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The TRT examined the documents (NRC's and DCA's) by which some of the larger 1 | The TRT examined the documents (NRC's and DCA's) by which some of the larger 1 | ||
, items were entered into the CEL, wnich.was provided to the TRT by TUEC . _. | , items were entered into the CEL, wnich.was provided to the TRT by TUEC . _. | ||
letter dated August 10, 1984. Also, the TRT examined the method by which the areas of the items were estimated. TheTRT found that determinations to place items in the CEL were made in a conservative manner and the methods of area e,s11mation were reasonably conservative. | {{letter dated|date=August 10, 1984|text=letter dated August 10, 1984}}. Also, the TRT examined the method by which the areas of the items were estimated. TheTRT found that determinations to place items in the CEL were made in a conservative manner and the methods of area e,s11mation were reasonably conservative. | ||
In the course of its review of the Backfit Testing Program and other aspects of the protective coatings, the TRT found a num~oer of items that should have been but were not included in the CEL. The largest of these are the areas of miscellaneous steel, concrete and containment liner which failed the coating backfit test program adhesion tests after the original dat | In the course of its review of the Backfit Testing Program and other aspects of the protective coatings, the TRT found a num~oer of items that should have been but were not included in the CEL. The largest of these are the areas of miscellaneous steel, concrete and containment liner which failed the coating backfit test program adhesion tests after the original dat | ||
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coatings which were not DBA qualified (see/yectLr :'!.b. ebm). One | coatings which were not DBA qualified (see/yectLr :'!.b. ebm). One | ||
~ | ~ | ||
example is inorganic ::inc coatings applied over organic topcoat 'in over-lap areas surrounding repairs to protective coatings over steel. By letter dated August 21, 1984, TUEC estimated this overlap area to be between 2,500 feet2 and 6,500 feet .2 Available documents do not indicate whether the 6,100 ft 2 of inaccessible _. | example is inorganic ::inc coatings applied over organic topcoat 'in over-lap areas surrounding repairs to protective coatings over steel. By {{letter dated|date=August 21, 1984|text=letter dated August 21, 1984}}, TUEC estimated this overlap area to be between 2,500 feet2 and 6,500 feet .2 Available documents do not indicate whether the 6,100 ft 2 of inaccessible _. | ||
or limited access areas described in TUEC's letter TXX-4262 dated August 21, 1984 in relation to allegation AQ0-31 were entered into the CEL. DCA 13140, Rev. 2. downgrades the requirements for these areas, but does not specify thatjegeas.shouldbeplacedintheCEL. | or limited access areas described in TUEC's letter TXX-4262 dated August 21, 1984 in relation to allegation AQ0-31 were entered into the CEL. DCA 13140, Rev. 2. downgrades the requirements for these areas, but does not specify thatjegeas.shouldbeplacedintheCEL. | ||
: 5. | : 5. | ||
Latest revision as of 17:06, 6 December 2021
| ML20205Q755 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1984 |
| From: | Matthews P NRC |
| To: | Oliu W NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20204J134 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606030139 | |
| Download: ML20205Q755 (108) | |
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- Document Name: -
l' COMANCHE PEAK INPUT CONT s
Requestor's ID: '
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i Document Comments: !
i- Oraft 11/13/84-Please return sheet when submitting revisions
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- 1. Allegation Grouo: Protective Coatings ieCoatings j
Exempt Log (CEL)
- 2. Allegation Numbers: No allegations were specifically directed at the CEL.
.i
- 3. Characterizations: In its investigation of the allegations concerning 'l deficiencies in the CPSES protective coatings work, the TRT noted that the number and area of the ccated items entered into CEL was a convenient mea- -
sure of plant coatings with unacceptable or indeterminate quality. The TRT also noted that many of the items referred to in the protective coat ,
ings allegations were entered into the CEL,fraand further that the ccmbined, area of ite,ms in the CEL was a significant : = d ied
= of the total coated area. The TRT therefore conducted a generic review.of the operation of the CEL at CPSES.
- 4. Assesniint'of Safety Significance: The implied safety significance of a CEL of excessive size is that poor quality coatings are more likely to' fail under accident corditions. Failed coatin g could interfere with the enysuced operation of 'q.:. d safeguard systems. An evaluation of the significance of this safety concern is reported in (later).
~
The CEL was established by TUEC Procedure No. CP-EP-16.4, " Protective Coat .
ings Exemption Log," to " provide the method for maintaining identification.
of items and/or areas that do not meet project coating requirements." In conducting its review, the TRT examined this procedure, interviewed several TUEC civil engineering and QA personnel regarding CEL operation and examined a number of documents by which scme of the larger areas (larger than 1000 feet2 ) were placed in the 1og. These documents included TUEC memoran-dum QTQ-416; DCA 17, 143; NRC-C-S4-00710; DCA 6114, Rev. 1; DCA 12,374, Rev. 1; DCA 16,106; and NRC-C-S4-01483, Rev. 4.
The TRT found several deficiencies in TUEC Procebure No CP-EP-16 4 I
1 l
l 11/13/84 1 COMANCHE FEAK INPUT CONT
]
l
It places responsibility for.' approving items to be included in t.he..CEL with
~
the Civil Engineer or his representative. However, CP-EP-16.4 provides no specific direction nor criteria to assure that items not meeting project d.ce.
coating requirements and not scheduled for repair or rework g systematically entered into the CEL.
