review. In any cases where the acceptance criteria of Section 4.6 are not met, the CPSES Startup Group will issue a Test Deficiency Report according to CP-SAP-16, " Test Deficiency and Non-conformance Reporting," in order to provide a full JTG review. In such cases, the CPRT will expand the review according to Section 4.7, " Decision Criteria."

4.3 Participants Roles and Responsibilities 4.3.1 CPSES Startup Group The Startup organization will provide support personnel to augment the CPRT third-party review.

4.3.2 CPRT Third-Party The CPRT Testing Program P.eview Team Leader is responsible for the actf.ons identified in Section 4.1.

4.4 Qualifications of Personnel, 4.4.1 CPSES Startup Croup Startup personnel assigned to augment the CPRT third-party staff will be qualified to a minimum of Level II in accordance with CP-SAP-19, " Training /

Qualification Requirements for Startup Personnel."

4.4.2 CPRT Third-Party The CPRT Testing Programs Review Team Leader meets the qualifications as described in the CPRT Program Plan and assures that other personnel are qualified.

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R: vision: 0 i Page 4 of 4 O ISAP III.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Sampling Program Each test data package is the end result of the sum of the preoperational testing activities. The CPRT has deemed that a random sample of acceptance criteria in the test data packages would be an appropriate method of investigation for potential programmatic deficiencies of the nature described herein.

The acceptance criteria population will be sampled according to the guidelines contained in Appendix D of the CPRT Program Plan, "CPRT Sampling Policy, Application and Guidelines." The recorded test results will be reviewed to ensure that stated acceptance criteria are met. The minimum sample size will be sixty. The total population of acceptance criteria contained in the 205 Test Data Packages is 3,391.

4.6 Acceptance Criteria The results of testing or retesting meet the stated acceptance O criteria and have been approved by the JTG, or if not, the JTG had approved the required retest on a Test Deficiency Report.

4.7 Decision Criteria i

If the acceptance criterion noted above is not met, the evaluation will be expanded according to Appendix D, "CPRT Sampling Policy, Applications and Guidelines."

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q CPRT-597 Log # TXX-4953 Y File # 10068  ;

TEXAS UTILITIES GENERATING COMPANY SKYW AY TOWER . 400 NORTH OLIVE STREET. L.B. S 8 . DALLAS. TEXAS 7530 8 August 11, 1986 052?k??.Y.1 !,

Director of Nuclear Reactor Regulation Attn: Vince S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

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

Dear Mr. Noonan:

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

I.a.4 Agreement Between Drawings and Field Terminations, Revision 2 I.a.5 NCR's on Vendor Installed Amp Terminal Lugs, Revision 1 VII.a.5 Periodic Review of QA Program, Revision 1 We shall issue future Results Reports on a periodic basis as they are approved by the CPRT Senior Rgview Team.

Very truly yours, W. G. Counsil By: h d. b>_

J. S. Beck Vice President WGC/arh Enclosures A DEVESION OF TEXAS EJTELETIES ELECTREC COMPANY

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CPRT-596 Log # TUS-4903 File # 10068 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 400 NORTM OLIVE WTREET, L.B. 4 8 . DALLAS. TEXAS 78908 August 11, 1986

" " T.US*

MEMORANDUM TO: Mr. W. G. Counsil

SUBJECT:

CPRT RESULTS REPORTS We transmit herewith the SRT approved Results Reports listed below. The files which contain supporting documentation for the Results Reports have been reproduced and are available in the Dallas file room for public inspection.

I.a.4 Agreement Between Drawings and Field Terminations, Revision 2 I.a.5 NCR's on Vendor Installed Amp Terminal Lugs, Revision 1 VII.a.5 Periodic Review of QA Program, Revision 1 John W. Beck l

Chairman,

! CPRT Senior Review Team JWB:arh Enclosures cc: CPRT File l

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V COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.a.4

Title:

Agreement Between Drawings and Field Terminations REVISION 2 l

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Issue Coordinator Date

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John F. Beck. Chairsan CPRT-SRT 7/z+/r s Date O

Ravision: 2 Page 1 of 16 (n)

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RESULTS REPORT ISAP I.a.4 Agreement Between Drawings and Field Terminations

1.0 DESCRIPTION

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

"...the TRT selected 380 cables, involving 1600 individual terminations, and inspected them in detail with respect to drawing requirements. This inspection revealed that six cables (five of which are safety-related) were not terminated in accordance with current drawings. These six cables are:

E9139880 in panel CP1-ECPRCB-14*

E9110040 in panel CP1-ECPRTC-16 E9118262 in panel CP1-ECPRTC-16, NK139853 in panel CP1-ECPRCB-02 (non-safety),

EG104796 in panel CP1-ECPRTC-27, and EG021856 in panel CPX-ECPRCV-01."

2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Item Number 6 (c), Page J-31)

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

Reinspect all safety-related and associated terminations in the j control room and in the termination cabinets in the cable spreading

room to verify that their locations are in accordance with all 4

current design documents. Should the results of this reinspection reveal an unacceptable level of nonconformance to design documents, the scope bf this reinspection effort shall be expanded to include all safety-related and associated terminations at Comanche Peak l Steen Electric Station (CPSES) .

3.0 BACKGROUND

The specific cables identified above have been re-inspected and the "as-built" configurations reviewed by TUGC0 Nuclear Engineering (TNE). The engineering review has considered design changes and temporary modifications authorized prior to the TRT identification.

The results of this review are as follows:

One cable (E9139880) was terminated correctly, but the color-code table on the drawing had not been correctly reflected in the conductor termination details. This drawing was corrected, and

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• The TRT notified TUEC that the panel identified as CP1-ECPRCB-14 should be CP1-ECPRCB-04.

Rsvision: 2 Page 2 of 16 m

I I RESULTS REPORT

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ISAP I.a.4 (Cont'd)

3.0 BACKGROUND

(Cont'd) all other drawings with the same type of cable were checked to ensure that this condition does not exist elsewhere. No errors were found.

One cable (E9110040) was found to be properly connected in accordance with the document revision in effect at the time the termination was made. However, a subsequent drawing revision changed the color code of the conductor for no apparent reason.

This drawing error was detected and corrected prior to the September 18, 1984, letter from the NRC to TUGCO.

One cable (E9118262) contained a drafting error at the time of the TRT inspection, (two green conductors shown). The cable was functionally correct as landed. The drawing error has been

. corrected.

l One cable (EG104796), a two conductor cable, was found to have wires interchanged on the terminal points. This connection has no polarity requirement. Thus, the interchange of wires had no affect on the operability of the circuit. The physical terminations have, however, been corrected to match the drawing.

One cable (EG021856) was found to be a designated " spare" per a

properly issued design change authorization (DCA) document (DCA 19948, dated March 21, 1984). However, the interconnection drawing for one end of the cable still showed the cable to be terminated.

The cable has been deleted from the current revision of the interconnection drawing.

