ML20215B749
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4 COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.b.3
Title:
Conduit to Cable Tray Separation REVISION 1 Y Y A b h Y $ a n !") WdlYs2G/f06 Issue Coordin gor // Date -
LA1. hralLA 3/zo/gG l Date I RJviewI m Lea' der Qw._4J. L Joh6/ W. Beck, Chairman CPRT-SRI 3 /2 <. h r.
Date 8610080496 861003 PDR FOIA GARDE 86-272 PDR F.-9
R2 vision: 1 Page 1 of 13 RESULTS REPORT l l
ISAP I.b.3 Conduit to Cable Tray Separation
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No. ;
7, Page J-42) j "The TRT found no evidence that the existing G&H analysis for establishing the criteria for a 1-inch separation between rigid conduits and cable trays, as stated in G&H Electrical Erection Specification 2323-ES-100, had been evaluated by the NRC staff for Comanche Peak. This analysis should have been referenced in the FSAR."
2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement No. 7, Item 6(e),
Page J-44)
"TUEC shall accomplish the following actions prior to fuel load:
Submit to the NRC the analysis substantiating the acceptability of the criteria stated in G&H electrical erection specification governing the separation between separate conduits and cable trays.
This analysis shall be supported with the necessary documentation in sufficient detail to perform an independent evaluation of how these criteria were established based on the analysis."
3.0 BACKGROUND
Raceway' separation criteria utilized in Gibbs & Hill electrical drawings and specifications were based upon the requirements of IEEE 384-1974, "IEEE Trial-Use Standard Criteria for Separation of Class 1E Equipment and Circuits", and Regulatory Guide 1.75, Revision 1. January 1975, " Physical Independence of Electric Systems". Although very specific criteria are provided in the standard and regulatory guide for separation between redundant
- cable trays, the same degree of specificity is not provided for separation between conduits and cable trays.
- All separation requirements in this report are for redundant cable trays and/or conduits. The word " redundant" as used herein means that the cable trays and/or conduits requiring separation belong to different trains, i.e., Class 1E train A, Class 1E train B, or non-Class 1E train C. Note that cable trays and/or conduits of the same train require no separation.
Rsvision: 1 Page. 2 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd)
3.0 BACKGROUND
(Cont'd)
Since Regulatory Guide 1.75, Revision 1, January 1975, and IEEE 384-1974 do not specifically provide criteria for conduit-to-cable tray separation, Gibbs & Hill originally interpreted these documents to require a one-inch minimum separation between a safety-related conduit and an open cable tray when the. conduit is below the top of the side rails of the cable tray. This interpretation was included in a Gibbs & Hill document entitled " Criteria for Separation of Class 1E Equipment and Circuits". This document was transmitted to the TUGCO project for their information and use via letter GTN-2441, dated February 19, 1975. The above criterion, along with separation requirements for safety-related conduits above cable trays, was added to Electrical
, Erection Specification 2323-ES-100 in the form of Design Change Authorization (DCA) 6132, dated November 16, 1979. This DCA also included all separation criteria for non-safety related conduit.
. Specification 2323-ES-100, Revision 2, dated January 1981, which incorporates DCA-6132, states in Section 4.11.1 that,the Engineering drawings showing the plant layout utilized the i separation criteria transmitted via Gibbs & Hill letter GTN-2441.
The separation criteria, as stated in 2323-ES-100, are to provide "the necessary information for assisting the contractor in field routing the conduit . . . ."
During the Gibbs & Hill review of DCA-15917, which authorized a reduction in the separation criterion for a conduit above an 4
enclosed' raceway from four inches to one inch, the adequacy of the existing one-inch separation criterion for safety-related. conduits and open cable trays was questioned. This issue was resolved by Gibbs & Hill memo EE-863, dated January 17, 1984, which included the Gibbs & Hill report and simplified analysis that the NRC-TRT
, reviewed on site (See Section 1.0). The purpose of the memo was to establish the. engineering interpretation of required separation between conduits and cable trays in accordance with established criteria in the standard and regulatory guide. This. supporting documentation was not submitted to the NRC staff for review because i the interpretation was not considered a deviation to the standard 1 or regulatory guide, but was considered documentation supporting the implementation of these requirements. .
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Revision: 1 Pcg2 3 of 13 e
RESULTS REPORT ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan was to substantiate the acceptability of the criteria governing the separation between conduits and cable trays and to submit the evaluation and supporting documentation to the NRC.
To achieve this objective, the following tasks were implemented:
- Gibbs & Hill prepared a report compiling criteria and supporting analyses
- The Eltetrical Review Team reviewed the report substantiating the separation criteria The TUGC0 Coordinator initiated the submittal of the report to the NRC 4.1.1 Report Preparation Gibbs & Hill prepared a report for TUGC0 presenting the methodology and criteria used in applying IEEE 384-1974 and Regulatory Guide 1.75, Revision 1, January 1975, to conduits requiring separation from cable trays. Included was a copy of a Sandia Report
(" Cable Tray Fire Tests", SAND 77-1125C). which documents a series of tests funded "by,the Nuclear Regulatory Commission to provide data needed for confirmation of the suitability of current design standards and regulatory guides for fire protection and control in water (cooled) reactor power plants".
4.1.2 Report Review The above report was submitted to the Electrical Review Team for review.
4.1.3 Report Submittal to NRC The TUGC0 Coordinator submitted an FSAR Change Request to TUGC0 Nuclear Engineering for submittal to the NRC for review. The FSAR Change Request provides a description of the existing conduit-to-cable tray separation criteria. Supporting documents are attached to the FSAR Change Request.
Rsvision: 1 Pcga 4 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 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 4.2.1.1 Assisted the Electrical Review Team in reviewing the report compiling the Gibbs &
Hill criteria.
4.2.1.2 Will submit, upon approval, the FSAR Change Request and supporting documents to the NRC.
4.2.1.3 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed the report compiling the Gibbs &
Hill criteria.
4.2.2.2 Personnel (prior to October ~ 18, 1985)
Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.3 Personnel'(starting October 18, 1985)
Mr. J. J. Ma11anda, Review Team Leader Mr. R. J. Bizzak, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 Gibbs & Hill 4.2.3.1' Prepared a report compiling the criteria used l in confirming the adequacy of conduit-to- l cable tray separation.
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Rsvision: 1 Pegs 5 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) ;
4.2.3.2 Personnel Mr. S. P. Martinovich, Principal Engineer-Electrical 4.2.4 Third-Party Adviser (prior to October.18, 1985) 4.2.4.1 Reviewed the report compiling the Gibbs &
Hill criteria.
4.2.4.2 Personnel Mr. L. D. Bates, Third-Party Adviser 4.3 Oualification of Personnel 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 1 requirements of the CPRT Program Plan. Activities performed-i 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 Not applicable.
4.5 Acceptance Criteria The acceptance criterion for the report was that it demonstrate'that the conduit-to-cable tray separation criteria meet the intent of IEEE 384-1974 and Regulatory Guide 1.75, Revision 1,_ January 1975. This was met as discussed in Section 5.0.
4.6 Decision Criteria If compliance with IEEE 384-1974 and Regulatory Guide 1.75, .
Revision 1, January 1975 could not be adequately demonstrated. l the conduits and cable trays would have to be modified, as ;
appropriate, to achieve compliance. This was not necessary as discussed in Saction 5.0.
Ravision: 1 j Pege 6 of 13
- 4 RESULTS REPORT
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ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summary A report based on the information contained in Gibbs & Hill memo EE-863 was prepared by Gibbs and Hill. This report addressed those separation distances between a conduit and an open cable tray which did not meet the criteria given in IEEE 384-1974 for open cable trays. The primary ~ reference used to substantiate the conduit-to-cable tray separation criteria was a Sandia report documenting a series of electrically initiated cable tray fires. One case which is not directly evaluated in the Sandia report is the case of a safety related conduit one inch beside or below an open cable tray. The justification presented in the Gibbs & Hill report for the one inch separation case mentioned above was a simplified anilysis from EE-863 which utilized cold wall heat flux values from the Sandia report.
The above Gibbs & Hill report, originally issued in September 1984, was reviewed by the Electrical Review Team during the late 1984/early 1985 time frame and revised several times to incorporate comments. Subsequent to the above review cycle, questions remained on the simplified analysis presented in the report. To alleviate these concerns, Gibbs & Hill performed computer analyses in the summer of 1985, using an alternate methodology, to substantiate the simplified analyses.
Although.the computer analyses were in agreement with the .
results of the simplified analysis, a subsequent review of the report and analyses in the last quarter of 1985 by the Electrical Review Team identified inconsistent assumptions in the simplified analysis which required subsequent justifications. A final report utilizing a revised computer analysis was completed and issued to TUGC0 by Gibbs & Hill.
The final report and analyses have been reviewed by'the Electrical Review Team Leader and Issue Coordinator. The i conclusion is that the above documents provide adequate ,
justification of the existing conduit-to-cable tray separation; therefore, no plant modifications'are required. A summary of the report is given in the following section.
5.2 Conduit / Cable Tray Separation criteria The separation criteria in Gibbs & Hill Electrical Erection Specification 2323-ES-100 are graphically presented on Drawing 2323-El-1702-02, Revision 2. " Cable and Raceway Separation Typical Details".
Rsvision: 1 4 Pegs 7 of 13 RESULTS REPORT ISAP I.b.3
, (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The separation criteria shown on Gibbs & Hill Drawing 2323-El-1702-02 apply only when hazards are limited to electrically-initiated fires due to failures or faults internal to electrical equipment or raceways.. This is consistent with the definitions given in IEEE 384-1974 for the cable spreading area and general plant areas.
l The criteria given in IEEE 384-1974 for separation of redundant cable trays for the above areas are:
Cable Spreading Area - Both I foot horizontally cable trays are open ventilated 3 feet vertically trays.
General Plant Areas - Both 3 feet horizontally cable trays are open ventilated 5 feet vertically trays.
Cable Spreading Area and 1 inch horizontally General Plant Areas - Both 1 inch vertically cable trays are enclosed.
The IEEE standard also allows the separation distances to be alternatively established by analyses / testing "to determine the flame retardant characteristics of the proposed cable installation. . . ."
Although the above specific criteria for redundant, open cable
- trays are provided in IEEE 384-1974 and Regulatory Guide 1.75, Revision 1 January 1975, the same degree of specificity is not provided for separation between conduits and cable trays.
However, the above separation distances for open cable trays could be reduced when one train of circuits is in conduit since a barrier
- now exists between.the two redundant trains. :
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The current CPSES conduit-to-cable tray separation criteria are depicted in Details 45 thru 49, 52 thru 55, and 57 of
-Drawing 2323-El-1702-02. A summary of these criteria followsi
- The IEEE 384-1974~ definition of a barrier is "a device or structure interposed between Class IE equipment or circuits and a potential source of damage to limit damage to Class IE systems to an acceptable level." J l
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Ravision: 1 Pcgs 8 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Cable Spreading 1 foot horizontally When conduit Area 2 feet vertically elevation
- is above the top of the cable tray side rails or when the cable tray is vertical.
General Plant 3 feet horizontally When conduit Area 3 feet vertically elevation
- is above the top of the cable tray side rails or when the cable tray is vertical.
Cable Spreading 1 inch horizontally When conduit Area and General 1 inch vertically elevation
- is below Plant Areas the top of the cable tray side rails (cable tray horizontal), conduit is non-safety related, or cable tray is enclosed.
In comparing the conduit-to-cable tray separation criteria given above to the criteria provided in IEEE 384-1974 for open ,
cable trays, the following three categories of differences are l noted:
Category 1 - Non-Safety Related Conduit J Separation between conduit and cable tray is one inch f when conduit is non-safety-related.
Category 2 - Safety-Related Conduit Above Cable Trays Vertical distances are 2 feet /3 feet for safety-related-conduits over open cable trays in the cable spreading / general plant areas, respectively.
Category 3 - Safety-Related Conduit Below the Top of the Cable Tray Side Rails Separation between conduit and cable tray is one inch when conduit elevation is below the top of the cable tray side rails.
- Conduit elevation is top of conduit.
Revision: 1 Pass 9 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Category 1 - Non-Safety-Related Conduit i The CPSES minimum separation for non-safety-related conduits l adjacent to safety-related cable trays is one inch, regardless l of orientation. The non-Class ~1E circuits in the conduit do i not have to be protected from a cable fire in the cable tray l since the non-Class 1E circuits do not provide a safety i function. However, the Class IE cables-in the cable tray do l have to be protected from a fire in the conduit. The conduit l in combination with a one inch air space will provide adequate protection to the safety-related cable tray. This configuration is similar to Figure 5 of IEEE 384-1974. 1 It should be noted that a fire in a conduit represents a less ,
severe source of damage than a fire in an enclosed cable tray-since:
Conduit size is limited to five inches thus limiting the volume of cables contained. l
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l Threaded connections provide an essentially air-tight medium which inhibits internal combustion and l effectively isolates internal events from the '
surroundings.
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- The curved surface of the conduit provides a radial distribution of radiant heat and, therefore, less favorable heat transfer characteristics to or from an adjacent cable tray than a flat surface of equivalent area.
Category 2 - Safety-Related Conduit Above Cable Trays The basis for the adequacy of vertical separations given in this category is electrically initiated fire tests conducted
' by Sandia Laboratories and presented in Report SAND 77-1125C,
" Cable Tray Fire Tests." One of the objectives of these tests was to use cables representative of those used in the nuclear industry. An industry survey of 13 leading architect-engineering firms, 13 utility companies, and 13 cable manufacturers was performed. Twenty (20) different cable types were screened on the basis of popularity of use, small scale electrically initiated cable insulation fire tests. UL FR-1 flame test, and pyrolyzer and thermal chromatograph testing (which measured insulation outgassing as a function of temperature). The cable constructions tested are I
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Rcvision: 1 Pag 2 10 cf 13 l
RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) representative of those used at CPSES. The cables used at CPSES comply with IEEE 383-1974, " Standard for Type Test of Class 1E Electrical Cables, Field Splices, and Connections for Nuclear Power Generating Stations". The cables used in the Sandia tests "were capable of passing IEEE Standard 383-74".
Therefore, the Class 1E cables at CPSES and the cables used in the Sandia tests have similar flame-retardant characteristics.
The Sandia testing showed that, for an electrically initiated cable tray fire, cables in an open tray located 10.5 inches vertically above the tray with the fire did not burn. All circuits in the cables above the fire remained functional. As noted above, the CPSES criteria for safety-related conduits located above cable trays is a minimum of two feet. It should be emphasized that the Sandia tests were performed using exposed cable; therefore, the CPSES criteria are even more conservative since the cables at CPSES are enclosed in a barrier.
Some of the more significant observations of the nature of electrically initiated fires noted in the Sandia Report are:
- The fire characteristics do not vary greatly from one cable fire to another.
-- The intense period of the fire at a particular location lasts between 40 and 240 seconds before die-out begins to occur.
- The luminous zone of the fire is optically thin which means that the major heat transfer mechanism is convection versus radiation.
Based on the above, given a specified separation, the worst configuration is conduit over the cable tray since the conduit will be exposed to both convective as well as radiation heat transfer. Since the exposed cable 10.5 inches above the fire remained functional, any cable enclosed in a conduit (which provides additional heat protection for the cable) 10.5 inches or more from an electrically initiated fire will also remain functional.
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R2 vision: 1 Pega 11 of 13 3
RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Category 3 - Safety-Related Conduit Below the Top of the Cable Tray Side Rails The only case where a safety-related conduit at CPSES can be less than 10.5 inches from an open cable tray is when the conduit elevation is below the top of the cable tray side rails. The major heat transfer mechanism for this configuration is radiation. Based on the above noted characteristic of the Sandia test fires (i.e. the luminous zone of the fire is optically thin), radiation is a minor part of the heat transferred from the fire to objects immersed in the flame.
In order to quantify the response of a conduit beside or below a cable tray, a computer analysis was performed by Gibbs &
Hill for the case of a conduit one inch directly below the fire. (Note that conduits alongside cable trays are partially blocked from the radiation from the flame by the cable tray side rails.) Cable fire parameters taken from the Sandia Report were used as inputs to this analysis.
The above analysis included the following conservatisms:
- The fire data used in the analysis was for the October 5, 1976, fire test, one of the most intense and i longest duration fires studied.
- The radiation heat flux applied to the conduit was taken just slightly above the burning tray (i.e., in the flame) rather than one inch away from the flame.
- The radiation heat flux, based on the maximum flame-temperature, was held constant from 30 seconds to 240 seconds. The test data showed that temperatures measured by a thermocouple in the flame varied from 1150*F to 700*F during this period.
- The flame diameter was held constant at eight inches.
- No blockage was assumed by other cables in the cable tray with the fire.
- The cable enclosed in the conduit was assumed to be at the same temperature as the conduit. No credit was taken for the cable acting as a heat sink.
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Revisien: 1
. Pag 2 12 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The results of the analysis showed that the conduit exceeded 302*F (150'C) for approximately 4-1/4 minutes with a maximum temperature of 357'F (181*C), assuming an ambient temperature of 122*F (50*C).
The Electrical Review Team reviewed the manufacturers' data for the cables used at CPSES. All cables are qualified for 302*F (150'C) for a minimum period of one week. Additionally, the cables with silicone insulation were tested at a minimum temperature of 392*F (200'C) for seven days and remained functional. Anaconda FR-EP cables were qualified for a LOCA, environment by testing at 385'F (196'C) for two twelve-minute periods. The remaining cables were LOCA tested at a minimum of 345'F (174*C) for a minimum of four hours. The cables subjected to the above. tests to simulate LOCA environmental conditions remained functional.
Additional evidence which supports the adequacy of CPSES conduit separation one inch below cable trays is provided in the results of the propane-fueled exposure fire tests also conducted by Sandia in which conduits and trays were included.
In these tests, fourteen (14) trays were stacked seven (7) high by two (2) wide separated vertically 10.! inches.
Directly below each tray (except for the bottom tray exposed to the propane-fueled source) was a conduit containing additional cables. Although all circuits in the conduits above the third tray failed during the exposure fire (the higher conduits experiencing heat input from all fires below l them), circuits in the lower two (2) conduits maintained circuit integrity throughout the duration of the fire.
- Considering that the fire in the lower two (2) trays was more severe than in an electrically initiated fire, being larger in 1 size and of longer duration, the results provide an indication I of the adequacy of protection offered by conduits installed with an air gap of one inch during the less severe electrical fire.
5.3 FSAR Change Request Submittal The TUGC0 Coordinator submitted an FSAR Change-Request to TUCCO Nuclear Engineering fer submittal to the NRC for review. ,
The FSAR Change Request provides a description of the existing i
conduit-to-cable tray separation criteria. Supporting documents were attached to the FSAR Change Request.
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Rsvision: 1 Page 13 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.4 Classification and Evaluation of Discrepancies No design deviations were noted in the implementation of this action plan. However, two design observations were noted.
The first observation was that analyses did not exist at the time that the criteria for conduit-to-cable tray separation were placed in design and construction documents. The basis for the criteria appeared to have been engineering judgment based on experience with other nuclear projects. The second observation was that inconsistent assumptions used in the Gibbs & Hill simplified analysis verifying the one-inch separation criteria were not discovered during the design verification process.
Since no deviations were found, no root cause analysis was performed. The observations were too few in nu=ber and too limited in scope to identify a trend. Therefore, the facts relating to these observations were transmitted to the Design Adequacy Review Team Leader in accordance with Appendix A.
" Design Adequacy Program Plan", to be included in the collective evaluations of that plan.
6.0 CONCLUSION
S The established conduit-to-cable tray separation criteria meet the intent of IEEE 384-1974 and Regulatory Guide 1.75, Revision 1, January 1975. No corrective actions are required.
7.0 ONGOING ACTIVITIES The FSAR Change Request and supporting documents have been issued to TUCCO Nuclear Engineering (TNE) by the TUCCO Coordinator. TNE will transmit the information to TUGC0 Licensing, which is the formal channel for submitting information to the NRC.
The design observations noted in Section 5.4 were forwarded to the DAP RTL in accordance with Appendix A, " Design Adequacy Program Plan", to be included in the collective evaluations of that plan. l 1
l 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Since no design deviations were found, no corrective actions were l required. l k -
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- -< .:n RELATED CORH6
! Filed: April 4, 1986 i .
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NUCLEAR REGULATORY COMMISSION 00C$TNu /CI.-
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i TEXAS UTILITIES GENERATING
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) 50-445((
50-446 -
4 COMPANY et al. )
' !l ) -(Application for an
/ (Comanche Peak Steam' Electric ) Operating License) l Station, Units 1 and 2) )
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NOTICE OF AVAILABILITY OF RESULTS REPORTS AND WORKING FILES ii!
U To: Anthony Z. Roisman, Esquire l
Executive Director Trial Lawyers for Public Justice 2000 P Street, N.W., Suite 611 Washington, D.C. 20036
, Please take notice that the Comanche Peak Response q
j Team Senior Review Team has approved and published the t
j l following reports:
..j I.a.4 Dwgs. Terminations
% I.b.3 Conduit / Cable Tray Separation l
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.) Distribution of copies of these results reports is
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being made in accordance with the controlled f distribution of the CPRT Program Plan; if yo'u have not i
9 . received a copy within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after your receipt of
<. ,i this notice, please contact the undersigned.
The Working Files for each of these ISAPs is now-
. available for inspection and copying at the offices of I
Texas Utilities Generating Company, Skyway Tower, 400
- North Olive Street, Dallas, Texas, upon 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />' notice of your intention to inspect the same.
y attorneys, D i ,
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'J Thomas G. Dipan, Jr. C
] R. K. Gad Ip Ropes & Gray
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225 Franklin Street Boston, Massachusetts 02110
, Telephone: (617) 423-6100
] l Dated: April 4, 1986. _
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y I, Robert K. Gad III, one of the attorneys for the Applicants k
herein, hereby certify that on April 4, 1986, I made service of the
/t[:
J lj within " Notice of Availability of Results Reports and Working
$j j Files," by mailing copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Mr. James E. Cummins
~a Chairman Resident Inspector j- Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission j U.S. Nuclear Regulatory P.O.- Box 38 4 -
Commission Glen Rose, Texas 76043 Washington, D.C. 20555
' 'i e 4 Dr. Walter H. Jordan Mr. William L. Clements il Administrative Judge Docketing & Services Branch j 881 W. Outer Drive U.S. Nuclear Regulatory Commission 1 Oak Ridge, Tennessee 37830 Washington, D.C. 20555 l
- l1 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel
([ U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission
'1 Commission Washington, D.C. 20555 Washington, D.C. 20555 k Stuart A. Treby, Esquire Mrs. Juanita Ellis l Office of the Executive President, CASE Legal Director 1426 S. Polk Street
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. U.S. Nuclear Regulatory Dallas, Texas 75224 a Commission
-] Washington, D;C. 20555 q l .
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! il Renea Hicks, Esquire Ellen Ginsberg, Esquire
-9 Assistant Attorney General Atomic Safety and Licensing l.1 Environmental Protection Division -Board Panel
- j P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Ccmmission
., Austin, Texas 78711 Washington, D.C. 20555
- 9 '
l fj Anthony Roisman, Esquire Joseph Gallo, Esquire qi Executive Director .
Isham, Lincoln & Beale Trial Lawyers.for Public Justice 1120 Connecticut Avenue, N.W.
d:.l ; 2000 P Street, N.W., Suite 611 Suite 840
! Washington, D.C. 20036 Washington, D.C. 20036
%)q Dri Kenneth A. McCollom Mr. Lanny A. Sinkin 2~ Administrative Judge Christic Institute
- d Dean, Division of Engineering, 1324 North Capitol Street
~U Architecture and Technology Washingtoni D.C. 20002
", Oklahona State University
- Stillwater, Oklahoma 74078
..- Ms. Billie Pirner Garde Mr. Robert D. Martin el Citizens Clinic Director Regional Administrator, Government. Accountability Project' Region IV 1901 Que Street, N.W. U.S. Nuclear Regulatory Commission
- . Washington, D.C. 20009 Suite 1000-l 611 Ryan Plaza Drive Arlington, Texas 76011
, : Elizabeth B. Johnson Geary S. Mizuno, Esquire Administrative Judge Office of the Executive l Oak Ridge National Laboratory Legal Director a P.O. Box X, Buildin.g 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee -37830 Washington, D.C. 20555 it j Nancy Williams y Cygna Energy Services, Inc.
O 101 California Street i]g
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I TEXAS UTILITIES GENERATING COMPANY SKYWAY 199FER e 400 NomTM OEJVE STREET. L.B. 81
- DALLAS TEXAS 75801 l <is-fd April 4, 1986 g YeEAs*0EU.*.$
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- j- Mr. Vincent S. Noonan Director of Nuclear Reactor Regulation
- 1 Comanche Peak Project j Division of Licensing U. S. Nuclear Regulatory Commission i Washington, D. C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION 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 .a r e 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 I.b.3 Conduit to Cable Tray Separation II.b Concrete Compression S ngth]
III d Preoperational Testing VII.b.2 Valve Disassembly We shall issue future Results Reports on a periodic basis as they are approved by the CPRT Senior Review Team.
Very truly yours, i'
W. G. Counsil WGC:tj Enclosure I
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a CPRT-0344 LOG NO. TUS-4829 j' FILE NO. 10068 s TEXAS UTILITIES GENERATING COMPANY
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i I April 3, 1986 JOMM W. SECK vecs resessent 4
T- MEMORANDUM l-
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TO: Mr. W. G. Counsil 1.
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SUBJECT:
CPRT RESULTS REPORTS 1.
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 i .I.b.3 Conduit to Cable Tray Separation II.b Concrete Compression Strength III.d Preoperational Testing l VII.b.2 Valve Disassembly
- j. .
4). L - J-hn W. Beck Chairman, CPRT Senior Review Team JWB:tj Enclosures cc: CPRT File A DIVISION OF TEXA8 (TFIIJTTES ELECFBIC COMPA.NY
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,l COMANCHE PEAK RESPONSE TEAM l
'l' RESULTS REPORT i-ISAP: I.a.4
Title:
Agreement Between Drawings and Field-Terminations 1q
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REVISION 1 1.
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Johnds. Beck, Chairman CPRT-SRI ' ,)a t e 1
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'l ISAP I.a.4 Agreement Between Drawings and Field Terminations h
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1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7 Page J-29)
"...the TRT selected 380 cables, involving 1600 individual P 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:
1
'h - E0139880 in panel CP1-ECPRCB-14*
E0110040 in panel CP1-ECPRTC-16, E9118262 in panel CPI-ECPRTC-16, NK139853 in panel CP1-ECPRCB-02 (non-safety),
EG104796 in panel CP1-ECPRTC-27, and ECO21856 in pans 1 CPX-ECPRCV-01."
2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Item Number 6 (c), Page J-31) j l
("".
"TUIC shall accomplish the following actions prior to fuel load:
Reinspect all safety-related and associated terminations in the control room and in the termination cabinets in the cable spreading
. room to verify that their locations are in accordance with all l current design documents. Should the results of this reinspection reveal an unacceptable level of nonconformance to design documents, the scope of this reinspection effort shall be expanded to include all safety-related and associated terminations at Comanche Peak P
Steam Electric Station (CPSES)."
3.0 BACKCROUND The specific cables identified above have been re-inspected and the "as-built" configurations reviewed by TUCCO Nuclear Engineering (TNE). The engineering review has considered design changes and te=porary modifications authorized prior to the TRT identification.
The results of this review are as follows:
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- The TRI notified TUEC that the panel identified as CP1-ECPRCB-14 l should be CP1-ECPRCB-04, i
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1 ISAP I.a.4 '
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3.0 BACKGROUND
(Cont'd) t~
N One cable (E0139880) was terminated correctly, but the color-code ic table on the drawing had not been correctly reflected in the
- conductor termination details. This drawing was corrected, and all other drawings with the same type of cable were checked to
,; ensure that this condition does not exist elsewhere. No errors
- j. were found.
i
[: One cable (E0110040) was found to be properly' connected in n accordance with the document revision in effect at the time the termination was made. However, a subsequent drawing revision
- i. chaaged the color code of the conductor for no apparent reason.
This drawing error was detected and corrected prior to the September 18, 1984, letter frem the NRC to TUCCO.
. One cable (E0118262) contained a drafting. error at the time of the l
~
TRT inspection, (two green conductors shown). .The cable was
! , k ,,g functionally correct as landed. The drawing error has been corrected.
': 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 h on the operability of the circuit. The physical terminations have, however, been corrected to match the drawing. i I
One cable (EG021856) was found to be a designated " spare" per a .
properly issued design change authorization (DCA) document (DCA l 19948, dated March 21, 1984). However,'the interconnection drawing .1 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 vender-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: j E0139880 Drawing error 1
E0110040 Drawing error
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RESULTS REPORT .
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ISAP I.a.4
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3.0 BACKGROUND
(Cont'.d)
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,] E6118262 Drawing e'rror
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EG104796 Interchanged conductors in a circuit with no j polarity requirements I
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- EG021856 Interconnection drawing not revised to incorporate a j DCA
'h NK139853 Spare conductors terminated (non-safety)
- T' 4.0 CPRT ACTION Pl.AN 4.1 Scope and Methodologv The objective of this action plan was to assure that the 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 program to inspect terminations was implemented.
I 4.1.1 Inspection Program An inspection program employing random. sampling was i
initiated which enabled a determination to be made with
. reasonable assurance of whether the essential (i.e.,
safety-related) Class 1E conductors in the control room and cable spreading room, which are in circuits that 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 1E terminations in the control room and cable spreading room that are in circuits
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. Page 4 of 15 z RESULTS REPORT ISAP I.a.4 (Cont'd)
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{ 4.0 CPRT ACTION PLAN (Cont'd) i which interface with the Alternate Shutdown Panel in Unit 1. This population of " safe shutdown" terminations was taken from over 14,000 Class 1E terminations in these two rooms.
f
", . The " safe shutdown" terminations were. chosen
[ as a sub-group of the population of all Class I -
1E terminations due to their crucial role in j plant safety. Since there are no product or process differences between this sub-group and the remainder of the Class 1E terminations, this approach allowed for an investigation, which focused on safety, while still attaining an engineering assessment of the quality of the larger population.
4.1.1.2 Random Sampling The sampling plan was designed in accordance with the guidelines of Appendix D, to test for rea=cnable assurance that programmatic deficiencies do not exist in the population.
I 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 l 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
'i deficiency would have been performed, and a sample expansion in accordance with Appendix D undertaken.
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RESULTS REPORT
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ISAP I.a.4 (Cont'd)
F 4
h 4.0 CPRT ACTION PLAN (Cont'd)
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- I If the number of deficiencies discovered in 1
the original sample had been two (2) or more,
[ or a programmatic root cause had been j identified, then a 1001 reinspection of all essential and essociated terminations in the control room sad cable spreading room of
.j Unit I would have been performed.
I 4.1.2 Use of Results i.
I If the CPRT inspection program had identified any deficiencies, then a root cause and generic
! implications evaluatien would have been performed, and i appropriate corrective action determined.
i , 4.2 Participants Roles and-Responsibilities k'
The organizations and personnel that participated in this effort are described below with their respective work scope.
I 4.2.1 TUCCO Comanche Peak Project l 4.2.1.1 Assisted the Review Team Leader in identifying the essential Class 1E terminations which interface with the
~
Alternate Shutdown Panel.
+
Prepared sample' inspection list using input 4.2.1.2 provided by the third-party statistics I 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 TUCCO Coordinator 4.2.2 Electrical Review Team
- 4.2.2.1 Reviewed sampling plan, inspection procedure.
NCRs (if any) and inspection reports.
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4.2.2.2 Evaluated inspection results and specified additional inspections, if required. ,
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RESULTS REPORT ISAP I.a.4 4
(Cont'd) .
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- 4.0 CPRT ACTION PLAN (Cont'd) l
4.2.2.3 Performed root cause, generic implications end safety significance evaluations, if
}' required.
.i i 4.2.2.4 Personnel (prior to October 18, 1985) i Mr. M. B. Jones, Jr. Review Team Leader Mr. E. P. Stroupe Issue Coordinator .
l
'I Personnel (starting October 18, 1985) 4.2.2.5 Mr. J. J. Ma11anda Review Team Leader Mr. J. R. Pearson Issue Coordinator lf ,~
l ( j- Mr. M. B. Jones, Jr. Third-Party Adviser
! Mr. E. P. Stroupe Third-Party Adviser
[ 4.2.3 CPRT - QA/QC Review Team
. 4.2.3.1 Prepared procedure for inspecting terminations, l-l
, 4. 2.3.2 Inspected terminations for compliance with
' acceptance criteria.
4.2.3.3 Personnel Mr. J. L. Hansel Review Team Leader -
QA/QC 4.2.4 Third-Party Statistics Adviser b
4.2.4.1 Provided . input to the sampling plan.
- 4.2.4.2 Personnel
+ Dr. F. A. Webster Statistics Adviser I3
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RESULTS REPORT ISAP I.a.4
- (Cont'd) 1'
{. 4.0 CPRT ACTION PLAN (Cont'd) 1
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.1 4.3 Qualifications of Personnel Where tests or inspections required the use of certified inspectors, qualifications at the appropriate level were to e
the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear i 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 ti _, procedures. .
. i
'- /
Other participants were qualified to the requirements of the
, CPSES Quality Assurance Program or to the specific' requirements of the CPRT Program Plan. Activities performed
.; by other than third-party personnel were governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan.
4.4 Procedures 4.4.1 Instruction QI-001, " Procedure for Class 1E Cable Terminations Inspection - CPRT. Action Item I.a.4".
9 4.5 Accept:nce Critaria 4.5.1 Inspections The acceptance criterion for the termination inspection was that either:
The termination was physically in agree =ent
, 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 electrically common point, or wires reversed in circuits with no polarity requirements).
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i RESULTS REPORT ISAP I.a.4
.(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.6 Decision criteria If any terminations had not been acceptable per Section 4.5.1, b 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 OT ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Sum =arv of Implementatiqn i The actions carried out under this ISAP consisted of a sa=ple
- inspection of " safe shutdown" terminations analysis of the J- results of that inspection and a further investigation of the specifi.c NRC-TRT findings.