Also, the procedure does not require each CEL entry to be signed and date'd .j by'the civil engineering representative and to identify the document des-cribin g the coatir.g deficiency and the basis for placing the item iii the
- h. '
The TRT examined the documents (NRC's and DCA's) by which some of the larger 1
, items were entered into the CEL, wnich.was provided to the TRT by TUEC . _.
letter dated August 10, 1984. Also, the TRT examined the method by which the areas of the items were estimated. TheTRT found that determinations to place items in the CEL were made in a conservative manner and the methods of area e,s11mation were reasonably conservative.
In the course of its review of the Backfit Testing Program and other aspects of the protective coatings, the TRT found a num~oer of items that should have been but were not included in the CEL. The largest of these are the areas of miscellaneous steel, concrete and containment liner which failed the coating backfit test program adhesion tests after the original dat
- c. ,
were corrected for the Elcometer calibration error. As reported in S*- Ds t '$:-5 E.B-
-;.1 1 2 :::, this total area may be as large as 57,500 ft2p*pproxi-mately 3000 ft2has already been entered into the CEL because of failed adhesion tests. The remainder of 54,500 ft should 2
be added to the CEL.
A second item which has not been included in the CEL involves coated areas l with deficiencies other than poor adhesion. For example, a number of NRCs relating to unsatisfactory Ory Film Thickness (DFT) (C-33-03103, Rev. 2; C-83-03104, Rev. 2; and C-83-3105, REv. 2) direct that all. miscellaneous s't' eel ite'ms with unsatisf actory. DFTs be "used-as .is" and be entered into the CEL. As a conservat~ive estimate of this area, TUEC used 5% of the total surface area of each category of miscellaneous steel for a .otal of 8,150 ft2 This estimate is conservative because the DFT test failure 11/13/84 2 CCMANCHE PEAK INPUT CONT
rate was well below 5% for the miscellaneous steel categories. Also, according to interviews between TRT and TUEC QA personnel, a' number of
~
discrepant areas were still net finally dispositioned by either rework or entry into the CEL. ,
'A third item which has not been included in the CEL involves non-standard c eafigs 5 5E R- Q
~
coatings which were not DBA qualified (see/yectLr :'!.b. ebm). One
~
example is inorganic ::inc coatings applied over organic topcoat 'in over-lap areas surrounding repairs to protective coatings over steel. By letter dated August 21, 1984, TUEC estimated this overlap area to be between 2,500 feet2 and 6,500 feet .2 Available documents do not indicate whether the 6,100 ft 2 of inaccessible _.
or limited access areas described in TUEC's letter TXX-4262 dated August 21, 1984 in relation to allegation AQ0-31 were entered into the CEL. DCA 13140, Rev. 2. downgrades the requirements for these areas, but does not specify thatjegeas.shouldbeplacedintheCEL.
- 5.
Conclusion:
The TRT concludes on the basis of the items listed above that the operation of the CEL system was deficient In several respects. The CEL procedure, CP-EP-16.4, did not provide adequate guidance and direction to assure that areas with coatings of unacceptable or indeterminate quality were either reworked or entered into the CEL.
The TRT further concludes that several sizable areas with coatings of ,
.indeterminatep quality have_not been included in the CEL. -M.._.m
> ='ut d- th_ ZL. These areas include 54,500 ft which 2 may have failed the : WAha according to the TRT audit of the BTP, and 2,500 ft: to 6,500 ft of 2
non-standard coatings which were.not DBA qualified. The total area which should be added to the CEL is therefore approximately 60,000 ft 2.
5efore including this additional area, the CEL identified approximately 55,000 ft of unqualiff d or indeterminate coatings. This value is 2
already considered high by the TRT, and it would be more than doubled by 11/13/54 3 COMANCHE PEAK INPUT CONT
V j including the additic'nal 60,000 2ft . The total of 115,000 ft2 is.approxi-mately 20?! of the total coated area in Unit I containment. ~The overall conclusion of the TRT is that this value is excessive compared to values at other nuclear plants. *
'The implication of the 20!; CEL value is that the remaining 80!; of the coat .
ings are of satisfactory quality. However, such a conclusion is not valid A A ' u' uritil the resolution of other TRT concerns such as assurance of DE3 quali-fication of coatings and their traceability is reached. (See Coati 7igs SSERs-2
~
and -3).
- 6. Actions Recuired: TUEC shall amend the CEL procedure CP-EP-16.4 to provide more specific g Jidance and direction on entering items into the CEL. Th e- _.
procedure should make it clear that all discrepant items which meet the following criteria shall be automatically included in the CEL: (a) dis-c positioned "use-as-is" by NRCs, (b) have been downgraded from s+uvw~rtn ai level IJy_CCAs, _or (c) determined not to meet project coating requirements by the civil engineer based on vend'or equipment specification. The pro-cedure should also require each CEL entry to be signed and dated by the civil engineering representative with a notati6n of the document by which the item was placed in the log. .
Also, TUEC should provide updated estimates of the additional items to be entered into the exempt log. These entries can be useful in planning future inspections of coatings in connection with inspecting for debris that could restrict sump inlets.
1521852E2h7
- 8. Attachments: None
- 9. Reference Documents:
(1) TUEC procedure CP-EP-16.4, " Protective Coatings Exemptions Log" 11/13/54 4 COMANCHE PEAK INPUT CCNT
e-(2) TUEC Memorandum QTQ-416 ..
(3) TUE DCA 17,142
~
(4) TUEC (NRC-C-84-00710 (5) TUEC DCA 6114, Rev. 1 ' ,j
~
l (6) TUEC DCA 12, 374 Rev. 1 (7) TUEC OCA 16, 106 (8) TUEC NRC-C-84-01488 Rev. 4 -
4 (9) TUEC letter to NRC dated August 10, 1984 (10) TUEC NRC-C-8_3-0313, Rev. 2 .