One cable (NK139853), a non-safety cable, had the orange and yellow / orange pair of conductors designated on the drawing as

" spare", but these conductors were left terminated. However, the corresponding vendor-side conductors had been removed from the ,

terminal blocks. The subject conductors have subsequently also been removed from the terminal blocks.

In summary, all of the cables identified by TRT were found to be functionally correct as landed. The causes of the discrepancies identified by the TRT are as follows:

E9139880 Drawing error E9110040 Drawing error l

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• Page 3 of 16

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RESULTS REPORT ISAP I.a.4 I

(Cont'd)

3.0 BACKGROUND

(Cont'd) I l

E6118262 Drawing error EG104796 Interchanged conductors in a circuit with no polarity requirements EG021856 Interconnection drawing not revised to incorporate a DCA i NK139853 Spare conductors terminated (non-safety) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology

The objective of this action plan was to assure that the i safety-related and associated cable terminations in the

control room and cable spreading room are in accordance with current design documents. To achieve this objective, a i

program to inspect terminations was implemented.

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4.1.1 Inspection Program l

An inspection program employing random sampling was initiated which enabled a determination to be made with reasonable assurance of whether the essential (i.e.,

' safety-related) Class IE conductors in the control room and cable spreading room that are in circuits that l interface with the Alternate Shutdown Panel were terminated in accordance with the applicable drawings.

A sample inspection was considered to be a reasonable

. approach for the following reasons:

1) No programmatic deficiencies had been identified in this population to date.

2) The population was homogeneous with respect to the attribute of agreement with drawings.

4.1.1.1 Population Identification The first step in the sampling program was to identify the population of all essential Class IE terminations in the control room and cable spreading room that are in circuits f

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's t RESULTS REPORT l ISAP I.a.4 (Cont'd) 1 4.0 CPRT ACTION PLAN (Cont'd)  !

I which interface with the /.lternate Shutdown Panel in Unit 1. This population of " safe ,

shutdown" terminations was taken from over '

14,000 Class IE terminations in these two rooms.

The " safe shutdown" terminations were chosen as a sub-group of the population of all Class IE terminations due to their crucial role in plant safety. Since there are no product or process differences between this sub-group and the remainder of the Class IE terminations, this approach allowed for an investigation that focused on safety while still attaining an engineering assessment of l the quality of the larger population.

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4.1.1.2 Randon Sampling The sampling plan was designed in accordance with the guidelines of Appendix D, to test for reasonable assurance that programmatic deficiencies do not exist in the population.

This plan employed a 95/1 screen, which was significantly more conservative than the 95/5 screen which was used in the majority of the ISAPs in which a sampling program was employed. The decision to enforce this higher standard (which increases sample sizes by approximately a factor of five) was made by the Electrical Review Team Leader (M. B.

Jones, Jr.).

Based on the preliminary determination of a population size of 3812, the minimum sample size according to Appendix D was 300 with a rejection number of zero (i.e., the critical region was one or more deficiencies found in the sample). If one (1) deficiency had been found, a root cause evaluation of the j

deficiency would have been performed, and a sample expansion in accordance with t Appendix D undertaken.

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-( RESULTS REPORT ISA? I.a.4 (Cont'd) i 4.0 CPRT ACTION PLAN (Cont'd)

If the number of deficiencies discovered in the original sample had been two (2) or more, or a programmatic root cause had been identified, then a 100% reinspection of all essential and associated terminations in the control room and cable spreading room of Unit I would have been performed.

4.1.2 Use of Results If the CPRT inspection program had identified any deficiencies, then a root cause and generic implications evaluation would have been performed, and appropriate corrective action determined.

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 TUGC0 Comanche Peak Project 4.2.1.1 Assisted the Review Team Leader in identifying the essential Class 1E terminations which interface with the Alternate Shutdown Panel.

4.2.1.2 Prepared sample inspection list using input provided by the third-party statistics adviser.

4.2.1.3 Processed NCRs, if any, generated as a result of this action plan.

4.2.1.4 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed sampling plan, inspection procedure, NCRs (if any) and inspection reports.

4.2.2.2 Evaluated inspection results and specified additional inspections, if required.

Rsvision: 2 Page 6 of 16 RESULTS REPORT

• (C ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.3 Performed toot cause, generic implications and safety significance evaluations, if ,

required.

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. J. R. Pearson Issua Coordinator Mr. H. B. Jones, Jr. Third-Party Adviser ,

k, s Mr. E. P. Stroupe Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Prepared procedure for inspecting terminations. ,

4.2.3.2 Inspected terminations for compliance vi~.h

! acceptance criteria.

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! 4.2.3.3 Personnel l

l Mr. J. L. Hansel Review Team Leader -

QA/QC 4.2.4 Third-Party Statistics Adviser 4.2.4.1 Provided input to the sampling plan.

4.2.4.2 Personnel Dr. F. A. Webster Statistics Adviser l

.w't.

Ravision: 2 e Page 7 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) <

4.0 CPRT ACTION PLAN (Cont'd) 4.3 Qualifications of Personnel O Where tests or 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 QFaality 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.

Other participants were qualified to the requirements of the

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

4.4 Procedures 4.4.1 Instruction QI-001, " Procedure for Class IE Cable

. Terminations Inspection - CPRT Action Item I.a.4".

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4.5 Acceptance Criteria i

4.5.1 Inspections The acceptance criterion for the termination inspection was that either:

l The termination was physically in agreement with the drawing (a conductor of a larger size than that shown on the drawing was also

( acceptable), or The termination was not in agreement with the drawing but was functionally correct (e.g.,

! connected to an ele:trically conunon point, or l wires reversed in circuits with no polarity

!% requirements).

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( RESULTS REPORT V ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.6 Decision Criteria If any terminations had not bean acceptable per Section 4.5.1, further investigations would have been performed including either sample expansion in accordance with Appendix D or a 100% reinspection. As discussed in Section 5, no further investigations were necessary.

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summary of Implementation The actions carried out under this ISAP consisted of a sample inspection of " safe shutdown" terminations, analysis of the i results of that inspection and a further investigation of the specific NRC-TRT findings.

, ( The inspection program was performed using the methodology specified in Section 4.1. No deviations from the acceptance l

j criteria of Section 4.5 were found. Two minor errors were l discovered, which did not affect the adequacy of the terminations. The identification of additional population members necessitated an additional sample inspection, which was also completed without finding any deviations from the acceptance criteria. The results of the entire inspection program are presented in Section 5.2.

For the purpcses of this ISAP, the population of terminations consisted of all conductors (including spares) that were in cables that contained " safe shutdown" circuits. Spare conductors were included because some of the original TRT findings involved spare conductors, and because of the I possibility of functional deficiencies that involve spare conductors. As discussed in Section 5.2.1, sufficient samples were drawn to ensure that at least 300 functioning conductors were inspected.

The results of the further investigation into the specific NRC-TRT findings are presented in Section 5.3.