I V) . /
The inspection program was performed using the methodology
.l specified in Section 4.1. No deviations from the acceptance
-j...
1 criteria of Section 4.5 were found. Two minor errors were
> discovered, which did not affect the adequacy of the terminations. The identification of additional population j members necessitated an additional sample inspection, which
, was also completed without finding any deviations from the I acceptance' criteria. The results of the entire inspection
- program are presented in Section 5.2.
~
The results of the further investigation into the specific NRC-TRT findings are presented in Section 5.3.
I 5.2 Results of the CPRT Inspection Program l S.2.1 Original Population and Inspection Results l Initially there were 3,812 terminations in the control l room and cable spreading room identified as being in Unit 1 essential Class 1E circuits which interface with
'I the Alternate Shutdown Panel. The population was identified by drawing review.
3 Though the initial minimum sample size was to be 300, a list of 350 randomly-selected terminations from the
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population was created. This list was generated in accordance with the guidelines in Appendix D to the m.- -w . m am - - = n ee %- e. ~- . ** g-. m . ee . ,s eeg se. wear , av == * *e me
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RESULTS REPORT *
. ISAP I.a.4 (Cont'd)
!J i-5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- i:
{. CPRT Program Plan. The extra 50 terminations in the
!. i list were included to cover duplicate numbers (inherent d in the random selection process), physically-
- inaccessible terminations, or any unforeseen problems, Hl which might later have required additional terminations d to be inspected.
~i .
This list of 350 terminations yielded 313 valid samples (thus still in excess of the 300 required to meet the 95/1 screen if no deficiencies were.found). The CPRT i) inspection of these 313 terminations uncovered one (1) drawing error and one (1) cable-tagging error. Both errors were judged to be minor, and neither violated i the acceptance criteria of Section 4.5. These two errors are discussed in detail in Section 5.2.2.
5.2.2 Discussion of Specific Findings
,' (-'s As noted in Section 5.2.1, two errors were found during
.l 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 j below.
5.2.2.1 Drawing Error The CPRT inspections revealed a cable number drawing error. On drawing 2323-El-0172-17 !
cable EG120248 was shown as "EG 20248". J Since all cable numbers have six digits, a l
, five-digit number would have been recognized ;
as a drawing error by maintenance or 1 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 a 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 adequacy of safety-related terminations, since it did not lead to an incorrect termination. The specific drawing has been reissued with the number corrected.
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RESULTS REPORT ISAP I.a.4 (Cont'd) 3 l .
- l. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSIC JF RESULTS (Cont'd) i' a 5.2.2.2 Cable-tagging Error l
The CPRT inspections also revealed an error in the prefix of a field-applied cable identification number (cable EG145725 was tag'ged as "EC145725"). "C" is not a valid character for the prefix of a cable number.
l As such, this tag number would be recognized j-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 criteria of Section 4.5 and would not have an j adverse impact on the adequacy of
! safety-related terminations, since it did not i lead to an incorrect termination. The j (;.-
specific tag has been corrected.
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 i be inspected. These errors were due to a tedious 4
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 eliminated from the final sample, even though the
. resultant termination had been inspected and found to be functionally correct. The final count of 313 valid samples reflects the elimination of these samples.
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, which were not included in the original population. These 105 omissions were due to: (1)
, incorrect count of conductors within some cables; and i (2) entire cables missing from the population list.
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( ISAP I.a.4 i j- (Cont'd) j l
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5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l
'l If the entire population of'3,917 terminations had been I 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 L, inspection program, which consisted of a random sample
] hsing drawn from the additional terminations. The
( sample size was chosen to be'in equal proportion to the additional population as the original sample size was
. to the original population. This approach restored an 4
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).
i
( ~' The 9 terminations were selected at random from the is population of 105.in accordance with the method lj specified in Appendix D. These 9 terminations were j' inspected in accordance with the action plan requirements and no deviations were found.
!l
} 5.2.4 Other Findings j i During the CPRT inspections, it was noted that two conductors had a low chromatic blue color.. The inspection reports noted the color as "gre'enish-grey and as such ene 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.
1 l 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
~
,i terminated due to the low chromatic purity of their 5
1 conductors.
! 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.
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i RESULTS REPORT -
.j ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
A discussion of the review for each of the 6 cables follows:
5.3.1 Cable E0139880 1 This cable was terminated correctly, but the color-code tj- table on the drawing had not been correctly reflected t in the termination details. This multi-conductor cable 1 was supplied with a different color code than shown on 4
.! the design documents. This drawing has been corrected, j and other drawings, which had this type of cable and j color-code table, were checked by CPRT to ensure that l they had also been corrected. No errors were found.
5.3.2 Cable E0110040 I The drawing and termination were in agreement at the j ,_., , time the termination was made. However, a subsequent drawing revision mistakenly changed the color code of p- (
k- -
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 E0118262 This cable was properly connected in accordance with 3
the document in effect' at the time the termination was
-j made. However, the. drawing contained a drafting error at the time of the TRT inspection, i.e., two green i
' conductors were shown for this cable. The drawing error has been corrected.' This is an isolated drafting j error, and did not adversely impact the adequacy of the i
termination.
i 5.3.4 Cable EG104796 C
This two-conductor cable was found to have its conductors reversed at the terminal block. The
- specific circuit had no polarity requirement and thus j the reversal did not have any functional impact on the
! circuit operation. The physical terminations have been
- corrected to match the drawing.
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. . Page 13 of 15 1
RESULTS REPORT ISAP I.a.4
-(Cont'd)
) .
5.0 IMPLIMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.5 Cable EG021856 This_ cable was found to be a designated " spare" per a properly issued design change document (DCA 19948, j 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
.l' interconnection drawing and is not terminated. There 1 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 j terminated at the time of the NRC-TRT inspection.
j Since the cause of this finding appeared to be a delay in updating the interconnection drawing to reflect a k ._, ' DCA, the Electrical RTL reques'ted 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 1 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 j- documents.
~
3 .
l 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
, conductors have subsequently also been lifted from the
- terminal blocks.
I 5.4 Root Cause and Generic Inclications r
- Since the activities carried out during the implementation of
- this action plan did not reveal any deficiencies, neither a root cause nor a generic implications evaluation is necessary. ;
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'f RESULTS REPORT i.
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4 ISAP I.a.4 h (Cont'd) d U-ii 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF REST,*LTS (Cont'd)
- j 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 necessary step in e 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 i: inspection procedure, the correctness of these terminations is
. verified by this process. In inspecting over 500 conductors l with butt splices, no functionally-incorrect terminations were j- discovered. One cable (A0130852) was noted to have two
- conductors reversed at the terminal points.- As in the case of j the conductor reversal-discovered by NRC-TRT, these conductors
- l were in a single circuit with no polarity requirement, and
- 8
.l
(.. thus were functionally correct. These conductors, however, have.been reterminated to match the* drawing. .
i i ;! ISAP VII.c. " Construction Reinspection / Document Review Program," will include an inspection of 60-120 cables
- (including at least 60 in circuits that are ir.portant to safety). One of the inspection attributes is the correctness
- l 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 in the results report for ISAP VII.c.
5.6 Out-of Scope Findings During the sample inspections, the inspectors found four (4)
. white conductors terminated at points which drawing
- 2323-El-0156 Revision CP-4, showed to be vacant. These conductors were not part of the sample. TNE reviewed this l drawing and determined that the subject conductors had.been l, deleted (by drafting error) during incorporation of a DCA.
j; The terminations were in accordance with the DCA and are
- functionally correct. The subject drawing has subsequently been corrected to show these terminations.
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I RESULTS REPORT .
ISAP I.a.4 j (Cont'd)
- 1
6.0 CONCLUSION
S
.i A CPRT inspection of 322 randomly-selected " safe shutdown" terminations found all to be functionally in accordance with the
{ applicable design documents. Further, of the six cases identified j by NRC-TRT involving cables not being terminated in accordance with
- drawing requirements, none was found to be in functional disagreement with design requirements. It is noted that the i 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 Plan VII.c). This inspection is not limited to only the " safe shutdown" terminations.
e
'. 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 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."
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE TUTURE i
Since no programmatic deficiencies were found, there ate no corrective actions required.
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.i COMANCHE PEAK RESPONSE TEAM j ,
RESULTS REPORT ISAP: 'I.b.3
Title:
Conduit to Cable Tray Separation REVISION 1
- I 1
8 4
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_ _ . YAb b Y- hJ $5lf Y .20/V$b i Issue Coordin e r ## Date LL1.hralL A 3/zo/eG Da(e #
RJviewI :n Lea' der Qw-4).8a-Joht'/ W. Beck, Chairman CFRT-SRI 3 /2 s, h c.,
Date.
s 4 DRN F860404 ADOCK 05000445 PnR
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[ . ISAP I.b.3.
Conduit to Cable Tray Separation N
i e
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No.
!' 7, Page J-42) r i "The TRT found no evidence that'the existing G&H analysis for-establishing the criteria for a 1-inch separation between rigid
. conduits and cable trays, as stated in G&H' Electrical Erection
- s Specification 2323-ES-100, had been evaluated by the NRC staff for i' Comanche Peak. This analysis should have been referenced in the FSAR."
1 2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement No. 7,' Item 6(e),
ji Page J-44) l "TUEC shall accomplish the following actions prior to fuel load:
l Submit to the NRC the analysis substantiating the acceptability of
, the criteria stated in C&H electrical erection specification
- l governing the separation between separate conduits and cable trays.
- l L This analysis shall be supported with the necessary documentation in sufficient detail to perform an independent evaluation of how these criteria were established based on the analysis."
4;
3.0 BACKGROUND
i' Raceway' separation criteria utilized in Gibbs & Hill electrical
)! ,
drawings and specifications were based upon the requirements of f
IEEE 384-1974, "IEEE Trial-Use Standard Criteria for Separation of ji Class 1E Equipment and Circuits", and Regulatory Guide 1.75,
- l '
Revision 1, January 1975, " Physical Independence of Electric Systems". Although very specific criteria are provided in the standard and regulatory guide for separation between redundant
- cable trays, the same degree of specificity is not provided for 9
separation between conduits and cable trays.
4 t
i-All separation requirements in this report are for redundant cable '
- trays and/or conduits. The word " redundant" as used herein means that the cable trays and/or conduits requiring separation belong to
~
i j, different trains, i.e., Class IE train A, Class 1E train B, or i
, non-Class 1E train C. No;e that cable trays and/or conduits of the
- same train require no separation.
i'
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} ISAP I.b.3 j (Cont'd) s i
4
3.0 BACKGROUND
(Cont'd)
Since Regulatory Guide 1.75 Revision 1. January 1975, and IEEE 384-1974 do not specifically provide criteria for conduit-to-cable tray separation, Gibbs & Hill originally interpreted these documents to require a one-inch minimum separation between a safety-related conduit and an open cable tray 3 when the conduit is below the top of the side rails of the cable tray. This interpretation was included in a Gibbs & Hill document
'l entitled " Criteria for Separation of Class l'E Equipment and Li Circuits". This document was transmitted to the TUGC0 project for i their information and use via letter GTN-2441, dated February 19, i 1975. The above criterion, along with separation requirements for safety-related conduits above cable trays, was added to Electrical Erection Specification 2323-ES-100 in the form of Design Change Authorization (DCA) 6132, dated November 16, 1979. This DCA also included all separation criteria for non-safety related conduit.
Specification 2323-ES-100, Revision 2, dated January 1981, which i incorporates DCA-6132, statas in Section 4.11.1 that the Engineering drawings showing the plant layout utilized the j separation criteria transmitted via Gibbs & Hill letter GTN-2441.
l The separation criteria, as stated in 2323-ES-100, are to provide i
"the necessary information for assisting the contractor in field
,, routing the conduit . . . ."
~! During the Gibbs & Hill review of DCA-15917, which authorized a
. . reduction in the separation criterion for a conduit above an enclosed' raceway from four inches to one inch, the adequacy of the '
3 existing one-inch separation criterion for safety-related conduits and open cable trays was questioned. This issue was. resolved by Gibbs & Hill memo EE-863, dated January 17, 1984, which included the Gibbs & Hill report and simplified analysis that the NRC-TRT reviewed on site (See Section 1.0). The purpose of the memo was to establish the engineering interpretation of required separation between conduits and cable trays in accordance with established criteria in the standard and regulatory guide. This. supporting documentation was not submitted to the NRC staff for review because the interpretation was not considered a deviation to the standard
- or regulatory guide, but ves considered documentation supporting the implementation of these requirements.
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ISAP I.b.3 (Cont'd) 1 j- 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan was to substantiate the acceptability of the criteria governing the separation between conduita and cable trays and to submit the evaluation and supporting documentation to the NRC.
To achieve this objective, the following tasks were implemented:
- Gibbs & Hill prepared a report compiling criteria and
- supporting analyses
, - The Electrical Review Team reviewed the report substantiating the separation' criteria 2 -
The TUGC0 Coordinator initiated the sub=ittal of the l report to the NRC I .
8 4.1.1 Report Preparation
, Gibbs & Hill prepared a report for TUCCO presenting the methodology and criteria used in applying IEEE 384-1974 and Regulatory Guide 1.75 Revision 1, l January 1975, to conduits requiring separation from i cable trays. Included was a copy of a Sandia Report
(" Cable Tray Tire Tests", SAND 77-1125C), which i documents a series of tests funded "by,the Nuclear Regulatory Commission to provide data needed for confirmation of the suitability of current design i standards and regulatory guides for fire protection and i control in water (cooled) reactor power plants".
4.1.2 Report Review t
The above report was submitted to the Electrical Review Team for review.
- Report Submittal to NRC 4.1.3
- The TUCCO Coordinator submitted an TSAR Change Request to TUCCO Nuclear Engineering for submittal to the NRC for review. The TSAR Change Request provides a description of the existing conduit-to-cable tray separation criteria. Supporting documents are attached to the TSAR Change Request.
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RESULTS REPORT l ISAP I.b.3 -
j (Cont'd)
}
'.! 4.0 CPRT ACTION PLAN (Cont'd) 1
! 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
'h 4.2.1.1 Assisted the Electrical Review Team in reviewing the report compiling the Gibbs &
- Hill criteria.
t 1 4.2.1.2 Will submit, upon approval, the FSAR Change Request and supporting documents to the NRC.
4.2.1.3 Personnel
! Mr. W. I. Vogelsang, TUCCO Coordinator
/
4.2.2 Electrical Review Team l
4.2.2.1 Reviewed the report compiling the Gibbs &
, Hill criteria.
4.2.2.2 Personnel (prior to October 18, 1985)
Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe. Issue Coordinator 4.2.2.3 Personnel (starting October 18, 1985)
! Mr. J. J. Ma11anda, Review Team Leader Mr. R. J. Bizzak, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser l
Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 Gibbs & Hill l 4.2.3.1 Prepared a report compiling the criteria used in confirming the adequacy of conduit-to-cable tray separation.
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i RESULTS REPORT
- 1 ,
)l ISAP I.b.3 (Coat'd)-
i q
- i 4.0 CPRT ACTION PLAN (Cont'd) !
11 ii si 4.2.3.2 Personnel !
Mr. S. P..Martinovich, Principal Engineer-
+
, Electrical i 1
Il 4.2.4 Tliird-Party Adviser (prior to October 18, 1985) cl l
- } 4.2.4.1 Reviewed the report compiling the Gibbs & l
- Hill criteria, i 3
4.2.4.2 Personnel
+
,i.
Mr. L. D. Bates, Third-Party Adviser I
jr 4.3 Oualification of Personnel 4i it i: Third-party participants in the implementation of this action
!l plan met the personnel qualification and objectivity j-
~
. requirements of the CPRT Program Plan and its implementing
) procedures. '
O Other participants were qualified to the requirements of the ;
ij; CPSES Quality Assurance Program or to the specific ij 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
.! Not applicable. l
- j 4
i j; 4.5 Acceptance Criteria ii Tj The acceptance criterion for the report was that it ii demonstrate that the conduit-to-cable tray separation criteria lj meet the intent of IEEE 384-1974 and Regulatory Guide 1.75,
- i Revision 1,. January 1975. This was met as discussed in l .Section 5.0.
,; 4.6 Decision Criteria
- I
- li If compliance with IEEE 384-1974 and Regulatory Guide 1.75, Revision 1 January 1975 could not be adequately demonstrated.
-_. the conduits and cable trays would have to be modified. as lj l, appropriate, to achieve compliance.- This was not necessary i
as discussed in Section 5.0.
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,- Page 6 of 13 RESULTS REPORT ISAP I.b.3 I (Cont'd) 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summarv A report based on the information contained in Gibbs & Hill memo EE-863 was prepared by Gibbs and Hill. This report addressed those separation distances between a conduit and an open cable tray which did not meet the criteria given in IEEE 384-1974 for open cable trays. The primary' reference used- to j substantiate the conduit-to-cable tray separation criteria was
! a Sandia report documenting a series of electrically initiated l cable tray fires. One case which is not directly, evaluated in j .the Sandia report is the case of a safety related conduit one inch beside or below an open cable tray. The just!1fication presented in the Gibbs & Hill report for the one inch separation case mentioned above was a simplified analysis from EE-863 which utilized cold wall heat flux values from the Sandia report.
l The above Gibbs & Hill report, originally issued in September
. i 1984, was reviewed by the Electrical. Review Team during the i .
late 1984/early 1985 time frame and revised several times to I incorporate comments. Subsequent to the above review cycle, j -
questions remained on-the simplified analysis presented in the
, report. To alleviate these concerns, Gibbs & Hill performed i computer analyses in the' summer of 1985, using an alternate l
} methodology, to substantiate the simplified analyses.
4 Although the computer analyses were in agreement with the results of the simplified analysis, a subsequent review of the ,
, report and analyses in the last quarter of 1985 by the ^
l
- j Electrical Review Team identified inconsistent assumptions in the simplified analysis which required subsequent justifications. A final report utilizing a revised computer
! analysis was completed and issued to TUGC0 by Gibbs 4 Hill.
The final report and analyses have been reviewed by the Electrical Review Team Leader and Issue Coordinator. The j conclusion is that the above documents provide adequate justification of the existing conduit-to-cable tray separation; therefore, no plant modifications are required. A summary of the report is given in the following section.
i 5.2 Conduit / Cable Trav Separation Criteria The separation criteria in Gibbs & Hill Electrical Erection Specification 2323-ES-100 are graphically presented on Drawing ,
' ~
2323-El-1702-02, Revision 2. " Cable and Raceway Separation l
, Typical Details". l
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ISAP I.b.3 "
(Cont'd).
l 5.0 IMPLEMENTATION OF ACTION PI.AN AND DISCUSSION OF RESULTS (Cont'd) i.
l The separation criteria shown on Gibbs & Hill Drawing j_ 2323-El-1702-02 apply only when hazards are limited to q- electrically-initiated fires due to failures or faults internal to electrical equipment or raceways. This is consistent with the definitions given in IEEE 384-1974 for the
. cable spreading ar'en and general plant areas.
i The criteria given in IEEE 384-1974 for separation of
- redundant cable trays for the above areas are
L Cable Spreading Area - Both I foot horizontally cable trays are open ventilated 3 feet vertically trays.
t General Plant Areas - Both 3 feet horizontally cable trays are open ventilated 5 feet vertically F trays.
p ,m i s _. Cable Spreading Area and 1 inch horizontally i General Plant Areas - Both 1 inch vertically cable trays are enclosed.
The IEEE standard also allows the separation distances to be i' alternatively established by analyses / testing "to determine the flame retardant characteristics of the proposed cable installation. . . ."
Although the above specific criteria for redundant, open cable trays are provided in IEEE 384-1974 and Regulatory cuide 1.75, Revision 1. January 1975, the same degree of specificity is not provided for separation between conduits and cable trays.
However, the above separation distances for open cable trays could be reduced when one train of circuits is in conduit since a barrier
- new exists between the two redundant trains.
The current CPSES conduit-to-cable tray separation criteris i are depicted in Details 45 thru 49, 52 thru 55, and $7 of
- Drawing 2323-El-1702-02. A summary of these criteria follows
I The IEEE 384-1974 definition of a barrier is "a device or structure interposed between, Class 1E equipment or circuits and a potential source of damage to limit damage to Class 1E systems to an acceptable level."
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- Page 8 of 13
-x RESULTS REPORT P
ISAP I.b.3' (Cont'd) ,
d 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Cable Spreading 'l foot horizontally When conduit .
Area 2 feet vertically elevation
- is above the top of the cable tray side rails or 4 when the cable tray 1s vertical.
l f General Plant 3 feet horizontally Wen conduit ~
? Area 3 feet vertically elevation
- is above
! the top of the cable j tray side rails or when the cable tray is vertical.
Cable Spreading 1 inch horizontally When conduit Area and General 1 inch vertically elevation
- is below
, Plant Areas the top of the cable j _
tray side. rails
+ / (cable tray j L- horizontal), conduit j is non-safety j related, or cable tray is enclosed.
l In cotaparing the conduit-to-cable tray separation criterf a i
given above to the criteria provided in IEEE 384-1974 for open
, cable trays, the following three categories of differences are i noted:
6 Category 1 - Non-Safety Related Conduit Separation between conduit and cable tray is one inch l when conduit is non-safety-related.
l Category 2 - Safety-Related Conduit Above Cable Trays Vertical distances are 2 feet /3 feet for safety-related conduits over open cable trays in the cable spreading / general plant areas, respectively.
. Cr.tegory 3 - Safety-Related Conduit Below the Top of the Cable Tray Side Rails Separation between conduit and cable tray is one inch l vhen conduit elevation is below the top of the cable !
~
tray side rails. j
- Conduit elevation is top of conduit.
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ISAP I.b.3 ,
I (Cont'd)
,. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
! Category 1 - Non-Safety-Related Conduit i
The CPSES minimum separation for non-safety-related conduits adjacent to safety-related cable trays is one inch, regardless of orientation. The non-Class 1E circuits in the conduit do l not have to be protected from~a cable fire in the cable tray-j since the non-Class IE circuits do not provide a safety function. However, the' Class IE cables in the cable tray do
} have to be protected from a fire in the conduit. The conduit t
in combination with a one inch air space will provide adequate d, . protection to the safety-related cable tray. This configuration is similar to Figure 5 of IEEE 384-1974.
It should be noted that a fire in a conduit represents a less severe source of damage than a. fire in an enclosed cable tray since:
- Conduit size is limited to five inches thus limiting the volume of cables contained.
j g3 i \
Threaded connections provide an essentially air-tight t
medium which inhibits internal combustion and effectively isolates internal events from the surroundings.
1 -
The curved surface of the conduit provides a radial
' distribution of radiant heat and, therefore, less favorable heat transfer characteristics to or from an-3 adjacent cable tray than a flat surface of equivalent ar.e a .
Category 2 - Safety-Related Conduit Above Cable Trays The basis for the adequacy of vertical separations given in this category is electrically initiated fire tests conducted by Sandia Laboratories and presented in Report SAND 77-1125C,
" Cable Tray Fire Tests." One of the objectives of these tests was to use cables representative of those used in the nuclear industry. An industry survey of 13 leading architect-engineering firms, 13 utility companies, and 13 cable manufacturers was performed. Twenty (20) different cable types were screened on the-basis of popularity of use, small scale electrically initiated cable insulation fire tests. UL FR-1 flame test, and pyrolyzer and thermal chromatograph testing (which measured insulation outgassing as a function of
- temperature). The cable constructions tested are
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- f. ,
ISAP I.b.3
]; (Cont'd)
[
!. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) representative of those used at CPSES. T'he cables used at CPSES comply with IEEE 383-1974, " Standard for Type Test of
]...
Class 1E Electrical Cables Field Splices, and Connections for
[ Nuclear Power Generating Stations". The cables used in the
~
J.
Sandia tests "were capable of passing IEEE. Standard 383-74".
l Therefore, the Class 1E cables at CPSES and the cables used in the Sandia tests have similar flame-retardant characteristics, i
- The Sandia testing showed that, for an electrically initiated cable tray fire, cables in an open tray located 10.5 inches
. vertically above the tray with the fire did not burn. All circuits in the cables above the fire remained functional. As noted above, the CPSES criteria for safety-related conduits located above cable trays is a minimum of two feet. It should be emphasized that the Sandia tests were performed using exposed cable; therefore, the CPSES criteria are even more conservative since the cables at CPSES are enclosed in a barrier. -
\
Some of the more significant observations of the nature of j electrically initiated fires noted in the Sandia Report are:
i
- The fire characteristics do not vary greatly from one i ' cable fire to another. .
- The intense period of the fire at a particular location lasts between 40 and 240 seconds before die-out begins to occur.
i .
The luminous zone of the fire is optically thin which means that the major heat transfer mechanism is convection versus radiation.
Based on the above, given a specified separation, the worst configuration is conduit over the cable tray since the conduit
, will be exposed to both convective as well as radiation heat transfer. Since the exposed cable 10.5 inches above the fire remained functional, any cable enclosed in a conduit (which
! provides additional heat protection for the cable) 10.5 inches or more from an electrically initiated fire will also remain functional. ,
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RESULTS REPORT kt i ISAP I.b.3 (Cont'd)
.g 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)-
7 Category 3 - Safety-Related Conduit Below the Top of the Cable
- f
- Tray Side Rails
. r
!!; The only case where a safety-related conduit at CPSES can be less than 10.5 inches from an open cable tray la when the conduit elevation is below the top of the cable tray side rails. The major heat transfer mechanism for this configuration is radiation. Based on the above noted jl [t characteristic of the Sandia test fires (i.e. the luminous j- zone of the fire is optically thin), radiation is a minor part
- ! of the heat transferred from'the fire to objects immersed in the flame. l
- e In order to quantify the response of a conduit beside or below a cable tray, a computar analysis was performed by Gibbs &
Hill for the case of a conduit one inch directly below the l} fire. (Note that conduits alongside cable trays are partially
!j -
blocked from tha radiation from the flame by the cable tray li.
I side rails.) Cable fire parameters taken from the'Sandia
- j Report were used- as inputs to this analysis.
The above analysis included the following conservatisms:
- R'
[ - The fire data used in the analysis was for the October 5, 1976, fire test, one of the most intense and
[L longest duration fires studied.
f The radiation heat flux applied to the conduit was taken just slightly above the burning tray (i.e., in
- l the flame) rather than one inch away.from the flame.
'! - The radiation heat flux, based on the maximum flame l} temperature, was held constant from 30 seconds to 240
- ! seconds. The test data showed that temperatures
'! measured by a thermocouple in the flame varied from
- f. 1150'T to 700*F during this period.
The flame diameter was held constant at eight inches.
I
!! - No blockage was assumed by other cables in the cable tray with the fire.
l The cable enclosed in the conduit was assumed to be at the same temperature as the conduit. No credit was j! .- taken for the cable acting as a h'aat sink.
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- lI'.
- I ISAF I,b.3 (Cont'd) p 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- l The results of the analysis showed that the conduit exceeded
, 302*F (150*C) for approximately 4-1/4 minutes with a maximum temperature of 357*F (181*C), assuming an ambient temperature
, of 122*F (50*C).
The Electrical Review Team reviewed the manufact'urers' data for the cables used at CPSES. All cables are qualified for j 302*F (150*C) for a minimum period of one week. Additionally,
.) the cables with silicone insulation were tested at a minimum t temperature of 392*F (200*C) for seven days and remained
,. functional. Anaconda FR-EP cables were qualified for a LOCA l environment by testing at 385'T (196*C) for two twelve-minute
- periods. The remaining cables were LOCA tested at a minimum I
of 345*F (174*C) for a minimum of four hours. The cables subjected to the above tests to simulate LOCA environmental conditions remained functional.
i!
j ,- Additional evidence which supports the adequacy of CPSES -
- i conduit separation one inch below cable trays is provided in 41 the results of the propane-fueled exposure fire tests also
- conducted by Sandia in which conduits and trays were included.
j In these tests, fourteen (14) trays were stacked _ seven -(7) i high by two (2) wide separated vertically 10.5 inches.
Directly below each tray (except for the bottom tray exposed to the propane-fueled source) was a conduit containing additional cables. Although all circuits in the conduits above the third tray failed during the exposure fire (the i higher conduits experiencing heat input from all fires below I them), circuits in the lower two (2) conduits maintained circuit integrity'throughout the duration of the fire.
l, i Considering that the fire in the lower two (2) trays was more severe than in an electrically initiated fire, being larger in aise end of longer duration, the results provide an indication
- ' cf the adequacy of protection offered by conduits in.stelled with an air gap of one inch during the less severe electrical fire.
L 5.3 FSAR Change Request Submittal k The TUCCO Coordinator submitted an FSAR Change Request to l
TUCCO Nuclear Engineering for submittal to the NRC for review.
The FSAR Change Request provides a description of the existing conduit-to-cable tray separation criteria. Supportir.g l m-- documents were attached to the FSAR Change Request. )
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, RESULTS REPORT *
! i..
- i. ISAP I.b.3 1~ (Cont'd) 1
',j .-
- 1 5.0 IMPLEMENTATION OT ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- j! 5.4 Classification and Evaluation of Discrenancies R
li No design deviations were noted in the implementation of this
.; action plan. However, two design observations were noted.
j' The first observation was that analyses did not exist at the
- i time that the criteria for conduit-to-cable tray separation I were placed in design and construction documents. The basis
' ;. for the criteria appeared to have been engineering judgment
.. based on experience with other nuclear projects. The second observation was that inconsistent assumptions used in the Gibbs & Hill simplified analysis verifying the one-inch separation criteria were not discovered during the design verification process.
Since no deviations were found, no root cause analysis was
- performed. The observations were too few in number and too limited in scope to identify a trend. Therefore, the facts
~'
(- relating to these observations were transmitted to the Design l
Adequacy Keview Team Leader in accordance with Appendix A,
.i " Design Adequacy Program Plan", to be included in the collective evaluations of that plan.
f
6.0 CONCLUSION
S i
)
. The established conduit-to-cable tray separation criteria meet the i intent of IEEE 384-1974 and Regulatory Guide 1.75 Revision 1, January 1975. No corrective actions are required.
, 7.0 ONGOING ACTIVITIES The FSAR Change Request and supporting documents have been issued to TUCCO Nuclear Engineering (TNE) by the TUCCO Coordinator. TNE ,
will transmit the information to TUGC0 Licensing, which is the l formal channel for submitting information to the NRC. l
' I The design observations noted in Section 5.4 were forwarded to the '
DAP RTL in accordance with Appendix A, " Design Adequacy Program Plan", to be included in the collective evaluations of that plan. )
1 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE i
'~
Since no design deviations were found, ne corrective actions were required.
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.j 3 COMANCHE PEAK RESPONSE TEAM i
, RESULTS REPORT L
2 I l ISAP: II.b '
y I
Title:
Concrete Compression Strength
}.
REVISION 1 i
.l l i
.s i
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f fuel 1 Iss e Cdorsind' tor
- ll/'
.2 2.7 f4 Date/
L R(vied'Teah LeaMgr*
~
) LJ V Date' 1hekc, O. _ <<l- L 2P EC_
Joh(./ W. Beck, Chair:an CPRI-SRI Date i
i i
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. Revision: 1 Page 1 of 31 RESULTS REPORT
. ISAP II.b
, , Concrete Cospression Strength
1.0 DESCRIPTION
OF ISSUE
- I ~.
The TRT investigated allegations that concrete strength tests were falsified. The TRT reviewed an NRC Region IV investigation (IE Report No. 50-445/79-09; 50-446/79-09) of this matter that included d:." g p{; interviews with fifteen individuals. Of these, only the alleger and one other individual stated they thought that falsification j1 occurred, but they did not know when or by whos. The TRT also l reviewed slump and air entrainment test results of concrete placed j: during the period the alleger was employed (January 1976 to i February 1977) and did not find any apparent variation in the l- uniformity of the parameters for concrete placed during this period. Although the uniformity of the concrete placed appears to minimize the likelihood that low concrete strengths were obtained, other allegations were raised concerning the falsification of i records associated with slump and air content tests. The Region IV j staf f addressed these allegations by assuming that concrete
- g strength test results were adequate. Furthermore, a number of l , other allegations dealing with concrete placement problems (such as .
i
, deficient aggregate grading and concrete in the mixer too long) were also resolved by assuming that co'ncrete strength test results were adequate.
1 The TRT found that the preponderance of evidence suggests that.
i falsification of results did not occur. However, since a number of
-! other allegations were resolved on the basis of concrete strength j: results, the TRT believes that action by TUEC is required to provide confirmatory evidence that the reported concrete strength
- test results are indeed representative of the strength of the i concrete placed in the Category I concrete structures. -
! l t *
-j 2.0 ACTION IDENTIFIED i
Accordingly, the NRC outlined the following action: TUEC shall ;
determine areas where safety-related concrete was placed between i January 1976 and February 1977, and provide a program to assure acceptable concrete strength. The program shall include tests, such as Schmidt Hammer tests, on a random sample of the concrete in areas who're safety is critical. The program shall include a comparison of the results with the results of tests performed on L i. concrete of the same design strength in areas where the strength of
- - the concrete is not questioned, to determine if any significant variance in strength occurs. TUEC shall submit the program for i
performing these tests to the NRC for review and approval prior to s_. performing the tests.
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1 !
RESULTS REPORT U' ISAP II,b (Cont'd)
J 3.0 BACKCROUND Si Falsification of concrete strength tests is alleged to have j} .
occurred between January 1976 and February 1977. Air content and slump data were reviewed by the TRT and no apparent variations were found in the the uniformity of the parameters for concrete placed
- during the allegation time frame. However, concrete compressive 4, strength tests have been used by the NRC to resolve previous allegations of falsifications of slump and air entrainment tests
- g. and. allegations dealing with concrete placement problems (such as
- . deficient aggregate grading and concrete in the mixer too long).