(11) TUEC NRC-C-83-03104, Rev. 2 (12) TUEC NRC-83-03105, ,Rev. 2 .
(13) TuGC0 letter to NRC dated August 21, 1984 (14) TUEC DCA 13140, Rev. 2 1
- 10. This Statement Prepared by: ,
S. S. Kirslis Date s
Reviewed by:
Group Leader P. Mathews - Date Approved by:
Project Leader.
Date i
11/13/54 5 COMANCHE PEAK INPUT CONT s
~
G- S ' Document Name:
SSER - ELECTRICAL 1 I* Requestor's ID:
JEAN Author's Name:
Chet Poslusny Document Cc=ments:
11/21/84 Redraft AE-13,16 etc. from CPI (REV.10/2 HQ)
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, Ul-l ; 1. Allegation Grouo: Electrical / Instrumentation Category No.1 - Electrical i ; Cable Terminations
- 2. Allegation Numbers: AE-13, AE-16, AE-18, AE-22, AE-26, AQE-12,AQE-36, I
and Parts of AQE-7, AQE-8, AQE-37, AQE-39, and AQE-46. l l 3. Characterization: It is alleged that: 1 Terminal lugs of improper size and type were utilized on cables in various panels and that improper cable splices existed within certain panels (AE-13). ll Loose bus bar and ground wire connections existed in a safeguards
- i panel (AE-16).
- !t Cables were being butt spliced inside panels in violation of
- e procedures (AE-18).
.- W m
.: Cable butt splices existed in panels without authorization or without being documented on drawings (AE-22). Cable termination connections were loose and improper-sized lugs were being used on cable terminations (AE-26). Cable terminations not in conformance with drawings were accepted by quality control (QC) personnel (AQE-12). Vendor-installed terminal lugs were excessively bent (AQE-36). Certain quality assurance / quality control (QA/QC) matters related to cable terminations were improperly implemented. The general concerns expressed in these allegations are within the scope of the above allegations and are addressed below as appropriate (parts of AQE-7, AQE-8, AQE-37, AQE-39, and AQE-46). ,g. .
i l 2-i 4, Assessment of Safety ~ Sionificance:
~ .
l Samole of $afety-Related Termination Installation. Since many of the l alleged conditions identified in AE-13, AE-16, and AE-26 were located in equipment containing nonsafety-related cabling, the Technical Review Team i
- (TRT) sampled safety-related installations to determine whether similar I
l conditions existed within them. Sixteen safety-related items (control ! panels, annunciator cabinets, termination cabinets, motor control centers, l and switchgear) were inspected for the following items: ' I j Proper size lugs used relative to cable size and screw size (AE-13). ' )
- Tightness of bus bar and ground wire cennectiens and terminal lugs on terminal. blocks (AE-16).
- General workmanship for such ttoms as shaved legs, proper washtes, and bend racii (AE-26).
The TRT found no unacceptable conditions *.vith the terminations inspected. Butt Splices. Allegations AE-13, AE-18, 'nd a AE-22 concerned butt spit:es in panels that could be in violation of regulatory requirements and site procedures. The practice of butt splicing cables in panels is allowac on a limited basis, as specifed in Section 8,1.5.2.4 of Amerdment 44 tc the Final Safety Analysis Recort (FSAR). Tne NRC staff reviewed TUEC's justi-fication for permitting butt spifces inside panels (corretcordence frem M. Srinivasan, NRC, Dower Systems Branch to B. J. Youngblood, NFC, Licens-ing Branch, July 30,1984), and concluaed that the practice is acceptable on a limited basis, subjeqt .to the .following conditions:
~
That adequate provisions be included in the installation pro:edures to verify operability cf those circuits for'which splices are being used,
... . . . . . . . ...-. . _. ..__-r_ . . . . . . . . .
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That the wire splices used are qualified for anticipated service conditions, and That splices are staggered within the panel so that they are not i adjacent to each other in the same wire bundle and pressing against one another.
! The TRT inspected, in detail, numerous butt splices in safety-related panels to determine whether they were installed in accordance with the requirements stated in Texas Utilities Generating Company (TUGCO) procedure -
QI-QF-11.3-28, Revision 21, " Class IE Cable Terminations." The TRT also j interviewed one alleger to clarify one allegation concerning butt splices. 4 j These sp'iices were fcund to be in conformance with all procedural require- , ment , with the following exception. All splices inspected were missing the " nuclear heat-shrinkable cable insula + ion sleeves," as required by
. ~p iragraph 3.2.15 of the_pscedure,,for_600 volt control and instrumentation
'cc rih ~e'et.i on s . Due to this recurrent condition, the TRT reviewed the QC inspection reports for 12 butt splices and found the following: ,
Nine of these splices were documented on the inspection form des'ignated in paragraph 3.3 of the procedure for post-installation ' inspections instead of on the correct form designated for witnessing-type inspections. It should be noted that all splices were required to be witnessed by QC personnel per paragraph 3.1.d of the procedure. Six of the nine incorrect forms contained handwritten notes by the inspector indicating that he had witnessed the splice; however, no ;. reference was added to indicate that the installation of the heat- 4 shrinkable sleeves was required to be witnessed. The remaining three of the nine incorrect forms did not indicate that the splices had been witnessed.