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( RESULTS REPORT ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)  !

l 5.2 Results of the CPRT Inspection Program o j 5.2.1 Original Population and Inspection Results I Initially there were 3,812 terminations in the control room and cable spreading room identified as being in Unit 1 essential Class IE circuits which interface with the Alternate Shutdown Panel. The population was identified by drawing review.

Though the initial minimum sample size was to be 300, a list of 383* randomly-selected terminations from the l population was created. This list was generated in I accordance with the guidelines in Appendix D to the

, CPRT Program Plan. The extra 83 terminations in the l l list were included to cover duplicate numbers (inherent l in the random selection process), physically-inaccessible terminations (i.e., spare conductors

/ located in wireways that were not disassembled for this inspection), or any unforeseen problems that might later have required additional terminations to be inspected, and to provide for at least 300 functioning conductors in the sample.

This list of 383 terminations vielded 347 valid samples.** (thus still in excess of the 300 required to meat the 95/1 screen if no deficiencies were found).

The CPRT inspection of these 347 terminations uncovered

[

one (1) drawing error and one (1) cable-tagging error.

Both errors were judged to be minor, and neither violated the acceptance criteria of Section 4.5. These

! two errors are discussed in detail in Section 5.2.2.

5.2.2 Discission of Specific Findings As noted in Section 5.2.1, two errors were found during the inspection of the terminations. Neither error constitutes a deviation from the acceptance criteria of Section 4.5, since in each case the conductor involved was terminated correctly. Those errors are discussed below.

• 350 in an initial list plus 33 in a supplemental list.

• • The term " valid samples" refers to randomly-selected terminations which were found to be accessible and were reinspected. In this case the 347 valid samples consisted of 309 functioning conductors and 38 spare conductors.

Revision: 2

Page 10 of 16 I

t i RESULTS REEORT

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- '] ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.2.1 Drawing Error i

The CPRT inspections revealed a cable number drawing error. On drawing 2323-El-0172-17 cable EG120248 was shown as "EG 20248".

Since all cable numbers have six digits, a five-digit number would have been recognized as a drawing error by maintenance or operations personnel who would have been using the drawing. The proper number could then have been determined by a drawing review of this and other related drawings. (It is also noted that the subject cable was in Unit 1, and cable numbers beginning with "2" are assigned to Unit 2 cables, a convention well-known to maintenance and operations personnel.) A drawing error of this type would not have an adverse impact on the (s,,\,1 adequacy of safety-related terminations, since it did not lead to an incorrect t

termination. The specific drawing has been l reissued with the number corrected.

5.2.2.2 Cable-tagging Error The CPRT inspections also revealed an error l

• in the prefix of a field-applied cable identification number (cable EG145725 was tagged as "EC145725"). "C" is not a valid l

character for the prefix of a cable number.

As such, this tag number would be recognized as an error in the sleeve identification.

Also, the six-digit number alone provides unique identification of the cable. An error of this type does not violate the acceptance l criteria of Section 4.5 and would not have an

[

adverse impact on the adequacy of

! safety-related terminations, since it did not lead to an incorrect termination. The specific tag has been corrected.

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Page 11 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.3 Population Changes and Additional Inspection Results As part of the CPRT overview of activities performed for this action plan, two types of anomalies in the CPRT sample identification process were uncovered. The first type consisted of errors in the process of

" mapping" random digits to the correct terminations to be inspected. These errors were due to a tedious manual method for performing this work, which was easily subject to human error. The entire mapping process has subsequently been checked by third-party personnel. Each incorrectly-mapped selection was inspected and found to be functionally correct.

Additionally, the correct selections were subsequently inspected and found to be functionally correct. The final count of 347 valid samples includes only the correctly-mapped selections.

() The second anomaly was in the determination of the total population (originally 3,812). A review by I third-party personnel uncovered an additional 105 terminations that were not included in the original population. These 105 omissions were due to: (1) l incorrect count of conductors within some cables; and (2) entire cables missing from the population list.

t

• If the entire population of 3,917 terminations had been identified originally, the required sample size per Appendix D would still have been 300. However, due to the actual sequence of events, none of the additional 105 terminations could have been selected for inspection. Therefore, CPRT instituted an additional inspection program, which consisted of a random sample being drawn from the additional terminations. The sample size was chosen to be in equai proportion to the additional population as the original sample size was to the original population. This approach restored an original premise of the sampling approach - that each population item had an equal chance of being selected for inspection. The additional sample size was thus calculated to be nine (9).

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'(\ RESULTS REPORT

\'

ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The 9 terminations were selected at random from the population of 105 in accordance with the method specified in Appendix D. These 9* terminations were inspected in accordance with the action plan l

requirements and no deviations were found.

5.2.4 Other Findings During the CPRT inspections, it was noted that two conductors had a low chromatic blue color. The inspection reports noted the color as " greenish-grey and as such the color code is indeterminate". This finding was investigated by a third-party consultant and the Electrical Review Team Leader (RTL). It was determined that the blue conductor would not have been confused with any other conductor.

O,'

s__ The subject conductors were terminated correctly, and the Electrical RTL considers that the conductors are sufficiently discernible from one another to ensure that other cables of this type will not be incorrectly terminated due to the low chromatic purity of their conductors.

i 5.3 Further Investigation of the NRC-TRT Findings The results of a review by TNE of the six (6) cables, which had been identified by NRC-TRT as not being terminated in accordance with current drawings, are presented in Section 3.0. A further review of these cables by CPRT was performed during implementation of this action plan.

A discussion of the review for each of the 6 cables follows:

5.3.1 Cable E6139880 This cable was terminated correctly, but the color-code table on the drawing had not been correctly reflected in the termination details. This multi-conductor cable was supplied with a different color code than shown on the design documents. This drawing has been corrected,

and other drawings, which had this type of cable and color-code table, were checked by CPRT to ensure that

- they had also been corrected. No errors were found.

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• 9 functioning conductors and no spare conductors.

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(Q t RESULTS REPORT ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.2 Cable E0110040 The drawing and termination were in agreement at the time the termination was made. However, a subsequent drawing revision mistakenly changed the color code of the conductor. The drawing has been corrected. This was an isolated drafting error, and did not adversely impact the adequacy of the termination.

5.3.3 Cable E6118262 This cable was properly connected in accordance with the document in effect at the time the termination was made. However, the drawing contained a drafting error at the time of the TRT inspection, i.e., two green conductors were shown for this cable. The drawing error has been corrected. This is an isolated drafting

[( ,, error, and did not adversely impact the adequacy of the termination.

! 5.3.4 Cable EG104796 This two-conductor cable was found to have its conductors reversed at the terminal block. The specific circuit had no p'olarity requirement and thus the reversal did not have any functional impact on the

' circuit operation. The physical terminations have been corrected to match the drawing.

5.3.5 Cable EG021856 This cable was found to be a designated " spare" per a

. properly issued design change document (DCA 19948, dated March 21, 1984). However, the interconnection drawing for Panel CPX-ECPRCV-01 still showed the cable to be terminated. The cable has subsequently been deleted from the current revision of the interconnection drawing and is not terminated. There is no potentially adverse impact on the adequacy of the termination, since the DCA had been properly used in determinating the cable, and the cable was not terminated at the time of the NRC-TRT inspection.