'!. Due to the importance of concrete compressive strength tests in
'l- assessing the allegations the TRT requested that additional tescing be performed by TUEC to confirm that concrete strength tests performed on the concrete in question are representative of the actual concrete strength. Therefore, TUEC implemented a program to test the concrete-at-issue for verification of acceptable strength.
j 4.0 CPRT ACTION PLAN I
4.1 Scope and Methodoloav,
.) This action plan was designed to verify the quality of the
, concrete-at-issue. It was proposed that the relative l strengths of concrete poured during the period in question
- i, i
(concrete-at-issue, or CAI) and concrete poured during the six months immediately following this period (control
'] ;
concrete, or CC) be compared using the Schmidt Hammer test as a relative measure of strength. This time period for the CC was selected to minimize any effect of aging on the comparison
!!:' of the two sets of hammer data and to provide approximately equal volumes of concrete for the CAI and CC. The Schmidt (Rebound) Hammer test, a non-destructive test, was conducted
'h in accordance with ASTM-C805-79 " Standard Test Method For Rebound Number of Hardened Con: rete" (Reference 7.1). The
- Schmidt Hammer is essentially a concrete hardness tester which measures the rebound of a spring loaded plunger after it has struck a smooth concrete surface.
l Using this indirect test of strength, those portions of the
~; two populations of concrete that were accessible for surface
- i. testing have been compared empirically and statistically. In
( addition to recording the raw rebound number data and average indication for each test, statistical summaries, such as means and variances, have been computed for both CAI and CC v
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Revision: 1 Page 3 of 31
- i RESULTS REPORT ,
7 ., ISAP II.b j' (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
- j. populations. Both normal and unspecified (non-parametric) il distributions have been considered for the populations. For
.) the normal distribution assumption, goodness-of-fit tests of
'/ ' the sample data were performed.
Concrete cylinder data for the two populations have also been it obtained, reviewed, and used for reference (see Section 4.4).
,! The two populations of average hammer indications have been
,; compared at the tenth percentile level. The tenth percentile is selected as a point of comparison based on the American Concrete Institute (ACI) Standard 214-65, " Recommended Practice for Evaluation of Compression Test Results of Field Concrete" (Reference 7.2), which gives the general guideline that no more than one out of ten cylinder compression tests shall fall below the design strength. The population of
- average hammer indications for the control concrete was used
, to establish a tenth percentile target and the tenth '
t percentile average hammer indications for the concrete-at-issue was then compared with this target value. Other CC target values (i.e., fractions of the CC tenth percentile) were also used for comparison. Hypotheses that the tenth percentile for the CAI is greater than or equal to various target values were tested at a minimum significance level of five percent. In addition, the significance level at which an hypothesis is just accepted was determined. A higher significance level passed indicates a greater confidence that the hypothesis is true.
4.1.1 Test Program
- l 4.1.1.1 TUGC0 Nuclear Engineering Civil Structural (TUCCO) determined the areas where concrete was placed in Category I structures between January 1976 and February 1977 (Reference 7.3).
4.1.1.2 From these areas, TUGC0 determined the number
.3 of truckloads of concrete for which part of the concrete of that truckload is exposed and a
testable (Reference 7.3).
_ 4.1.1.3 Each truckload identified as exposed and testable was assigned a unique number (Reference 7.3).- .
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, ,j ;
!! ,' RESULTS REPORT 4
ISAP II b l (Cont'd) l[ 4.0 CPRT ACTION PLAN (Cont'd)
].
4.1.1.4 Grid volumes corresponding to these truckloads were selected at random to be tested (Reference 7.3).
i
- 3. 4.1.1.5 The concrete surface for each selected volume j, was prepared by Brown & Root Craft personnel g; for testing per ASTM C805-79. Southwest
- j. Research Institute (SWRI) personnel were j responsible for inspecting and accepting the
- L prepared surfaces before testing.
1 "I
- 4.1.1.6 The prepared areas were tested by SWRI personnel (Reference 7.4) in accordance with
' ASTM C805-79.
4.1.1.7 TUGC0 determined the areas where concrete va:
- ! placed in Category I structures between Maren l 1977 and August 1977 (Reference 7.3).
I j 4.1.1.8 From these areas, TUCCO determined the number j ~~
of truckloads of concrete for which part of the concrete of that truckload is exposed and testable (Reference 7.3).
4.1.1.9 Each truckload identified as exposed and a
testable was assigned a unique numb'r e (Reference 7.3).
i 4.1.1.10 Grid volumes corresponding to these .
truckloads were selected at random for -
l testing (Reference 7.3).
4.1.1.11 The concrete surface for each selected grid volume was prepared by Craft personnel for
, testing per ASTM C805-79 and inspected by
- . SWRI prior to testing.
I
, [. 4.1.1.12 The prepared areas were tested by SWK1
- (Reference 7.4) in accordance with ASTM C805-79.
4.1.1.13 Third-party overview consisted of review and check of activities in 4.1.1.1 through 4.1.1.5 and 4.1.1.7 through 4.1.1.11 i ii __ (Reference 7.5). 1 1
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- Revision: 1 Page 5 of 31
(. - '
.l. RESULTS REPORT .
i
- 1 ISAP II.b l
- ). (Cont'd) !
l l o
a- 4.0 CPRT ACTION PLAN (Cont'd)
~j; 4.1.2 Sampling Plan
- j-1- At Comanche Peak, concrete placement quality procedures
'k were based on the required air content and slump tests being performed on each truckload. Test cylinders from the first truckload and every tenth truckload thereafter were required to verify quality. These
[ procedures were based on ACI-ASME 359 and ACI 318 l (References 7.6 and 7.7, respectively), which reference I i appropriate ASTM standards. Since the original quality
.j' control program was based on the unit of a truckload.
.i the truckload was empicyed as the unit to be tested in
, the present quality evaluation. This is consistent with the inherent assumption in the ACI code that a truckload represents the smallest unit of concrete with uniform material properties.
.I f Since Schmidt Hammer tests can only be performed on
. exposed surface area, the determination of the number
, - of truckloads which were placed as exposed testable
, concrete was determined as follows:
i j -
For slabs on grade, the number of truckloads
- j; was calculated as:
(l depth,X Surface Area)/10 yd' per truck A depth of one foot was used, because, during placement, vibrators caused the concrete to
~
flow and level out. Thus, only truckloads placed in the last foot of the slab would be exposed.
For columns and walls the number of
, truckloads was calculated as:
t Total Volume /10 yd 8 per truck '
4 For suspended slabs up to 28 inches chick,
,: the number of truckloads was calculated as:
! Total Volume /10 yd 8 per truck
~-
Each truckload was considered to be accessible on either surface for slabs less than 18 inches thick. For slabs between 18 i
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Revision: 1 Page 6 of 31 RESUI.TS REPORT
- . . ISAP II.b t; (Cont'd) *
- l:
f 4.0 CPRT ACTION Pt.AN (Cont'd)
- j. and 28 inches the total number of truckloads were distributed equally between the top and
- [ bottom halves of the slab.
- j: -
For suspended slabs between 28 and 46 inches
- ! thick. the volume of concrete was split into
- !. three equal quantities, with one third at the top, one third on the bottom and one third in the middle of the slab. The top and bottom
'[ layers were considered as exposed and
,4 testable. The middles layer was included.if
- it could be tested from the side.
- ,. Slabs not falling into the above categories were handled on a case by case basis. For example, a portion of a thick slab on grade below the one foot
.j depth was accessible from a tunnel and hence was
- , . included. ,
J
- j Of the 326 Category I concrete pours placed between
.) January 1976 and February 1977, 103 were for seal
'i slabs, shotcrete, grout, or concrete backfill, and are inaccessible for surface testing. Of the remaining 223
- L pours, 197 were found to be at least partially
.}' accessible for Schmidt Hammer testing (Reference 7.3),
which corresponds to a testable CAI population of approximately 1300 truckloads. A total of 119 randomly
,y
- selected truckload units was tested from this
, population. Table 1 gives a breakdown of the .
' Category I concrete pours placed'in the allegation time frame. .
' Comparable numbers of truckloads define the population of testable control concrete and the sample cf the truckload units that were tested (see Table 2).
4.1.3 Concrete Cylinder Data !
l The 28-day cylinder strength data (Reference 7.8) were
- i obtained from the TUGC0 Records Center for the time period in question and the control concrete time frame.
' The data, which represents all Category I concrete
.; pours except seal slabs, etc., were statistically evaluated and used as reference ~informacien in the
't '
hammer data evaluation. The completeness of the data list was checked by the third-party (Reference 7.5).
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Page 7 of 31
. l I
~
RESULTS REPORT g
ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
.1 4.2 Participants Roles and Responsibilities J
t
.,t- The organizations and personnel that have participated in this work. are described below with their respective scopes of effort j
}
'l l, -
4.2.1 TUCCO Nuclear Engineering Civil Structural 4.2.1.1 Scope i
ti Concrete population determination Sample selection Lo' cation of test areas and preparation of operational traveler
.i -
' Acquisition of 28-day cylinder data Assistance in evaluation of test data and preparation of Results 4 Report
': 4.2.1.2 Personnel 1
Mr. R. Hooton Project Discipline 4
> Supe rvisor Mr. R. k'illiams Supervising Engineer Mr. C. Corbin
. Civil Engineer 1
4.2.2 Brown & Root
.i 4.2.2.1 Scope J
Prepare concrete test surfaces
- 4.2.2.2 Personnel
. 4 Craft personnel as required 4.2.3 Third-Party Activities 4.2.3.1 Scope Review of sample selection
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,R3visien: 1 Paee 8 of 31 RESULTS REPORT i
ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) j y
Perform hammer tests (SWRI)
Document tests (SWRI)
- Review test data
! - Review and statistical evaluation of j test results
- - Preparation of Results Report i
4.2.3.2 Personnel Mr. H. A. Levin TERA, CPRT Civil /
- Structural Review Tea =
Leader i
j Dr. J. R. Nonekamp TERA Manager TRT Issues, i
i Dr. F. A. Webster .JBA, Associate (Engineering Statistical Consultant)
{
i Dr. D. Veneziano MIT, Professor of Civil l Engineering (Engineering
- Statistical Consultant)
Mr. G. Lagleder SWRI Manager -(Testing j e and Inspection) 4.3 Oualifications of Personnel 4
Where inspections required the use of cartified inspectors,
. qualification were to the requirements of ANSI N45.2.6 I
(Reference 7.9) at the appropriate level. CPSES personnel
. were qualified in accordance with applicable project requirements. Third-party inspectors were certified to the requirements of the third-party employer's quality assurance program and in accordance with USNRC Regulatory Guide 1.58, Revision 1 (Reference 7.10). The third-party inspectors were specifically trained to the requirements of SWRI Procedure X-FE-108-1, Revision 1 (Reference 7.11).
Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan (Ref erence 7.12), as appropriate.
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- } ?
m -
ISAP II,b
! .l .
(Cont'd) d n
4.0 CPRT ACTION PLAN (Cont'd) t!:
. 4.4 Acceptance Criteria
] A review of the historie 28-day cylinder strength data for (I both time frames (see Figure 1 or Table 3) indicated that, .
Ja regardless of whether falsification of data occurred during
- ] the allegation period or not, it is likely that the CAI,is i lower in strength than the CC. This observation is not-U unusua'1, since under normal construction processes, there is
- only a 50 percent chance that the concrete strength (and 2
hammer indication) in the allegation period we'uld be equal to or greater than that in any other comparable period. There is a' Iso a 50 percent chance that it would be less than that in any other comparable period. Therefore, the appropriate acceptance criterion was determined to be that of accepcing the CAI population if the tenth percentile hammer indication was not "significantly lower" than that of the CC-population. ,
!j In this case, "significantly lower" means not more than about
.. ten percent. This is based on the fact that the design
- strength of 4000 psi is 18.6 percent lower than the CC tenth l . percentile 28-day cylinder strength (see Table 3), and this
- j'
! change in compressive strength (psi) corresponds to.a relative i
chan'e g in hammer indication of approximately ten percent (see i
References 7.13 and 7.14). Thus, the hypothesis that the
, Schmidt Hammer indication tenth percentile for the CAI is not
- j. "significantly lower" than'that of the CC was tested at a minimum statistical significance level of five percent.
l 4.5 Decision Criteria J
Three hypothesis tests were considered for the co=parison of
. the Schmidt Hammer data, with the understanding that the one (or ones) with the most power
- would be used to test the two
, populations. The three test methods include:
. 4.5.1 Method A tests whether the tenth percentile hammer indication of the CAI is greater or equal to the. target value of the CC, where both populations are assumed to be normally distributed (see Reference 7.20). Note, the target value is defined as the CC populacion tenth percentile or a fraction thereof.
Power is defined as the probability of rejecting the hypothesis
- when it is not true. The power function gives the power as a function of disparity with the hypothesis.
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. 'Page 10 of 31
- .. s RESULTS REPORT ISA? II.h
'l (Cont'd) .
-{ l 1 ,
ij' 4.0 CPRT ACTION PLAN (Cont'd)-
1 1
- 4.5.2 Method 5 tests whether the percentage of hammer l
.i indications in the CAI population above~the target '
4 value of the CC is greater or equal to 90 percent. In l
.!- this test the CC population is assumed to be normally 1 distributed for purposes of establishing the target
.T value (which may be defined as the tenth percentile or
- ! a fraction thereof), but the distribution of CAI ham =er i indications is unspecified.
- t 4.5.3 Method C tests whether individual CAI hammer indication
'] data values belong to the same distribution as the control concrete rebound values. No assumptions are
, made regarding either population distribution.
Although the power functions for these three methods are not
- i directly comparable Methods A and B are of similar power and are better than Method C (References 7.15, 7.20, and 7.21) .
Therefore, both Methods A and B were retained to compare the two populations.
- { ..
j Base.d on the sample outcome's for the two concrete populations,
,!' test statistics were computed and the hypotheses regarding the CAI population were either accepted or rejected at the' 5
, percent level of significance. In addition, the levels of
- l significance at which the hypotheses are accepted were also determined.
-t
- ; The action identified by the NRC (Section 2.0) is considered complete now that all Schmidt Hammer tests have been
- completed, the results statistically analyzed, and the two concrete populations compared.
Since the comparison indicates that the CAI population of hammer indications is not "significantly lower" than the CC, no further evaluation of the CAI is necessary, nor is it necessary to calibrate the Schmidt H2mmer test to concrete of known strongth and age or test cores from the CAI.
- 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS
't .
5.1 Sumnarv of Imeleme*tation ---
i The implementation of this action plan followed the flew chart shown in Figure 2. vith the four major aspects of the pregra=
being: 1) identification of all CAI and CC Category I pours
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RESULTS REPORT .
I
~
ISAP II.b (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 4 ll and surface testable truckload populations; 2) the randem selection of truckloads; 3) the preparation and testing of selected areas; and~4) the test data evaluation.
f 4
,e Detailed descriptions of the population identification and random selection processes are contained in Reference 7.3. In i;
summary, all Category I concrete pours in the two time frames l were identified and an estimate of how many and which p truckloads are surface testable was made. These estimated
-( testable truckload populations were randomly sampled for
-[ testing with the Schmidt Hammer, their accessibility verified,
- i and the selected accessible areas were prepared for testing.
'l j Once the test areas were prepared, certified SWRI personnel
- verified the surface preparation, performed the Schmidt Ha=e r
-l tests, sume:arized the ha=e readings, determined the average hammer indication for each test area, and submitted a report (Reference 7.4)?to TUCCO containing these Bata. -
i The third-party statistically evaluated the hammer data is (Reference 7.16), and performed the hypothesis tests which ij were used to compare the two castable populations
- j (References 7.17). A copy of the average hammer indications,
~) as summarized from the SWRI raw data sheets, is listed in j
Appendices A and B of this Results Report. Cumulative frequency plots of the two sample data sets are shown in
, Figure 3.
, In addition to the hammer data, the reported 28-day concrete
'l cylinder strength data.for both populations were obtained from t
the TUGC0 Records Center (Reference 7.8) and statistically
- evaluated (Reference 7.18). -Cumulative frequency plots for these two data sets are shown in Figure 1.
5.2 Data Evaluation
- j Before comparing the two populations using Methods A and 3, 4
the hammer data were first evaluated (Reference 7.16) by
- ! calculating mean values, standard deviations, coefficients of ji variation (see Table 4), and-cumulative frequencies (see Figure 3). The two data sets were tested for goodness-of-fit
'I .to the normal distribution (References 7.17 and 7.19). .
Normality of the two populations is accepted at the five percent significance level.
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b -
ISAP II.b (Cont'd) j 5.0. IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESUI.TS (Cont'd)
To compare the two testable concrete truckload populations,
- p Methods A and B hypothesis tests were performed using target j values of 1.0, 0.975, and 0.95 times the CC population tenth 1 percentile value. The hypothesis that the CAI population
.L tenth percentile is greater or equal to 1.0 times the CC l[ ~
population tenth percentile is rejected at the five percent
] significance level. The hypothesis that the CAI population
' i- tenth percentile is greater than or equal to 0.975 times the.
j CC population tenth percentile is accepted at the five percent
'l significance level, and is also accepted at the ten percent significance level. The hypothesis that the CAI population p
.; tenth percentile is greater than or equal to 0.95 times the CC
, population tenth percentile is accepted at thr. five percent
- i significance level, and is also accepted at f.ne 95 percent
, significance level. This means that, although there.is not a high confidence that the CAI population of hammer indications
-i is equal to or better than the.CC population, there is a high
., . . . confidence that the CAI is within five percent of the CC yy ,
population at the tenth percentile value and therefore well 4 ~
vithin the ten percent range required by the acceptance t
criteria (see Section 4.4.).
The 28-day cylinder compressive strength data'for.the 223
, Category I concrete pours (see Section 4.1.2) in the CAI time frame and comparable data in the CC time frame were j statistically analyzed. The mean values, standard deviations.
4 j and coefficients of variation are listed in Table 3. These
! data were also ordered and cumulative frequency plots were constructed (see Figure 1). The results of the cylinder data evaluation are consistent with the Schmidt Hammer tests in
- that both show a slightly higher mean value and tenth percentile value for the control concrete. In fact, the ll cylinder data indicate that the compressive strength of the l
! CAI is 9.3 percent lower than that of the CC at the pcpulation j tenth percentile value (see Table 3). This corresponds
, approximately to a five percent difference in hammer 1 indications (Reference 7.13). Thus, the results show that. '
not only are the compressive strengths of both the CC and CAI i well above the 4000 psi design 'value, but that the reported 28-day cylinder data truly represents the CAI at the i population tenth percentile value.
t Regarding potencial f alsification of 28 ' day cylinder records, 3
there are two general categories of interest. -Of greater
,,, concern is the masking of out-of-specification concrete by recording it to be within specification. Of lesser concern is the recording of within-specification concrete when the tests
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. Page 13 of 31 l l RESULTS REPORT
.' ISAP II.b if , (Cont'd) wi:
LI:
24 - 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
~ .1 1'
were not performed. Neither of these two types of
- (!'
- falsification appears to have occurred in a systematic way,
- b since there is no obvious' bimodal behavior in the hammer
- j. indication data and the' shift between the CC and CAI
! populations for the cylinder data is consistent with that of i the hammer indication data. '
{ During third-party review (Reference 7.5) of the Schmidt
- l. Hammer. test program development, some errors were found due to j' arithmetic, accessibility determinations, and volume modeling l assumptions. A portion of these errors, if corrected, would
> result in fewer truckloads being included in the populations;
- the other portion would result in more truckloads being added to the population. Hewever, no systematic errors were found.
The total error in the CAI truckload volume is three percent underestimated. For the CC population the estimate is less I' than half of one percent overestimated. Considering only those truckloads which were not included in the testable
- (~ populations, but should have been (i.e., were not in the k- population from which the sample was drawn), the error rate is
' [:, about six percent for the CAI and less than one percent for i; the CC. The samples do not strictly represent the excluded 4
truckloads. However, these error rates are not significant,
- i. and even if additional samples were obtained to represent'the f
?
excluded truckloads, the conclusions would not be affected.
i
6.0 CONCLUSION
S I .
Although the present strength of the concrete in question has not been measured directly, based on the hammer indication data obtained, in association with the 28-day cylinder data for the control concrete, it is concluded that the tenth percentile value of the CAI testable concrete is well above the design strength of 4,000 psi. The 28-day cylinder strength data are consistent with the hammer indication data. There is no evidence that systematic falsification of cylinder data or the non-performance of required tests occurred. Finally it is concluded that the reported 28-day t cylinder strength data represents the testable CAI population, thus validating the utilization of these data to address other
, allegations of concrete records falsification.
a
+u umame t e* eheO +9m e.wggspm
- emm e mm< dme esm ensw Maim *eemse.ee >. m a p= e e>n m j p ,emi.**A- e , emp+m. emge p.,ph gN,. gyy F, # g-' " - d
- Y- D
, ,'M T E
x -
=
._v - . a a.2p --
- s. *
. 4 Revisien: 1 Page 14 of 31 RESULTS REPORT ISAP II.b .
(Cont'd)
~c.
7.0 REFERENCES
7.1 ASTM Comittee C-9, " Standard Test Method for Rebound Number of Hardened Concrete", (ASTM C805-79), American Society for Testing and Materials, Philadelphia, PA, 1979.
l$ 7.2 ACI Committee 214 " Recommended Practice for Evaluation of Compression Test Results of Field Concrete", (ACI 214-65),
- j - , ,
American Concrete Institute, Detroit, MI, 1965.
~J.
l~ 7.3 " Test Program Development Report", CPRT File No. II.b.6.C.1, 1 October, 1985. .
7.4 " Testing to Confirm Acceptability of Concrete Strength Data for the Comanche Peak Steam Electric Station, Units 1 and 2",
Final Report. Project 8478 Southwest Research Institute, San Antonio, TX, September, 1985. (CPRT File No. II.b.6.C.2)
.l:
j, , . 7.5 " Third-Party Review and Verification of Sampling Activities
( and Procedures for.CPRT Issue II.b Concrete Compressive Strength",'CPRT File II.b.6.C.3, October, 1985.
l I 7.6 ACI-ASME Committee 359, " Code fo Concrete Reactor Vessels and Containments" (ACI-ASME 359-83), American Society of 1
Mechanical Engineers, New York, NY, 1983.
.I t
7.7 ACI Committee 318, " Building Code Requirements for Reinforced Concrete", (ACI 318-83), American Concrete Institute, Detroit, *
- MI, 1983. .
7.8 " Cylinder Data", CPRT File No. II.b.6.C.1.I.
'I 7.9 ASME Committee en Nuclear Quality Assurance, '? Qualifications ti of Inspection, Examination, and Testing Personnel for Nuclear
'; Power Plants". (ANSI /ASME N45.2.6-1978), American Society of Mechanical Engineers, New York, NY, 1978.
7.10 Office of Standards Development. " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel",
, (USNRC Regulatory Guide 1.58. Revision 1), U.S. Nuclear Regulatory Commission, Washington, DC, September, 1980.
ji 7.11 "Schmidt Hammer Test on Concrete at the Comanche Peak Stea- l Electric Station", Nuclear Projects Operatine Procedure l X-FE-108-1, Revision 1, Sourhwest Research Institute, San Antonio, TX, January, 1985. (CPRT File No. II,b.6.A) y ___ . . . . _ . _ _
.. ,~. - ~ -
m --
'~
- '7 m r. _ :C " ~
~;.;> _
~
,,'. h .,
.e -
. . . - -_...s t *
- i Revision
- 1 Page 15 of 31 RESULTS REPORT -
j ISAP II.b.
1 (Cont'd) l a <
'h 7.0 ' REFERENCES (Cont'd)
.l .
ij 7.12 " Comanche Peak Response Team Program Plan.and Issue-Specific Action Plans", Revision 3. TUGCO, Glen Rose TX, January 24,
-]
- o ~1986. (CPRT File No. II.b.1) 7.13 Operating Instructions Concrete Test Hammer Types N and NR, Copyright 1977 PROCEQ, Zurich Switzerland. (CPRI File No.
'l II.b.11) 1 i 7.14 Attachment A of F. Webster, " Target Tenth Percentile" CPRT File II.b.4a-003, February, 1985.
2 7.15 F. Webster, " Slides on Data Evaluation Methods Presented at
.; NRC-TRT Meeting of 1/7/85", Memo to File, CPRT File II.b.10-004, January, 1985.
E 7.16 A. Boissonnade "Schmidt Hammer Data Statistical Evaluation",
CPRT File II.b.4a-010. August, 1985.
1 1 5._ . 7.17 F. Webster, " Hammer Data Hypothesis Tests", CPRT File' *
- l- II.b.4a-011 July, 1985. -
'l 7.18 A. Boissonnada, " Statistical Evaluation of Cylinder Data", l
- p
[ CPRT File II.b.4a-012, August, 1985. '
I 7.19 F.-Webster, " Chi-Square Goodness-of-Fit Test of Hammer Data", I CPRT, File II.b.4a-013. September, 1985. j 7.20 D. Veneziano, " Comparison of the Fractiles of Two Normal j
Populations: A Large Sample Test and Its Power", CPRT File II.b.4a-001, December, 1984 J; 7.21 F. Webster, " Additional Background for TUCCO-NRC Meeting of i 3/6/85", CPRT File II.b.4a-008, May,-1985.
i e
- , . - . . . _ . . . . ~ . . . . . . . . . _
- ). .
- r. :
~ - = ~
,.~.u. - _
..nc. ._
q Rsvision: 1 Page 16 of 31
- . , RESULTS REPORT ,
ISAP II.b (Cont'd)
~
TABLE 1 Y
CHARACTERIZATION OF CATEGORY I CONCRETE PLACED IN ALLEGATION TIME FRA".E
.f d NUMBER OF NUMBER OF
.) POURS TRUCKLOADS l
i All Category I 326 4
31 50G* 1780 50G
. Category I (Other Than 223 4,080 192 C.W,ES*
Seal Slabs, Shocerece, 2300 C.W ES Grout, or Backfill)
, 19 SOG 315 SOG
. ... Testable Category I 197 1,305- -
. . ,. C . , 178 C,W ES 990 C,W,ES p
l
- SCG = Slabs on Grade j C = columns W = Walls ES = Elevated Slabs
'i t
l 2 l
W""*
- Deqs e9,s .W* 4 m- p erm g M T"" - - "
-- p w 'y , e-- { g ,,
,_-_~~~w~-- .
=- - . , _ . --~ -
.s
- i
?
- j , Revision
- 1
.; Page 17 of 31 -
,l RESULTS REPORT ,
+
'.j ISAP II.b (Cont'd) j' TABLE 2 i,
~
CHARACTERIZATION OF CATEGORY I CONCRETE PLACED IN CONTROL CONCRETE TIME FRAME NUMBER OF NUMBER OF POURS TRUCKLOADS
] All Category I 324 il i
l .
24 SOG* 920 SOG Category I (Other Than 291 2,715 Seal Slabs, Shocerece, 267 C.W,ES* 1,795 C.W,ES t Grou t , or Backfill) 24 SOG 353 SOG l i. Testable' Category I 282 2,090 258 C,W,Es 1,737 C.W,ES l
l 4
I t-
- SOC = Slabs on Grade
- C = Colu=ns W = Walls
. ES = Elevated Slabs 4-6 e me o- e e o. mo e.m o -
k]5 d *.g ( % 4 km N5 ' b % #
- 14
- _ e
__m,-- m-- : - : c__ , ..m_ :. , . - .
__. ..u--
s .
- . Revision: 1
! Page 18 of 31 1
1 RESULTS REPORT ,
t ISAP II.b
- 4. (Cont'd) i j TABLE 3 28-DAY STANDARD CURE CYLINDER DATA STATISTICAL SUMMARIES .
4I' C'onerate at Issue Control Concrete Number of Data 509 372
,'. Mean Value 5158 psi 5441 psi
! Standard 475 psi 383 psi Deviation Coefficient of 0.09 0.07 Variation
~
1 Tenth 4457 psi 4913 psi i, j ' Percentile,
,. Minimum 4047 psi 4540 psi f
f e
k I
.. -nn w~ - - . . ,s. . , - - - - > ~ . . ~ - .
w 7
._, ; ; - c. . --.. . .. . . -e . - .:_. mg. _ - - __
l{, Revision: 1
!. Page 19 of 31 I
t i
l RESUI.TS REPORT ,
~
}-
ISAP II.b
}
(Cont'd)
. TABLE 4 i.
.-i .
4 SCHMIDT HA'.'MER DATA STATISTICAL St.T'. ARIES
'I i i
Concrete at Issue Control Concrete
-],
j Number of Data 119 132 j Mean Value ,
48.57 49.14 Standard 3.13 2.87 Deviation Coefficient of 0.06 0.06 Variation
- Tenth 44.1 45.3
_ Percentile
-s Minimum 38.5 39.7 . . .
I
?
i i
4 i
I 6Mw%- em , M@.Ms AO"We 6y e a p , ,
,*~ ..~% %' b 4 w - -
!->~ , , , ;- r v --
?i ' ~N
3_- -
- w ~ - . r ., w ;.;u =
- , c,n ,.8c ------------------:--
g .. . .
l . e i
- 3 Revision: 1 Page 20 of 31 I
RESULTS REPORT f'
I~ ISAP II.b I
(Cont'd)
.I-
'l :
FIGURE 1 t
!+
CAI and CC CYLINDER DATA CUMUI.ATIVE FREQUENCIES I:
J t
I : -
. s 1 . p
.9 -
- p
/
- /
i
- .B ,-
[ #
r m
N*
> .7 h CAI -j CG
. l '/
$.a :
~
- /
j -
g /
j' w : /
- g. w .5 --
f 3
~
p
.,i.
.4 .- j
! ~
/
- s. w .3 5 ,
/
t i
- *I
.2 -
~
/
CAI CYL 5treagp ' ,
- 10 tai eercenwie=4451
.t
=
/
,' CC CTL $trengti letti percestite=4913
>e
. s
>- . et "" , I i 1 , t , t , t , t , ! , t , ! , 8 . '
Il bm 4200 4400 se00 se00 5000 5200 S400 5800 5900 0000 82:0 6400 5600 0000 7:00 t 28 DAY STU CURE CCNCRETE CCMPRESSIVE STRENGTH il.
4 i
l y.
l1 -
,i I
i . .
l l)
. _. .. - , . . . . . - . . . m. . . . ..
-y .= .. .--
- .-- e u.c m .m ; m. r o -
t g- .
l . .
- f i Rsvision: I Page 21 of 31 r
.t
- RESULTS REPORT i.
ISAP II.b (Cont'd) 9 FIGURE 2 4
i f
ISSUE II.b FLOk' CHART
.s i
l i
ettu asunsata 3 m conecatTE CoupetStoe simpacTu AtPO4fmGJ f a et an,ag g. . w . ,,,,, o
,; ihrtwact '****
i
- _t_.. . . . - - . -. _. _ _ . . . - . . . . ..
. p<=.=.o
.=l* . .se
,~. . . . . . .
ame se
.. . as'n . e I.'a'a F-' =.y, -
= nW' " 'F2L l' ' 'L*'S. %,
i . . . . .
" i
= ..
.'.* & .%TI peo4CT ENG*E ta*G o
w g
Den T,f uwene
'a de e.e.
" I I h v&LustsCN ...,"
,- ,-'. . .r m
, (d aNO e- * *R ms
, gg g,3 w 'IsE!=
., ACTitefit5 , ,
t -
I.
.i, ~ senses .es gg se,nieen si,e I&a I -- -. -- . . ~
pacatCT .
C 6ss.es' reis h5AE*TICNs y **'.*k'**
TE 5 T.shG F.,**y acTivitiC5
{
w TMinD s
,,,,, a=.=.=..=.
- 's.i.e., _,
I "
i aCTawstit5 I I* *
- MS D. us m.e' M T,*' l l W .0,f f g
i
?
1
- ~ -
, es-- -
, , - _ , ._, -- m ,e--- - --
-. ._ ..__. .v. - - r :, .w :- =u :_- - . - , -
.. ~ - ,
e, .
t R3visien: 1 Page 22 of 31 RESULTS REPORT ISAP II.b
-):
i (Cont'd)
FIGURE 3 3
CAI and CC HA.T!ER DATA CUMULATIVE FREQUENCIES i
f 4
' I -
u #
! .e L .
I r
.s - f A : CA! feet Cato f 1 0 .
/ - we c .7 -
=enna o .
/
t- 3 :
/
CT" a ..e= .
j ( , I :
f
- CC feet Cats g .5
\
i.~ = f f
dQ .4 L .
I 1 .
i 3. : (
W
$3 : 7
/
/
.2 L cat Weaunee Samole /
10th Percentitee44.1/
CC Wo m e 54*ste
- t -
/ % ICtn Perceatile=45.3 4 : /
- , , t,, , , , , - ' . , i e 35 40 45 5: 55 60 30 Avercge Schmidt Hcmmer- Indice1cn h
l s ,
- ~ ^ " # - * * * * * . . * , e e.-w . . , , ,
i
-v=-rm r - r m 5m - - - - - , , , ,
,- ,yy w , . , s-- w -v -W
,px _ n . , ._ g__ w -- -
wvn-m --
_y 5
~
Revision: 1 Page' 23 of 31
~*
'i RESULTS REPORT ISAP II,b (Cont'd)
- I APPENDIX A CAI AVERAGE HA.T.ER INDICATIONS HAMMER TEST DATA SHEET POUR PACKAGE No.- MEAN REBOUND VALUE No. GRID AREA TEST LOCATION HORIZ. UP DOWN 8 002-2790-004-H TR-85-066-8904 44.38 10 002-4790-005-I TR-85-005-8904 47.67 13 002-4790-037-HH TR-85-100-8704 44.0
!! 24 002-4792-005-B TR-85-029-8904 38.5 37 002-2778-002-WW TR-85-060-8904 46.1
': 46 002-5778-001-D TR-85-123-8904 43.9 72 002-4792-008-F TR-85-001-8904 42.9 73 002-5778-001-Q TR-85-079-8904 47.4 i 74 002-5778-001-R TR-85-098-8904 46.0
- 1 76 002-5778-001-Z TR-85-095-8904 46.6
(- 77 002-5778-001-AA TR-85-096-8904 46.6
. 79 002-6778-005-A TR-84-204-8904 43.8 80 002-2778-002-X TR-85-056-8904 42.0 9!