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For three splices which were cocumented on the correct forms, the for:::s ali centain an "N/A" (not applicable) handwritten by the inspector on the line indicating that the installation of the heat-
! shrinkable sleeve was witnessed.
i Nuclear heat-shrinkable sleeves are commonly required only in "high radia-tion" areas, and their absence would constitute a condition of safety
.j significance. The butt splices inspected by the TRT were found inside control, annunciator, relay, and termination cabinets which were not l located in "high radiation" areas. Thus, the requirement to cover the splices with nuclear heat-shrinkable sleeves did not apply to them. Hew- '
l ever, as indicatea above, the TRT determined that the QC electrical _ ,,
,i inspectors did not know when installation of the heat-shrinkable sleeves i
was required to be witnessed. Should butt splices exist in enclosures in "high raciation" arsas, the absence of these sleeves would constitute a condition of. safety significance. This lack of awareness of where the ' Me~at-shrinkaole sleeves should be installed, as reflected in the QC [ ~ inspection form, when coalea with the high percentage of missed and/or t improperly documented inspecticns requiring witnessing, indicates that
\craftandinspectionpersonnellackfamiliaritywiththeseprocedural reqbirements. This apparent lack of familiarity may be indicative of poor training.r(WTElectrical/ Instrumentation Category No. 6, " Electrical QC '
'O
, pector Training / Qualification.")
[ + Nenconformance of Cabl_e Teminations with Drawin6s. Allegation AQE-12 involves DC inspectors " buying off" terminations that did not conform to drawing requirements. In view of the lack of specific information con-cerning this allegation, the TRT selected 380 cables, involving 1600 incividual terminations, and inspected them in detail with rcspect to drawing requirements. This inspection revealed that six cables (five of whicn are safety-related) were not terminatec7n accordance with currniit - drawings. Inese six cables are: ._ _ T e-U
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. _ ~
- ~. - . . . - .- - - . . . -
I 1 t <! : . j (1) E0139880 in panel CP1-ECPRCB-14, (2) E0110040 in panel CP1-ECPRTC-16, (3) E0118262 in panel CP1-ECPRTC-16, (4) NK139853 in panel CPI-ECPRCB-02 (non safety), (5) EG104796 in panel CPI-ECPRTC-27, and g (6) EG021856 in panel CPX-ECPRCV-01, t Terminal Lucs. Allegation A0E-36 involved vendor-installed Amp Product Corporation (APC) terminal lugs in ITT Gould-Brown Boyeri, 6.9 kv switch-gear being excessively bent in the area between the ring and the barrel. The TRT discovered 16 nonconformance reports (NCRs) (E-84-01066 through E-84-01081) issued early in April 1984 which documented this condition. The TRT review of TUEC action taken regarding these NCRs revealed the
.following:
The NCRs described the APC lugs either as beirig bent in excess of 50 degrees or twisted. 4 The documented record of a telephone conversation between TUEC and tne representative of the lug manufacturer (reference letter VBR-16624) states that lugs bent to 90 degrees one time are to be considered acceptable; that lugs bent to 120 degrees could be accept-l able after utilizing an engineering evaluation by the end-user; and 1 that although lugs bent to 120 degrees would not maintai.n their full mechanical strength, they would maintain their electrical character-istics. This acceptance criteria for field bent lugs was changed by APC due to the dispositioning cf NCR E-84-00972 regarding General Electric (GE) motor control center (MCC) thernal overload relay replacement program. The TRT findings regarding the closure of these NCRs were as follows: The dispositf ow block of the NCR form states that many of the lugs ' are "determised nct to pose an equipment serviceability probicm."
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However, there is no reference to or evidence of an engineering , evaluation, as required by the lug manufacturer prior to a change in the acceptance criteria on NCR E-84-00972. Only the " bent" condition of the lugs has been addressed by both the vendor representative and TUEC engineering. Neither the mechanical strength nor the electrical characteristics were ever addressed with respect to " twisted" lugs.
~'
These NCRs have been improperly closed in that the full scope of the 1.dentified problem was not addressed and the "use-as-is" dispositions were nut adecuately justified.
- 5. Conclusions and Staff Positions: The TRT concludes that significant safety concerns e,xist in the following areas relative to cable terminations:
The adequacy of butt splices in safety-related panels (AE-13, AE-18
& AE-22).
The acceptability of vendor-installed terminal lugs in ITT Gould-Brown Boveri switchgear (AQE-36). s. Safety-related terminations which are not in conformance with current \. drawings (AQE-12). g/)' T_heA;e.cy of QC inspection and supporting documentatien, parti- i, cularly with respect to termination activities requiring witnessing f by QQ personnel (A0E-12 & AQE-18). e S. Actions Required: TUEC shali accoinplish the following actions prior to fuel load: (1) Reevaluate.and redispositten all NCRs related to vendor-installed r ~ ---- .. terminal lug Tin ATT'G5?iTd-Brown i~o7Eri soi whgear taking into con-sideration the effects of twisted as well as bent lugs, and perform 7,,_ , . . . ._
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A ~ .g , ; _..;3 L,U b us @ C- J C. Q A.r . - - Ed m a e, & , - t e ,.Yc-[ #( d c%. 4.. . ... and document the results of engineering analyses to justify any re_sulting "use-as-is" dispositions.
,/4.: .:i (2) Develop adequate installation / inspection procedures to ensure the operability of those circuits which contain butt splices in panels to ensure that the wire splicing materials and methods used are qualified for anticipated service conditions, and to ensure that splices are staggered within the panel so that they are not adjacent to each other in the same bundle.
(3(Reinspec+ s all safety-related and associated terminations in the con-trol. room and in the termination cabinets in the cable spreading room. This shall be done in accordance with all current design documents to ensure that terminations are in accordance with design requirements. TUEC shall sub. nit the results of this reinspection to the NRC for review. Should the results of this reinspection reveal an unaccept-able level of nonconformance to drawing requirements, the scope of this reinspection effort shall be expanded to include all safety-related and associated terminations at Ccmanche Peak, Units 1 and 2. (4) Physically identify all butt splices in panels; clarify procedural requirements with respect to the areas in which nuclear heat-shrinkable sleeves are required on splices; ensure that such sleeves . are installed where required; ensure that all QC inspections - . - requiring witn.e.isisfca splices baye been performed and properly documented;.. . and, in view of the previously stated dtficiency concerning compliance
. with drawing requirements, ensure that all butt splices are properly identified on the appropriate cesign drawings, i.e., wiring diagrams.