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f \ RESULTS REPORT V ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Since the cause of this finding appeared to be a delay in updating the interconnection drawing to reflect a DCA, the Electrical RTL requested a third-party review of the drawing update process. This review indicated that delays had been caused by the volume of changes and by priority having been given to activities necessary to support the Unit I start-up effort. The review also found, however, that an effort had been initiated by TUGC0 in September of 1984 to significantly reduce the volume of open design change documents.

5.3.6 Cable NK139853 The drawing for this non-safety cable had the orange and yellow-orange pair of conductors designated as

" spare", but the conductors were left terminated.

However, the corresponding vendor-side conductors had

> correctly been lifted from the terminal blocks and thus there was no functional deviation. The subject spare 4

conductors have subsequently also been lifted from the terminal blocks.

< 5.4 Root Cause and Generic Implications Since the activities carried out during the implementation of this action plan did not reveal any deficiencies, neither a l root cause nor a generic implications evaluation is necessary.

5.5 Discussion of Related CPRT Activities ISAP I.a.2, " Inspection Reports on Butt Splices," includes the inspection of all AMP preinsulated environmentally-sealed butt splices in safety-related circuits in the control room and cable spreading room of Unit 1. A necissary step in identifying the location of these butt splices is to trace conductors from terminal points to butt splices (and vice-versa). While not an attribute of the ISAP I.a.2 inspection procedure, the correctness of these terminations is verified by this process. In inspecting over 500 conductors with butt splices, no functionally-incorrect terminations were discoversd. One cable (A6130852) was noted to have two conductors reversed at the terminal points. As in the case of the conductor reversal discovered by NRC-TRT, these conductors l were in a single circuit with no polarity requirement, and

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Page 15 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

thus were functionally correct. These conductors, however, have been reterminated to match the drawing. The details of all findings discovered during implementation of ISAP I.a.2 i and other ISAPs will be presented in either the Results Report or the working files for those ISAPs.

ISAP VII.c, " Construction Reinspection / Document Review Program," will include an inspection of 60-120 cables (including at least 60 in circuits that are important to safety). One of the inspection attributes is the correctness of terminations, and thus all conductors in each of these cables will be checked to ensure that they are correctly terminated. The results of this inspection will be included ir. the results report for ISAP VII.c.

5.6 Out-of Scope Findings i

l During the sample inspections, the inspectors found four (4)

V white conductors terminated at points that drawing l 2323-El-0156 Revision CP-4, showed to be vacant. These conductors were not part of the sample. TNE reviewed this drawing and determined that the subject conductors had been

deleted (by drafting error) during incorporation of a DCA.

l The terminations were in accordance with the DCA and are functionally correct. The subject drawing has subsequently l

been corrected to show these terminations.

l l

6.0 CONCLUSION

S l A CPRT inspection of 356 randomly-selected " safe shutdown" l t terminations found all to be functionally in accordance with the L applicable design documents. Further, of the six cases identified i

by NRC-TRT involving cables not being terminated in accordance with l drawing requirements, none was found to be in functional disagreement with design requirements. It is noted that the j NRC-TRT inspection included 1600 terminations consisting of both

safety-related and non-safety-related cables. Functional correctness of an additional 500-600 terminations was assured as a necessary step in completing Action Plan I.a.2 involving butt-splice inspections. Inspection of the terminations of all conductors in 60-120 cables is being performed by CPRT as part of the Quality of Construction program (specifically within Action l Plan VII.c). This inspection is not limited to only the " safe shutdown" terminations.

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(\ RESULTS REPORT ISAP I.a.4 (Cont'd)

6.0 CONCLUSION

S (Cont'd)

The rigorous sample inspection program performed under this Action Plan, together with the added screens provided by the related inspections and tests discussed herein, provide reasonable assurance that there are no undetected safety-significant or programmatic deficiencies that involve correctness of safety-related electrical terminations.

The small number of anomalies, none of which adversely affected the adequacy of safety-related terminations, is within the bounds to be expected, given the number of terminations reviewed.

7.0 ONGOING ACTIVITIES l

There are no activities still ongoing with respect to CPRT effort for this action plan. Related inspections will be reported in the Results Report for ISAP VII.c, " Construction Reinspection /

Documentation Review Plan."

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8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Since no programmatic deficiencies were found, there are no corrective actions required.

l l %s l

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COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.a.5

Title:

NCRs on Vendor Installed Amp Terminal Lugs REVISION 1 rc saue Coordinator 7 N sc "

Date 1,4 1.)t s A . 7h4 Arc l '

view T p Leader Da t e'

% w.fl.a.

Johlf W. Beck, Chairman CPRT-SRT 7/z4la Date O

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/ RESULTS REPORT s_ ' i ISAP I.a.5 NCRs On Vendor Installed AMP Terminal Lugs

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-30)

" Allegation AQE-36 involved vendor-installed AMP Product Corporation (APC) terminal lugs in ITT (sic) Gould-Brown Boveri, 6.9 Kv switchgear being excessively bent in the area between the ring and the barrel. The TRT discovered 16 NCRs (E-84-01066 through E-84-01081) issued early in April 1984, which documented this condition. The TRT review of TUEC action taken regarding these NCRs revealed the following:

The NCRs described the APC lugs either as being bent in excess, of 60 degrees or twisted.

The documented record of a telephone conversation between TUEC and the representative of the lug manufacturer (reference

. letter VBR-16624) stated that lugs bent to 90 degrees one time were to be considered acceptable; that lugs bent to 120 p)

\' ' ,

degrees could be acceptable after utilizing an engineering evaluation by the end-user; and that although lugs bent to 120 degrees would not maintain their full mechanical strength, they would maintain their electrical characteristics. This acceptance criteria for field bent lugs was changed by APC due to the dispositioning of NCR E-84-00972 regarding the General Electric (GE) motor control center (MCC) thermal overload relay replacement program.

l l'

The TRT findings regarding the disposition of these NCRs were as follows:

The disposition block of the NCR form stated that many of the lugs were " determined not to pose an equipment i serviceability problem." However, there was no i reference to or evidence of an engineering evaluation.

l, as required by the lug manufacturer prior to a change

in the acceptance criteria on NCR E-84-00972.

Only the " bent" condition of the lugs was addressed by

both the vendor representative and TUEC engineering.

l Neither the mechanical strength nor the electrical characteristics were ever addressed with respect to l

, " twisted" lugs.

l The TRT determined that these NCRs were improperly dispositioned in that the full scope of the identified problem was not addressed and the "use-as-is" dispositions were not adequately justified."