4 81 002-2778-002-KK TR-85-120-8904 44.1
_. ; . 88 105-4785-003-C TR-84-101-8903 48.2
- i. 89 002-4790-016-I TR-85-009-8904 48.3
'j: 92 002-6778-010-A TR-85-122-8904 48.3
': 118 002-6790-001-A TR-85-017-8904 44.6 127 002-7792-003-B TR-85-103-8904 44.4
~
128 002-2778-002-L TR-85-119-8904 42.8
'l. 129 002-4792-018-A TR-85-028-8904 39.1 i 130 002-4790-037-0 TR-85-188-8904 44.1 L. 131 002-4790-037-C TR-85-104-8904 43.0
!! 145 101-5805-003-M TR-85-162-8902 49.3
- l 153 002-4778-001-D TR-85-149-8904 48.2 154 002-5778-007-C TR-85-092-8904 49.4 157 101-5805-003-D TR-85-161-8902 48.4 163 002-5790-002-A TR-85-207-8904 47.4 ii 165 002-4792-003-A TR-85-146-8904 43.0
- t 166 002-7792-001-P TR-85-150-8904 45.4 167 002-4792-009-A' TR-85-191-8904 47.4 168 002-7792-001-3B TR-85-151-8904 45.8 169 002-5778-006-A TR-85-099-8904 47.6 ;
') 211 105-5790-005-I TR-85-113-8903 50.4 !
214 101-5805-002-P TR-85-160-8902 50.7 i 215 . 101-5805-003-Q TR-85-163-8902 49.0 217 {
. 002-2778-002-T TR-85-057-8904 44.4 1 218 002-2778-002-P TR-85-058-8904 46.1 l
~219 002-2778-002-Q TR-85-059-8904 43.- !
220 002-5776-001-X TR-85-094-8904 49.9 l
^ - > myy n.5
. ,. o A. . r' 1=,w.=;.='-' rTJ'T Js M+e N"" #- \ ' '
M' * * * *
+gw -- mpu - = - - - -
3- _. ~- c p up e y s -- s . 1 A '
1 Revision: 1 Page 24 of 31 l
RESULTS REPORT ISAP II.b q (Cont'd) 4 g APPENDIX A g (Cont'd) 1 CAI AVERAGE HAMMER INDICATIONS (Cont'd)
HAMMER TEST DATA SHEET POUR PACKAGE No.- MEAN REBOUND VALUE No. CRID AREA TEST LOCATION- HORI,Z . UP DOWN 3
4 226 101-2808-004-A TR-85-105-8902 44.3 l
230 101-2808-003-N TR-85-110-8902 42.0 236 002-4790-046-A TR-85-006-8904 44.2 4
238 002-4790-037-AA TR-85-101-8904 47.0 239 002-5790-009-B TR-85-091-8904 47.7 240 002-6790-012-B TR-85-014-8904 49.7
- 248 002-4792-008-D TR-85-192-8904 44.0 i 249 002-4792-001-G TR-85-121-8904 44.8 i 262 105-5773-001-U TR-85-329-8903 45.9 263 i 105-5773-001-N TR-85-331-8903 47.4
.( ~~,
264 105-5773-001-T TR-85-328-8903 54.2 .
- f. 265 105-5773-001-X TR-85-330-8903 50.6
!_ 266 105-7785-001-Q TR-85-268-8903 49.3 i' 267 105-5773-001-KK TR-85-341-8903 50.4 268 105-5773-001-JJ TR-85-342-8903 52.2 j 269 105-5773-004-N TR-85-267-8903 50.4
', 270 105-4785-001-D TR-85-269-8903 47.8 271 105-5773-001-RRRR TR-85-338-8903 46.2 '
272 105-4773-003-B TR-85-332-8903 49.0 273 105-5773-001-LLL TR-85-333-8903 52.8 1 274 105-5773-001-BBBB TR-85-334-8903 ~43.3 275 105-5773-001-DDDD TR-85-335-8903 48.7
- 276 105-5773-001-NNNN TR-85-336-8903 48.5 i
277 105-5773-001-ZZ TR-85-343-8903 52.3 278 105-5773-001-DDD TR-85-366-8903 47.6 279 105-5773-001-TTF TR-85-?44-8903 50.3 i
280 105-5773-001-GGG TR-85-345-8903 56.1
, 282 105-5790-001-BB TR-85-350-8903 47.8 283 105-5790-001-T TR-85-339-8903 47.1 288 105-5773-004-F TR-85-327-8903 52.6 i 289 002-2790-001-WW TR-85-315-8904 44.0 290 002-5790-001-E TR-85-323-8904 50.8 291 002-2790-001-YY TR-85-325-8904 48.4 293 002-2790-001-UU TR-85-320-8904 '45.4 294 002-4790-004-Q TR-85-314-8904 48.2 296 002-4790-016-A TR-85-319-8904 51.8 297 002-4790-026-B TR-85-318-8904 49.3 298 002-4790-038-C TR-85-317-8904 50.1 299 002-2790-001-II. TR-85-316-8904 43.3 300 002-4790-004-J TR-85-322-8904 49.7 303 002-7792-001-X TR-85-353-8904 46.6
. _ _ . . . _ _ _ _ .~ _ _. - --- - -
mem.-- , , , , , , - , , , w= - - -- w < - >m- r - - ' '
3: * -
- T~~
_ _- _ - - _ - _ __ . --, w _- . - - . _ - -
m . . -
l*'. .
Rnvision: 1 Page 25 of 31 RESULTS RE? ORT F
., ISAP II.b
, (Cont'd)
APPENDIX A 1 (Cont'd)
- i CAI AVERAGE HAMMER INDICATIONS (Cont'd) y HAMMER TEST DATA SHEET POUR PACKAGE No.- MEAN REBOUND VALUE No. GRID AREA TEST LOCATION HORIZ. UP D0'a'N 304 002-7792-001-B TR-85-354-8904 47.3 n 306 101-5805-001-T TR-85-265-8902 50.2
- t 307 101-5805-001-5 TR-85-278-8902 53.6 j 308 101-5805-002-V TR-85-363-8902 51.0 309 101-5805-002-X TR-85-361-8902 51.9
+
310 101-5805-004-N TR-85-371-8902 53.4
.1 313 101-5805-004-U TR-85-373-8902 50.8 314 101-5805-003-X TR-85-360-8902 50.9
! 315 101-5805-005-S TR-85-372-8902 51.2 317 002-2785-001-KK TR-85-368-8904 51.1 318 002-2785-001-YY TR-85-369-8904 53.3
.I '
319 002-2785-001-Q TR-85-260-8904 51.6 4! - - 320 002-2785-001-BB TR-85-266-8904 51.1
-l- 321 002-2785-001-S5 TR-85-270-8904 50.5
. j, 322 002-2785-001-BBB TR-85'-263-8904 53.0
- 323 002-2785-001-Z TR-85-262-8904 52.6
[ 324 035-5782-003-F TR-85-280-8906 50.8
- j 325 035-5782-003-C TR-85-279-8906 49.1 326 035-5782-001-L TR-85-264-8906 50.9 327 035-5782-001-I TR-85-259-8906 49.6
.i 328 002-4790-038-G TR-85-324-8904 45.7 330 002-2790-001-R TR-85-321-8904 45.8
, 333 002-5778-013-H' TR-85-358-8904 43.4 334 002-5778-013-B TR-85-359-8904 55.7 370 101-5805-004-BB TR-85-364-8902 48.5 374 101-5805-004-FF TR-85-362-8902 52.4 377 101-5805-001-M TR-85-275-8902 49.7 378 1Cl-5805-001-P TR-85-276-8902 50.3 379 101-2808-003-L TR-85-349-8902 50.0 383 101-2808-003-E TR-85-348-8902 45.8 390 101-2808-002-F TR-85-370-8902 50.0 i
391 101-2808-002-C TR-85-347-6902 48.5
'! 394 002-7807-001-P TR-85-356-8904 46.8
'I 395 002-7807-001-W TR-85-357-8904 47.0 396 002-7792-001-MM TR-85-351-8904 44.8 -
- j '
397 002-7792-001-FF TR-85-352-8904 44.3 398 105-5773-001-GGGG TR-85-337-8903 55.0 405 101-5805-005 -J TR-85-365-8902 50.0
+ ea ee. # g.6 ew f. , engame g - e. -=.m. e e 4 =
[*-it 'a ,
b 3 J g. 4 k * =f [ '# ' I pp g g . b g , % '
. Revision: 1 Page 26 of 31
+
- t. RESULTS REPORT +
ISAP II.b (Cont'd)
APPENDIX A
, (Cont'd)
Ll
] CAI AVERAGE HA!O'IR INDICATIONS 6
i l
f I ,,
i :
. .9 .- -
s .
.e .
A :
O A '
C- M .7 =
Assumed Morest emment c - : g a a j
, 6" mC "('8 U 3*I3 I
't i .
g
[$* [ feet Date
\ .
I g 3 a .5 -
> == .
" d .d = 0.049 .
M Q .4 J Q - -
1 - 3 .
.! 3 E :
). E 3 .3 -- .
3 U U
! .2 -
l . . ,
i .
.I .
1 l O 30 35
" 'o a 45 50 55 60 Average Schm1dt Hcmmer Indicetien l' I
i i I
I e
t i
I f
e 1
l l
. I a
1 .. . . . . _ . . _ _ . _ _ ._ _ . .
I giheI *
{ } k 7%' 'D f 11 y 7 Y f Wg , _ ~ ~W6[)T, h I ,p' MS $g I " ' '
= ._ ,- ~ _- ~ ---
um w - - - - - - - - - - - - - - - - - - - - -
t
\. .
' Revision: 1 Page 27 of 31 RESULTS REPORT ,
I ISAP II.b (Cont'd)
APPENDIX B f
CC AVERAGE HAMMER INDICATIONS l
J SHEET No.
CONCRETE POUR PACKAGE No.
MEAN REBOUND VALUE
. TEST LOCATION HORIZ. UP DOWN OTHER 15 002-7810-002-X TR-85-078-8904 40.7 i 20 002-7810-001-EE TR-85-126-8904 42.3 i 25 002-4792-007-B TR-85-030-8904 41.3
] 34 002-7810-003-DD TR-85-127-8904 44.2
}- 35 105-4810-021-J TR-85-051-8903 45.5 1 54 105-4790-016-C TR-85-038-8903 43.9
' 57 101-5805-012-P TR-85-186-8902 49.9 96 105-4790-015-C TR-85-114-8903 45.7 110 105-4810-021-D TR-85-048-8903 43.4
.i 115 101-5803-010-E TR-85-169-8902 48.2 i 116 101-58CS-012-E TR-85-176-8902 49.0
.l 124 002-5807-002-G TR-85-157-8904 48.1 r 125 002-5807-002-E TR-85-027-8904 40.9 i
. " 137 003-4785-002-III TR-85-200-8901 47.8 129 003-4785-007-U TR-85-201-8901 46.9 140 003-4785-002-TF TR-85-202-8901 45.6
, 141 003-4785-002-0 TR-85-204-8901 43.7
! 142 003-4785-002-N TR-85-203-8901 48.6 143 003-2810-004-E TR-85-141-8901 46.6 144 105-5790-002-E TR-85-196-8903 46.2 148 002-5810-004-H TR-85-116-8904 45.3 149 101-5805-012-0 TR-85-185-8902 52.1 150 101-5805-012-K TR-85-184-8902 49.1 l 151 101-5805-006-F TR-85-168-8902 50.3
, 155 003-2810-005-D TR-85-093-8901 49.7 156 003-2810-002-D TR-85-040-8901 48.4
. 158 101-5805-010-G TR-85-171-8902 48.7
! 162 105-4810-021-S TR-85-208-8903 43.9 164 002-5810-001-GG TR-85-019-8904 46.5 170 201-5805-002-F TR-85-190-8902 48.2 1 171 002-5807-002-Y TR-85-156-8904 39.7 l 179 101-5805-013-U TR-85-179-8902 50.6 e 180 101-5805-012-V TR-85-183-8902 50.6
- 182 101-5805-013-BB TR-85-180-8902 53.0 j 185 105-4810-021-B TR-85-050-8903 45.9 186 003-4785-002-RRR TR-85-206-8901 50.9 j 187
' 003-4785-002-B TR-85-205-8901 48.5 188 101-4808-009-I TR-85-158-8902 52.2 191 101-4812-005-J TR-85-135-8902 50.0 193 105-7810-002-N TR-85-229-8903 51.3 I 194 105-7800-001-B TR-85-210-8903 48.1 l
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1 ISAP II.b
.! (Cont'd)
LJ l APPENDIX B q (Cont'd)
CC AVERAGE HAMMER INDICATIONS (Cont'd)
SHEET CONCRETE POUR MEAN REBOUND VALUE No. PACKAGE No. TEST LOCATION HORIZ. UP DOWN OTHER
. 199 002-7810-003-LL TR-85-222-8904 48.5 200 . 002-7810-001-W TR-85-220-8904 53.0
~
207 105-7810-001-D TR-85-227-8903 45.6
' 105-7810-007-A
.- 209 TR-85-133-8903 52.9 I 210 105-5790-002-1 TR-85-039-8903 46.4 I
212 105-4810-021-I TR-85-049-8905 49.8 i
213 105-4810-021-G TR-85-148-8903 50.7 l 221 101-5805-011-G TR-85-173-8902 49.7 s 222 101-5805-011-K . TR-85-174-8902 50.8 223 101-5805-011-L TR-85-175-8902 52.0 i' 225 101-4808-004-D - TR-85-139-8902 48.5 241 105-4790-011-B TR-85-043-8903 47.8 244 002-4807-002-F TR-84-153-8904 47.7
(- 245 201-5805-002-D TR-85-187-8902 53.4 252 002-7807-002-G TR-85-085-8904 50.4
} 255 002-7807-003-A TR-85-086-8904 46.8 L 256 002-7807-002-Q TR-85-155-8904 48.0 257 002-4810-020-1 TR-85-020-8904 47.9 281 105-4790-003-G TR-85-236-8903 48.3 284 105-4800-001-F TR-85-235-8903 48.5 285 -
105-7810-007-S TR-85-237-8903 58.8
, 286 105-5790-003-L TR-85-238-8903 48.9 287 105-7790-002-D TR-85-306-8903 48.5
, 292 002-7810-001-000 TR-85-300-8904 49.2 -
295 002-7810-001-CCC TR-85-305-8904 52.1
- 301 002-5830-001-N TR-85-312-8904 47.7 302 035-3790-001-B TR-85-257-8906 49.4 305 002-5807-003-L TR-85-242-8904 49.9 <
311 101-5805-007-U TR-85-378-8902 53.0 I 312 101-5805-008-Z TR-85-272-8902 52.4 l 316 002-7810-001-WV TR-85-301-8904 52.9 ;
329 002-7810-002-00 TR-85-302-8904 49.9 l l' 331 002-7810-003-SS TR-85-303-8904 44.6 l 332 002-4790-027-P TR-85-258-8904 43.1 '
. 335 002-7810-001-RR TR-85-291-8904 49.9 !
336 002-5810-001-A TR-85-367-8904 33.2 337 002-7810-001-1 TR-85-295-8904 43.2 338 002-4810-015-H TR-85-284-8904 49.1 002-4810-015-M TR-85-283-8904 50.8
._ 339 340 002-7810-002-M TR-85-285-8904 46.1 e
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} .
ISA? II.b
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I (Cont'd) '
l j APPENDIX B d
(Cont'd)
. CC AVERACE HAMMER INDICATIONS (Cont'd) t SHEET CONCRETE POUR MEAN REBOUND VALUE No. PACKAGE No. TEST LOCATION HORIZ. UP DOWN OTHER 4 341 002-7810-003-DD TR-85-294-8904 47.3
?
342 002-5810-002-MM TR-85-232-8904 50.7
- 343 002-5810-002-S
- TR-85-282-8904 48.8 1 344 002-7810-003-CCC TR-85-290-8904 44.9 l 345 002-7810-003-EEE ~TR-85-281-8904 47.9 l 346 002-7810-003-XX TR-85-293-8904 48.7 347 002-4810-002-V TR-85-233-8904 48.1 348 002-7810-002-C TR-85-286-8904 45.9 349 002-4810-002-H TR-85-288-8904 46.5 350 002-7810-002-EE TR-85-292-8904 44.2 352 002-5810-014-C TR-85-287-8904 48.6 353 003-2810-007-H TR-85-326-8901 46.7 7
354 003-2813-002-AA TR-85-254-8901 46.5
- { -
355 -
003-2810-007-BB TR-85-246-8901 48.2 4 356 003-2810-001-M TR-85-253-8901 48.7
!- 357 003-2810-002-T TR-85-249-8901 51.3 358 003-2810-002-VV TR-85-248-8901 51.6
'l 359 ~003-2810-002-L TR-85-251-8901 51.2 l 360 003-2810-002-AA- TR-85-250-8901 51.2
- 361 003-2810-007-CC TR-85-247-8901 51.7 362 003-2813-001-N TR-85-252-8901 52.8
, 363' 003-2813-001-U TR-85-244-8901 54.4 364 003-2813-001-T TR-85-243-8901 52.9 365 003-2810-004-R TR-85-245-8901 47.8 366 201-5805-002-V TR-85-374-8904 52.4 367 201-5805-001-R TR-85-377-8902 52.0 368 003-2813-002-G TR-85-256-8901 48.7 369 003-2813-001-AA TR-85-255-8901 52.2 371 101-5805-010-HH TR-85-376-8902 52.7 372 101-5805-012-LL TR-85-375-8902 53.4 373 101-5805-009-JJ TR-85-274-8902 51.4 375 105-7810-001-B TR-85-304-8903 44.3 l 376 105-2810-001-D TR-85-234-8903 48.2 380 101-2812-001-BBB TR-85-239-8902 50.5 I 381 101-6808-008-A TR-85-355-8902 48.4 l 382 101-2812-001-00 TR-85-241-8902 48.7
, 384 101-2812-001-C TR-85-240-8902 53.3 385 101-4812-001-M TR-85-309-8902 51.2 386 101-4812-001-J TR-85-310-8902 50.3 387 101-4812-001-B TR-85-311-8902 52.3 l
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, ISAP II.b l (Cont'd) j APPENDIX B j . (Cont'd) j CC AVERAGE HAMMER INDICATIONS
.1 (Cont'd)
SHEET CONCRETE POUR MEAN REBOUND VALUE No. PACKAGE No. TEST LOCATION HORIZ. UP DOW OTHER
. 388 101-4812-002-H TR-85-307-8902 49.6 il 389 101-4812-002-K TR-85-308-8902 51.3 392 002-5807-001-L TR-85-346-8904 49.3
j 393 002-5807-001-E TR-85-296-8904 47.4 399 101-5805-008-K TR-85-271-8902 51.1
- i 400 101-5805-009-0 TR-85-273-8902 53.2 401 002-6807-008-A TR-85-297-8904 51.0 402 002-6807-009-C TR-85-313-8904 50.2 403 002-7807-002-0 TR-85-299-8904 47.3 404 002-7807-002-R TR-85-298-8904 48.6 406 002-7810-002-A TR-85-289-8904 47.7
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ISAP II.b (Cont'd)
AVERAGE SCHMIDT HAMMER INDICATION 1
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COMANCHE PEAK RESPONSE TEAM
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RESULTS REPORT
'l I. ISAP: III.d
Title:
Preoperational Testing i'
REVISION 1
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, REftLTS RE7CRT l ISAP III.d
'I
.i Preoperational Testing l
1.0 DESCRIPTION
OF-ISSUE The NRC-TRT described the issues in the CPSES Safety Evaluation Report, Supplement No. 7, as follows:
"In TP Category 5, the TRT found that System Test Engineers (STEs) were not on controlled distribution for design. changes i applicable to systens to which they were assigned; rather, they were required to obtain this information on their cwn
- initiative from the document control center prior to starting i a test and were then required to incorporate that information, as applicable, into the test procedure. While the TRT did not identify any specific problems as a result of this practice,
. it considers this practice to be weak sines it relies too heavily on the motivations and initiatives of test personnel to ensure that they have current design information when they are developing test procedures and before conducting tests.
I (
Typically, these are periods when they could be under more than normal pressure. Additionally, because of the number and nature of the problems found in the docu=ent control system by
.i the TRT QA/QC Group, the TRT could not reasonably conclude that the document control system problems identified did not
, affect testing activities." Page J-13. Item 3.2.3, " Findings for Test Program Issues."
"The TUEC Startup Group relies heavily on the accuracy and completeness of the design documents, which are included in
, the document control system, in its preparation of test procedures and during the conduct of testing., A number of problems were identified in the document control system by the i
TRT QA/QC Group during its review. While the TRT Test Program Group did not find that these problems adversely affected those portions of the testing program that it included in its review, the TRT cannot conclude with reasonable assurance'that the document control system problems had no adverse effect on testing activities." Page J-14 Item 3.2.4, "Overall l As ses sment and Conclusions."
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,' ,a Sections 1.0 through 4.0sof this report are reproductions of Revision 4 to the ISAP, dated February 27, 1986.
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. hvision: 1 Page 2 of 23 J I
'! RESUI.TS REPORT
- ISAP III.d (Cont'd)
- 1 4
>; 2.0 ACTION IDENTIFIED BY NRC The actions identified by the NRC-TRT in the CPSES Safety l y Evaluation Report, Supplement No. 7 at Page J-18, Item 4.2.4,'
"Preoperational Testing," as being necessary to resolve this issue are as follows:
" Establish measures to provide greater assurance that STEs and 4r other responsible test personnel are provided with current controlled design documents and change notices.
~
Provide NRC with reasonable assurance that the document
!j! control system problems identified by the TRT QA/QC Group did not affect the testing activities."
3.0 BACKGROUND
j! O The Startup Administrative Procedure CP-SAP-21,'" Conduct of
(~ Testing," as reviewed.by the NRC-TRT, stated that the STE was required to:
" Review the system drawings and applicable design changes to
,, determine that the as-built component /syste= will be
- l adequately tested by.the current procedure revision to
- j demonstrate proper component / system operation."
~i The.TRT reviewers' concerns were twofold: (1) that this requirement i may rely too heavily on an STE's motivation and initiative at the )
time when he is under more than normal job pressure and is expected to start testing activities and that he may not have the latest
,, design information in his possession, and (2) that'the problems
!! identified by the NRC-TRT QA/QC Group with the Document Control
~} Center (DCC) for construction activities may have adversely
, affected the testing program.
! The NRC-TRT QA/QC Group's findings were specifically addressed in CPSES Safety Evaluation Report, Supplement No. 11 at Page 0-10,
.! Item 3.2.2, " Document Control Issues," as follows:
i l "The QA/QC Group found that prior to 1984, there were numerous recurring administrative and procedural deviations in'the
' document control function. Many of these recurring l
- deficiencies were identified by internal and external audits, l l But there was little follow up or verification by TUEC l - management that effective corrective actions were taken, until early in 1984 when the document control center (DCC) monitoring team began reporting to senior management. The l --- -
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f RESULTS REPORT' '
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ISAP III.d (Cont'd)
- 1
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3.0 BACKGROUND
(Cont'd) current document control program, with an estimated error rate of one percent or less, was found to be adequately staffed and effective. The problem of incorrect and incomplete drawing packages appears to have been corrected.
In summary, the QA/QC Group found the current documentation control program to be acceptable. However, prior to 1984, as identified by CAT (Construction Assessment Team] and TUEC,
{ there was a document control breakdown. Although many of the
, document control deficiencies have been corrected, the implication of past inadequacies on construction and i inspection have potential-generic significance which has not
! yet been fully analyzed by TUEC."
,( ,. Subsequent to TUEC submitting Revision 2 of the CPRT Program Plan
! /s and ISAP to the NRC, sampling from the populac' ion described below 1
- k.- in Section 4.1.2.4, " Prerequisite Test Population Definition," has proceeded. The original intent was to prepare one population to be sampled, screened, and evaluated for impact on both the prerequisite and preoperational test programs. The original population identified proved adequate for prerequisite testing.but not, for preoperational testing. The CPRT, with SRT concurrence, proceeded to prepare a separate population for the preoperational
- test program evaluation. The additional population prepared for
!! the preoperational test program evaluation is' described below in ll Section 4.1.2.5, "Preoperational Test Population Definition."
!! The action plan presented in Section 4.0 was developed to in.clude a
!; review of past and current administrative requirements for use of-l; design documents during testing; a review of the technical test
!j procedures utilizing the design documents; and a random sampling i; and evaluation program to determine the effectiveness of the
!. administrative requirements.
.)
4.0 CPRT ACTION PLAN l' 4.1 Scope and Methodolorv 1:
l1 The objective of this action plan is to resolve the two design document related issues identified by the NRC-TRT. The first i
!: issue will be investigated to determine any additional l j! measures required to insure that STEs and other responsible test personnel are efficiently and effectively provided with I
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a RESULTS REPORT I
ISAP III.d (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) i current design documents for use in their testing activities.
The second issue will be investigated to determine if the p problems with DCC identified by the NRC-TRT QA/QC Group had an y adverse affect on the testing program activities.
T
.j The individual objectives and tasks for each issue are g discussed separately below.
j 4.1.1 STE's Access to Current Design Documents i
This task will determine if administrative procedures and work practices by the Startup and DCC organizations
, are adequate to provide for the use of current design 5
, documents in the performance of testing activities, and
, to identify additional requirements,' if any, which need
[ (. x to be established to ensure compliance with this
( requirement.
i The steps required to complete this task are: reviewing i the Startup Administrative Procedures as they relate to E use of current design documents; reviewing the organizational interface and work practices between the Startup and DCC' organizations; and interviewing q individual STEs. J 4.1.1.1 Startup Administrative Procedure Review Review Startup administrative procedures to i determine if practices are likely to lead to
{ a programmatic discrepancy. The procedures )
- will be reviewed to determine when '
, administrative requirements need to be i applied to the use~of design documents, that the requirements are clearly stated, and indicate the timeliness for use of current
{ design documents. The CPRT will perform this review.
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(Cont'd)
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4.0 CPRT ACTION PLAN (Cont'd)
~
4.1.1.2 Startup and DCC Interface Review the" organizational interfaces and work practices between the Startup and DCC organizations which are applicable to the acquisition and use of current design .
- [' documents. Determine the adequacy
. of past and present practices in meeting the.
- d. requirements of the testing program.
l Identify and implement improvements if M required. The CPRT will perform these
reviews.
li 4.1.1.3 System Test Engineer Interviews i:
]! . Interview System Test Engineers to deter =ine 7 ..s
- . their methods of complying with the current
( '+c design document requirement and to further assess the need'to_ upgrade existing procedures and methods. The CPRT will conduct these interviews.
4.1.2 Potential for DCC Problems to Adversely Affect the Testing Program N -
This task will evaluate the effect of DCC problems
, identified by NRC-TRT QA/QC Group on the testing 3
- program by determining the Startup organization's
,, response to properly authorized design changes
'! initiated by Engineering, processed through the DCC a organization, and requiring a testing response by Startup.
1 The Startup organization utilizes drawings as a primary d resource in the preparation of technical test ll procedures and the execution of testing. Other
! resources are used, however they are not controlled by
,l the DCC. Startup responds to three methods of changing l' the design by Engineering. The three Engineering
, design change procedures are: direct issuance of a' O revision'to a design drawing which does not incorporate
~! the other two methods; issuance of a Design Change
~
. Authorization (DCA) .which is a design drawing change described in approved documents issued temporarily until the actual design drawings may be updated and issued; and issuance of a Component Modification Card (CMC) which is similar to the DCA.
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, ISAP III.d (Cont'd)
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4.0 CPRT ACTION PLAN (Cont'd)
An evaluation progra= will be developed and performed which will focus on opportunities for a DCC error to begin a chain of events which results in a testing error. Error opportunities involve design changes, communicated by way of changes to design documents .
a distributed and controlled by DCC, where the design i change created a need to change a test procedure, I
c perform ratesting, or perform additional testing.
This type of evaluation was designed to preclude the
.f nature of DCC errors from affecting the results.
The Startup organization utilizes only a fraction of the design documents prepared for the project. This 7, subset of design documents and the changes to the= are easily identified and the boundaries of a valid I. ,, population of design changes readily established.
_s The CPRT decided that a sampling program to resolve i this issue would be appropriate because there are no i programmatic deficiencies identified to date, the criteria by which they will be evaluated in this study will be the same, the population of items to be sampled l~
is homogeneous (i.e., the process by which these items are handled by the DCC is the same), and thus a
(
- sampling program in accordance with Appendix D vill aid
- in determining whether or not systematic discrepancies exist. .
1 The potential adverse effect of the DCC problems
, identified by the NRC-TRT QA/QC Group on the testing
, programs will be evaluated by: deter =ining a calendar
, interval when DCC problems could have adversely affected startup; identifying and reviewing procedures and instructions which utilized DCC controlled design documents; defining the population of changes to the design doc ~uments; random sampling the population of ,
! changes; and evaluating the sampled design changes for 1 j adverse effects on the prerequisite and preoperational j test programs. I
- The steps which are required to accomplish this task ,
j are described below: )
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ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.1 Period of Interest Determine the period of interest during which !
Startup could have been adversely affected by ;
DCC problems. This period will begin at the !
start of prerequisite testing by Startup and the end date will be based on the results of CPRT review and assessment of CPSES Monitors Team monitoring reports of DCC performance.
These same reports were utilized by the a
]' NRC-TRT in their evaluations.
! 4.1.2.2 Prerequisite Test Instruction Review
. ,I j, All prerequisite test instructions will be j reviewed to determine the types of design
_ documents controlled by DCC which were used
( '- during the execution of prerequisite testing.
s- All design documents of this tppe will.be included in the prerequisite test populatien.
The CPRT will perform this review.
4.1.2.3 Preoperational Test Procedure Review All preoperational test procedures performed during the period of interest and not i completely reperformed thereafter will be reviewed to identify the design documents referenced by the test procedures and controlled by DCC. The design documents i
identified will be included in the prerequisite test population. A preoperational test sub-population will be identified from this list of referenced design documents. This review will be
! performed by the CPRT.
I j 4.1.2.4 Prerequisite Test Population Definition i
j The population of all design drawing i revisions, al'1 DCAs, and all CMCs issued during the period of interest and used by the !
Stattup organization in the preparation of !
test procedures or during the executien of 1
- testing will be identified. The CPRT will
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Page 8 of 23 1
RESULTS REPORT ISAP III.d (Cont'd)
} 4.0 CPRT ACTION PLAN (Cont'd) identify the prerequisite population with assistance from TUCCO Nuclear Engineering.
Preliminary estimates indicate that the L. population will include approximately 75,000 items.
- l. '4.1.2.5 Preoperational Test Population Definition i'
The preoperational test population will be
, identified from the design document reference.
f . list created by Section.4.1.2.3 which includes only the flow diagrams and control
- circuit schematic diagrams. In the hierarchy of engineering design documents, these two <
classes of drawings will have the most p significant influence on preoperational
!! 5., testing. This population will be identified ,
i '
by the CPRT. Preliminary estimates indicate that the population will include approxi-ately 1,100 items.
4.1.2.6 Population Screening Criteria i Each document change in the prerequisite and
} preoperational test populations will be i screened until it meets the following l
! criteria:
l t
The change is to a design document.
The change is issued through DCC.
The document is referenced by a test procedure or is used during the performance of a specific test.
t l
'; .- The test procedures which reference or utilize the affected documents I
were performed during the period of j interest and were not completely
, reperformed following the period of interest.
The document change occurred prior to performance of the test.
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. RESULTS REPORT 1
ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
J.
t.-
} - The change would' require a test or retest.
2 ' -
The CPRT will perform the evaluations with 1
assistance from TUCCO Startup.
'ls-4.1.2.7 Sample Evaluation
'h rp 'After random selection and screening, testing records will be examined for each sample item to determine the following:
Whether a test was conducted by Startup per the change, or Whether Startup documentation
[ (~s demonstrated they were aware of the change.
e .A negative finding in both cases vill p
constitute a discrepancy. The CPRT will perform the evaluations with assistance from TUGC0 Startup.
4.1.3 Identified discrepancies, if any, will be processed ti according to Appendix E. "CPRT Procedure for the l j' Classification and Evaluation of Specific Design or ,
- l Construction Discrepancies Identified by CPRT." !
Corrective action, if required, will be implemented l lS according to Appendix H. "CPRT Procedure for the !
lE Develop =ent. Approval, and Confirmation of Implementation of Corrective Action."
,h 4.2 Participants Roles and Responsibilities 4.2.1 Organizations involved 4.2.1.1 CPSES Scartup Group
- l 4.2.1.2 TUCCO Nuclear Engineering Group
', [ 4.2.1.3 CPRT Testing Programs Review Team l i l l l
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RESULTS RE? ORT ISAP II'I.d -
(Cont'd) 1:
) 4.0 CPRT ACTION PLAN (Cont'd) -
4.2.2 Scope for each Organization 4.2.2.1 CPSES Startup Group
- Revise Startup Administrative Procedures and instruct STEs on new
, 'l ' procedure requirements,
. 'i
- [ - Implement corrective actions
, resulting from the CPRT investigation into the effect on testing due to DCC problems, and
- Provide qualified personnel to assist in the screening and sample l- ,. evaluaticn.
E
(-- ': 4.2.1.2 TUCCO Nuclear Engineering Group
'j -
Provide engineering drawing history data for sample preparation.
i j' 4.2.2.3 CPRT Testind Programs Review Team Evaluate the CPSES document control progra= and applicable
} Startup Adcinistrative Procedures ,
and control methods, Review and concur with applicable l Startup Administrative Procedures
- revision, t
o 1 -
Determine whether the testing
! program has been adversely affected i by DCC problems and specify
'; corrective actions, if necessary,
- and i
Overview the work perfor=ed by other t organizations assisting CPRT.
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- l.
- RESL'LTS REPORT l
ISAP III.d (Cont'd) l
- 1;
.d i 4.0 CPRT ACTION PLAN (Co. nt'd) 4.2.3 Lead Individuals 4.2.3.1 Mr. S. M. Franks CPSES Startup Group i 4.2.3.2 Mr. J. E. Rushwick CPRT Testing Programs Review Team Leader 3(' .
j
.): 4.3 Personnel Qualifications
- i l 4.3.1 The CPRT Testing Programs Review Team Leader meets the qualifications as described by the CPRT Progra= Plan.
4.3.2 The Startup persorael participants will be qualified in accordance with CP-SAP-19. " Training / Qualification
>I Requirements for Startup Personnel."
(-
_. 4.3.3 The Review Team Leader assures that other personnel providing assistance are qualified.