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,8. Attachments: None. -w , . . .
9 _ \
- 9. Reference Occuments:
- 1. Comanche Peak Steam Electric Station (CPSES) FSAR, Section 8,
- 2. Procedure QI-QC-11.3-28, Revfsien 21, " Class IE Cable Terminations."
l
- 3. Nonconformance Reports E-84-01066 through E-84-01081.
- 4. QC Inspection Reports: ET-1-0005396 ET-1-0005395 ET-1-0005394 ET-1-0007162 l ET-1-0005393 ET-1-0006776 ET-1-0014790 ET-50419 ET-51218 {
ET-51217 ET-33666 ~. ET-33669 1 75 . . . . . , . . . . . . . . . . . . . . . . . . -
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.. 9
- 5. Drawings: 2323-El-0171-02, Revision CP-1 2323-El-0171-04, Revision 11 2323-El-0172-16, Revision CP-2 2323-El-0172-27, Revision CP-3 2323-El-0174-12, Revision CP-1
, 2323-El-0172-02, Revision CP-1 i !! 2323-E-1-0174-01, Revision 18 l 2323-El-0174-03, Revision CP-4 l 2323-El-0159, Revision CP-3 I 6. Design Change Authorization DCA-19264, Revision 2 y
- 7. Correspondence from M. Srinivasan, NRC, to B. J. Youngblood, NRC, d July 30, 1984 1
ti
- 8. IEEE Std. 420-1973, "IEEE Trial-Use Guide for Class 1E Centrol Switchboards for Nuclear Power Generating Stations."
- 9. NRC Regulatory Guide 1.75 Revision 2, " Physical Independence of Electric Systems."
- 10. NRC Investigative Report 50-445/82-29 and 50-446/82-15, December 21, ,
1982.
- 11. NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5, 1981.
- 12. NRC Inspection Report 50-445/83-24 and 50-446/83-15, August 19, 1983. '
- 13. TUGCO, et al., Hearing before ASLB, September 15, 1982, page 4871-4877.
14 Confidential Affidavit of GAP Witness (Paragraph 6), June 27, 1984. W
- 15. GAP Notes of April 1984 (Confidential), GAP Witness H, Paragraphs 6 and 16. '
m
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- 16. NRC Inspection Report 50-445/30-16.
l
- 17. CASE letter to NRC, Region IV, August 4, 1982.
- 18. Deposition of GAP Witness H (In Came'ra) TUEC's Discovery Deposition, Voltme II, July 20, 1984, Pages 339-564.
- 19. Initial Deposition, Telephone Conversation with GAP Witness H, July 31,1984,
- 20. NRC Special Review Team Report, July 13, 1934.
} 21. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on i Issues Resulting From Interviews with Electrical Inspectors," May 22, 1984.
- 22. Deposition of GAP Anonymous Witness, July 25, 1984, Pages 58,503-58,591.
- 23. Deposition of GAP Witness, July 16, 1984, Pages 53,003-53,263.
- 24. NRC RIV Summary of Comanche Peak Open Issues Tracking System, July 13,1984.
L
- 25. NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18, 50-446/83-12, April 11, 1983.
- 26. TUGCO, et al., Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; (June 13, 1983, Pages 7733-7755; June .
15, 1983, Pages 8160, 8231, 8261-5263; June 16, 1983, Pages 8358, 8367, 8368-8373.
- 27. NRC Interview with SRT Alleger A-3, September 6, 1984, Pages 17-27, 30-43, 75-79, 91, 92.
,7 . .
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- 10. This Statement Prepared by: i William S. Marint Date TRT Reviewer .
Reviewed By: Jose A. Calvo Group Leader. Date Approved Ey: Vincent S. Neonan Project Director Date- , s I W ' l 1 1 1 g.
Document Nam:: SSER 2 ELECTRICAL
.- Requestor's ID:
IRENE Author's Name: A. Vietti/kb Document Comments: 11/16/84 Redraft 11/2 space
. . . . . . . . - - . . = . - . - - = - - . - + - = * * - + - + = . . - - - - ~ ~ * * * * = = + + e - ~ ~ ~ -- - -' *
- h
~
- 1. Allegation Grouo: Electrical / Instrumentation Category No. 2 - Electrical Cable Tray and Conduit Installation
- 2. Allegation Number: AQE-10, AE-14, AE-27, AE-29, AE-31, AH-14, and
^ Parts of AQE-3, AQE-4, and AE-24 _
- 3. Characterization: It is alleged that, in general, there were problems wi +.h :
The design . changes on cable tray supports (AH-14). The addition of higher sices to cable trays (/.5-29). ' The clearance of process pipes from cabl.es in cable trays (AE-31). / Loose conduit fittings (AE-27). - The training of personnel installing cable tray supports (AQE-10). , The cable tray attachments to the seism'ic supports (AE-14, AH-14). The spacing of the seismic supports for cable trays (AH-14j. ' The material traceability for cable traf supports (AH-14). o
- 4. Assessment of Safety Significance: The Technical Review Team (TRT) ceter-mined that the first two concerns (changes on cable tray supports and the ,
acdition of higher sides to cable trays) related to,whether the positions .j of Regulatory Guide 1.29, " Seismic Design Classification," as. augmented by Final Safety Analysis Report (FSAR) Section-5.2, were considered by the Texas Utilities Electric Company (TVEC) during design of the support system for both safety-related and nonsafety-rel,ated cab'le trays.