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/'~ RESULTS REPORT

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ISAP I.a.5 (Cont'd) l l

2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7 Item 6.(a), Page J-31)

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

Reevaluate and redisposition all NCRs related to vendor-installed terminal lugs in ITT (sic) Gould-Brown Boveri switchgear, taking into consideration the effects of twisted as well as bent lugs, and perform and document the results of engineering analysis to justify any resulting "use-as-is" dispositions."

l

3.0 BACKGROUND

l The issue involved bending of AMP terminal lugs (also known as ring l tongue terminals). In 1981, during the process of terminating (landing) conductors it became obvious that under certain configurations it was impossible to land conductors without bending i

the AMP terminal lug. Accordingly, Brown & Root Engineering contacted AMP Special Industries, a subsidiary of AMP Incorporated, for guidance on bending of AMP terminal lugs. The response (vendor letter VBR-16624), which formed the basis for acceptance criteria at CPSES, stated that AMP terminal lugs could be bent one time to 4

60'.

I In the first quarter of 1984 when a GE thermal overload relay was I

being replaced, it was noted by TUGC0 that the AMP terminal lugs had to be bent 90' to 120' to install the relay. Because this violated the criteria for bending established in 1981, a Non-conformance Report (NCR E-84-00972) was issued. Shortly thereafter, during a scheduled TUGC0 QC inepection of ITE Gould-Brown Boveri Switchgear, it was noted that some of the I

vendor-installed AMP terminal lugs were bent in excess of 60' and/or twisted.

NCRs were issued to document the condition (NCRs E-84-01066 through E-84-01081). These are the NCRs identified by TRT as giving rise to this issue.

In responding to the NCRs, in April 1984 AMP once again was contacted and the existing situation (including the criteria established in 1981) was discussed. AMP responded that the  !

terminal lugs could be bent two (2) times to 45' or one (1) time to 90'. Further, AMP stated that bending more than 90' and up to and including 120' is acceptable if the product user evaluated the specific application by considering the length of conductor to be

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Page 3 of 9 J-I RESULTS REPORT ISAP I.a.5 (Cont'd)

3.0 BACKGROUND

(Cont'd) supported by the terminal and the susceptibility of the final installation to vibration. AMP also advised that, while a terminal l

l. lug bent more than 90* still maintained electrical characteristics, it would not maintain full mechanical strength. This information

was documented in telephone conversation record CPPA 38,241, which was provided to AMP for review.

j TUGC0 Nuclear Engineering (TNE) judged that the AMP criteria gave appropriate guidance to the concerns raised regarding bent and/or l twisted terminal lugs. In applying these criteria, TNE decided

that the terminal lugs in question would be replaced if the bending i

! was in excess of 90' or the terminal lug showed signs of fatigue i l (i.e., flaking, cracking or other physical discontinuities).

! At the time, TNE did not discuss the term " twisted" with AMP. This '

was due to TNE's evaluation that the term " bent" appropriately i described the physical configuration of the small AMP terminal lugs and that TUGC0 QC's description of " bent and twisted" connoted a situation to which the AMP criteria applied. (As it turns out, anything other than bending requires excessive force and could not

'Je done by hand. Terminal lugs described as being twisted were judged by TNE as being bent in a manner not exactly perpendicular to the axis of the terminal lugs, a condition consistent with physically landing the conductors by hand.)

1

Based on this information, the NCRs were dispositioned as follows prior to the TRT review

NCR E-84-00972 - An engineering evaluation was conducted by

! TNE as part of the NCR disposition approving bending the AMP l terminal lugs associated with the GE relay in excess of 90' l but less than 120'. (The TRT did not state any concern with this evaluation.)

NCRs E-84-01066 through 01081 - Each terminal lus in question

, had been inspected by TNE and where it had been documented that the bending had been in excess of 90' or the terminal lug showed signs of fatigue (i.e., flaking, cracking or other physical discontinuities), the terminal lug was to be replaced. The decision to replace all of the terminal lugs l bent in excess of 90' had been based on the fact that it was l not necessary for installation to bend the terminal lugs more l than 90', and replacing them would negate the need for an

engineering analysis to justify their acceptance. However,

the vast majority of the terminal lugs, including most noted i

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' I Page 4 of 9 RESULTS REPORT

\

ISAP I.a.5 I

(Cont'd)

3.0 BACKGROUND

(Cont'd) i in the NCRs to be " twisted", had been dispositioned "use-as-is". The basis for the "use-as-is" disposition had been stated in the NCRs as follows:

4 "The current Manufacturer's position is that terminals may be bent one time to 90*, and up to 120* with j' engineering evaluation. 2ngineering has reviewed the ,

following terminals in question .... It is our t

determination that these terminals do not pose an

, equipment serviceability problem and may be used as

is."

i

! Since the TNE disposition was that all terminal lugs bent greater than 90* were to be replaced, engineering evaluatior..

were not required. (Note that TUCCO QE approved the above i disposition.)

i I While it was TNE's position that the stated dispositions were i technically correct, and that the AMP criteria on bent terminal lugs encompassed the concerns regarding bent and/or i twisted terminal lugs, the TRT was concerned that the NCRs did j not clearly provide justification for the "use-as-is" disposition. To resolve its concerns, the TRT directed that

the NCRs related to the bent and/or twisted terminal lugs in I the ITE Gould-Brown Boveri switchgear be reevaluated and I redispositioned.

! 4.0 CPRT ACTION PLAN 4.1 Scope and Methodolony l

l The objective of this action plan was to reevaluate and f redisposition all NCRs related to vendor-installed terminal lugs in ITE Gould-Brown Boveri switchgear to take ints consideration twisted as well as bent terminal lugs, confirm i the acceptability of the "use-as-is" dispositions, rnd have

AMP substantiate their change in acceptance criteria.

The following tasks were implemented to achieve tais objectiver The sixteen (16) identified NCRs were redispositioned to justify the actual disposition.

A vendor analysis of the bent and tw'.sted terminal lugs was obtained.

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Page 5 of 9

/ RESULTS REPORT ISAP I.a.5 (Cont'd) i i

4.0 CPRT ACTION PLAN (Cont'd) 4.1.1 Disposition of Non-Conformances The Non-conformance Reports on bent and twisted terminal lugs (NCRs E-84-01066 thru E-84-01081) were

< redispositioned. The redispositioned NCRs more clearly state the observed condition of the terminal lugs and the engineering justification for "use-as-is". The initial disposition of these NCRs did not allow any terminal lugs which were " bent or twisted" more than 90* to remain in service.

4.1.2 Vendor Analysis AMP was requested to and did provide documented analysis to substantiate the change from a 60' bend being acceptable to a 90* bend being acceptable. This analysis included an evaluation of " twisted" terminal l ('~' lugs.

V} 4.1.3 Use of Results If the results of this Action Plan had identified deficiencies in the "use-as-is" dispositions by TNE, then a root cause and generic implications evaluation

would have been performed and appropriate corrective action determined.

4.1.4 Related Activities An evaluation of the dispositioning of NCRs including the adequacy of the technical justification is the subject of Action Plan VII.a.2, "Non-conformance and Corrective Action Systems".