4.4 Procedures The following procedures will govern revision of Startup Administrative Procedures:
, CP-SAP-1, Startup Administrative Procedures Manual l
.i' -
CP-SAP-21, Conduct of Testing 4.5 Acceptance criteria
- 4 The acceptance criteria for the two investigated issues are discussed below:
l 4.5.1 STEs Access to Current Design Documents j~ The procedures and methods are adequate to the
't satisfaction of the Testing Programs Review Team Leader
, to assure that STEs and other responsible test
? personnel are cognizant of and are provi:td with l current design documents. This finding must be
' supported by the results of random sampling and evaluation of the use of design change documents.
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RESULTS REPORT ISAP III.d
. l (Cont'd) q.
E' 4.0 CPRT ACTION PLAN (Cont'd)
P -
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4.5.2 Potential for DCC Problems to Adversely Affect the Testing Program In order fer DCC problems identified by the NRC-TRT' QA/QC Group to be judged to have had no adverse effect i on preoperatienal or prerequisite testing, a properly i selected, screened, and evaluated design change
- [ document sample must meet the following criteria:
l 4.5.2.1 Prerequisite Test Program The design change was tested as evidenced by approved test data or was documented as being
,! monitored by Startup as an open ite=.
i j - . 4.5.2.2 Preoperational Test Program 1
Q'- ~ A preoperational test precedure incerporated the design change or was documented as being monitored by Startup as an open item.
j 4.6 Decision Criteria 1
1 4.6.1 STE's Access to Current Design Documents 4
The administrative procedure (s) are satisfactory or, if necessary, are revised to the satisfaction of the Testing Pro' grams Review Team Leader and concurred with by the Senior Review Team.
! 4.6.2 Potential for DCC Problems to Adversely Affect the Testing Program The objective of the random sampling and evaluation program is to provide reasonable assurance that the problems identified by the NRC-TRT did not, in fact, adversely affect the test program. If one or more discrepancies are found to have adversely affected the
, test program an expanded investigation will be undertaken in~accordance with Appendices D and E.
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( F RES'JLTS REPCRT
{
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a ISAP III.d I. -
(Cont'd) a
'a . ,
j' 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS te
'[ The following sections present a summary of action plan implementation and specific discussions of the results of each l'
1 issue investigated.
.} -
5.1 Summarv of Action Plan Implementation f The NRC-TRT issues were investigated by a combination of 1
administrative procedure, organizational interface, and test i procedure. review; interviews with personnel; and random
'. sampling and. evaluation. To perform these analyses, the CPRT
. reviewed approximately 6000 documents which consisted of administrative procedures, test procedures, drawing revisions, design change documents, and audit reports.
l 5.2 STE Access to Current Design Documents l
! The CPRT reviewed the Startup Administrative Procedures and i the Startup and DCC organizational interface, and interviewed individual STEs. The requirements for administration of the n
test program with regard to the use of current design information were evaluated during these reviews.
i 5.2.1 Startup Administrative Procedure Review j I
Prior to the CPRT review of the Startup administrative procedures, TUCCO Startup had revised administrative '
l procedures and initiated required retraining of I personnel in response to the NRC letter of September
- - 18, 1984 The CPRT reviewed the Startup administrative procedures in effect as of September, 198% to deter =ine where the activity being controlled needs administrative requitements applied to the use of design documents, if the requirements are' clearly stated, and if they indicated the timeliness for the use of current design documents. k*ith respect to the above criteria, the Startup administrative procedures are adequate.
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,, Page 14 of 23 RESL'LTS REPORT
, ISAP III.d
. (Cont'd)
.i2 .
i- 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
-l l' 5.2.2 Startup and DCC organizational Interface Review The NRC-TRT implied that each STE should have a s controlled-distribution copy of drawings and design
- change. documents applicable to the STE's assigned 8; systems. With this concept in mind, the CPRT reviewed i! the history of the Startup DCC satellite and the evolution of the methods by which the Startup and DCC
'! organizations attempted to provide convenient access to i current design documents. The following presents the results of this review.
! Prior to April 1983, the control and distribution of
. design documents was centralized in the main DCC facility. The main DCC provided design document duplication and distribution services to all the
'! ~ ( -
I i
- construction related organizations onsite. The,STEs l found this process burdensome in that the main DCC was
.} remote from their work location and the process was g
time consuming and unresponsive-to their specific needs. In April 1983, the specific needs of the lh Startup organization, and others, were more adequately j addressed by establishing DCC satellites, subordinated
- to the main DCC, in close proximity.to each
' organization's place of work.
I v
' The first DCC satellite was established in the Startup facility. Initially, the DCC satellite provided the STEs with controlled-distribution drawings of their choice. After approximately one year, a review was conducted of the control of these drawings. The review found that the system was working; however, the system was cumbersome and an administrative burden on each organization. The DCC satellite had approximately 20,000 controlled drawings and design change documents distributed throughout the Startup facility. DCC satellite personnel were required to replace and destroy superceded documents. STEs were held accountable for an item-by-item inventory of these .
documents. DCC and Startup supervision decided to eliminate controlled- distribution drawings to individual STEs due to the administrative burdens placed on both organizations. !
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4 RESULTS REPORT ,
ISAP.III.d j (Cont'd) 5.0 IMPLEY.ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
In April 1984, Startup and DCC supervision elected to provide libraries of controlled-distribution drawings to those Startup groups performing similar activities, to provide independent user libraries within the
!' facilities, and to expand the reference facilities near the Startup DCC satellite area.
As an example, the electrical and hydrostatic test groups established reference libraries within their separate office areas. The controlled-distribution i drawings and design change documents within these i libraries are maintained current by DCC satellite personnel. The libraries contain copies of the current controlled-distribution drawings and design change f
- documents required to perform their respective testing 1 activity.
(_;
. 5.2.3 STE Interviews Discussions were held with eight individual STEs out of j approximately sixty to determine their methods of v reviewing design documents and incorporating the current design information into preoperational test procedures. The STEs were selected from the Balance of
, Plant; Electrical; Nuclear Steam Supply;
, Instrumentation and Controls; and Heating, Ventilating, r and Air Conditioning disciplines. For the most part, c the STEs performing the largest number of preoperational tests in each discipline were selected. Seven STEs stated that their method for handling design document changes was to present a list of drawings to DCC, receive a current status report, obtain changed documents, and review and incorporate appropriate changes into the preoperational test i procedures. The eighth STE's procedures were written and approved to the most current design documents and l performed immediately thereafter, precluding an impact by design changes. From the uniformity of the interview responses, it was concluded that document i review offered more useful information relative to the I issues being addressed and the CPRT decided not to s- continue interviewing.
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Page 16 of 23 l RESCLTS REPORT ISAP III.d (Cont'd) i i
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.4 Conclusions -
The CPRT concluded that the Startup and DCC
, organizations have established sufficient measures to i assure that STEs and other responsible personnel are i -
provided access to controlled design documents. This I conclusion is based upon reviewing the startup l administrative procedures; the Startup and DCC i organizations' previous experience with STEs having
. controlled-distribution drawings for their assigned systems; the establishing of libraries within the Startup facilities; and the results of the random'
- sampling and evaluation program.
- It should be noted that the results of the CPSES L[% .-
Monitors Team, activity and DCC supervisory personnel contributions to improving the performance of DCC, combined with establishing DCC satellite distribution
! centers for user convenience, have contributed to
! alleviating the previous burden placed upon the STEs.
1 Of further note is Engineerings' self-established
- limitation on the number of design change documents
- which may be outstanding against a drawing at any given I time. This factor alone contributed significantly to i alleviating the previous problems for STEs. -
! 5.3 Potential For DCC Problems to Adverselv Affect the Testine Proeram j The objective of this task was to evaluate the effect the DCC problems had on the testing program by determining whether the Startup organization was cognizant of authorized design changes initiated by Engineering. Cognizance was measured by looking for the approved test data for the design change in TUCCO's records vault, or by the design change being logged ln I an approved Startup tr'acking system. This evaluatien was
} designed to preclude the nature of DCC errors from affecting the results by examining only the origin and destination of a design change.
I Due to the large number of design changes and the similarity in the process by which they were handled by the DCC, a randem sample review of these documents was deemed by the CPKT to be an appropriate method of investigation of potential progran=atic deficiencies. A random sample of authori:ed design changes requiring Startup's cogni:ance was selected for review in accordance with Appendix D. "CPRT Sampling Policy,'
Applications and Guidelines."
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! Revision: 1 l 1 Page 17 of 23 i RESULTS REPORT ISAP III.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The Startup organization utilizes only a fraction of the design documents prepared for the project. This subset of
, design documents and the changes to them were identified by
- the following steps: first, the calendar interval when DCC problems could have adversely affected startup was determined; j second, the procedures and instructions which utilized DCC controlled design documents were identified and reviewed; and l
finally, this information was used to define the population of changes to the design documents affecting Startup.
5.3.1 Period of Interest f.
The period of interest during which DCC problems could have adversely affected prerequisite testing was defined as the start of testing in mid-1979 until i e May 15, 1984 The period of interest for preoperational testing was-frem JTG approval of the
]i specific preoperational test procedute until May 15, 1984 May 15, 1984 was decided upon by the
- g ,
Testing Programs Review Team by evaluating CPSES
- ! Monitors Team reports to assess the effectiveness of the Startup DCC satellite.
l: The CPSIS Monitors Team was an auditing group established by TUCCO management at the same time the DCC satellites were created. The purpose of the group
~
was to monitor the effectiveness of the document control systees. The Monitors Team continues to i perform its audit function.
I The CPSES Monitors Team reports were also utilized by the NRC-TRT QA/QC Group in their evaluations and were
. their basis for making the judgment that in July 1964, the DCC satellites supporting the construction
. organization appeared to be working properly.
i l 5.3.2 Prerequisite Test Instruction Review t
Each of the thirty-two prerequisite test instructiens in existence at the start of implementation of this ISAP were reviewed to identify those which required
- utilization of design documents during the testing activity. From this review, the types of project design docu=ents used in preparation and execution of prerequisite test instructions were determined. This information was utilized in identification of the prerequisite test population of design changes.
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- t. .
- 'ISAP III.d
, (Cont'd)
- 5.0 IMPLEw.ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.3 Preoperational Test Procedure' Review
, All preoperational test procedures were reviewed to determine which test procedures were performed during the period of interest'and not completely reperformed after May 15, 1984 The preoperational test procedures
- which met these criteria were identified. The design
{ drawings referenced by these procedures and controlled 1- by DCC were identified. These referenced drawings were
! used to assist in the identification of the ,
preoperational test popula. tion of design changes.
- 5.3.4 Prerequisite Test Population Identification
'; The prerequisite test population was identified by.
.; examining the types of Project design documents, a'- -
examining the projeqt design change methods, and
(*s) uniquely identifying each design change in the population.
s ,
- ! The design documents for the* project include such 1- documents as correspondence, calculations, analyses, r reports,. drawings, sketches, and specifications. These design documents are generated by various engineering j , disciplines such as architectural, civil, structural, j i mechanical, electrical, instrumentation and control,
- .i etc. These same design documents are utilized for various purposes by different organizations such as 3 l
- electrical construction versus electrical QA/QC, or
- ,' civil / structural construction versus Startup testing.
- [ By examining the types of design documents required for j; test procedure preparation and/or.. execution, the
- specific types of design documents utilized by Startup
- j were identified and included in the population.
lj Several examples of the. types of design documents
!! included in the population are mechanical and
! electrical specifications, flow diagrams, instru=ent
! li and control logic diagrams, electrical three-line
- i
, diagrams, and electrical connection diagrams. Several examples of the types of design documents which were
- j not an essential element of the testing activities and in '
were excluded from the population are the ll '
architectural, civil, and structural design, drawings
) ;' _
and specifications. .
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- ISAP III.d (Cont'd) fl' 5.0 ^ IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The Startup organization utilizes design documents as the primary resource in~the preparation of test j, procedures and the execution of testing. Startup i; responds to three design change methods used by -
1: Engineering. The three Engineering design change
.i: procedures are: direct issuance of a revision to a I design drawing; issuance of a Design Change Authorization (DCA) which is a design document change
.; issued prior to the actual design drawings being i updated and issued; and issuance of a Component l Modification Card (CMC) which is similar to the DCA,
- but site oriented.
I The design change population contained changes J initiated by revision of Gibbs & Hill /TUCCO Nuclear
}.
Engineering drawings, by DCA, and by CMC. Engineering
. ~. apaci,fications were changed by DCA and were.in the DCA l
e i s change subpopulation.
- l. ,
5.3.5 Prerequisite Test Population Screening Process j The following screening criteria were used to identify j design changes belonging to.the prerequisite test 3
population:
1-The change was to a design document.
l -
The change was issued through the DCC.
t l' -
The document was referenced by a test procedure or was used during the performance of a specific test.
The test procedures which referenced or i
utilized the affected documents were i
performed during the period of interest.
The docu=ent change occurred prior to performance of the test.
j - The change required a test or retest.
i i Drawing revisions which were issued to incorporate l j m only DCAs or CMCs were excluded to preclude biasing the l j population by multiple references to a particular design change.
5
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- RESULTS REPORT ISAP III.d (Cont'd)
, 5.0 .1MPLEF.ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
During screening, the CPRT found that design changes i! were initiated, logged, and tracked by the TUGC0 Design Change Request (TDCR). The TDCR is a Startup procedure which seeks Engineering review and approval of a, proposed change to the design. Since Startup initiated lI. and tracked these changes, they were excluded from the
_ll sample.
- j. 5.3.6 Prerequisite Test Sampling Results j A sample consisting of sixty-one approved design changes requiring Startup to perfor= a test was evaluated. The evaluation showed that each of these
, sixty-one samples met the following acceptance criteria:
4 ( The design change was tested as evidenced by
\. - approved test data, or was documented as being monitored by Startup as an open itee.
. An open item means the design change was docu=ented as i being logged in a Startup organization tracking syste=,
'[ 1.e., a tracking system such as the Master Data Base, or Startup Work Authorization log. Since no f ,
discrepancies were identified during the evaluation.
- the saeple size was not expanded.
l
'; 5.3.7 Preoperational Test Program Population Definition l'
In the overall organization of engineering drawings,
- [ the flow and control circuit schematic drawings-are the definitive design documents specifying system and
?
component functionality; the other engineering drawings are required to ir.plement the design presented in these i drawings. The object'ive of preoperational testing is to test and verify system and component function.
Based on this, it was determined that changes to the
!. control circuit schematic and flow diagrams would have
- j. the greatest potential impact on a preoperational test.
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.j RESULTS REPORT ISAP III.d j
- ). (Cont'd) i
}, 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) j
> p:
H The preoperational test population was therefore l identified from the list of referenced drawings prepared during the review of preoperational test procedures conducted prior to May 15, 1984 and not completely reperformed after that date. The final preoperational test population contained the flow and
.l control circuit schematic diagrams identified from this -
- J
'l
- l list.
5.3.8 Preoperational Test Population Screening Process
- The following screening criteria were used to identify design changes belonging to the preoperatiohal test population:
I
'l
- The cl.ange is to's design document.
( .
- The change is issued through DCC.
I - The document is referenced by a test i procedure or is used during the
- j; performance of a specific test.
e !! - The testsprocedures which reference or -
t utilize the affected documents were
,! performed during the period of interest
- j- and were not completely reperformed following the period of, interest.
- j -
The document change occurred prior to performance of the test.
- The change would require a test or retest.
- 4 i 5.3.9 Preoperational Test Sampling Results
.t i A sample consisting of sixty approved design changes
!! requiring a test by Startup was evaluated. The evaluation showed that each of these sixty samples met the following acceptance criteria:
,- - A preoperational' test proc dure incorporated the design change, or was documented as being monitored by Startup as an open item.
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, Page 22 of 23 RESULTS REPORT ISAP III.d (Cont'd)
I 5.0 IMPLEM.ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
, An open item means the design change was documented as being logged in a Startup organization tracking systen, i.e., a tracking system such as the Master Data Base, or Startup Work Authorization log. Since no discrepancies were identified during the evaluation.
the sample size was not expanded.
l 5.4 Evaluation of Results
,. The CPRT implemented the tasks in the action plans and ll measured the results against the acceptance criteria.
5.4.1 STE Ac' cess to Current Design Documents ll
] The CPRT evaluation verified that TUGC0 has established
- t g
. measures to provide reasonable assurance that STEs and other responsible test personnel are provided with current controlled design documents and changes. The i
l sampling and evaluation pregram confirmed that, during the period of concern, the STEs did use current design
.;. documents in the conduct of both preoperational and
- g. prerequisite testing activities.
5.4.2 Potential For Dcc Problems to Adversely Affect the j, Testing Program f' The CPRT evaluation provided ninety-five percent confidence that at le'ast ninety-five percent of the design changes which could have affected the !
prerequisite and preoperational testing due to document
- j control center problems did not adversely affect these is programs. ;
'I 5.5 Root Cause and Generie Imolications I
i The potential generic implications of document control problems were that Startup testing activities may have been i, . adversely affected such that safety-related plant systems and
! components may not be properly tested. This evaluation
~ . determined that the Startup organization was using effective
. . . methods for the use of design documents and was not adversely affected by the document control problems. Consequently, root i - 'cause and generic implication evaluations were not necessary.
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RESULTS REPORT ISAP III.d (Cont'd)
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6.0 CONCLUSION
S The CPRT concluded that the Startup and DCC organizations have
.{ established sufficient measures to assure that STEs and other
- - responsible personnel are provided access to controlled design documents.
4 l The results of this evaluation provide reasonable assurance that i the document control problems which existed prior to 1984 did not i adversely affect the testing program.
7.0 CNGOING ACTIVITIES There are no ongoing activities related to this issue.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE .
,l Based upon the CPRT review, there is no further action required to 1 preclude future occurrence.
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- f. RESULTS REPORT
+- .
E l' 1:
-n. ISAP: VII. b . 2
Title:
Valve Disassembly
- I REVISION 1 l-
.. j
'I l
- I jl 1
wr M Issue Coordinator s/wA Detie /
f
, l.du v f so f uw Revi Team Leader Dat4 '
i C,~ u. Lc Sans
- Johp'. Beck. Chairman CPRT-SRT Date ,
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3 ISAP VII.b.2 Valve Disassembly
1.0 DESCRIPTION
OF ISSUE (USNRC Letter of January 8, 1985, Page. 23) d "The TRT found that installation of certain butt-welded valves in three systems required removal of the valve- bonnets and internals prior to welding to protect temperature-sensitive parts. The three systems involved were the spent fuel cooling and cleaning system, 4
s the baron recycle system, and the chemical and volume control
-l- system. This installation process was poorly controlled in,that j.
disassembled parts were piled in uncontrolled areas, resulting in
]- lost, damaged, or interchanged parts. This practice created the
- { potential for interchanging valve bonnets and internal parts having j.
different pressure and temperature ratings."
t 2.0 ACTION IDENTIFIED
't
{ Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of the pacential i safety implications should include, but not be limited to the areas or activities selected by the TRT."
i -l --
" Address the root cause of each finding and its generic j implications..."
tj
!! " Address'the collective significance of these deficiencies..."
'l
- l.
't
" Propose an action plan...that will ensure that such problems do not occur in the future."
{, 3.0 BACKCROUND i
The valves identified by the NRC staff are of a particular type which r.equired disassembly for installation. Other possible
'i; reasons for valve disassembly include hydrotest, flushing, purging, j,i and repair, and therefore many different valve types could be affected if the concern is substantiated. Accordingly, all valves
,) which had been disassembled under the Construction QA program, regardless of valve type or reason for disassembly, were included
, ;' , in this action plan.
1-The loss of or damage to valve parts is not a concern if the parts 1
- . ' are replaced with acceptable spare parts and properly documented.
The program for valve testing provides assurance that valve damage ;
that would hinder proper operation of the valve is detected and' -i f corrected. As the issue as stated in SER-11 did not allege any j l
)
4
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i-Revision: 1 Page 2 of 20 RESULTS REPORT
- ISAR VII.b.2 (Cont'd)
,T -
3.0 BACKGROUND
(Cr.?tt'd)
-i improper handling of lost or damaged valve parts this action plan t
focused on the " potential for interchanging valve bonnets and internal parts having different pressure and temperature ratings".
, SER-11 states in part that:
"The TRT interviewed QC inspectors who, knew of recent incidents involving lost, misplaced or interchanged valve 1
bonnets. The QC inspectors stated that when these valves were disassembled for system flush under the direction of startup
[ test engineers, one bonnet was lost and a mismatch between valve body and bonnet occurred. -Although these incidents were e- documented in nonconformance reports, see e.g., NCR M-11645 (May 8, 1984), the problems associated with maintaining control of valve parts during installation, system flush, and ig startup indicated to the TRT that in spite of the issuance of
- l
i
/
the revised traveler and CP-CPM-9.18 in June 1983, loss, L
damage, and interchange of valve parts continued to occur. '
The TRT did not find any evidence that B&R addressed the problem on a programmatic basis, e.g., by use of a formal corrective action request (CAR)...
The TRI concludes that the allegation concerning interchanged valve parts (AQ-52) was substantiated. The TRT also concludes j that this condition has potential quality significance due to L
the generic implications. The generic. implications are based on documented evidence that the interchange of valve parts did
[ occur and effective programmatic corrective action was not
'I implemented to identify the problem and to prevent the loss.
I damage, and interchange of valve parts."
{ An assesement of TUCCO's handling of programmatic corrective action will be included in ISAP VII.a.2, "Nonconformance and Corrective
{ Action Systems". This action plan (Valve Disassembly) was l structured to e. valuate the adequacy of current procedures to i
j control the valve disassembly / reassembly process and to evaluate the physical status of valves which are installed in the plant and '
have been disassembled and reassembled.
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.t.
(Cont'd)
- )b.
[. 4.0 CPRT ACTION PLAN il.
j,j 4.1 Scope and Methodology The objective of this action plan was two fold: 1) to evaluate if procedures are adequate to control the valve jj ' disassembly / reassembly process; 2) to evaluate if valves that -
' required disassembly were properly reassembled and, if not, whether an improperly reassembled valve could result in a code 4
violation or have a safety consequence.
, The following tasks were implemented to achieve these
- objectives
Identification of all valves which have been disassembled and reassembled under the Construction QA program.
qj -
A procedure review to determine adequacy of control of valve components during. disassembly and reassembly.
A safety consequence analysis to determine if valve component parts from one valve are physically capable of fitting up to another valve of the sans type but i;t having a lower pressure / temperature rating or Code class and identification of potential risks if such
! reassembly occurred.
- l
'j A reinspection of valves which have been disassembled i ,
l and reassembled to establish confidence that valves t were properly reassembled. -
.t The first three of the above tasks were considered Phase I of this action plan. Phase II of this plan was the fourth task. ;
The specific methodology is described below:
4.1.1 The first step in this investigation was to identify the population of valves which have been disassembled.
All valve disassembly and reassembly was accomplished under operation travelers or Item Removal Notices I (IRNs). A log of all operation travelers was reviewed and those pertinent to valve disassembly were utilized 5
to develop a list of all valves which have been disassembled. The log includes QC Checklists for valves (QCVs) which accompany IRNs applicable to valve disassembly.
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RESULTS REPORT ,
,4 i
ISAP VII.b.2
! (Cont'd)
't a
4.0 CPRT ACTION PLAN (Cont'd) 1 From this list another list was developed of those valves in the population identified in the TRT issue (diaphragm valves in the spent fuel cooling and cleaning system, the baron recycle system, and the j chemical and volume control system).
.t.
4.1.2 Applicable procedures were reviewed, for both j
construction and QC, to determine,1f they provided J' adequate controls of materials during valve disassembly j and reassembly. In addition to proper matching of J.
components, the procedures were reviewed for their adequacy to identify and replace parts damaged during the disassembly, storage and reassembly process.
i For procedures-which changed during the course of i-construction, the historieel file of procedures was j
reviewed to determine if improper reassembly was more
, likely to occur.during a particular time frame. Units
( .
1, 2 and Common used the same procedures. .
In teras of valve installation processes, present procedures were viewed as adequate or not, based on their clarity, completeness and on the practicality of
{' their use.
i j
4.1.3 In parallel with the procedure review, an analysis was made to determine the safety consequences of improperly assembled valves. The analysis included potential I
failure modes resulting from improper reassembly of the generic valves in question. Generic valves are those which required disassembly of all valves of that type. s This analysis was to be performed on a case basis for non generic valve types pending the results of g
reinspections. (As discussed in Section 5. this was not required.)
In addition, an evaluation was made to defir potential code violations.which could result from improperly assembled valves.
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Revisient 1 Page 5 of 20 RESULTS REPORT
,l'
- .' ISAP VII.b.2 (Cont'd) 8~
4.0 CPRT ACTION PLAN (Cont'd)
- I. 4.1.4 A reinspection of valves which were disassembled was sh d
performad to provide assurance that the valves were ib reassembled using the correct components. A sample of valves from the population of all valves which were ji disassembled was rainspected, and an additional sample
~F 1
of valves from the population comprised of the valves identified in the TRT issue was reinspected. Both n- samples were in accordance with the sampling criteria
{^ guidelines of Appendix D. Sample reinspection was considered to be a reasonable approach for the following reasons:
-{ -
No programmatic deficiencies were identified in Phase I of this ISAP.
The population of valves which have been
-[
disassembled is homogeneous. Specifically, all the valves were disassembled by the same
'i ( craft under the same procedures. '
., 4.1.5 Manufacturers drawings and' disassembly procedures were
.] reviewed and documentation packages were assembled for
- those valves selected in the random samples. The inspection procedure was predicated on the results of this review. -If review of the documentation for a ll specific valve indicated probable improper reassembly, reinspection was to include a verification of internal lj{-
parts. Probable improper reassembly would have been indicated by an inconsistency in internal component serial numbers from one Operation Traveler to another '
for a particular valve. (As discussed in Section 5, l internal verification was not found to be necessary.)
U 4.2 Procedures 11
,3 '
Construction and QC procedures now in effect were reviewed for use if disassembly, inspection, reassembly and test of any valves.had been necessary as a result of the implementation of this ISAP.
i 4.3 Participants Roles and Responsibilities j
' The organizations and personnel that participated in this effort are described below with their respective scopes of i
.- work.
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Page- 6 of 20 RESULTS REPORT
^ ^
l ,
ISAP VII.b.2 4
(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.1 TUGC0 Comanche Peak Project Engineering CPPE 4.3.1.1 Scope Assisted the QA/QC Peview Team in
., the identification and provision of all necessary specifications,
~
- drawings, procedures and other
.t documentation necessary for the i execution of this action plan.
, t, j -
Assisted in determining the physical location of the valves selected for inspection.
Process NCRs that were generated due
- to this action plan.
. 4.3.1.2 Personnel Mr. C. Moehlman TUGC0 Coordinator Mr. D. Snow QA/QC Coordinator I
j 4.3.2 ' Brown & Root M111vright Shop
- 4.3.2.1 . Scope -
i Disassemble and reassemble valves, as i
required, for inspection. (As' discussed in Section 5, this was not required.)
4.3.2.2 Personnel Mr. C. Moehlman TUGC0 Coordinator 4.3.3 CPRT-QA/QC Review Team l
4.3.3.1 Personnel All activities not identified in 4.3.1 and 4.3.2 abeve were the responsibility of the j QA/QC Review Team.
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i ISAP VII,b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l] 4.3.3.2 Personnel Mr. M. Obert Issus Coordinator Mr. C. Spinks Inspection Supervisor
- j. Mr. J. Adam
~
Safety Significance Evaluation Supervisor -
Mr. J. L. Hansel QA/QC Review Team Leader
-i 4.4 Qualifications of Personnel Where inspections required the use of certified inspectors,
- qualification was to the requirements of ANSI N45.2.6 at the i appropriate level. CPSES personnel were qualified in j accordance with applicable project requirements. Third-party
'l ,-
\
inspectors were certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the requirements of the CPSES quality j procedures.
Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific p requirements'of the CPRT Program Plan.
i
- 4.5 Sampling Plan The sampling plan was designed in accordance with the guidelines of Appendix D, to result in reasonable assurance that programmatic deficiencies do not exist in the population.
The minimum sample size according to Appendix D is 60, with a detection number of zero (i.e., the critical region is one or more deficiencies found in the sample). -
7 4.6 Acceptance Criteria A valve was accepted if the body markings and bonnat markings found in the field were traceable to the Manufacturer's Data Report (Form NPV-1) in the Receipt Inspection Report for that valve. Valves which have Permanent Equipment Transfers l
documenting replacement of valve components and for which the j new component was. traceable to a form NPV-1 of a valve of j identical make, pressure rating, temperature racing, metallurgical type and Code class are acceptable. l l
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4 RESULTS REPORT ,
j ISAP VII.b.2 -
] .(Cont'd) .
.]~
f 4.0 CPRT ACTION PLAN (Cont'd) 4.7 Decision criteria 4.7.1 The action plan will be closed if the valves which were disassembled and reassembled can perform their intended safety function. Otherwise ner.assary corrective action will be recommended to meet the
,4 design requirements.' '
4
.l 4'. 7. 2 If a safety-significant deficiency is found the sample j will be expanded and a root cause and generic i implication. analysis will be done. If deviations are j found, trend analysis will be done and for any adverse
, trend identified a root cause and generic implication analysis will be performed. Any QA/QC Program deficiencies found will be identified to the QA/QC Progracusatic Issue Supervisor for analysis.
t
( 5 .'O IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS
( 5.1 SummarvofActionPlanImpEementation s
5 The first step of implementing this action plan was identification of the subject valves in the population. This
- l vas accomplished in two ways.
i j First, the generic valves (i.e., those valves which required
, disassembly by nature of their type) were identified by l reviewing installation procedures. It was concluded that i
ITT-Grinnell supplied diaphragm valves were those addressed in -
the TRT issue which " required removal of the valve bonnets and internals prior to welding to protect-temperature sensitive parts". AdCtionally, it was found that Borg-Warner supplied
~ check valves were disassembled after receipt on site to perform a modification identified by the manufacturer. These two generic valve types were included in the population using
, a listing of valve tag numbers (unique numbers'given to an l installed valve) by purchase order. The 1.' sting. groups the 3 valves ac::ording to their manufacturer and type. For these valves an analysis was' performed to determine if physical j reinspection was required. This' analysis lists the possible j offects of interchanging those parts of the generic valves I
where parts of one rating or class valve are physically j capable of fitting up with a valve of another racing or class.
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, s RESULTS REPORT l i t. .
- i: ISAP VII.b.2 (Cont'd)
\
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i
- }..
In addition to the generic valve types requiring disassembly. l
}lM
- ?-
other specific valves were disassembled for various reasons such as repair, maintenance, or testing. To identify these Q valves, operation traveler logs were researched. Due to the large number of valve types / sizes in this category and the !
, relatively small number of valves of any given type / size {
actua31y disassembled, an analysis such as was performed for l the generic valves was not performed unless it was determined I during the reinspection program that a deviation was found for ly[ a specific valve type. No such cases were found.
- t-
!. A population of one thousand three hundred forty-five (1345)
- valves that were disassembled and reassembled was identified.
.I Approximately seven hundred (700) of these valves were 1
. l; ITT-Crinnell diaphragm valves. From within this overall l
.; population a second set of three hundred thirty-four (334) valves was identified consisting of those valves addressed in
. j- '
the TRT issue (i.e., ITT-Grinnell diaphragm valves in the p 'A spent fuel cooling and cleaning system, the baron recycle system, and the chemical and volume control system). The
- j;;
populations were considered to be homogeneous for the
- ( following reasons
L .
I 1. The valves were disassembled by members of the same craft i.e., Brown-& Root millwrights, p 2. All valves were disassembled using the same i
.[ construction and QA/QC procedures. j i *
.l 3. All valves in the samples could be and were reinspected to the same checklist and attributes and used the same
- acceptance criteria.
A random sample was chosen from both the general population
- o and the TRT issue valves. The samples were randomly selected to obtain at least sixty (60)-items from each group in order 4
to achieve the confidence level prescribed in Appendix D of the CPRT Program Plan. During random selection of the sixty ,
(60) valves for the general population some sample overlap
- occurred. Valves which satisfied the criteria of the TRT issue sample were selected in the general population sample.
This required selection of only a sufficient number of additional valves in the TRT issue sample to have sixty (60)
! L valves from each p,pulation. Thus, the total number of valves i
reinspected was one-hundred six (106).
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Page 10 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) i
)
{ 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) !
ih For each valve selected in the sample an inspection package I
- j. was assembled containing the manufacturers drawing, piping j-isometric, and operational travelers associated with that
't. valve. These documents were reviewed for any indications of
'!' incorrect valve reassembly which might require disassembly of the valve for inspection of internal components. To make this 3 determination the travelers were checked for variances in _j 3
internal component serial numbers. No such cases were found. '
. r.
- j.
The valves in the sample were then physically inspected in l accordance with QI-018. Reinspection of Previously
'? Disassembled Vaives. The purpose of the inspection was to verify that the body and bonnet installed in the field could 7i be traced back to proper documentation showing that they were received from the manufacturer as part of the same-valve i l
assembly or that plant documentation showed replacement of the l
- valve component.
.s lI. Valves which had their body and/or bonnet markings obscured by i'
'-' insulation, paint, etc., were classified as inaccessible and were replaced by the next randomly selected valve. Forty-two j
(42) valves were found to be inaccessible. No bias was introduced as insulation or paint does not effect the methods used for the control of the disassembly / reassembly of the valve.
5.2 Evaluation and Categorization of Inspection Findings No safety-significant deficierci+*, were found during the ll: course of the reinspection pra, cat for this issue. '
l Description of Deviations
'! There were four (4) valid deviations. These were all on ITT-Grinnell diaphragm valves. The deviations consisted of
- l the bonnet assemblies installed on the four (4) valves being different from the bonnet assembly that the Manufacturer's
}[ Data Report Form (NPV-1) indicated belonged on the valve.
- {
j The total of one-hundred six (106) valves reinspected consisted of seventy-nine (79) ITT-Grinnell diaphragm valves i and twenty-seven (27) valves from eight (8) manufacturers.