, l The TRT examined cable tray support installation notes and detail drawings, design change authorizations (DCAs), work packages, physical configuration i drawings, and other documents pertinent to its sampling of 29 supports in 3 ,
{i p the Safeguards, Auxiliary, and Control BuildiMgs. The TRT und no M
/ ."'t significantproblemswithinstallationofth'esupports.fTheTRTalso.
e evaluated a sample of cable trays in the cable spreading room to assess
. -d(
the concern about the higher cable tray sides. This evaluaticn and its gv
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conclusions are presented in Electrical Instrumentation Category No. 7,
" Electrical Cable Installation." ?
I i The third concern was the process pipe-to-cable-tray clearances as outlined in Gibbs & Hill (G&H) electrical specification 2323-ES-100,
, as amended by DCA 13045 and DCA 15917. The TRT conducted a walkdown inspection of approximately 2500 feet of cable tray in the auxiliary building and identified 16 cases that appeared not to meet installation guidelines set forth in the specification. The TN Eaniined the DCAs pertaining to each of the 16 cases and determined that the guidelines had ! been met or were currently in the process of being met for all 16 cases.
t i The fourth concern was the "use-as-is" d sposition on a nonconformance - report (NCR) which reported two 1.cos onduit elbow fittings on the south and east end of the Unit 1 diesel generator, i v ' , .,.o
- 6. f g.;.
3
,. The TRT inspected the Unit .1 diesel generator conduit and found two <
- e, , .wt
~ . _ y_,-
l loose fittings. However, the TRT determined that the function of the tcid ,, l cables within the fittings is of secondary importance to operation of C' l M '", - l the diesel generator and the loose fittings would not prevent the cables y- l 9 ,
! from performing their intended function.
The fifth concern was the lack of training of personnel._ _insta.l._ ling cable ..
.- -tray supports. The TRT interviewed craft personnel, craft supersisors, and training personnel to determine the availability and effectiveness of the training program and found that there was a training program for newly .- .-.
hired personnel or transfers
~
..e installation 4h included ceriodic briefings on procedure anges. This program did not, at' rst, appear ,\
to be effective be-tuse 7 of the 11 crew members interviewec were not i cognizant of Man al 2323-S-0910, " Conduit and Junction Box Supports," j which is the pr
' mary reference manual for installation of y6pports.
owever, the[e DTrew members'had no 'need to ' Utilize 4his manual ~on ir job assign, ents. - -
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The sixth concern was that cable tray attachments to the seismic supports were not being installed according to design. The TRT inspected 60 cable tray attachments in the Safeguards Building and did not find any unaccept-able cable tray attachments in the sample. ] g ' M The seventh and eighth concerns was that the designed spacing of the f .s -. ; (seismiccabletraysupportswasnotadheredtoduringconstructionand}. .
./ .' hat the supports _did not have proper material f.raceability. The TRT + /
,, / conducted a walkdown inspection of seismic cable tray supports in the 3 /t / , &y e Safeguards and Auxiliary Buildings and compared the installed cable tray
.?e .,, i support spacing with the designed support spacing, including material i O 7 1 traceability for the supports. Two deviations were located out of 40 ,Cm
[f, , examples inspected, and TUEC engineering was asked to provide the analyses W
# for these two deviations because they were outside the. design.e.d sypp_qrt spacing. The TRT reviewed the analyses and found them acceptable.
- 5. Conclusions and Staff Position: Based on the review of. engineering drawings and direct inspection of the installation, the TRT found no indications of construction contrary to commitments made in the FSAR Section 3.2. The clearance requirements set forth in G&H electrical specification 2323-ES-100, as amended'by DCA 13045 and DCA 15917, have
/ / been met in every case identified during the walkdown inspection. The
, S TRT found no problems with cable tray attachments to seismic y ppor,ts, _
. nding which agrees with NRC Region IV investigation findings on this '
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i yb_.iect in. Inspection _Re. port (IR) 50-445/83-52. , The TRT determined that ( (% ~ ~ - ~ ~ the cable tray support spacing met design requirements and had proper material traceability, except for two deviations that were analyzed by the TRT and found to be acceptable.
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v{'O^ ' " pu 50+ w. 2 , .~ (. e . c. , SJ M '" M$k.. . Based on the inspection of the installations and reviews 6f pertinent7 - drawings, the TRT concludes that the allegations, as presented, have ' neither safety significance nor generic implications.
- 6. Actions Recuired: None.
1 7, . . . . . . . . .. . _ . . .. .. _ . . , . . . . . , _ _ . . , , , ,
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- 8. Attachments: None.
- 9. Reference Documents:
- 1. Regulatory Guide 1.29, " Seismic Design Classification."
- 2. Comanche Peak, Units 1&2, FSAR Section 3.2.
- 3. G&H Specification No. 2323-ES-100, Revision 2, " Electrical Erection Specification."
- 4. RIV Inspection Report 50-445/83-52.
- 5. DCA 13045 and DCA 15917.
- 6. G&H Specification 2323-S-0910, " Conduit and Junction Box Supports."
- 7. Drawing 2323-El-602-01-S, " Safeguard Bldg Cable Tray Support Plan."
- 8. Drawing 2323-El-701-01-S, " Auxiliary Bldg Cable Tray Support Plan."
- 9. Drawing 2323-S-0901-sheet (sh) 1, " Cable Tray Supports."
10 Drawing 2323-S-0902-sh 2, " Cable Tray Supports."
- 11. Drawing 2323-S-0903-sh 3, " Cable Tray Supports."