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

4.2.1 TUGC0 Comanche Peak Project I

4.2.1.1 Processed NCRs identified in this action i plan.

4.2.1.2 Obtained AMP analysis of bent and twisted terminal lugs.

Revision: 1

.I Page 6 of 9 RESULTS REPORT

, ISAP I.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.2 Personnel Mr. W. I. Vogelsang TUCCO Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed ths final disposition of the NCRs.

4.2.2.2 Reviewed the AMP analysis.

4.2.2.3 Performed root cause, generic implications, .

! and safety significance evaluations, if required.

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) l

, Mr. J. J. Ma11anda Review Team Leader l Mr. J. R. Pearson Issue Coordinator l

• Mr. M. B. Jones, Jr. Third-Party Adviser Mr. E. P. Stroupe Third-Party Adviser 4.3 Qualification of Personnel Third-party participants in the implementation of this action plan met the personnel qualification 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 speciffc 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.

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RES'JLTS REPORT ISAP I.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Procedures Not applicable 4.5 Acceptance Criteria The acceptance criterion is as follows:

The NCRs must be properly dispositioned by either justifying the "use-as-is" disposition or requiring replacetnent of the terminal lugs.

4.6 Decision Criteria The decision criteria are:

4.6.1 If the justification for using terminal lugs bent up to O 90* can not be provided, they will be replaced. This was not necessary as described in Section 5.0.

4.6.2 If the justification for using twisted terminal lugs cannot be provided, they will be replaced. This was not necessary as described in Section 5.0.

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS Each of the NCRs dispositioned "use as is" for bent and twisted terminal lugs in the ITE Could-Brown Boveri switchgear was reviewed by TNE and redispositioned to provide a more complete justification for the "use as is" determination. Significantly, the TNE review reflected that no terminal lug originally dispositioned "use as is" showed signs of fatigue or was bent in excess of 90*. Accordingly, based on the vendor-provided criteria, the terminal lugs were acceptable without further analysis or rework.

AMP provided an Engineering Evaluation Report (including testing and analysis) supporting its 1984 position that bending an AMP terminal lug one time up to 90* was acceptable. This testing and analysis concluded that even with " moderate vibrations such as that set up by heavy equipment running, we feel that the testing proves that the terminations will withstand such a condition without any l detrimental affects". The ITE Gould-Brown Boveri switchgear terminations are not installed near vibrating equipment and will

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1 Page 8 of 9 f%

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RESULTS REPORT ISAP I.a'.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) experience little, if any such vibration during their lifetime.

Also, a metallurgical analysis of bent or twisted terminal lugs was performed by AMP to demonstrate that the mechanical strength of the terminal lugs was not degraded in such a way that the seismic qualification of the terminal lugs was negated.

The AMP testing and analysis also reflected that terminal lugs twisted to 45' (approximately the maximum possible twist without risking damage to the terminal lug *) were acceptable given the

" moderate" vibration described above.

The Electrical Review Team Leader (RTL) has reviewed the AMP Engineering Evaluation Report and associated metallurgical analysis and confirmed that the original qualification of the subject terminal lugs is supported by AMP for terminal lugs that are bent to 90' or twisted to 45*.

The Electrical RTL, using the redispositioned NCRs, performed an j

Q evaluation of the dispositions by a visual examination of all terminal lugs listed in the applicable NCRs written on the Unit 1 ITE Gould-Brown Boveri switchgear. All terminal lugs designated "use-as-is" were not bent more than 90' or twisted more than 45*.

However, some of the "use-as-is" terminal lugs appear to have been replaced. The new terminal lugs also meet these criteria. One terminal lug (NCR E-84-01074, terminal lug attached to terminal point PR-1) was dispositioned by TNE to be replaced. Even though this NCR has been closed by QE, the RTL has concluded that this terminal lug has not been replaced. NCR E-86-100831S was issued by TUGC0 to document this deviation. Closure of this NCR will specifically be examined by the RTL in accordance with Section 7.0 below.

Since the "use-as-is" dispositions of the referenced NCRs do not involve any discrepancies, safety significance, root cause and generic implications evaluations were not performed. However, the deviation noted above on NCR E-86-100831S has been forwarded to the QA/QC RTL in accordance with Appendix B. " Quality of Construction and QA/QC Adequacy Program Plan," to be included in the collective evaluations of that plan.

)

• The Review Team Leader (M. B. Jones, Jr.) was informed by AMP that V in preparing " twisted" specimens for testing, the maximum twist achievable without risking damage (e.g., cracking of the terminal lug's plating) was approximately 45*.

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Revision: 1 y Page 9 of 9 RESULTS REPORT ISAP I.a.5 (Cont'd)

6.0 CONCLUSION

S i In April 1984 AMP advised TNE that bending up to 90' of the subject terminal lugs was acceptable. AMP further stated that bending from 90'-120' could be acceptable subject to an end-use engineering

review. Prior to the TRT review, TNE determined that all terminal 2

lugs that were bent in excess of 90' should be replaced.

The actions performed by CPRT, augmented by AMP's testing and analysis of bent and twisted terminal lugs, showed that the original dispositioning of the NCRs at issue was technically acceptable. TNE's decisions pertaining to the appropriateness of the April 1984 AMP criteria appear validated. The NCRs have all been redispositioned to provide a clear documented basis for acceptance of the existing equipment condition.

I 7.0 ONGOING ACTIVITIES i

Additional NCRs have been written by TUGC0 on bent and twisted lugs on various equipment in Units 1 and 2. TUGC0 has identified and will review the NCRs that were written prior to February 1, 1986.

Any that have the "use-as-is" disposition will be evaluated to assure that all non-conforming conditions have been addressed and

! that required engineering justifications are adequate. CPRT will overview this activity and will issue a Supplementary Report when the overview is complete.

The deviation noced in Section 5.0 on NCR E-86-100831S was j forwarded to the QA/QC RTL in accordance with Appendix B, " Quality '

of Construction and QA/QC Adequacy Program Plan," to be included in l the collective evaluations of that plan.

i

The evaluation of'dispositioning of NCRs including the adequacy of technical justification is the subject of Action Plan VII.a.2,

! "Non-conformance and Corrective Action Systems". i

! 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE

The installation specification (2323-ES-100) has been revised to incorporate criteria for inspecting vendor furnished terminal lugs.

This revision utilized the results of AMP's testing and analysis and provides assurance that bent and twisted terminal lugs will be  !

i appropriately addressed in the future on Units 1 and 2.