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. Page 11 of 20 RESULTS REPORT
. ~
, l
' ' 1 ISAP VII.b.2 j (Cont'd) ;
M 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) e-
- Review of the documents assembled for the reinspection
! packages revealed one case where the bonnet of a diaphragm
- j; valve had been lost and one case where the bonnet had been
'3 damaged. These were not considered deviations as they were l
properly identified by TUGC0 using the NCR system and ;
traceability of the installed components was maintained using '
Permanent Equipment Transfers. ,
3 1
,i The ITT-Grinnell diaphragm valves required disassembly for f installation to protect the non-metallic diaphragm from heat damage during velding of the body into the pipe l line. The disassembly of the valve is accomplished by unbolting the valve bonnet and lifting the bonnet off the i body. The diaphragm and other internals remain attached to L
the bonnet so that the valve is essentially in two pieces, the 3 body and the bonnet. Further disassembly of the bonnet is not required for installation.
!' . x i
' :' *; The reason for the deviations being limited to the
.f ITT-Grinnell diaphragm valves is judged to .be due to the much 1
greater opportunity for the switching of parts. This
! opportunity arose from there being a relative'ly large number 4
{ of this type valve, all of which had to be disassembled to be installed. This resulted in many valve bonnets of the same size and type in storage avaiting reassembly at the same time.
, The only noticeable difference in the valves vculd be the marking of the valve tag number on the bag in which the bonnet was kept. Thus the opportunity. existed to retrieve the wrong j storage bag. No other kind of valve was disassembled in such
- large numbers at a given time.
Two types of ITT-Grinnell diaphragm valves were supplied. The i first type is a standard Class 150 valve per ANSI B16.5. This class is cammonly referred to as the 150 lb. class valves but i
{ in fact are good for pressures higher than 150 psi depending i
upon the temperature. The design pressure and temperature of the ITT-Grinnell standard Class 150 valve is 255 psi at
.' 150' F.
l.
I For some applications valves rsted for 300 psi at 150' F were
- specified. The valves provided for these applications
! - are slightly modified versions of the standard Class 150
}' valve. These modifications are only made to valve sizes 2",
4
!~ 3", and 4". Other valve sizes are. identical irrespective of 5 ;
., pressure / temperature rating. '
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6 Rsvisica: 1 Page 12 of 20' RESULTS REPORT i
ISAP VII.b.2 (Cont'd)
, 5.0 IMPLEMENTATION OF ACTION PLAN AND, DISCUSSION OF RESULTS (Cont'd) 1 1: There are two modifications. The most significant modification 1
is the addition of a support sheet behind the diaphragm to
- l. increase diaphragm life by reducing abrasion to the back of 1
the diaphragm operating at the higher pressure. The support
! sheet is not required for safe operation of the valve.
1- Additionally, the manually operated valves rated at a design 1
pressure of 300 psi have a brass spindle instead of stainless j steel. This is to reduce galling at higher operating ,
l- pressures. Valves with air operators have stainleas steel 4-spindles for both pressure / temperature ratings. The change in
}, spindle material does not affect safe operation of the valve.
Both modifications described are made only to improve valve lifetime and do not affect the safety performance of the valve. The valves with design pressure of 255 psi and the valves with design pressure of-300 psi have bonnets and bodies of identical material type and metal thickness and identical l- diaphragas.
ji Oj 2
Both of the valve types (255 psi and 300 psi, design pressure) were supplied to CPSES in ASME Code class 2 and 3.
The.ASME ' ,
valves of a given pressure rating are manufactured the same
,, regardless of desired Code class. After manufacturing they
- . are certified to the desired Code class through different post j; manufacturing testing, with the more stringent testing being
!- performed on Code class 2. The difference in testing involves
- only the body of the valve. There is no difference in the certification of the bonnets of class 2 and class 3 valves.
Therefore, there is no substantive effect of interchanging
] class 2 and class 3 bonnets on ITT-Grinnell diaphragm valves.
Additionally, some non-ASME class diaphragm valves were
{. supplied. The difference in non-ASME and ASME manufacturing processes for the bonnets and these valves are all in the 1 level of QA requirements and documentation. The chemical and physical properties identified in the material specifications i
of the non-ASME and ASME Code class valve bonnets are the
,' same. Also the post manufacturing testing performed on th'e j
non-ASME valve bonnets is the same as that for the ASME -
l bonnets, and therefore, the likelihood of an undetected valve bonnet defect is the same for both ASME and non-ASME valves.
i It is concluded that'there is no substantive effect of I
interchanging a non-ASME bonnet with an ASME bonnet on l- . ITT-Grinnell diaphragm valves.
I '..-
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+;. RESULTS REPORT '
ISAP VII,b.2 (Cont'd) 5.0 IMPLDENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The valve bonnet of a given ITT-Grinnell diaphragm valve size
' will physically fit up with any valve body of the same size, regardless of their respective pressure / temperature rating or
' Code class. Any undocumented interchange of one valve bonnet for another discovered during the reinspection was considered q a deviation.
e d
For two of the bonnets found to be deviations (valve tag no.
2-8422 and 2-7131B), documentation was found in the TUGC0 vault substantiating that the valve bonnets installed are identical in pressure / temperature rating and Code class to
,j those which were supposed to be installed.
.r
?
Of the remaining two deviations, one of the valves (valve tag
! '. no. XSF-179) is a standard (255 psi at 150*F) rated valve, ASME Code class 3. Documentation was not found to identify
- j the pressure / temperature racing and Code class of the installed bonnet. However, the bonnet was verified through y (m)
~' markings stamped on the bonnet to be an ASME Code class
- h component so it must be equal to or better than Code class 3.
j Likewise since only two valve types were supplied to CPSES the installed bonnet must be equal to or better in pressure / temperature rating.
- j The remaining valve deviation (valve tag no.1-7046) was on a
- i. Code class 3 valve rated at.300 psi and 150*F. No
documentation was found identifying the installed bonnet but
- j it was verified through markings stamped on the bonnet as an
- ! ASME Code class component so it must be equal to or better i' than required. The reasoning used to classify the deviation as non-safety significant is as follows. Making a worst case ,
{
-,; assumption, the installed bonnet is assumed ta be a standard j
.g would, at most, have the modification of adding the plastic support sheet. This valve is air operated, so the spindle is
' stainless steel regardless of the bonnet type. Per ITT-Grinnell, use of a standard valve in a 300 psi system is not recosunended; however, lack of the support sheet would
reduce diaphragm life but would not prevent proper valve
- operation. This, coupled with the fact that the valve
': pressure containing boundary (body and bonnet valls) for both
,l. valve types are identical, led to the conclusion of non-safety significance of the deviation. No credit was taken for this valve's expected operating pressure and temperature being substantially lower than even the standard valve's capabilities.
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^. RESULTS REPORT l j ,
ISAP VII.b.2 J (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- J '
The valves found to have deviations were installed between l early 1979 and late 1981. This was a period of high activity l for diaphragm valve installation. It should be noted that the installation travelers for two of the valves. Tag No. 1-7046 !
disassembled in December, 1980 and Tag No. 2-8422 disassembled '
in January, 1981.-included requirements to record the markings )
on the bonnets and to verify the numbers at reassembly. This I was.done and indicates that the valves as originally issued I for installation and as currently installed in the plant are !
the same. This means that the switching of the bonnets l occurred prior to their issue for installation. No '
documentation has been found indicating disassembly prior to j installation issue, nor any reason found for disassembly prior <
1 to issue.
.i The travelers for the other two valves with deviations were written prior to the practice of recording bonnet markings so it is unknown when the switching of the bonnets occurred. .
' (s Procedure Review
- Procedures pertaining to valve disassembly / reassembly are
.g; designed to:
O.
{' 1. Provide instructions to craft for proper process
- completion.
- 2. Provide control for tracking of components (valve -
'{ bonnets) to ensure removed parts are returned to proper locations or to ensure interchanged parts are properly
-{ recorded (on PETS).
i
,; 3. Provide control for identification and proper i
replacement of lost or damaged parts.
l The valve installation process was performed under Construction Procedure CP-CPM-6.9, General Piping Procedure
- I including Appendix E. Pipe Fabrication and Installation initially issued in October 1978. '
I:
From the initial issue of this procedure in October, 1978, j through the present time the requirement has existed to perform valve disassembly / reassembly using Construction Operation Traveler's prepared using Construction Procedure CP-CPM-6.3, " Preparation. Approval, and Control of Operation a . _-- w- - - - - - - - "~ ^ ~ - ^ ^ ^ ^ ^ ^ ^ ~ ~ ^-
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Page 15 of 20 l .
ll RESULTS_,RE10,RJ ISAP VII.b.2 (Cont'd) .
,)
l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) h Travelers". The operation traveler " serves as a fabrication /
installation / inspection checklist of operatiohs necessary to l.
achieve a quality and product". Both CP-CPM-6.9 and
, CP-CPM-6.3 provide for Quality Assurance participation in both the preparation of the traveler, to ensure proper inspection hold points were included, and during the actual disassembly / reassembly. Procedure CP-CPM-6.9 has also always
- ] contained a provision that the parts from disassembled valves
'i be placed in a bag or box which was marked with the valve
- j number. The bag / box was required to be stored in the valve t vicinity for large valves or in a secure storage area for i smaller valves (ITT-Grinnell diaphragm valves can all be considered small).
The early procedures in use did not specifically call for recording on the travelers the marking stamped on the valve 1
pieces stored nor for QC verification that the same components were being reassembled as were removed. They were adequate,
!! ./R however, if properly followed, to accomplish the disassembly /
[ G reassembly of valves with correct components. This conclusion
(- follows from the requirements to mark the bag containing the i disassembled components and to store them in specified areas.
The valve storage area at the' aillwright shop was inspected
} and it was found that valves are currently being marked and stored correctly. The millwright shop personnel are
! knowledgeable in requirements for equipment component l' traceability and have implemented an effective program to meet j these requirements. These personnel have been in charge since early 1983. Sufficient information for evaluating valve l storage prior to this' time is not available.
i The issue related to documentation of interchanging bonnets on the diaphragm valves was recogn ued by TUCCO and as early as 1980 travelers began to be writ en requiring that the body and bonnet identification numbers (numbers that are marked on the individual component and are different : rom the valve assembly
', - serial number) be recorded at the time of valve disassembly.
In-June, 1983 the procedures were revised and a new procedure.
CP-CPM-9.18, Valve Disassembly / Reassembly was issued. This procedure covers valve types including the ITT-Grinnell-i diaphragm valves. At the same time Quality Assurance issued
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.; , RESULTS REPORT
- l
- y. ~- .
ISAP VII.b.2 (Cont'd) q.
e 5.0 IMPLDfENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l J*
procedure QI-QAP-11.1-39A Valve Disassembly / Reassembly corresponding to CP-CPM-9.18. This QA procedure specified use I of a "QCV" check 11st'which requires the recording of body and !
bonnet identification numbers upon disassembly and a j verification of the proper numbers at the time of reassembly. '
3 This ensures that the proper bonnet is returned to the valve.
I The requirements of Procedure QI-QAP-11.1-39A have now been.
j incorporated into QI-QAP-11.1-26, ASME Pipe Fabrication and j Installation Inspections.
1
,0 CP-CPM-9.18 allows valve disassembly to be initiated through i- use of an operations traveler (CP-CPM-6.3) or an IRN
, (CP-CPM-6.10). The IRN is used if valves are only disassembled / reassembled without addition of spare parts and
! disassembly / reassembly procedures are included in CP-CPM-9.18.
Otherwise the operations traveler is used. In both cases QC h
1, is involved as specified in QI-QAP-11.1-26. The QC checklist 7 -g used with both the operations traveler and the IRN requires 1,
i vl recording of the bonnet identification numbers.
p Administrative actions were taken in mid-1985 to ensure the
- l above requirements were fully implemented in the startup test j program.
.l'
- j. The current program provides the controls necessary to ensure:
U 1.
j Proper installation of valve components and
i 2. That non-conformances (lost or damaged parts or interchanges affecting performance characteristics)
? will be identified and corrected.
.! The example of a lost valve cited by TRT in SSER-11 is not
.l ' unexpected in a large project. The procedures are structured to detect such problems. The particular instance sentioned
,1 was detected by the project and documented on a Nonconformance i Report, thereby demonstrating that the procedure system is
!; working as designed to identify and correct any lost or i damaged parts.
i 5.3 Trend Analysis
-l l l
^
l A trend analysis was performed for the four (4) valid deviations found.
All deviations were found in ITT-Crinnell diaphragm valves.
It is significantly less likely that similar deviations exist in valves other than ITT-Grinnell valves for the following reasons:
.,.......7
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.I.i Revisitna 1 t
Pago 17 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
P,
- 1. These valves (non-diaphragm) were not disassembled such that large numbers of compatible valve parts were available for interchange as was the case with the
.ITT-Grinnell diaphragm valves. Even though all the valves were disassembled by the same craft and under the same procedural control, the' valves other than E
ITT-Grinnell diaphragm valves were less likely to be interchanged as there was less potential.
i}-
j] '
- 2. Of the valves other than ITT-Grinnell diaphragm valves reinspected, no valid deviations were found.
h
'For the ITT-Crinnell diaphragm valves, it was determined that the effect of using a valve bonnet rated at 255 psi on a valve l}, body rated for 300 psi vould not cause a safety-significant
-6 deviation in any instance. This comes from the fact that the
} pressure boundaries of the valve and the diaphragm are
- j- identical for both ratings. The only differences (diaphragm y support sheet and brass spindle in . higher rated bonnet) are
- d. g3 Q for increased life / reduced maintenance and are not required for the safe operation of the valve.
1; No deviations in code class were found so no trend for code class violations exists. ,
The non-ASME and ASME Code class valve bonnets are manufactured by the same physical process and use the same
- i materials. Addii:ionally, the post manufacturing testing of the non-ASME bonnets is the same as for the ASME bonnets.
' j{ , While the potential for switching non-ASME and ASME Code class bonnets did exist, there is no implication that switching of non-ASME and ASME valve bonnets could be safety-significant.
{f Therefore, the four deviations were not judged to be an adverse trend.
5.4 Root Cause and Generic Implication Evaluation 1
{ The reinspection program found no construction deficiencies.
- i No adverse trend exists. Therefore, no root cause or generic l implication analyses were required.
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, Revision: 1 Page 18 of 20 l l
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': RESULTS REPORT 4 -
ISAP VII.b.2 1 3 (Cont'd) i
..4 1 5.0 IMPLDIENTATION OF ACTION PLAN AND DISCUSSION OF.RESULTS (Cont'd)
The NRC hypothesized root cause that the process for valve i disassembly / reassembly was not controlled was partially substantiated. The lack of adequate control was limited to
~
ITT-Grinnell valves that were disassembled in large numbers at 4
the same time. Although the procedures at that time appeared .
adequate to accomplish the disassembly / reassembly of valves
.I correctly, they did not contain requirements to record and verify valve bonnet identification numbers, and undocumented interchanges occurred as large numbers of assembly / disassembly a] operations were performed with similar valves. The procedures 1 were strengthened in June, 1983.
l l The problem does not extend to the general population because i large numbers of other types of valves were not disassembled.
,i at the same time. The results of our investigation support
- j this.
- .5 5.5 Evaluation of Results Against Action Plan Decision Criteria No construction deficiencies were found. The valves found I with deviations were determined to be able to perform their intended functions under the design conditions. Therefore, the action plan is to be considered closed.
This action plan required expansion of the sample upon finding one or more construction deficiencies. Since none was found,
'l N
the sample was not expanded.
5.6 Identification and Discussion of Corrective Action-l }I
'4
- The programmatic requirements to preclude switching valve j bonnets at the time of reassembly have already been addressed 1
.by TUCCO. The change of personnel and revamp of the ll millwright valve storage area in February, 1983 .should act to
!- minimize loss, damage or inadvertent interchange of valve i
, bonnets. The procedures in place since mid-1983 requiring the verification during reassembly that the body and bonnet identification numbers match those when the valve was
,, disassembled preclude an inadvertent and undetected switching l of the valve bonnets.
't i The specific valves found with deviations have been identified
'l to TUCCO and huve been entered into the TUCCO Non-conformance I --
Report (NCR) system.
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- R:visicn: 1 Page 19 of 20 RESULTS REPORT
\ ~:
,, 1 SAP VII.b.2 (Cont'd)
.1 j
, .)
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- 1, 5.7 Out of Scope observations 1
. During the course of reinspection, thirteen (13) valves were j found to have the required code data tag missing. This tag lists the manufacturer's name and serial number, Code class, pressure / temperature rating. and year built. These valves were identified to TUGC0 and NCRs written covering this observation. TUGC0 had already identified a problem with missing coda data tags and has in place acceptable procedures for handling missing data tags. The absence of these tags has 4
no effect on the performance or safety of the valves. -
No other out-of-scope observations were noted during implementation of this action plan.
I- _,
6.0 CONCLUSION
S.
ll ('
j '. --
Two valid deviations were found in the sample from the general t
population of valves disassembled and reassembled, one of which was ij- also part of the TRT issue population. Two more valid deviations
'j were found in the additional samples selected just from the TRT
{ population. No construction deficiencies and no' code-class j deviations were found in the samples.
I i- A safety significance evaluation has shown that no construction i'
deficiencies can occur on the ITT-Grinnell valves due to interchanged parts occurring during reassembly of disassembled
, valves. l Based on the results of the reinspection program the following conclusions are dravn: -
\
There is a 95 percent confidence that at least 95 percent of the general. population of valves that were disassembled were reassembled in a functionally correct manner and have no pode class deviations (i.e., sero construction deficiencies or code class deviations found in a sample of sixty).
There is a 95 percent confidence that at least 95 percent of i,
the TRT issue valves (i.e., ITT-Grinnell valves in the spent fuel cooling and cleaning system, the boron recycle system.
{ and the chemical and volume control system) that were
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i RESULTS REPORT l t ,
ISAP VII b.2
)
n (Cont'd)
- l i 7.0 ONGOING ACTIVITIES (Cont'd) 1
]. disassembled were reassembled in a functionally correct manner and have no code class deviation (i.e., sero construction deficiencies or code class deviations found in a sample of sixty).
7 The procedures for valve disassembly / reassembly were reviewed and t determined to provide adequate control requirements except in cases j where large numbers of similar valves were simultaneously j disassembled. Furthermore, no instances were found that the i control process broke down except in the case of the ITT-Grinnell
'. valves. The improvements made to the control process since 1983 0
provide reasonable assurance that an adequate control process is in place.
I The four deviations occurred on ITT-Grinnell diaphragm valves in a time frame when relatively large numbers of valves were disassembled at the same time. This fact, along with confidence in the process
~
(
for the control of valve disassembly / reassembly, indicates that uncontrolled switching of valve bonnets does not extend to the general population. .
'i
. 7.0 ONGOING ACTIVITIES
- )-
l[
- j The SRT considers the implementation of VII.b.2 to be complete.
The disposition of the NCRs for the four deviations will correct 3 the "as installed" documentation for the valves.
l The assesraent of TUGCO's handling of programmatic corrective
' action regarding control of valve disassembly / reassembly will be
- addressed in ISAP VII.a.2.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE l As previously discussed the control process currently in effect is adequate to ensure proper valve disassembly / reassembly.
Additionally, discussions with millwright supervision and the supervisor of the valve storage area in the millwright shop revealed an appreciation for the need to maintain proper material traceability. -
!{ -
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d o,, UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION
}. { . ,i WASHINGTON, D. C. 20555
- %*****/ APR 141986 MEMORANDUM FOR: B. Grimes, Director Division of Quality Assurance,
- Vendor and Technical Training Programs, IE E. Johnson, Director Division of Reactor Safety and Projects, Region IV R. Ballard, Chief Engineering Branch Division of PWR Licensing-A, NRR F. Rosa, Chief Electrical, Instrumentation and Control Systems Branch Division of PWR Licensing-A, NRR FROM: Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWR Licensing-A, NRR
SUBJECT:
EVALUATION OF COMANCHE PEAK ISAP ISAP No. I.b.3
Title:
Conduit to Cable Tray Separation The plan for NRC review and evaluation of this ISAP is as outlined below.
Section numbers refer to sections of the NRC evaluation to be produced by those persons identified below:
Lead Project Manager: C. Trammell i
lead Technical Reviewer: J. E. Knight ;
Section Title Person !
1.0 Introduction J. E. Knight )
2.0 CPRT Approach J. E. Knight >
I 3.0 Evaluation 3.1 Evaluation of CPRT Approach J. E. Knight 3.2 Evaluation of ISAP Implementation J. E. Knight 4.0 Conclusion .J. E. Knight Person to provide assistance as requested by lead technical reviewer P. C. Wagner
% YiAl99 LI" $90 &
. 4 I
Person IE contact as required: D. Norkin Region IV contact as required: T. West'ennan NRC Consultant: L. Stanley Schedule: (Date of receipt of report - April 14,1986)
April 24 (10 days following receipt):
Identify any additional information needed to Comanche Peak lead project manager.
May 9 (25 days following receipt):
Evaluation inputs as shown above completed and signed out by E. Rossi (NRR), E. Johnson (Region IV) and B. Grimes (IE) as appropriate.
May 12 (26 days following receipt):
Meeting between technical reviewers, section leaders, PM, and OELD to discuss issuance of evaluation at day 45 (or other schedule) and prepare notice to Licensing Board at day 30.
May 29 (45 days following receipt):
Evaluation to be issued to all parties (normally, unless an exception is identified at the meeting).
. O r R Projec irectorate No. 5 Division f PWR licensing-A cc: H. Denton L. Chandler J. Taylor G. Mizuno D. Eisenhut R. Bachmann R. Vollmer A. Vietti-Cook R. Martin, R-IV C. Early I: En M'*;rev E. Christenbury G. Bagchi J. Scinto D. Jeng L. Shao J. E. Knight T. Westerman, R-IV D. Norkin J. Calvo P. C. Wagner, R-IV
r 4
j i
, / p na g'o,, UNITED STATES
,i '. ! g NUCLEAR REGULATORY COMMISSION -'
- y WASHINGTON, D. C. 20655
- ' h 14 g [o:@[2, N h Y J :.10 ) " O 1
MEMORANDUM FOR: B. Grimes, Director Division of Quality Assurance, p, %'
Vendor and Technical Training gw Programs, IE E. Johnson, Director o' Division of Reactor Safety l
and Projects, Region IV h ~ /W M Chief Engineering Branch Division of PWR Licensing-A, NRR F. Rosa, Chief i~ Electrical, Instrumentation
- l and Control Systems Branch j Division of PWR Licensing-A, NRR FROM: Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWR Licensing-A, NRR
SUBJECT:
EVALUATION OF COMANCHE PEAK ISAP ISAP No. II.b
Title:
Concrete Compression Strength The plan for NRC review and evaluation of this ISAP is as outlined below.
Section numbers refer to sections of the NRC evaluation to be produced by those persons identified below:
I Lead Project Manager: C. Trammell j Lead Technical Reviewer: D. Jeng Section Title Person 1.0 Introduction D. Jeng 2.0 CPRT Approach D. Jeng 3.0 Evaluation 3.1 Evaluation of CPRT Approach D. Jeng 3.2 Evaluation of ISAP Implementation D. Jeng 4.0 Conclusion D. Jeng Person to provide assistance as requested by lead technical reviewer L. Ellershaw
- 9 6 & ll 2 .L 3 0 ;c u.,._----,-_-_.--_ . _ , ,
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- APR 14 mes fi ;
- Person 1
j IE contact as required: D. Norkiri Region IV contact as required: T. Westerman
-l NRC Consultant: R. Philleo Schedule: (Date of receipt of report - April 14,1986)
April 24 (10 days following receipt):
e Identify any additional information needed to Comanche Peak lead project manager. ,
May 9 (25 days following receipt):
Evaluation inputs as shown above completed and signed out by E. Rossi (NRR), E. Johnson (Region IV) and B. Grimes (IE) as appropriate.
May 12 (26 days following receipt):
, Meeting between technical reviewers, section leaders, PM, and OELD to discuss issuance of evaluation at day 45 (or other schedule) and prepare notice to Licensing Board at day 30.
May 29 (45 days following receipt):
Evaluation to be issued to all parties (normally, unless an exception is identified at the meeting).
o n, Director
.Proje t Di ctorate No. 5 Division of PWR Licensing-A cc: H. Denton L. Chandler J. Taylor G. Mizuno D. Eisenhut R. Bachmann R. Vollmer A. Vietti-Cook R. Martin, R-IV C. Early T. Novak C. Tramell E. Rossi I. Barnes, R-IV E. Christenbury G. Bagchi J. Scinto D. Jeng L. Shao J. E. Knight T. Westerman, R-IV D. Norkin J. Calvo
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f [' / 'o g UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20666 n rj
'
- s e
,f /
' h 14 g ' -
i MEMORANDUM FOR: B. Grimes, Director l *
'I Division of Quality Assurance, Vendor and Technical Training
-l - Programs, IE E. Johnson, Director Division of Reactor Safety
- j and Projects, Region IV j
I
' R. Ballard, Chief l
Engineering Branch
- J
- Division of PWR Licensing-A, NRR F. Rosa, Chief Electrical, Instrumentation and Control Systems Branch Division of PWR Licensing-A,<NRR
, FROM: Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWR Licensing-A, NRR ,
i
SUBJECT:
EVALUATION OF COMANCHE PEAK ISAP i
ISAP No. II.b 1
Title:
Concrete Compression Strength The plan for NRC review and evaluation of this ISAP is as outlined below.
Section numbers refer to sections of the NRC evaluation'to be produced by those
' persons identified below: .,
Lead Project Manager: C. Trammell Lead Technical Reviewer: D. Jeng Section Title Person 1.0 Introduction D. Jeng
< 2.0 CPRT Approach D. Jeng 3.0 Evaluation 3.1 Evaluation of CPRT Approach D. Jeng
?
3.2 Evaluation of ISAP Implementation D. Jeng D. Jeng 4.0 _ Conclusion Person to provide assistance as requested by lead technical reviewer L. Ellershaw y':0&bSS.T
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! '. ' ' , APR 14 20s Person IE contact as required: D. NorWin j, Region IV contact as required: T. Westerman NRC Consultant: R. Philleo I Schedule: (Date of receipt of report - April 14,1986) j April 24 (10 days following receipt):
, Identify any additional information needed to Comanche Peak lead project manager.,
May 9 (25 days following receipt):
Evaluation inputs as shown above completed and signed out by E. Rossi (NRR), E. Johnson (Region IV) and B. Grimes (IE) as appropriate.
May 12 (26 days following receipt):
Meeting between technical reviewers, section leaders, PM, and OELD to discuss issuance of evaluation at day 45 (or other schedule) and prepare j notice to Licensing Board at day 30.
! May 29 (45 days following receipt):
Evaluation to be issued to all parties (normally, unless an exception is l identified at the. meeting).
A o n, Director III Proje t Dir ctorate No. 5 1 Division of PWR Licensing-A l cc: H. Denton L. Chandler J. Taylor
. G. Mizu'no D. Eisenhut R. Bachmann R. Vollmer A. Vietti-Cook R. Martin, R-IV C. Early T. Novak C. Trammell E. Rossi I. Barnes, R-IV
': i M *"'"
L. Shao T. Westerman, R-IV W J. E. Knight D. Norkin J. Calvo i
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/ %, UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION
- a WASHINGTON. D. C. 20655
, o
- s.,
/
APR 14 ggg MEMORANDUM FOR: B. Grimes, Director '
Division of Quality Assurance, Vendor and Technical Training Programs, IE E. Johnson, Director Division of Reactor Safety and Projects, Region IV [ '
R. Ballard, Chief Engineering Branch
. Division of PWR Licensing-A, NRR ,
F. Rosa, Chief Electrical, Instrumentation and Control Systems Bra'.ch.
Division of PWR Licensing-A, NRR FROM: Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWR Licensing-A, NRR
SUBJECT:
EVALUATION OF COMANCHE PEAK ISAP ISAP No. VII.b.2
Title:
Valve Disassembly The plan for NRC review and evaluation of this ISAP is as outlined below.
Section numbers refer to sections of the NRC evaluation to be produced by those persons identified below:
Lead Project Manager: C. Transnell lead Technical Reviewer: G. Bagchi l
Section Title Person 1 1.0 Introduction G. Bagchi 2.0 CPRT Approach G. Bagchi 3.0 Evaluation 3.1 Evaluation of CPRT Approach G. Bagchi )
3.2 Evaluation of ISAP Implementation L. Ellershaw ]
4.0 Conclusion G. Bagchi Person to provide assistance G. Bagchi to assist w/
implementation
% tj Q 3t @
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~
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Person IE contact as required: D. Norkin Region IV contact as required: T. West'erman Schedule: (Date of receipt of report - April 14,1986)
April 24 (10 days following receipt):
Identify any additional information needed to Comanche Peak lead project manager.
May 9 (25 days following receipt):
Evaluation inputs as shown above completed and signed out by E. Rossi (NRR), E. Johnson (Region IV) and B. Grimes (IE) as appropriate.-
May 12 (26 days following receipt):
Meeting between technical reviewers, section leaders, PM, and OELD to discuss issuance of evaluation at day 45 (or other schedule) and prepare notice to Licensing Board at day 30.
May 29 (45 days following receipt):
Evaluation to be issued to all parties (normally, unless an exception is identified at the meeting).
/
.N ( an, Director R Project pirectorate No. 5 Division of PWR Licensing-A cc: H. Denton L. Chandler J. Taylor G. Mizuno D. Eisenhut R. Bachmann R. Vollmer . A. Vietti-Cook R. Martin, R-IV C. Early T. Novak C. Trammell E. Rossi I. Barnes, R-IV E. Christenbury G. Bagchi J. Scinto D. Jeng L. Shao J. E. Knight T. Westerman, R-IV D. Norkin J. Calvo L. Ellershaw, R-IV
e-
. ,? s
>2 E84 g* UNITED STATES
[
g kE NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
~s***** / APR If g MEMORANDUM FOR: B. Grimes, Director
- Division of Quality Assurance.
Vendor and Technical Training Programs, IE E. Johnson, Director Division of Reactor Safety and Projects, Region IV R. Ballard, Chief Engineering Branch
- Division of PWR Licensing-A, NRR F. Rosa, Chief Electrical, Instrumentation and Control Systems Branch Division of PWR Licensing-A, NRR FROM: Vincent S. Noonan, Director PWR Project Directorate No._5 Division of PWR Licensing-A, NRR
SUBJECT:
EVALUATION OF COMANCHE PEAX ISAP ISAP No. III.d
Title:
Pre-Operational Testing The plan for NRC review and evaluation of this ISAP is as outlined below.
Section numbers refer to sections of the NRC evaluation to be produced by those persons identified below:
Lead Project Manager: C. Tramel Lead Technical Reviewer: W. Smith Person Section Title 1.0 Introduction W. Smith 2.0 CPRT Approach W. Smith 3.0 Evaluation 3.1 Evaluation of CPRT Approach W. Smith 3.2 Evaluation of ISAP Implementation W. Smith !
4.0 Conclusion W. Smith i l
l
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-[ ( \
Person IE contact as required: D. Norkin Region IV contact as required: T. West'ennan NRC Consultant: J. Malonson (Teledyne)
Schedule: (Date of receipt of report - April 14,1986)
April 24 (10 days following receipt):
Identify any additional information needed to Comanche Peak lead project manager..
May 9 (25 days following receipt):
Evaluation inputs as shown above completed and signed out by E. Rossi (NRR), E. Johnson (Region IV) and B. Grimes (IE) as appropriate.
May 12 (26 days following receipt):
Meeting between technical reviewers, section leaders, PM, and OELD to discuss issuance of evaluation at day 45 (or other schedule) and prepare notice to Licensing Board at day 30.
May 29 (45 days following receipt):
Evaluation to be issued to all parties (normally, unless an exception is identified at the meeting).
s
. , r ctor R Projec Dire orate No. 5 Division of PWR Licensing-A cc: H. Denton L. Chandler J. Taylor G. Mizuno D. Eisenhut R. Bachmann R. Vollmer A. Vietti-Cook
. oa E. Rossi I. Barnes, R-IV E. Christenbury G. Bagchi J. Scinto D. Jeng L. Shao J. E. Knight T. Westerman, R-IV D. Norkin J. Calvo 1
l
' # %7, UNITED STATES
~f NUCLEAR REGULATORY COMMISSION
, ( h CASHINGTON, D. C. 20555
/ APR 14 BBS MEMORANDUM FOR: B. Grimes, Director Division of Quality Assurance, .
Vendor and Technical Training Programs, IE E. Johnson, Director Division of Reactor Safety and Projects, Region IV R. Ballard, Chief Engineering Branch Division of PWR Licensing-A, NRR F. Rosa, Chief Electrical, Instrumentation and Control Systems Branch Division of PWR Licensing-A, NRR FROM: Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWR Licensing-A, NRR
SUBJECT:
EVALUATION OF COMANCHE PEAK ISAP ISAP No. I.a.4
Title:
Agreement Between Drawings and Field Terminations The plan for NRC review and evaluation of this ISAP is as outlined below.
Section numbers refer to sections of the NRC evaluation to be produced by those persons identified below:
Lead Project Manager: C. Trammell Lead Technical Reviewer: J. E. Knight Section Title Person 1.0 Introduction J. E. Knight 2.0 CPRT Approach J. E. Knight 3.0 Evaluation 3.1 Evaluation of CPRT Approach J. E. Knight 3.2 Evaluation of ISAP Implementation P. Wagner 4.0 Conclusion J. E. Knight g; men -
p-Ib
d .
-f Person IE contact as required: D. Norkin Region IV contact as required: T. Westeman NRC Consultant: L. Stanley Schedule: (Date of receipt of report - April 14,1986)
April 24 (10 days following receipt):
Identify any additional information needed to Comanche Peak lead project manager.
May 9 (25 days following receipt):
Evaluation inputs as shown above completed and signed out by E. Rossi (NRR), E. Johnson (Region IV) and B. Grimes (IE) as appropriate.
May 12 (26 days following receipt):
Meeting between technical reviewers, section leaders, PM, and OELD to discuss issuance of evaluation at day 45 (or other schedule) and prepare notice to Licensing Board at day 30.