- 12. Drawing 2323-S-0904-sh 5, " Cable Tray Supports."
- 13. Drawing 2323-S-0916-sh 15, " Cable Tray Supports."
- 14. Drawing 2323-S-0930-sh 28, " Cable Tray Supports Alternate Heavy Duty Tray Clamp Details."
- 15. Drawing FSE-00187, " Safeguard Bldg Cable Tray Support Plan EL 810'-6 inches."
- 16. Drawing FSE-00188, " Auxiliary Bldg Cable Tray Support Plan El 810'- 6 inches."
- 17. Drawing FSE-00214, " Auxiliary Bldg Cable Tray Support Plan EL 807'-0 inches."
- 18. Drawing FSE-00159-sh 1317, " Safeguard (SFGD) Bldg Cable Tray Hanger Assembly (Assy)."
- 19. Drawing FSE-00159-sh 925, "SFGD Bldg Cable Tray Hanger Assy."
- 20. Drawing FSE-00159-sh 1109, "SFGD Bldg Cable Tray Hanger Assy."
?. s ..5.s= . ,
- 21. Drawing FSE-00159-sh 1080, "SFGD Bldg Cable Tray Hanger Assy."
- 22. Drawing FSE-00159-sh 1070, "SFGD Bldg Cable. Tray Hanger Assy."
i
- 23. Drawing FSE-00159-sh 1047, "SFGD Bldg Cable Tray Hanger Assy." ,
f 24. Drawing FSE-00159-sh 5553, "SFGD Bids Cable Tray Hanger Assy." j 25. Drawing FSE-00159-sh 904, "SFGD Bldg Cable Tray Hanger Assy." i
- 26. Drawing FSE-00159-sh 1076, "SFGD Bldg Cable Tray Hanger Assy."
- 27. Drawing FSE-00159-sh 912, "SFGD Bldg Cable Tray Hanger Assy."
i 28. Drawing FSE-00159-sh 1048, "SFGD Bldg Cable Tray Hanger Assy."
- 29. Drawing FSE-00159-sh 1313, " Aux Bldg Cable Tray Hanger Assy."
- 30. Drawing FSE-00159, sh 12454, " Aux Bldg Cable Tray Hanger Assy."
- 31. Drawing FSE-00159, sh 5326, " Aux Bldg Cable Tray Hanger Assy."
- 32. Drawing FSE-00159, sh 1316, " Aux Bldg Cable Tray Hanger Assy."
- 33. Drawing FSE-00159, sh 13062, " Aux Bldg Cable Tray Hanger Assy."
- 34. Drawing FSE-00159, sh 13193, " Aux Bldg Cable Tray Hanger Assy."
- 35. Drawjng FSE-00159, sh 5335, " Aux Bldg Cable Tray Hanger Assy."
- 36. Drawing FSE-00159, sh 4237, " Aux Bldg Cable Tray Hanger Assy."
- 37. Drawing FSE-00159, sh 4210, " Aux Bldg Cable Tray Hanger Assy."
- 38. Drawing FSE-00159, sh 1296, " Aux Bldg Cable Tray Hange' As'sy."
- 39. Drawing FSE-00159, sh 3918, " Aux Bldg Cable Tray Hanger Assy."
- 40. Drawing FSE-00159, sh 6477, " Aux Bldg Cable Tray Hanger Assy."
- 41. Drawing FSE-00159, sh 4114, " Aux Bldg Cable Tray Hanger Assy."
- 42. Drawing FSE-00159, sh 4115, " Aux Bldg Cable Tray Hanger Assy."
- 43. Drawing FSE-00159, sh 4116, " Aux Bldg Cable Tray Hanger Assy."
- 44. Draw'1g FSE-00159, sh 4117, " Aux Bldg Cable Tray Hanger Assy."
- 45. Drawing FSE-00159, sh 4352, " Aux Bldg Cable Tray Hanger Assy."
- 46. Drawing FSE-00159, sh 4368, " Aux Bldg Cable Tray Hanger Assy."
- 47. NRC OI Report 4-83-013, November 3,1983, Page 8, Paragraph 3 and 4.
- 48. NRC Inspection Report 50-445/83-52, February 21, 1984.
- 49. NRC Report of Inquiry No. Q4-83-023, September 20, 1983.
- 50. NRC Report of Inquiry No. Q4-83-021, August 29, 1983. ;
- 51. GAP Notes of April 1984 (Confidential) Paragraph 33, GAP Witness Anonymous and Paragraph 4, GAP witness C.
- 52. NRC Special Review Team Report, July 13, 1984.
~
- 53. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on Issues Resulting From Interviews with Electrical Inspectors,"
May 22, 1984.
- 54. NRC RIV Summary of Comanche Peak Open Issues Tracking System, July 13,1984.
- 55. NRC Interview with SRT Alleger A-3, September 6, 1984, Pages 49-50.
- 10. This statement prepared by:
~
George N. Myers Date TRT Reviewer Reviewed by: Jose A. Calvo Group Leader Date Approved by: Vincent S. Noonan Project Director Date l f
.....-,-...........-......_...J...._'.......... . .. . . . , .,
Document Name: SSER - ELECTRICAL 3 Requestor's ID: JEAN Author's Name: A. Vietti/kb , Document Com.ents: 11/15/84 Redraft I space t
- g. .n . . . - . - . . - . . .
. . . - - . . - . ~ - - . . . . . . . . . . . . - - . . . . - -
- 1. Allecation Grouo: Electrical / Instrumentation Category No. 3 -
Electrical Equipment Separation
- 2. Allegation Numbers: AQE-6, AQE-11, AE-15, AE-20, AQE-49, AE-51, AE-53, AQE-54 and Part of AQE-44.