6 O

COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: VII.a.5 ,

Title:

Periodic Review of QA Program REVISION 1 O

. 9 3Ifl$e Coord,inator / [/ Date Cd/L Rev w Team Leader 24, Ac Date / f Or, 4). $=2 -- 7/1tl14 Jcg t W. Beck, Chairman CPRT-SRT Date s'

O

i R3visient I Page 1 of 11 4

i RESULTS REPORT ISAP VII.a.5 l Periodic Review of QA Prograa

1.0 DESCRIPTION

OF ISSUE I

j The Comanche Peak SSER 11. Appendix P. Section 4.7, pages P-31 through P-34, describes the NRC concerns in the areas of audit and reporting. The concerns pertaining to the Periodic Review of QA j program have been extracted and are presented heret i "The TRT found that TUEC management had failed to periodically  ;

review the status and adequacy of their QA program. This was l'

{ confirmed by Region IV (IR 50-445/84-32). TUEC i representatives stated that there had been no regular l

assessments or reviews of the adequacy of the total QA prograa ,

j by upper management, as required in Criterion II of 10CFR50, l Appendix B, and as couaitted in the FSAR.

l With respect to follow-up corrective action for previous findings cited against the audit program by NRC and TUEC consultant audit / inspection teams, the TRT found TUEC's corrective action follow-up to be not fully effective. The Fred Lobbin Report (a TUIC consultant), dated February, 1982, I identified four major findingst (1) level of experience within ,l the TUGC0 QA organisation is low; i.e., commercial nuclear  !

l plant design and construction QA experience; (2) staffing for

! the audit and surveillance functions is inadequate; (3) the

!j number and scope of design and construction audits conducted l

by TUGC0 QA to date has been limited; and (4) QA management >

i has not defined clearly the objectives for the surveillance

{ program resulting in a program which, in the author's opinion

! "is presently ineffective." To date, findings (2), (3) and I (4) have not been adequately addressed by TUEC. (Region IV Report No. 50-445/84-32.)

Based on its findings and observations, the TRT concludes that the QA audit and reporting program has had and continues to exhibit deficiencies. Over a significant period of time, recurring deficiencies includes.... failure by management to i

review the QA program for effectiveness; procedural and

! implementation inadequacies;....and insufficient management direction and understanding. In suaration, the QA/QC group finds the past audit and reporting systen less than adequate, and the audit and reporting program at the time of the TRT l review was questionable." J l

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RESULTS REPORT ISAP VII.a.5 (Cont'd) 2.0 ACTION IDENTIFIED 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 implicaeions..."

" Address the collective significance of these deficiencies..."

" Propose an action plan...that will ensure that such problems do not occur in the future."

3.0 BACKGROUND

The intent of this Issue-Specific Action Plan (ISAP) was to ensure k that, for any remaining construction or modification activities for Unit 1, the remaining construction phase for Unit 2 and for operations, a Periodic Review of QA Program has been developed which will provide corporate management with data concerning the adequacy and effectiveness of the overall QA Program and which will provide for the evaluation, by management, of adverse findings and subsequent corrective action follow up. l This ISAP was not intended to perform evaluations which would result in conclusions regarding the installed hardware. The quality of hardware and any potentiel safety implications will be assessed from other hardware and programmatic ISAPs and the self-initiated Construction Reinspection / Documentation Review Plan.

ISAP VII.c.

! Any past effects of an inadequate management review of the QA Program would be addressed through the implementation of other CPRT l ISAPs. One example is ISAP VII.a.4, " Audit Program and Auditor l

Qualification," which identified inadequacies in the TUCCO QA Audit

Program which continued uncorrected for long periods of time. In j addition, the topic of overall assessment of the QA Program will be addressed during the collective evaluation of QA/QC Program adequacy. Therefore, the first three items in Section 2.0 of this report, which pertain to consideration of the implications of the?

l TRT findings on construction quality, their root cause and generic

implications, and their collective significance, will be addressed j elsewhere. ,

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3.0 BACKGROUND

(Cont'd)

In addition to the TRT issue, the NRC issued a notice of violation (445/8432-02; 446/8411-02):

" Contrary to the requirements, the applicant did not establish quality assurance procedures to regularly review the status and adequacy of the construction quality assurance program; nor did the applicant appear to have reviewed the status and adequacy of the construction quality assurance program."

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 The purpose of this action plan was to assess the adequacy of the current CPSES Periodic Review of QA Program against criteria to be developed as part of

\ this plan. The Review Team was to consult with INPO to define criteria for an adequate and effective Periodic Review of QA Program.

The Review Team then evaluated the current CPSES Periodic Review of QA Program against the criteria developed.

4.1.2 .The specific methodology is described below.

4.1.2.1 The Review Team obtained information from INPO governing Periodic Review of QA Programs for both construction and operations phases.

4.1.2.2 The Review Team reviewed the current TUCCO written program and practices implementing the Periodic Revie.w of QA Program.

4.1.2.3 Utilizing the information gathered, a set of criteria was developed to define an effective Periodic Review of QA Program for CPSES which addresses, among others, the following

- Scheduling and performance of 6' reviews at least annually,

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- Reports directed to, and responses received from, a sufficiently high level of management to ensure effective corrective action.

- Ongoing contact by management with program status, Identification of corrective action.

- Tracking and follow-up.

4.1.2.4 The current TUGC0 program was evaluated against the criteria developed to assure that an adequate Periodic Review of QA Program is in effect for any remaining construction or modification activities for Unit 1, the remaining construction phase of Unit 2 and for the operations phase.

4.1.2.5 Copies of the Results Report for this ISAP will be provided to TUGC0 for their consideration in responding to the NRC Notice of Violation (445/8432-02; 446/8411-02).

4.2 Participants Roles and Responsibilities 4.2.1 TUCCO 4.2.1.1 Scope TUGC0 assisted in identifying and locating applicable information and documentation to

support the Review Team activities, and provided contact with INPO.

4.2.1.2 Personnel Mr. John Streeter, Director, Quality

Assurance, provided coordination between the i Review Team and TUGCO. 6' L

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ISAP VII.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Conc'd) 4.2.2 ERC 4.2.2.1 Scope -

ERC communicated with outside organizations and TUCCO Management, reviewed data, developed criteria and evaluated the current program.

4.2.2.2 Personnel ,

Mr. J. Hansel Review Team Leader i

Mr. J. Gelzer Issue Coordinator Quality Engineers as required.

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4.3 Qualifications of Personnel i

Participants were qualified to the specific requirements of the CPRT Program Plan.

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l Periodic Review of QA activities shall be in compliance with 10CFR50, Appendix B, Criterion 11 and ANSI N45.2-1971, Section 2. Specifically, such activities are acceptable if a description is provided of how management (above or outside the QA organization) regularly assesses the scope, status, adequacy, and compliance of the QA Program to 10CFR50, Appendix B. These measures should include:

4.4.1 Frequent contact with program status through reports, meetings, and/or audits.

4.4.2 Performance of an annual review preplanned and documented. Corrective action is identified and tracked.

J 4.5 Decision criteria This item will be considered complete when the following have been accomplished:

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4.5.1 A set of criteria for an effective Periodic Review of QA Program has been developed.

i 4.5.2 The TUGC0 Program has been evaluated against the 4

criteria.

4.5.3 The results of the evaluation have been transmitted to

, TUGC0 for consideration in their program.