May 29 (45 days following receipt):
Evaluation to be issued to all parties (nomally, unless an exception is identified at the meeting). g f
/
. k na Director R Projec Directorate No. 5 Division o PWR Licensing-A cc: H. Denton L. Chandler J. Taylor G. Mizuno D. Eisenhut R. Bachmann R. Vollmer A. Vietti-Cook R. Martin, R-IV C. Early 4 T. Novak C+A M -~ l E. Rossi I. Barnes, R-IV E. Christenbury G. Bagchi J. Scinto D. Jeng L. Shao J. E. Knight T. Westerman, R-IV D. Norkin J. Calvo- P. Wagner 1
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+*p c LEeu Jg UNITED STATES g NUCLEAR REGULATORY COMMISSION
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-l WASHINGTON, D. C. 20555 t
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APR 2 g 586 -
Docket Nos. 50-445 and 50-446 Mr. W. G. Counsil Executive Vice President Texas Utilities Generating Company 400 North Olive Street, L. B. 81 Dallas, Texas 75201
REFERENCE:
letter to V.'S. Noonan (NRC), from W. G. Counsil (TUGCO),
Subject:
Comanche Peak Steam Electric Station CPRT Results Reports, dated April 4,1986.
Dear Mr. Counsil:
By the above referenced letter you provided the staff with five Comanche Peak Response Team results reports (I.a.4, I.b.3, II.b III.d. VII,b.2). The staff has completed its initial review of these reports. Enclosed is the staff request for additional infonnation. In order for the staff to comply with established schedules for an evaluation, we must receive your response no later than COB May 2, 1986. Should you have any questions or need further clarification, contact Annette Vietti-Cook, Pro.iect Manager on telephone number (301) 492-8525.
Sincer ,
q'4.)Alstor Vincent S. Noonan Director PWR Projet.t Directorate #5 Division of PWR licensing-A
Enclosure:
I m Recuest for Additional Information !
cc: See next page !
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. W. G. Counsil Comancha Peak Steam Electric Station Texas Utilities Generating Company Units 1 and 2 cc:
Nicholas S. Reynolds, Esq. Resident Inspector / Comanche Peak '
Bishop, liberman, Cook, Nuclear Power Station Purcell & Reynolds c/o U.S. Nuclear Regulatory Commission 1200 Seventeenth Street, NW P. O. Box 38 Washington, D.C. 20036 Glen Rose, Texas 76043 Robert A. Wooldridge, Esq. Regional Administrator, Region IV i Worsham, Forsythe, Sampels & U.S. Nuclear Regulatory Commission Wooldridge 611 Ryan Plaza Drive. Suite 1000 2001 Bryan Tower. Suite 2500 Arlington, Texas 76011 Dallas, Texas 75201 -
lanny A. Sinkin
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Mr. Homer C. Schmidt Manager - Nuclear Services Christic Institute Texas Utiljties Generating Company 1324 North Capitol Street Skyway Tower Washington, D.C. 20002 400 North Olive Street, L.B. 81
- Dallas, Texas 75201 Ms. Billie Pirner Garde Citizens Clinic Director Mr. Robert E. Ballard, Jr. Government Accountability Project Director of Projects 1901 Que Street, NW Gibbs and Hill, Inc. Washington, D.C. 20009 11 Pen Plaza New York, New York 10001 David R. Pigott, Esq.
Orrick, Herrington & Sutcliffe 600 Montgomery Street Mr. R. S. Howard San Francisco, California 94111 Westinghouse Electric Corporation P. O. Box 355 Anthony 7. Roisman, Esq.
Pittsburgh, Pennsylvania 15230 Trial lawyers for Public Justice 2000 P. Street, NW Renea Hicks, Esq. Suite 611
- Assistant Attorney General Washington, D.C. 20036 Environmental Protection Division P. O. Box 12548, Capitol Station Nancy E. Wiegers Austin, Texas 78711 Spiegel & McDiarred I
- 1350 New York Avenue, NW Mrs. Juanita Ellis, President Washington, D.C. 20005-4798 Citizens Association for Sound Energy L 1426 South Polk Roy P. Lessy, Jr.
Dallas, Texas 75224 Morgan, Lewis & Bockius 1800 M. Street, NW Ms. Nancy H. Williams Suite 700, North Tower i CYGNA Washington, D.C. 20036 i 101 California Street i San Francisco, California 94111 i
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Texas Utilities Electric Company Comanche Peak Electric Station
. Units 1 and 2 l CC*
Resident Inspector - Comanche Peak -
c/o U.S. Nuclear Regulatory Commission P. O. Box 1029 Granbury, Texas 76048 Mr. John W. Beck Vice President Texas Utilities Electric Company Skyway Tower 400 N. Olive Street, LBf81 Dallas, Texas 75201 -
Mr. Jack Redding licensing
. Texas Utilities Generating Company 4001 Fairmont Avenue -
Bethesda, Maryland 20814 William A. Burchette. Esq.
Counsel for Tex-la Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washington, D.C. 20007 GDS Associates, Inc.
2525 Cumberland Parkway Suite 450 Atlanta, Georgia 30339 e.
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Request for Additional Information For the five ISAP results reports (I.a.4, I b.3 II.b, III.d. and VII.b.2) and future results reports.
- 1. Address those questions raised in ASLB Memorandum, Proposed Memorandum And Order dated April 14, 1986, and provide appropriate documentation.
- 2. Address whether the issues raised in the results reports had implications of deficiencies in the QA/QC program, design and/or construction and reference documents that will be provided to the staff that will address these implications.
- 3. Where an ISAP resulted in corrective action, address the status of the 1 corrective action and identify the method you plan for communicating to the staff the corrective action is completed.
- 4. Describe how findings from one ISAP, which relate to a particular ISAP
. that is being address'ed are considered.
I.a.4 Agreement Between Drawings and Field Terminations
- 1. For the instances identified by the NRC TRT and Region IV, and CPRT where the drawings have not yet been revised to reflect the existing field termination conditions, provide the actions you are .taking to upgrade your as-built field termination drawings.
- 2. What is the basis for considering terminated and non-terminated spare conductors as valid population sample items for essential Class IE Systems.
I.b.3 Conduit to Cable Tray Separation Provide the folicwing information:
(1) Gibbs and Hill analysis report on conduit separation; (2) Documentation to indicate that TUGC0 has approved the Gibbs and Hill analysis report; (3) DCA-15917 mentioned on page 2 of the results report which reduced the conduit separation to one inch (this may be incl.uded in the G&H analysis reportl, and (4) Gibbs and Hill memo EE-863, 1/17/84, which contained simplified analysis reviewed by.NRC-TRT on site (this may oe included in the G&H analysis report);
II.b Concrete Compression Strength
- 1. Paragraph 2 on page 13 of ISAP II.b results report refers to errors in the Schmidt Hammer test program identified by third party review, and refers to them as "not significant." Provide the basis for your concluding that the errors are not significant i
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- 2. Review of Figure 1 of page 20 of ISAP II.b results report shows that CA!
compression strength is approximately 9.4% less than CC comprenion strength at the 10th percentile level. It appears that this level of -
deviation was judged by applicants as not "significantly lower "than CC compression strength to trigger a need to implement calibration of the l' Schmidt Hammer test. Discuss the technical basis for the-judgement.
- 3. The resolution to ISAP II.b as presented in the results report may not be i able to identify localized problems where the number of falsified records i
~; is small. Discuss potential safety implications on overall adequacy of the concrete strength due to such localized problems. ;
~
III.d Preoperational Testing
- 1. Section 5.4.1 of the results report stated, in part, that System Test Engineers (STEs) "...did use current design documents in the conduct of
. preoperational and prequisite testing activities." During an inspection of documentation related to the 60 preoperational test samples that were -
evaluated by the CPRT, the NRC inspector identified 26 preoperational tests that were performed where the STEs failed to update the revisions of design documents referenced in Section 3.0 of the test procedures.
The documentation clearly showed the CPRT's awareness of this discrepancy, but it was not identified in accordance with Appendix E of the Program Plan. The NRC inspector informed the CPRT that failure to identify the discrepancy was deviation from Program Plan comitments.
The results report should have addressed this discrepancy. The staff needs to know what actions were taken to determine whether this was a DCC 1 problem or an STE problem, what impact this had on the objectives of the ,
ISAP, and what assurance exists that other tests of safety related :
components and systems, not evaluated under this ISAP, were conducted using current design documents.
- 2. During the inspection of documentation related to the 60 preoperational
- test samples that were evaluated by the CPRT, the'NRC inspector identified an unresolved issue regarding twelve screening checklists that were not completely filled in. Three of the twelve checklists failed to show the CPRT's review to ensure the associated preoperational tests were conducted using current design documents. This issue must be resolved before the staff will be able to accept the results report.
VII.b.2 Valve Disassembly
- 1. Section 4.1.2 of the results report states, "in addition to proper matching of components, the procedures were reviewed for damage during
.the disassembly, storage and reassembly process."
Please provide the results of this review.
- 2. Section 5.2 (page 12 of 20, last paragraph) addresses differences in non-ASME and ASME manufacturing processes for the bonnets. The results i
4
report states that physical and chemical properties identified in the material. specification would be the same for both and also that. post ,
manufacturing testing would be the same.
! Please address how you considered the differences between ASME Code and commercial requirements such as material identification and traceability, welding and weld repairs, personnel qualifications, and nondestructive examinations.
- 3. It.should be noted that NRC Inspection Report 50-445/85-14; 50-446/85-11 identified an unresolved item (Appendix E, paragraph 6.j) pertaining to the differences identified between the Westinghouse and Gibbs & Fill (G&F1 (fnes Designation Tables, and differences between G&P Tables and Code Data Sheets.
I Please provide the necessary information for resolution of this unresolved item (445/85-14-U-15).
- 4. On page 1 in second paragraph under Section 3.0 reference is made to a valve testing program (a) Identify the program and/or programs and clearly indicate the scope i.e. how many and what typ of valves are included, what types of valves are excluded, etc. (b) the loss or damage of valve parts is a QA programmatic concern when it's repetitive and
< uncontrolled, even if its documented. Explain how this issue is 4
addressed in your implementation process.
i Section 4.1.2 the third paragraph addresses an evaluation of the adequacy of present procedures. Was there a sampling inspection of valves (and documentation) installed under the present procedures? What are present
! procedures as opposed to past procedures?
- 5. Section 4.1.3 second paragraph states in part an evaluation was made to define potential code violations. ;
- What are they? They should be identified.
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- 6. Section 4.1.4 first sentence states that reinspection of valves which were disassembled was performed to provide assurance that the valves were i reassembled using the correct components. l l
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It is not clear how, or from what documentation,-the correct components I were identified.
- 7. Section 4.2 procedures are not identified per program plan attachment 3 ISAP .fonnat.
- 8. Section 4.6 appears to apply to only diaphragm valves - what was the basis acceptance of other types of valves with interchangeable top works and trim.
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- 9. Section 5.1 second paragraph l The review installation procedures,-revisions and dates should % -
identified.
- 10. Section 5.0 page 11 first paragraph states that a lost bonnet and a i damaged bonnet were not deviations because they were properly identified on NCRs and PETS.
The valve type, size, gag numbers, date of installation, the NCR and PET numbers should also state if the NPV-1 form was revised, or annotated.
- 11. Section.5.0 page 11 fourth paragraph states that two types of ITT Grinnell valves were supplied. This paragraph should also provide complete identification of the valve types (manufacturer's drawing or identification numbers), valve sizes, rating and applicable code class.
, 12. Section 5.0 fifth paragraph states in part: For some applications...the i applications should be identified.
- 13. Section 5.0 page 12 first paragraph is not clear in its description of valve modifications.
l 1 - were the modifications made specifically for CPSES valves at the i specified 300 PSIG, or
! 2 - are these valves just different configurations furnished by the
- supplier when the user specifies service conditions, pressure / temperature, that are higher than design.
i 14. Section 5.0 page 13 second paragraph, identifies two valves by tag numbers.
This paragraph should further identify the manufacturer's drawing or identification number, size, rating, code class and date of i installation. Additionally this paragraph should identify the documents i
(e.g. NCR, IR, PET) that substantiated acceptance of the installed valve body and bonnet.
- 15. Section 5.0 page 13 the second and third paragraphs, identify two valves by tag number. These paragraphs should also identify the manufacturer's drawing or identification number, size, rating and code class and date of installation.
- 16. Section 5.0 page 14 first paragraph states that because the installed valves (with deviations) match the numbers recorded on the operations travellers, this means that the bonnets were interchanged prior to issue for installation.
The staff finds that this deduction may not be valid if the valve was i disassembled, installed and reassembled on the same day. If the '
traveller records these operations as performed on the same date (same i shift), there is no assurance that the required information was recorded i prior to disassembly. Another pctential is the switching of valve tags.
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- 17. Section 5.0 page 14 second paragraph relates to travellers for the other two valves that were written prior to the practice of recording -
bonnet markings...
This paragraph should identify the two valves in question, the date installed, the procedure and applicable revision at the time of 4 installation.
- 18. Section 5.0 page 15 second paragraph refers to early procedures.
The specific procedures, revisions and dates should be identified.
- 19. Section.5.0 page 15 third paragraph last sentence states: sufficient information for evaluating valve storage prior to this time is not available.
. The istue of concern was the storage of disassembled valve components.
The TRT found that the storage at installation locations was poorly -
controlled. The paragraph should address the storage of disassembled valve components.
- Additionally, this paragraph refers to an effective program implemented
! by M111 wrights.
This " Effective Program" should be addressed in the aspect of the implementation of an identified procedure and the verification of l training of millwright personnel in the applicable procedure.
l 20. Section 5.0 page 15 the fourth paragraph states that the issue related to i
documentation of the interchange of valve bonnets was recognized by TUGCO...
- This paragraph should state the basis (NCRs, irs, etc.) for TUGCO's recognition and address this subject by including the identification of
- the procedures, rev hions and dates.
- 21. Section 5.0 page 16 the second paragraph states that the QC checklist requires reccrding of the bonnet identification number.
For the installation of valves, since valve tags.can also be interchanged, the staff finds that the procedure should require that the checklist should record both the body and bonnet identification.
I
- 22. Section 5.0 page 16 third paragraph states the administrative action was
, taken (by TUGCO) in the startup test program.
i i The administrative action should be identified in terms of identification of any applicable procedures, revisions and the CPRT verification of the training of personnel, i
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- 23. Section 5.0 page 16 the fourth paragraph cites an example identified by the TRT as evidence of procedure implementation and effectiveness. -
, The TRT also identified (in SSER-11) numerous PETS that documented the interchange as replacements for lost and/or damaged valve components.
The staff wishes to emphasize that the issue essentially was procedural inadequacy to control the interchange, loss and damage of disassembled valve componets. The staff disagrees with the CPRTs reasoning that this is an example of procedure effectiveness. The TRT stated that although the deficiency was reported on the NCR, and procedures were in place, the loss and damage continued to occur.
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- 24. Section 5.6 page 18 identification and discussion of Corrective Action
.first paragraph is vague.
The paragraph should identify the level of responsibility of the. changed personnel and identify the procedures, revisions and dates as they apply to the subject of this paragraph.
- 25. Section 5.7 page 19 Out of Scope Observations.
The paragraph refers in part to: acceptable TUGC0 Procedures...
The procedures shouid be identified.
- 26. Section 6.0 page 20 the second paragraph states that procedures were reviewed and found to be adequate except for..and further, the last
- sentence states that improvements to the control process since 1983...
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! The procedures, revisions and dates should be identified, and the j improvements to the control process should be specifically detailed in l this paragraph. l l . 27. Section 7.0 page 20 1
]
- Does not clearly identify any of the results of the implementation of
, this plan (e.g. procedure inadequacy, lack of control, etc.) that must
- be addressed by TUGCO, and then evaluated under ISAP VII.a.2.
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CPRT-0347 LOG NO. TXX-4752 1 -
FILE NO. 10068 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER e MOEFM OUVE WFREEY, I E. 81
. April 4, 1986
.UTE8c.*828.".Ir Mr. Vincent S. Noonan Director of Nuclear Reactor Regulation i Comanche Peak Project j Division of Licensing j U. S. Nuclear Regulatory Commission J Washington, D. C. 20555
't i
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION l 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 l office. Anyone wishing to inspect these files should contact Ms. Susan Palmer (214/979-8242).
+
i I.a.4 Agreement Between Drawings and Field Terminations I.b.3 Conduit to Cable Tray Separation II.b Concrete Compression Strength l III.d Preoperational Testing l VII.b.2 Valve Disassembly We shall issue future Results Reports on a periodic basis as they are approved by the CPRT Senior Review Team.
Very truly yours, d
W. G. Counsil l WGC:tj Enclosure l 3 , ,) i , , _, , , A osvssson or Texas urturzzs es.scrnsc cour.sur i
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l TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 400 NOSTN OLIVE WTESKF. L.B. 81
- D a r I A m. TEXAS 75991 i
April 3, 1986 JOH.N v W SE.C.,K
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1 MEMORANDUM i
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- TO
- Mr. W. G. Counsil 1
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.
t I.a.4 Agreement Between Drawings-and Field Terminations I,b.3 Conduit to Cable Tray Separation II.b Concrete Compression Strength III.d Preoperational Testing VII,b.2 Valve Disassembly 0ww m k/ %. A1, - j- -
hn W. Beck Chairman, CPRT Senior Review Team JWB:tj Enclosures
, cc: CPRT File A DEVISION OF TEXAS ETTELETIES EE.ECTRIC COMPANY ,
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l COMANCHE PEAK RESPONSE TEAM l RESULTS REPORT ISAP: II.b
Title:
Concrete Compression Strength t-
! REVISION 1 1
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- 0) ' A R(view' Team Lea'Epf V alula, Date'
- 4.). L 2. P fG Johy W. Beck, Chairman CPRT-SRT Date t
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Ravision: 1 Page 1 of 31 RESUI.TS REPORT ISAP II.b Concrete Compression Strength
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1.0 DESCRIPTION
OF ISSUE' The TRT investigated allegations that concrete strength tests were falsified. The TRT reviewed an NRC Region IV investigation (IE Report No.- 50-445/79-09; 50-446/79-09) of this matter that included i interviews with fifteen individuals. Of these, only the alleger I and one other individual stated they thought that falsification j occurred, but they did not know when or by whos. The TRT also reviewed slump and air entrainment test results of concrete placed during the period the alleger was employed (January 1976 to February 1977) and did not find any apparent variation in the i uniformity of the parameters for concrete placed during this
- period. Although the uniformity of the concrete placed appears to
. minimize the likelihood that low concrete strengths were obtained, other allegations were raised concerning the falsification of t records associated with slump and air content tests. The Region IV
- staff addressed these allegations by assuming that concrete
! strength test results were adequate. Furthermore, a number of
,o other allegations dealing with concrete placement problems (such as j (j deficient aggregate grading and concrete in the mixer too long) 1 were also resolved by assuming that concrete strength test results were adequate.
', The TRT found that the preponderance of evidence suggests that
! falsification of results did not occur. However, since a number of I other allegations were resolved on the basis of concrete strength results, the TRT believes that action by TUEC is required to i provide confirmatory evidence that the repor^ted concrete strength test results are indeed representative of the strength of the concrete placed in the Category I concrete structures.
1 2.0 ACTION IDENTIFIED Accordingly, the NRC outlined the following action: TUEC shall
, determine areas where safety-related concrete was placed between January 1976 and February 1977, and provide a program to assure acceptable concrete strength. The program shall include tests, j[ such as Schmidt Hammer tests, on a random sample of the concrete in l' areas where safety is critical. The program shall include a comparison of the results with the results of tests performed on i
concrete of the same design strength in areas where the. strength of l2 the concrete is not questioned, to determine if any significant variance in strength occurs. TUEC shall submit the program for performing these tests to the NRC for review and approval prior to
) performing the tests.
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- . R vision: 1 Page 2 of 31 g RESULTS REPORT i-)
ISAP II.h l
1 (Cont'd) -
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3.0 BACKGROUND
a .
i Falsification of concrete strength tests is alleged to'have i occurred between January 1976 and February 1977. Air content and-j slump data were reviewed by the TRT and no apparent variations were
- j found in the the uniformity of the parameters for concrete placed
.; during the allegation time frame. However, concrete compressive j strength tests have been used by the NRC to resolve previous
, allegations of falsifications of slump and air entrainment tests
- and allegations dealing with concrete placement problems (such as
! deficient aggregate grading and concrete in the mixer too long).
Due to the importance of concrete compressive strength tests in assessing the allegations the TRT requested that additional testing be performed by TUEC to confirm that concrete strength tests
. performed on the concrete in question are representative of the actual concrete strength. Therefore, TUEC implemented a program to test the concrete-at-issue for verification of acceptable strength.
4.0 CPRT ACTION PLAN i rm
! k_- 4.1 Scope and Methodology This action plan was designed to verify the quality of the concrete-at-issue. It was proposed that the relative
, strengths of concrete poured during the period in question j (concrete-et-issue, or CAI) and concrete poured during the six months immediately following this period (control concrete, or CC) be compared using the Schmidt Hammer test as i a relative measure of strength. This time period for the CC
,; was selected to minimize any effect of aging on the comparison of the two sets of hammer data and to provide approximately l equal volumes of concrete for the CAI and CC. The Schmidt I
(Rebound) Hammer test, a non-destructive test, was conducted in accordance with ASTM-C805-79 " Standard Test Method For .
Rebound Number of Hardened Concrete" (Reference 7.1). The l Schmidt Hammer is essentially a concrete hardness tester which i, measures the rebound of a spring loaded plunger after it has struck a smooth concrete surface.
t
'i Using this indirect test o. strength, those portions of the two populations of concrete that were accessible for surface testing have been compared empirically and statistically. In addition to recording the raw rebound number data and average indication for each test, statistical summaries, such as means
-~, and variances, have been computed for. both CAI and CC j
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RESULTS REPORT
. M '
i I C ISAP II.b (Cont'd)
- 4.0 CPRT ACTION PLAN (Cont'd) populations. Both normal and unspecified (non-parametric) y distributions have been considered for the populations. For i, the normal distribution assumption, goodness-of-fit tests of the sample data were performed.
Concrete cylinder data for the two populations have also been
- , obtained, reviewed, and used for reference (see Section 4.4).
1, .
[j The two populations of average hammer indications have been i compared at the tenth percentile level. The tenth percentile-
- e is selected as~a point of comparison based on the American Concrete Institute (ACI) Standard 214-65, " Recommended Practice for Evaluation of Compression Test Results of Field 1 Concrete" (Reference 7.2), which gives the general guideline I
that no more than one out of ten cylinder compression tests shall fall below the design strength. The population of
- 3 average hammer indications for the control concrete was used 1 ; to establish a tenth percentile target and the tenth
! ! .8 percentile average hammer indications for the concrete-at-
' l Q)
) issue was then compared with this carget value. Other CC target values (i.e., fractions of the CC tenth percentile)
- i were also used for comparison. Hypotheses that the tenth ji percentile for the CAI is greater than or equal to various i'
target values were tested at a minimum significance level of five percent. In addition, the significance level at which an l, hypothesis is just accepted was determined. A higher
.. significance le_ vel passed indicates a greater confidence that i
!! the hypothesis is true.
]i 4.1.1 Test Program I
- j 4.1.1.1 TUCCO Nuclear Engineering Civil Structural l (TUGCO) determined the areas where concrete l }!
vas placed in Category I structures between
!i January 1976 and February 1977 (Reference
!! 7.3).
.I
- j 4.1.1.2 From these areas, TUGC0 determined the number a of truckloads of concrete for which part of
!! the concrete of that truckload is exposed and j! testable'(Reference 7.3).
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4.1.1.3 Each truckload identified as exposed and
.. , testable was assigned a unique number
,/ , (Reference 7.3).
1
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I R visien: 1 Page 4 of 31 RESULTS REPORT (75g U ISAP II.b
] (Cont'd) 1 4.0 CPRT ACTION PLAN (Cont'd) i
' 4.1.1.4 Grid volumes corresponding to these
] truckloads were selected at random to be 1 tested (Reference 7.3).
4 i 4.1.1.5 The concrete surface for each selected volume was prepared by Brown & Root Craft personnel for testing per ASTM C805-79. Southwest j Research Institute (SWRI) personnel were i responsible for inspecting and accepting the prepared surfaces before testing.
4.1.1.6 The prepared areas vers tested by SWRI personnel (Reference 7.4) in accordance with ASTM C805-79.
4.1.1.7 TUGC0 determined the areas where concrete wa3
! placed in Category I structures between Marc ~n 1977 and August 1977 (Reference 7.3).
1 (
4 4.1.1.8 From these areas, TUCCO determined the number
- of truckloads of concrete for which part of the concrete of that truckload is exposed and testable (Reference 7.3).
i
! 4.1.1.9 Each truckload identified as exposed and testable was assigned a unique number (Reference 7.3).
4.1.1.10 Grid volumes corresponding to these truckloads were selected at random for testing (Reference 7.3).
4.1.1.11 The concrete surface for each selected grid volume was prepared by Craft personnel for testing per ASTM C805-79 and inspected by SWRI prior to testing.
4.1.1.12 The prepared areas were tested by SWRI (Reference 7.4) in accordance with ASTM C805-79.
4.1.1.13 Third-party overview consisted of review and check of activities in 4.1.1.1 through
~-
4.1.1.5 and 4.1.1.7 through 4.1.1.11 4
_) (Reference 7.5).
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Page 5 of 31 I
I RESULTS REPORT
. ISAP II.b
]ti ,
(Cont'd)
- t j 4.0' CPRT ACTION PLAN (Cont'd)
] 4.1.2 Sampling Plan
,) At Comanche Peak, concrete placement quality procedures i were based on the required air content and slump tests
.being performed on each truckload. Test cylinders from
~
i .the first truckload and every tenth truckload t thereafter were required to verify quality. These
- procedures were based on ACI-ASME 359 and ACI 318 l (References 7.6 and 7.7, respectively), which reference i appropriate ASTM standards. Since the original quality control program was based on the unit of a truckload, the truckload was employed as the unit to be tested in the present quality evaluation. This is consistent with the inherent assumption in the ACI code that a truckload represents the smallest unit of concrete with uniform material properties.
Since Schmidt Hammer tests can only be performed on O exposed surface area, the determination of the number of truckloads which were placed as exposed testable cencrete was determined as follows:
t
- For slabs on grade, the number of truckloads
. was calculated as:
.. (l' depth X Surface Area)/10 yd3 per truck i A depth of one foot was used, because, during placement, vibrators caused the concrete to flow and level out. Thus, only truckloads placed in the last foot of the slab would be exposed.
For columns and walls the number of truckloads was calculated as:
Total Volume /10 yd8 per t' ruck
- For suspended slabs up to 28 inches thick, the number of truckloads was calculated as:
Total Volume /10 yds per truck Each truckload was considered to be I accessible on either surface for slabs less l than 18 inches thick. For slabs between 18 r
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' ISAP II,b (Cont'd) 1
~l
{; 4.0 CPRT ACTION PLAN (Cont'd)
- and 28 inches the total number of truckloads W were distributed equally between the top and
, bottom halves of the slab.
2
'{
- For suspended slabs between 28 and 46 inches
- thick, the volume of concrete was split into j three equal quantities, with one third at the I top, one third on the bottom and one third in j the middle of the slab. The top and bottom i layers were considered as exposed and testable. The middles layer was included if it could be tested from the side.
Slabs not falling into the above categories were handled on a case by case basis. For example, a portion of a thick slab on grade below the one foot i depth was accessible from a tunnel and hence was included.
A (s; '
Of the 326 Category I concrete pours placed between
- January 1976 and February 1977, 103 were for seal slabs, shoterete, grout, or concrete. backfill, and are inaccessible for surface testing. Of the remaining 223 pours, 197 vere found to be at least partially 1 accessible for Schmidt Hammer testing (Reference 7.3),
i which' corresponds to a testable CAI population of approximately 1300 truckloads. 'A total of 119 randomly selected truckload units was tested from this
, population. Table 1 gives a breakdown of the Category I concrete pours placed in the allegation time
. frame, i
Comparable numbers of truckloads define the population
, of testable control concrete and the sample of the truckload units that were tested (see Table 2).
4.1.3 Concrete cylinder Data l
4 The 28-day cylinder strength data (Reference 7.8) were l obtained from the TUGC0 Records Center for the time I period in question and the control concrete time frame.
The data, which represents all Category I concrete )
pours except seal slabs, etc., were statistically evaluated and used as reference information in the hammer data evaluation. The completeness of the data list was checked by the third-party (Reference 7.5).
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, RESULTS REPORT i .
ISAP II.b 2
(Cont'd) 1
] 4.0 CPRT ACTION PLAN (Cont'd) 1 4 4.2 Participants Roles and Responsibilities The organizations and personnel that have participated in this effort are described below with their respective scopes of .
work.
l 4.2.1 TUGC0 Nuclear Engineering Civil Structural
-l 4
j 4.2.1.1 Scope
- Concrete population determination
- Sample selection Location of test areas and preparation of operational traveler Acquisition of 28-day cylinder data z
- Assistance in evaluation of test
- data and preparation of Results
' Report
! 4.2.1.2 Personnel
! Mr. R. Hooton Project Discipline Supervisor Mr. R. Williams Supervising Engineer
- Mr. C. Corbin Civil Engineer
, 4.2.2 Brown & Root !
1 1
4.2.2.1 Scope Prepare concrete test surfaces 4.2.2.2 Personnel .j 1
Craft personnel as required 4.2.3 Third-Party Activities 1
) 4.2.3.1 Scope
- Review of sample selection
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e Revisicn: 1 Page 8 of 31 l l
l RESULTS REPORT'
+ ISAP II.b (Cont'd)'
c 4.0 CPRT ACTION PLAN (Cont'd) lI Perform hammer tests (SWRI) 3 Document tests (SWRI)
~l Review test data d
Review and statistical evaluation of
? test results ,
ll
- Preparation of Results Report
}l 4.2.3.2 Personnel-Mr. H. A. Levin TERA, CPRT Civil /
, Structural Review Team
] Leader 3!
Dr. J. R. Honekamp TERA, Manager TRT Issues l : (
Dr. F. A. Webster JBA, Associate
!! (Engineering Statistical ll Consultant) 3 !. Dr. D. Veneziano MIT, Professor of Civil
!! Engineering (Engineering l!
Statistical Consultant) -
- Mr. G. Lagleder SWRI, Manager (Testing
- and Inspection) 4.3 Qualifications of Personnel i;
Where inspections required the use of certified inspectors, qualification were to the requirements of ANSI N45.2.6 j, (Reference 7.9) at the appropriate ~1evel. CPSES personnel 1: were qualified in accordance with applicable project requirements. Third-party inspectors were certified to the
~'
requirements of the third-party employer's quality assurance program and in accordance with USNRC Regulatory Guide 1.58, Revision 1 (Reference 7.10). The third-party inspectors were specifically trained to the requirements of SWRI Procedure-X-FE-108-1, Revision 1 (Reference 7.11) .
/ ~'i Other participants were qualified to the requirements of the
- V' CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan (Reference 7.12), as appropriate.
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t RESUI.TS REPORT ri
" f
- d. i ISAP II.b 4
? (Cont'd) !
k) 4.0 CPRT ACTION Pl.AN (Cont'd)
- )
[ 4.4 Acceptancebriteria ~
l A review of the historic.28-day cylinder strength data for both time frames (see Figure 1 or Table 3) indicated that, ,
regardless of whether falsificatica of data occurred during l the allegation period or not, it is 1.' i kely that the' CAI is
,i lower in strength than the CC. This observation is not '
II unusual, since under normal construction processes, there is
}l only a 50 percent chance that the concrete strength (and hammer indication) in the allegation period would be equal to or greater than that in any other comparable period. There is
- I also a 50' percent chance that it would be less than that in i any other comparable period. Therefore, the appropriate acceptance criterion was determined to be that of accepting 3
the CAI population if the tenth percentile hammer indication j was not "significantly lower" than that of the CC population. I
, In this case, "significantly lower" means not more than about ten percent. This'is based on the fact that the design
. strength of 4000 psi is 18.6 percent lower than the CC' tenth
,,I percentile 28-day cylinder strength (see Table 3), and this "l
, change in compressive strength (psi) corresponds to a relative change in hammer indication of approximately ten percent (see
- ) . References 7.13 and.7.14). Thus, the hypothesis that the Schmidt Hammer indication tenth percentile for the CAI is not-ljt "significantly lower" than that of the CC was tested at a
!' minimum statistical significance level of five percent.
j, 4.5 Decision criteria 3 Three hypothesis tests were considered for the comparison of i' the Schmidt Hammer data, with the understanding that the one 1; (or ones) with the most power
- would be used to test the two populations. The three test methods include:
4.5.1 Method A tests whether the tenth percentile hammer -
indication of the CAI is greater or equal to the target
!; value of the CC, where both populations are assumed to l: be normally distributed (see Reference 7.20). Note, ,
- ; the target value is defined as the CC population tenth !
i percentile or a fraction thereof.
t
- Power is defined as the probability of rejecting the hypothesis 3j when it is not true. The power. function gives the power as a function of disparity with the hypothesis.
4 5
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,j k . R visicn: 1 Page 10 of 31 l
- RESULTS REPORT ISAP II.b (Cont'd) 1 rj 4.0 CPRT ACTION PLAN (Cont'd) f 4.5.2 Method B tests whether the percentage of hammer t ind:. cations in the CAI population above the target value of the CC is greater or equal to 90 percent. In this test the CC population is assumed to be normally distributed for purposes of establishing the target
- value (which may be defined as the tenth percentile or i a fraction thereof), but the distribution of CAI hammer
- indications is unspecified.
l 1 4.5.3 Method C tests whether individual CAI hammer indication i data values belong to the same distribution as the control concrete rebound values. No assumptions are made regarding either population distribution.
Although the power functions for these three methods are not directly comparable, Methods A and B are of similar power and
- are better than Method C-(References 7.15, 7.20, and 7.21).
, Therefore, both Methods A and B were retained to compare the l',A two populations.
, Based on the sample outcomes for the two concrete populations, test statist.cs# were computed and the hypotheses regarding the CAI population were either accepted or rejected at the 5 percent level of significance. In addition, the levels of
! significance at which the hypotheses are accepted were also l determined.
! The action identified by the NRC (Section 2.0) is considered I complete now that all Schmidt Hammer tests have been completed, the results statistically analyzed, and the two concrete populations compared.
s Since the comparison indicates that the CAI population of hammer indications is not "significantly lover." than the CC, no further evaluation of the CAI is necessary, nor is it necessary to calibrate the Schmidt Hammer test to concrete of known strength and age or test cores from the CAI.
i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summarv of Implementation The implementation of this action plan followed the flow chart
- i n) shown'in Figure 2, with the four major aspects of the program being: 1) identification of all CAI and CC Category I pours
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j i l Revision: 1 Page 11 of 31 i
,I
/D RESULTS REPORT
. ; s.J ISAP II.b s (Cont'd)
'l
- 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) and surface testable truckload populations; 2) the random
, selection of truckloads; 3) the preparation and testing of selected areas; and 4) the test data evaluation.
'l
, Detailed descriptions of the population identification and j random selection processes are contained in Reference 7.3. In l~
summary, all Category I concrete pours in the two time frames were identified and an estimate of how many and which truckloads are surface testable was made. These estimated
.; testable truckload populations were randomly sampled for testing with the Schmidt Hammer, their accessibility verified, i and the selected accessible areas were prepared for testing.
i Once the test areas were prepared, certified SWRI personnel verified the surface preparation, performed the Schmidt Ha=mer tests, sum =arized the hammer readings, determined the average
) hammer indication for each test area, and submitted a report (Reference 7.4) to TUGC0 containing these data.
The third-party statistically evaluated the hammer data t (Reference 7.16), and performed the hypothesis tests which i were used to compare the two testable populations l (References 7.17). A copy of the average hammer indications, I as summarized from the SWRI raw data sheets, is listed in l Appendices A and B of this Results Report. Cumulative
, frequency plots of the two sample data sets are shown in i Figure 3.
.i
~
In addition to the hammer data, the reported 28-day concrete e
cylinder strength data for both populations were obtained from the TUGC0 Re03rds Center (Reference 7.8) and statistically ;
! evaluated (Reference 7.18). Cumulative frequency plots for i these two data sets are shown in Figure 1. t 5.2 Data Evaluation j Before comparing the two populations using Methods A and B, i the hammer data were first evaluated (Reference 7.16) by l calculating mean values, standard deviations, coefficients of i
variation (see Table 4), and cumulative frequencies (see Figure 3). The two data sets were tested for goodness-of-fit to the normal distribution (References 7.17 and 7.19).
- -s Normality of the two populations is accepted at the five 4 l percent significance level.
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- ." Rsvision: 1 Page 12 of 31
- RESUI.TS REPORT
'I
. ISAP II.b
{ (Cont'd)
! 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESUI.TS (Cont'd) [
. To compare the two testable concrete truckload populations, ,
i Methods A and B hypothesis tests were performed using target j values of 1.0, 0.975, and 0.95 times the CC population tenth
- percentile value. The hypothesis that the CAI population i
- tenth percentile is greater or equal to 1.0 times the CC j population tenth percentile is rejected at the five percent
- significance level. The hypothesis that the CAI population tenth percentile is greater than or equal to 0.975 times the
- CC population tenth percentile is accepted at the five percent significance level, and is also accepted at the ten percent
, significance level. The hypothesis that the CAI population
- tenth percentile is greater than or equal to 0.95 times the CC population tenth percentile is accepted at the five percent significance level, and is also accepted at the 95 percent significance level. This means that, although there.is not a high confidence that the CAI population of hammer indications is equal to or better than the CC population, there is a high
, confidence that.the CAI is within five percent of the CC
! ,r -. population at the tenth percentile value and therefore well
{' within the ten percent range required by the acceptance criteria (see Section 4.4.).
l The 28-day cylinder compressive strength data for the 223 l
- Category I concrete pours (see Section 4.1.2) in the CAI time l frame and comparable data in the CC time frame were statistically analyzed. The mean values, standard deviations, ;
and coefficients of variation are listed in Table 3. .These :
data were also ordered and cumulative frequency plots were constructed (see Figure 1). The results of the cylinder data evaluation are consistent with the Schmidt Hammer tests in I I that both show a slightly higher mean value and tenth i percentile value for the control concrete. In fact, the cylinder data indicate that the compressive strength of the l CAI is 9.3 percent lower than that of the CC at the population tenth percentile value (see Table 3). This corresponds approximately'to a five percent difference in hammer indications (Reference 7.13). Thus, the results show that, not only are the compressive strengths of both the CC and CAI
-well above the 4000 psi design value, but that the reported 28-day cylinder data truly represents the CAI at the population tenth percentile value.
l Regarding potential f.tisification of 28-day cylinder records,
,3 there are two general categories of interest. Of greater i : concern is the masking of out-of-specification concrete by recording it to be within specification. Of lessser concern is the recording of within-specification concrete when the tests 4
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i l
{ ... RESULTS REPORT L.
.f ISAP.II.h j (Cont'd)
.I 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
I were not performed. Neither of these two types of d falsification appears to have occurred in a systematic way, i since there is no obvious bisodal behavior in the hammer j
indication data and the shift between the CC and CAI populations for the cylinder data is consistent with that of i the hammer indication data.
\ .
j During third-party review (Reference 7.5) of the Schmidt l Hammer test program development, some errors were found due to
' arithmetic, accessibility determinations, and volume modeling 1 assumptions. A portion of these errors, if corrected, would l' result in fewer truckloads being included in the populations; g \ the other portion would result in more truckloads being added bMJ i to the population. However no systematic errors were found.
3
~# I The total error in the CAI truckload 761umsTs three percent unde re_s.t_imatad. For the CC population the estimate is less 1-[.
j g,thanhalfofonepercentoverestimated. Considering only those truckloads which were not included in the testable l
i ' populations, but shoul'd have Teen"(i.e., were not in the population from which the sample was drawn), th,e error rate is
_about six percent for the CAI and less than one percent for, the CC. The samples do not strictly repre Rsehe excluded
- truckloads.- However, these error rate's afe not signiT EE jtTIT j and even i'f additional sar.ples were obtained to represent the
- excluded truckloads, the conclusions would not be affected.
l l
6.0 CONCLUSION
S Although the present strength of the concrete in question has not been measured directly, based on the hammer indication data
, obtained, in association with the 28-day cylinder data for the
,. contrcl concrete, it is ::oncluded that the tenth percentile value of the CAI testable concrete is well above the design strength of 4,000 psi. The 28-day cylinder strength data are consistent with
. the hammer indication data. There is no evidence that systematic
- falsification of cylinder data or the non-performance of required 2 tests occurred. Finally it is concluded that the reported 28-day cylinder strength data represents the testable CAI population, thus validating the utilization of these data to address other allegations of concrete records falsification.
m
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. RESULTS REPORT
? %J
.] ISAP II.b (Cont'd) f
7.0 REFERENCES
i 7.1 ASTM Conunittee C-9, " Standard Test Method for Rebound Number
! of Hardened Concrete", (ASTM C805-79), American Society for Testing and Materials Philadelphia, PA, 1979.
~l
?, 7.2 ACI Committee 214. " Recommended Practice for Evaluation of il Compression Test Results of Field Concrete", (ACI 214-65),
1 American Concrete Institute, Detroit, MI, 1965.
t i
7.3 " Test Program Development Report", CPRT File No. II.b.6.C.1, l1 ', October, 1985.
-l 7.4 " Testing to Confirm Acceptability of Concrete Strength Data for the Comanche Peak Steam Electric Station, Units 1 and 2",
Final Report, Project 8478, Southwest Research Institute, San Antonio, TX, September, 1985. (CPRT File No. II,b.6.C.2)
J 7.5 " Third-Party Review and Verification of Sampling Activities j m and Procedures for CPRT Issue II.b Concrete Compressive Strength", CPRT File II.b.6.C.3, October, 1985.
Q l ,! 7.6 ACI-ASME Committee 359, " Code for Concrete Reactor Vessels and
- Containments", (ACI-ASME 359-83), American Society of
- Mechanical Engineers, New York, NY, 1983.
I i
-! 7.7 ACI Committee 318, " Building Code Requirements for Reinforced Concrete", (ACI 318-83), American Concrete Institute, Detroit, MI, 1983.
7.8 " Cylinder Data", CPRT File No. II.b.6.C.1.I.
i 7.9 ASME Committee on Nuclear Quality Assurance, " Qualifications
'4 of Inspection, Examination, and Testing Personnel for Nuclear Power Plants", (ANSI /ASME N45.2.6-1978), American Society of i Mechanical Engineers, New York, NY, 1978.
7.10 Office of Standards Development, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel",
" ll (USNRC Regulatory Guide 1.58, Revision 1), U.S. Nuclear
{ Regulatory Commission, Washington, DC, September, 1980.
, 1
< 7.11 "Schmidt Hammer Test on Concrete at the Comanche Peak Steam
! Electric Station", Nuclear Projects Operating Procedure X-FE-108-1. Revision 1, Southwest.Research Institute, San
! ," Antonio, TX, January, 1985. (CPRT File No. II.b.6.A)
' \ s}
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R vision: 1 I Page 15 of 31 RESULTS REPORT ISAP II.b
- (Cont'd)
7.0 REFERENCES
(Cont'd) -
t 7.12 " Comanche Peak Response Team Program Plan and Issue-Specific Action Plans", Revision 3, TUGCO, Glen Rose, TX, January 24, 1986. (CPRT File No. II.b.1) 1 J 7.13 Operating Instructions Concrete Test Hammer Types N and NR, 1 Copyright 1977, PROCEQ, Zurich, Switzerland. (CPRT File No.
] II.b.11)
I
! 7.14 Attachment A of F. Webster, " Target Tenth Percentile", CPRT j File II.b.4a-003, February, 1985.
1 7.15 F. Webster, " Slides on Data Evaluation Methods Presented at NRC-TRT Meeting of 1/7/85", Memo to File, CPRT File II.b.10-004, January, 1985.
t
'! 7.16 A. Boissonnade "Schmidt Hammer Data Statistical Evaluation",
CPRT File II b.4a-010, August, 1985.
(Ggj 7.17 F. Webster, " Hammer Data Hypothesis Tests", CPRT File II.b.4a-011, July, 1985.
7.18 A. Boissonnade, " Statistical Evaluation of Cylinder Data",
l CPRT File II.b.4a-012. August, 1985.
I j 7.19 F.-Webster, " Chi-Square Goodness-of-Fit-Test of Hammer Data",
CPRT File II.b.4a-013, September, 1985.
j 7.20 D. Veneziano, " Comparison of the Fractiles of Two Normal
! Populations: A Large Sample Test and Its Power", CPRT File
, II.b.4a-001, December, 1984 i
, 7.21 F. Webster, " Additional Background for TUCCO-NRC Meeting of
, . 3/6/85", CPRT File II.b.4a-008, May, 1985.
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1 l < RESULTS REPORT i s_-
l ISAP II.b l (Cont'd) 5 j TABLE 1
') CHARACTERIZATION OF CATEGORY I CONCRETE
! PLACED IN ALLEGATION TIME FRAME I
.i j- NUMBER OF NUMBER OF POURS TRUCKLOADS 1 All Category I 326 31 SOG* 1780 SOG Category I (Other Than 223 4,080
)
Seal Slabs, Shoterete, 192 C W,ES* 2300 C.W,ES Grout, or Backfill) 19 SOG 315 SOG l
g-- Testable Category I 197 1,305 g j 178 C,W.ES 990 C,W,ES
- SOG = Slabs on Grade C = Columns W = Walls ES = Elevated Slabs
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'I
() RESULTS REPORT ISAP II.b (Cont'd)
TABLE 2 I
CHARACTERIZATION OF CATEGORY I CONCRETE
]
PLACED IN CONTROL CONCRETE TIME FRAME t NUMBER OF NUMBER OF i POURS TRUCKLOADS
. All Category I 324 i.
24 SOG* 920 SOG Category I (Other Than 291 2,715 Seal Slabs, Shotcrete, 267 C.W.ES* 1,795 C,W,ES Grout, or Backfill)
! 24 SOG 353 SOG
! '~'s Testable Category I 282 2,090 j (c,) 258 C.W,ES 1,737 C,W,ES i
l
+
- SOG = Slabs on Grade
'i C = Columns
- W = Walls
! ES = Elevated Slabs I l i
g j
-]
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- R:visicn: 1 Page 18 of 31 RESULTS REPORT ISAP II.b (Cont'd)
TABLE 3 28-DAY STANDARD CURE CYLINDER DATA STATISTICAL SL'MMARIES Concrete at Issue Control Concrete Number of Data '509 372 i
Mean value 5158 psi 5441 psi Standard 475 psi 383 psi Deviation i
t Coefficient of 0.09 0.07 Variation t
- Tenth 4457 psi 4913 psi Percentile i Minimum 4047 psi 4540 psi
'I i
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( f.
ISAP II.b f (Cont'd) i l TABLE 4 1
SCHMIDT HAMMER DATA STATISTICAL SUMMARIES i
1 a
1 i
l Concrete at Issue Control Concrete
] Number of Data 119 132 j Mean Value 48.57 49.14
.i Standard 3.13. 2.87
, Deviation Coefficient of 0.06 0.06
, Variation Tenth 44.1 45.3
. . - - Percentile l Minimum 38.5 '39.7
?
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1 .
]O. U RESULTS REPORT
) ISAP II.b lj (Cont'd) i t
, FIGURE 1 a
CAI and CC CYLINDER DATA CUMULATIVE FREQUENCIES J
i i
t
'?
. I. ,<
1 : ,-
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. r t
. /
.s -
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f
- 3 -
e w : f
< 4 -
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g
.2 -
/
. : CAI CYL Strengpi'
- 10th Percens41e=4451
, .I ~*'- ,' CC CTL StrengtM
,' 10'M Percentile =4913
-'?", t , t , t , f , f , t , t , ! , 1 , ! , f , ! ,
bm 4200 4400 4800 4400 5000 5200 5400 5800 5000 8000 8200 8400 6600 0000 7000 29 DAY STD CURE CONCRETE COMPRESSIVE STRENGTH' l
9 1
I l
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RESULTS REPORT
. 1
- U; y ISAP II.b I (Cont'd) i FIGURE 2 d.
?
.{
t ISSUE II.b FLOW CHART
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'. Rcvision: 1 Page 22 of 31 u], RESULTS REPORT ISAP II b (Cont'd)
FIGURE 3 t
l CAI and CC HAMMER DATA CUMULATIVE FREQUENCIES I..
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1 :
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Rsvision: 1 Page 23 of 31
- g. RESULTS REPORT Y.J ISAP II,b (Cont'd)
APPENDIX A i
,j CAI AVERAGE HAMMER INDICATIONS HAMMER TEST j DATA SHEET POUR PACKAGE No.- MEAN REBOUND VALUE 4
No. GRID AREA TEST LOCATION . HORIZ. UP DOWN l
i 8 002-2790-004-H TR-85-066-8904 44.38 10 002-4790-005-I TR-85-005-8904- 47.67 13 002-4790-037-HH TR-85-100-8704 44.0 i 24 002-4792-005-B TR-85-029-8904 38.5
- 37 002-2778-002-WW TR-85-060-8904 46.1
'l 46 002-5778-001-D TR-85-123-8904 43.9 4 72 002-4792-008-F TR-85-001-8904 42.9 73 002-5778-001-Q TR-85-079-8904 47.4 i 74 002-5778-001-R TR-85-098-8904 46.0
. 76 002-5778-001-Z TR-85-095-8904 46.6 j .
77 002-5778-001-AA TR-85-096-8904 ~ 46.6 79 002-6778.-005-A TR-84-204-8904 43.8
(' ' '
80 002-2778-002-X TR-85-056-8904 42.0 1 81 002-2778-002-KK TR-85-120-8904 44.1 I 88 105-4785-003-C TR-84-101-8903 48.2 i 89 002-4790-016-I TR-85-009-8904 48.3 I
92 002-6778-010-A TR-85-122-8904 48.3
! 118 002-6790-001-A TR-85-017-8904 44.6 t 127 002-7792-003-B TR-85-103-8904 44.4 128 002-2778-002-L TR-85-119-8904 42.8 1 129 002-4792-018-A TR-35-028-8904 39.1 ;
i 130 002-4790-037-0 TR-85-188-8904 44.1 131 002-4790-037-C TR-85-104-8904 43.0 145 101-5805-003-M TR-85-162-8902 49.3 153 002-4778-001-D TR-85-149-8904 48.2 154 002-5778-007-C TR-85-092-8904 49.4 I 157 101-5805-003-D TR-85-161-8902 48.4 163 002-5790-002-A TR-85-207-8904 47.4
~165 002-4792-003-A TR-85-146-8904 43.0 )
166 002-7792-001-P TR-85-150-8904 46.4
, 167 002-4792-009-A TR-85-191-8904 47.4 168 002-7792-001-BB TR-85-151-8904 45.8 169 002-5778-006-A TR-85-099-8904 47.6
- 211 105-5790-005-I TR-85-113-8903 50.4 i 214 101-5805-002-P TR-85-160-8902 50.7
- 215 101-5805-003-Q TR-85-163-8902 49.0 t 217 002-2778-002-T TR-85-057-8904 44.4
(,)'_
218 002-2778-002-P TR-85-058-8904 46.1 219 002-2778-002-Q TR-85-059-8904 43.4 l 220 002-5778-001-X TR-85-094-8904 49.9 j L w - . ~ m m_ __ _
-_--~..m. nw- ._ - _ =w, , . :-,., rm .. J
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Rsvisicn: 1 Page 24 of 31
.RESULTS REPORT ISAP II b
) (Cont'd) l APPENDIX A l (Cont'd)
I CAI AVERAGE HAMMER INDICATIONS
] (Cont'd) ll 1 HAMMER TEST j DATA SHEET POUR PACKAGE No.- MEAN REBOUND VALUE i No. GRID AREA TEST LOCATION HORIZ. '
UP DOWN l 226 101-2808-004-A TR-85-105-8902 44.3 i 230 101-2808-003-N TR-85-110-8902 42.0 1
236 002-4790-046-A TR-85-006-8904 44.2
- 238 002-4790-037-AA TR-85-101-8904 47.0 239 002-5790-009-B TR-85-091-8904 47.7 240 002-6790-012-B TR-85-014-8904 49.7 248 002-4792-008-D TR-85-192-8904 44.0 249 002-4792-001-G TR-85-121-8904 44.8 262 105-5773-001-U TR-85-329-8903 45.9 I
263 105-5773-001-N TR-85-331-8903 47.4 264 105-5773-001-T TR-85-328-8903 54.2 Ov. 265 266 105-5773-001-X TR-85-330-8903 TR-85-268-8903 50.6 49.3 105-7785-001-Q J 267 105-5773-001-KK TR-85-341-8903 50.4 268 105-5773-001-JJ TR-85-342-8903 52.2
, 269 105-5773-004-N TR-85-267-8903 50.4
]i 270 105-4785-001-D TR-85-269-8903 47.S 271 105-5773-001-RRRR TR-85-338-8903 46.2 l 272 105-4773-003-B TR-85-332-8903 49.0 j 273 105-5773-001-LLL TR-85-333-8903 52.8
- 274 105-5773-001-BBBB TR-85-334-8903 43.3
, 275 105-5773-001-DDDD TR-85-335-8903 48.7
, 276 105-5773-001-NNNN TR-85-336-8903 48.5 277 105-5773-001-ZZ TR-85-343-8903 52.3 278 105-5773-001-DDD TR-85-366-8903 47.6 279 105-5773-001-FFF TR-85-344-8903 50.3 280 105-5773-001-GGG TR-85-345-8903 _ 5 6.1 -
282 105-5790-001-BB TR-85-350-8903' 47.8 283 105-5790-001-T TR-85-339-8903 47.1 288 105-5773-004-F TR-85-327-8903 52.6 289 002-2790-001-WW TR-85-315-8904 44.0 l 290 002-5790-001-E TR-85-323-8904 50.8 291 002-2790-001-YY TR-85-325-8904 48.4 293 002-2790-001-UU TR-85-320-8904 45.4 294 002-4790-004-Q TR-85-314-8904 48.2 l ~, 296 002-4790-016-A TR-85-319-8904 51.8 i.
'1 297 002-4790-026-B TR-85-318-8904 49.3
' \ 298 002-4790-038-C TR-85-317-8904 50.1 299 002-2790-001-II TR-85-316-8904 43.3 300 002-4790-004-J TR-85-322-8904 49.7 303 002-7792-001-X TR-85-353-8904 46.6 b_ m, _ _ . . ,,me. - - - , m.mmx-- - we _._. ,m _
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Ravicion: 1 Page 25 of 31
]
V RESULTS REPORT 3 ISAP II.b j (Cont'd) .
APPENDIX A
] .
(Cont'd)
CAI AVERAGE HAMMER INDICATIONS j] (Cont'd) i l HAMMER TEST
]
J DATA SHEET POUR PACKAGE No.- MEAN REBOUND VALUE No. GRID AREA TEST LOCATION HORIZ. UP DOWN
.k
! 304 002-7792-001-B TR-85-354-8904 47.3 j 306 101-5805-001-T TR-85-265-8902 50.2
! 307 101-5805-001-S TR-85-278-8902 53.6
! 308 101-5805-002-V TR-85-363-8902 51.0 309 101-5805-002-X TR-85-361-8902 51.9 310 101-5805-004-N TR-85-371-8902 53.4
, 313 101-5805-004-U TR-85-373-8902 50.8 314 101-5805-003-X TR-85-360-8902 50.9 315 101-5805-005-S TR-85-372-8902 51.2
! 317 002-2785-001-KK TR-85-368-8904 51.1
.~ '
318 002-2785-001-YY TR-85-369-8904 53.3 i 319 002-2785-001-Q TR-85-260-8904 51.6 l 320 002-2785- 001-BB TR-85-266-8904 51.1 j
321 002-2785-001-SS TR-85-270-8904 50.5 322 002-2785-001-BBB TR-85-263-8904 53.0 323 002-2785-001-Z TR-85-262-8904 52.6 4 324 035-5782-003-F TR-85-280-8906 50.8 325 035-5782-003-C TR-85-279-8906 49.1 326 035-5782-001-L TR-85-264-8906 50.9 327 035-5782-001-I TR-85-259-8906 - 49.6
! 328 002-4790-038-G TR-85-324-8904 45.7
'l 330 - 002-2790-001-R TR-85-321-8904 45.8
- 333 002-5778-013-H TR-85-358-8904 43.4
! 334 002-5778-013-B .TR-85-359-8904 55.7 )
370 101-5805-004-BB TR-85-364-8902 48.5 374 101-5805-004-FF TR-85-362-8902 52.4 377 101-5805-001-M TR-85-275-8902 49.7
~ 378 101-5805-001-P TR-85-276-8902 50.3 379 101 2808-003-L TR-85-349-8902 50.0 383 101-2808-003-E TR-85-348-8902 45.8 390 101-2808-002-F TR-85-370-8902 50.0
- 101-2808-002-C 391 TR-85-347-8902 48.5 394 002-7807-001-P TR-85-356-8904 46.8 002-7807-001-W TR-85-357-8904 395 47.0 l 396 002-7792-001-MM .TR-85-351-8904 44.8 l 397 002-7792-001-FF TR-85-352-8904 44.3 3
,V 398 105-5773-001-GGGG TR-85-337-8903 55.0 405 101-5805-005-J TR-85-365-8902 50.0
$ 4 y 9 a m % P 4 f W s 1. . me,+m #M M +/ ' - - ' ^
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Ravisicn: 1 Page 26 of 31 l
RESULTS REPORT
?
\.
ISAP II.b (Cont'd)
,) APPENDIX A j (Cont'd) l
.j CAI AVERAGE HAMMER INDICATIONS
~k 1
I 1
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s
. .a .
~
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Rcvicien: 1 l Page 27 of 31
[ RESULTS REPORT ISAP II.b
. (Cont'd)
APPENDIX B 1
l CC AVERAGE HAMMER INDICATIONS
.?
ii SHEET CONCRETE POUR HEAN REBOUND VALUE l No. PACKAGE No. TEST LOCATION HORIZ. UP DOWN OTHER l
15 002-7810-002-X TR-85-078-8904 40.7 l 20 002-7810-001-EE TR-85-126-8904 42.3
, 25 002-4792-007-B TR-85-030-8904 41.3 l 34 002-7810-003-DD TR-85-127-8904 44.2 1
35 105-4810-021-J TR-85-051-8903 45.5 I I 54 105-4790-016-C TR-85-038-8903 I
43.9 I 57 101-5805-012-P TR-85-186-8902 49.9 96 105-4790-015-C TR-85-114-8903 45.7 110 105-4810-021-D -TR-85-048-8903 43.4 115 101-5805-010-E TR-85-169-8902 48.2 116 101-5805-012-E TR-85-176-8902 49.0 124 002-5807-002-G TR-85-157-8904 48.1 125 002-5807-002-E TR-85-027-8904 40.9 l 137 003-4785-002-III TR-85-200-8901 47.8 j 139 003-4785-007-U TR-85-201-8901 46.9 t 140 ' 003-4785-002-FF TR-85-202-8901 45.6 003-4785-002-0 141 TR-85-204-8901 43.7 142 003-4785-002-N TR-85-203-8901 48.6 143 003-2810-004-E TR-85-141-8901 46.6 144 105-5790-002-E TR-85-196-8903 46.2 148 002-5810-004-H TR-85-116-8904 45.3
, 149 101-5805-012-0 TR-85-185-8902 52.1 1
150 101-5805-012-K TR-85-184-8902 49.1 4
151 101-5805-006-F TR-85-168-8902 50.3 155 003-2810-005-D TR-85-093-8901 49.7
, 156 003-2810-002-D TR-85-040-8901 48.4 158 101-5805-010-G TR-85-171-8902 . 48.7 162 105-4810-021-S TR-85-208-8903 43.9 164 002-5810-001-GG TR-85-0:4- 904 46.5 170 201-5805-002-F TR-85-190-3')2 48.2 171 002-5dO7-002-Y TR-85-156-89t's 39.7 179 101-5805-013-U TR-85-179-8902 50.6 180 101-5805-012-V TR-85-183-8902 50.6
[ 182 101-5805-013-BB TR-85-180-8902 53.0 185 105-4810-021-B TR-85-050-8903 45.9 i
186 003-4785-002-RRR TR-85-206-8901' 50.9 187 003-4785-002-B J.R-85-205-8901 48.5
,_s 188- 101-4808-009-I TR-85-158-8902 52.2 191 101-4812-005-J TR-85-135-8902 50.0 i 'i ') 193 105-7810-002-N TR-85-229-8903 51.3 194 105-7800-001-B TR-85-210-8903 48.1
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. l R3visisn: 1 .
Page 28 of 31 l RESULTS REPORT ISAP II b
, (Cont'd)
APPENDIX B f (Cont'd)
CC AVERAGE HAMMER INDICATIONS 4 (Cont'd)
SHEET CONCRETE POUR MEAN REBOUND VALUE 4 No. PACKAGE No. TEST LOCATION HORIZ. UP DOWN OTHER 199 002-7810-003-LL TR-85-222-8904 48.5 200 002-7810-001-W TR-85-220-8904 53.0 3 207 105-7810-001-D TR-85-227-8903 45.6 209 105-7810-007-A TR-85-133-8903 52.9 210 105-5790-002-I TR-85-039-8903 46.4
} 212 105-4810-021-I TR-85-049-8903 49.8 105-4810-021-G TR-85-148-8903 50.7 213
. 221 101-5805-011-G TR-85-173-8902 49.7 222 101-5805-011-K TR-85-174-8902 50.8 223 101-5805-011-L TR-85-175-8902 52.0 l 225 101-4808-004-D TR-85-139-8902 48.5 e 241 105-4790-011-B TR-85-043-8903 47.8 l,y,g 244 002-4807-002-F TR-84-153-8904 47.7
- j 245 201-5805-002-D' TR-85-187-8902 53.4 i 252 002-7807-002-G TR-85-085-8904 50.4
[ 255 002-7807-003-A TR-85-086-8904 46.8 256 002-7807-002-Q TR-85-155-8904 48.0 257 002-4810-020-1 TR-85-020-8904 47.9 ,
281 105-4790-008-G TR-85-236-8903 48.3 i 284 105-4800-001-F TR-85-235-8903 48.5 l 285 105-7810-007-5 TR-85-237-8903 58.8
- 286 105-5790-003-L TR-85-238-8903 48.9 1 287 105-7790-002-D TR-85-306-8903 48.5 1
292 002-7810-001-000 TR-85-300-8904 49.2
! 295 002-7810-001-CCC TR-85-305-8904 52.1 i 301 002-5830-001-N TR-85-312-8904 47.7
! 302 035-3790-001-B TR-85-257-8906 49.4 305 002-5807-003-L TR-85-242-8904 49.9
, 311 101-5805-007-U TR-85-378-8902 53.0 l 312 101-5805-008-Z TR-85-272-8902 52.4
- 316 002-7810-001-W TR-85-301-8904 52.9 l 329 002-7810-002-00 TR-85-302-8904 49.9 1 331 002-7810-003-SS TR-85-303-8904 44.6
! 332 002-4790-027-P TR-85-258-8904 43.1 3
335 002-7810-001-RR TR-85-291-8904 49.9
- 336. 002-5810-001-A TR-85-367-8904 53.2
% 337 002-7810-001-1 TR-85-295-8904 43.2 i 338 002-4810-015-H TR-85-284-8904 49.1 339 002-4810-015-M TR-85-283-8904 50.8 340 002-7810-002-M TR-85-285-8904 46.1 d
a
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R visicn: 1 Page 29 of 31 RESULTS REPORT lC ISAP II.b (Cont'd)
APPENDIX B j (Cont'd)
} CC AVERAGE HAMMER INDICATIONS i (Cont'd)
SHEET CONCRETE POUR MEAN REBOUND VALUE No. PACKAGE No. TEST LOCATION HORIZ. UP DOWN OTHER 341 002-7810-003-DD TR-85-294-8904 A7.3
'. 342 002-5810-002-N&! TR-85-232-8904 50.7 1 343 002-5810-002-S TR-85-282-8904 48.8 1 344 002-7810-003-CCC TR-85-290-8904 44.9 345 002-7810-003-EEE TR-85-281-8904 47.9
-l 346 002-7810-003-XX TR-85-293-8904 48.7 347 002-4810-002-V TR-85-233-8904 48.1 348 002-7810-002-C TR-85-286-8904 45.9 349 002-4810-002-H TR-85-288-8904 46.5 350 002-7810-002-EE TR-85-292-8904 44.2 352 002-5810-014-C TR-85-287-8904 48.6
- 353 003-2810-007-H TR-85-326-8901 46.7 l -
354 003-2813-002-AA TR-85-254-8901 46.5 355 003-2810-007-BB TR-85-246-8901 48.2 356 003-2810-001-M TR-85-253-8901 48.7 j 357 003-2810-002-T TR-85-249-8901 51.3 358 003-2810-002-VV TR-85-248-8901 51.6
. 359 003-2810-002-L TR-85-251-8901 51.2
{ 360 003-2810-002-AA TR-85-250-8901 51.2 361 003-2810-007-CC TR-85-247-8901 51.7
, 362 003-2813-001-N TR-85-252-8901 52.8
. 363 003-2813-001-U TR-85-244-8901 ~54.4
- 364 003-2813-001-T TR-85-243-8901 52.9 365 003-2810-004-R TR-85-245-8901 47.8 366 201-5805-002-V TR-85-374-8902 52.4 367 201-5805-001-R TR-85-377-8902 52.0 368 003-2813-002-G TR-85-256-8901 48.7 369 003-2813-001-AA TR-85-255-8901 52.2 371 101-5805-010-HH- TR-85-376-8902 52.7 372 101-5805-012-LL TR-85-375-8902 53.4 373 101-5805-009-JJ TR-85-274-8902 51.4 1 375 105-7810-001-B TR-85-304-8903 44.3
- 376 105-2810-001-D TR-85-234-8903 48.2 380 101-2812-001-BBB TR-85-239-8902 50.5 381 101-6808-008-A TR-85-355-8902 48.4
,L 382 101-2812-001-00 TR-85-241-8902 48.7
! 384 101-2812-001-C TR-85-240-8902 53.3
~ ! /*. 0% 385 101-4812-001-M TR-85-309-8.902 51.2 l\ _, ) 386 101-4812-001-J TR-85-310-8902 50.3 387 101-4812-001-B TR-85-311-8902 52.3
(' wmw.w n& pmmWWm wwwmy.7n ' 7 " r ~"T~
s - _ _ _. _ - - _ .s . _ . - - . ,, .
.4 ** t
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Rsvisicn: 1 Page 30 of 31 i.
. RESULTS REPORT l
(f ISAP II.b (Cont'd)
I APPENDIX B 1
(Cont'd)
CC AVERAGE HAMMER INDICATIONS
.i (Cont'd) l l SHEET CONCRETE POUR MEAN REBOUND VALUE No. PACKAGE No. TEST LOCATION HORIZ. UP DOWN OTHER 388 101-4812-002-H TR-85-307-8902 49.6 389 101-4812-002-K TR-85-308-8902 51.3 392 002-5807-001-L TR-85-346-8904 49.3 l
. 393 002-5807-001-E TR-85-296-8904 47.4
! 399 101-5805-008-K TR-85-271-8902 51.1 400 101-5805-009-0 TR-85-273-8902 53.2
- 401 002-6807-008-A TR-85-297-8904 51.0 402 002-6807-009-C TR-85-313-8904 50.2 j 403 002-7807-002-0 TR-85-299-8904 47.3
- 404 002-7807-002-R TR-85-298-8904 48.6
! 406 002-7810-002-A TR-85-289-8904 47.7
$) '
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< R3visien: 1 Page 31 of 31 RESULTS REPORT -
i i^'l i . .-
ISAP II.b i (Cont'd) 1 i
. AVERAGE SCHMILI HAMMER INDICATION 5
t j-4 r
- P
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I -
t *I 7.
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x :
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G
- fees Deto l
f35
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model
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f ~ 3 -
l 3 E
' E 3 .~ 3 -
J U -
d, = 0.003
- y -
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1 -
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30 35 40 45 50 55 60 Average Schmidt Hammer Indication G
k 5
E 4
4
'~;; , ym =2pms. ~ . . . -, y : . ,--
-r- . ; - -~ ,, ; m *- ~ '~ T* 7-* r * ~