5.0 INPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS l

} The following sections address the development of criteria for a Periodic Review of QA Program and the evaluation of the current

TUGC0 program.

l 5.1 Development of Criteria f

The TUCCO licensing commitment for the Periodic Review of the QA Program is contained in 10CFR50, Appendix B Criterion II, which states in part, ". . . The applicant shall regularly

review the status and adequacy of the quality assurance

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program. ... " In addition, ANSI N45.2-1971, to which TUGC0 i is committed, states in Section 2. ". . . The program shall j provide for the regular review, by management of organizations

' participating in the program, of the status and adequacy of l that part of the quality assurance program for which they have

! designated responsibility."

l In addition to these regulatory commitments made by TUGCO, the

! NRC Standard Review Plan, NUREG-0800, contains acceptance l criteria for the review of QA programs. In Section 17.1, the l

criteria pertaining to Periodic Review of QA Program is as l

follows:

f " Activities related to quality assurance program (17.1.2) are acceptable ifs . . .

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i 2.C.1 A description is provided of how management (above or outside the QA organization) regularly assesses the scope, status J l

l adequacy, and compliance of the QA program to l 10CFR Part 50, Appendix B. These measures l should includes

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a. Frequent contact with program status through reports, meetings, and/or audits. .

b. Performance of an annual assessment preplanned and documented.

Corrective action is identified and tracked."

INPO was considered as an additional source for input to the development of criteria. INPO identified three criteria documents to the RTL which they felt might be applicable, and copies were obtained from TUGCO.

After review and consideration of the information available, and because the applicable INPO information was similar, it f,\ was decided that the criteria to be developed in this ISAP

\ should closely reflect and expand upon the criteria contained in the Standard Review Plan. As a result, the following set of criteria for periodic review of QA program has been ,

developed:

5.1.1 The program shall require the regular assessment of the scope, status, adequacy, and compliance of the QA program to 10CFR50, Appendix B.

5.1.2 The program shall define the management positions responsible for the Periodic Review cf QA Program.

These positions shall be above er outside the QA organization and the line managers directly responsible for activities affecting quality.

5.1.3 The program shall describe the methodology for performing the QA program assessments and their frequency. As a minimum, the methods described shall include the following:

- Frequent contact, by personnel responsible for the reviews, with program status through reports, meetings, and/or audits.

p - Performance of preplanned and documented

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assessments to be performed at least annually.

R: vision: I Page 8 of 11 RESULTS REPORT ISAP VII.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.1.4 The program shall describe the methodology for reporting, tracking and follow-up of the results of the Periodic Review of QA Program. .

5.2 Review of Current Program The written program for periodic review of the QA program is contained in the TUGC0 Nuclear Engineering and Operations (NEO) Policies and Procedures Manual and consists of the following documents that collectively define and implement the I program:

- A memorandum dated August 30, 1985, from the President of TUGC0 that transmitted policy statements that )

identified TUGC0 corporate goals and objectives to the Executive Vice President, NEO with a request to initiate NEO policies and procedures to ensure implementation of the policy statements. Policy Statement Number 5 states in part, "Overall effectiveness of the quality assurance program shall be ,

regularly reported to Corporate Management...."

- NEO Policy Statement Numbar 2 " Quality Assurance Program," Revision 0, dated June 23, 1986.

- . Procedure NEO 2.20, " Senior Management QA Overview Program," Revision 1, dated June 23, 1986.

- Procedure NEO 2.08, " Joint Utility Management Audit Program," Revision 0, dated June 23, 1986.

A review of these documents was performed utilizing the criteria in Sections 5.1.1 through 5.1.4 above. Based on this review, a review of the minutes of previous Senior Management QA Overview Committee (Committes) meetings and observation of two Committee meetings, the following has been determined:

5.2.1 The program provides for a regular assessment of the status and adequacy of the QA Program.

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Revision: 1 6 Page 9 of 11 RESULTS REPORT ISAP VII.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.2 The program defines the management positions responsible for the periodic review of QA Program as the Executive Vice President, NEO and the Vice Presidents reporting to him. These positions are above and outside the QA organization and the line managers directly responsible for activities affecting quality.

5.2.3 The program describes the methodology for performing the program assessments and their frequency.

- Frequent contact with program status is accomplished by personnel responsible for the reviews through reports and meetings.

- Provision has been made for preplanned and scheduled annual assessments to be performed by senior management and also for an outside, independent audit of the TUGC0 QA Audit Program.

5.2.4 The program describes the methodology for reporting, tracking and follow-up of the results of the periodic review of QA Program.

5.2.5 Revision 1 of Procedure NEO 2.20 states that the

. committee shall meet at least quarterly. Since the inception of the committee in September 1985, through July 1986, there have been five committee meetings.

This is in excess of the minimum number established.

5.2.6 The Committee meetings have focused on identified problems in the QA program such as the control of non-conformances; consolidated reporting of open item status; trend analysis system; development of, and the setting of priorities for, the NEO Policies and Procedures; interface requirements; and transition to operating status.

5.2.7 The minutes of the first three committee meetings, prepared prior to procedure revision, lack details for some items addressed, responsibilities assigned and J actions taken. This was due, at least in part, to the fact that the Executive Vice President, NEO, and all committee members were present at, and participated in, the meetings and were therefore cognizant of the actions which transpired.

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ISAP VII.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Revision 1 of Procedure NEO 2.20 contains specific requirements for the content of committee meeting minutes, including a method to track all items requiring committee action. The minutes of subsequent meetings (May 8, 1986 and July 8, 1986) are much improved in this respect and provide additional detail and a more descriptive record of the committee activities.

5.3 Evaluation of Findings Based on the evaluation described in Section 5.2 above, it is concluded that the TUGC0 written program for the Periodic Review of QA Program is acceptable. The RTL has no further recommendations.

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6.0 CONCLUSION

S With the issue of the TUGC0 Corporate Nuclear Policy in August 1985, and the subsequent development of the NEO Policies and Procedures Manual Table of Contents, and the subsequent development of individual policies and procedures, TUGC0 management has taken positive steps to define an effective system to provide the necessary controls and guidance to ensure the adequate and effective implementation and review of the QA program.

t It is further concluded that, based on discussions with the l

Executive Vice President NEO, his vice presidents and review of Committee activities, current management at this level understands the importance of an effective QA program and also the need for regular review of the program to measure its adequacy and effectiveness.

Recent activities at this level have consisted of assembling the upper management team, identifying and implementing the data gathering and reporting methodology to enhance management review capabilities, and identifying priorities for development of the individual NEO Policies and Procedures.

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Finally, it is concluded that continued implementation of the E Periodic Review of the QA Program as recently demonstrated, and in accordance with the program as presently defined, will result in an adequate and effective Periodic Review of the QA Program.

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ISAP VII.a.5 (Cont'd) 7.0 ONGOING ACTIVITIES The program for the periodic review of the QA Program will be applicable to any remaining construction or modification activities for Unit 1, the remaining construction phase on Unit 2 and for the operating phase of the plant.

8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE TUGC0 Management implementation of the program as outlined in the NEO Policies and Procedures Manual will ensure a continuing acceptable program for the Periodic Review of the QA Program, s

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