- 3. Characterization: It is alleged that the:
Installation of safety-related cables and conduits inside the reactor control panels in the main control room did not conform to the cable separation criteria (AE-15). Separation between independent safety-related cable trays and con-duits, and between them and nonsafety-related trays and conduits,.in the cable spreading room did not conform to the positions set forth in Regulatory Guide (RG) 1.75, " Physical Independence of Electric Systems." It is also alleged that the separation requirements set forth in Gibbs & Hill (G&H) specification 2323-ES-100, " Electrical Erection Specification," applicable to the cable installation in the cable spreading room was inconsistent with the separation criteria documented in the Institute of Electrical and Electronics Engineers (IEEE) Standard 384-1974, "IEEE Trial-Use Standard Criteria for Separation of Class 1E Equipment and Circuits," as augmented by RG 1.75 (AE-20). Ladder type cable trays did not quality as acceptable barriers; therefore, the 1-inch minimum separation criteria between separate trays and conduits routed under the trays are not applicable (AQE-54). Nonconformance Report (NCR) E-84-007095 concerning the separation I between conduits ESB1-4 and C14K30975 was corrected without approved conduit bending equipment (AE-53). l l
... . . . . . . . . . - - - - - . . -~v ~.--~~~~~.--.~.~~e.* - - - -
- j-
.- _2_
Post-construction inspection of electrical equipment and raceways in i' the fuel building revealed a deficiency concerning cable separation which was dispositioned "used-as-is" (Part of AQE-44). Conduit 22G06343 was about 3 feet below cable tray T130CCP38 located l: in th'e control room building at the 854-foot elevation (AE-51).' i.
- , Inspection of the separation of cables did not follow established C
procedures (AQE-6); quality control (QC) inspection acceptability l regarding separation of equipment was compromised due to the needs of production management (AQE-11); and, in numerous cases, of rework was done with regard to separation (AQE-49). These allegations expressed, in very general terms, concerns with cable separation and did not specifically identify the location of problem areas in the facility. This discussion will focus.on the installation aspects of cable separation brought by these allega-
- tions. Quality assurance / quality control (QA/QC) matters raised by
} these allegations are addressed under Electrical / Instrumentation Category No. 8, " Electrical Procedures," and Electrical /Instrumenta-3 tion Category No. 6, " Electrical QC Inspector Training / Qualifications."
- 4. Assessment of Safety Significance:
1 Control Room Panels. The criteria governing the separation of cables inside panels are stated in Section 5.6.2 of IEEE Standard 384-1974, which j is endorsed by RG 1.75. As documented in Sections 7.1.2.2 and 8.3.1.4 of the Final Safety Analysis Report (FSAR), Texas Utility Electric Company (TUEC) is committed to provide a cable installation which is in accordance with IEEE Standard 384-1974, as augmented by RG 1.75.
/
i Section 5.6.2 of IEEE Standard 384 states, in part, that the minimum separation distance between redundant Class IE equipment and wiring , internal to the control switchboards (panels) can be established by i
- .-- .. _ .-- -- ~ - , _ .. - - ._.. - - - -
j'.
~~-
}
i
.- 1 analysis of the proposed installation. Where the control switchboard 5
materials are flame retardant and analysis is not performed, the minimum separation distance shall be 6 inches. In the event these separation i distances are not maintained, barriers shall be installed between re-f dundant Class 1E equipment and wiring. The criterion specifying a 1-inch j separation between redundant conduits which are considered enclosed raceways is stated in Section 5.1.3 of IEEE Standard 384. i The Technical Review Team (TRT) examined the electrical erection specifi-cations, cable and raceway separation engineering drawings, design change authorizations ~(DCAs), work packages, and other documents pertinent to the separation of cables, conduits, and devices inside the main control room panels. The TRT also inspected cables, flexible conduits, tarmina-tions, and devices inside six safety-related panels to determine ~that this equipment was installed in accordance with established separation requirements. In addition, the TRT inspected the separation of cable trays and rigid conduits entering the bottom of the panels from the cable spreading room. The TRT found that the minimum 6-inch air gap or fire retardant barrier between redundant Class 1E panel-mounted devices (including their cable or wire connections) and nonsafety related devices and their connections q was maintained in all six panels inspected, except for one isolated case h[ where a fire-retardant barrier had been removed. The devices involved were FI-2456A, PI-2453A, PI-2475A, and IT-2450, associated with train A, and FI-2457A, PI-2454A, PI-2476A, and IT-2451, associated with train B. These devices were located in the auxiliary feedwater panel no. CP1-EC-PRCB-09. The TRT also found in panel CP1-EC-PRCB-03, adjacent to the six panels inspected, another isolated case of redundant safety related field wiring g7,. I not being separated by either the 6-inch minimum distance or by a barrier. The field wiring was associated with devices HS-5423 (train B) and HS-5574 [D
l. i .- . (nonsafety- related). In regard to the separation of cable trays and I rigid conduits entering the bottcm of the control room panels, the TRT g found no deficiencies. i i The TRT found several instances where (1) redundant safety-related flexi- \s ble conduits inside the panels were in direct contact with each_other and \
! (2) safety and nonsafety-related flexible conduits inside the panels were also in direct contact with each other. The TRT also found various cases where safety and nonsafety-related cables were in direct contact with '
f safety-related cables within flexible conduits associated with the other l redundant train inside the panels. These are identified in Table 1. t 1 Table 1 Cases of Safety or Nonsafo.ty-Related Cables in Lantact with Other Safety-Related Conduits in Control Room Panels
- 1. Control Panel CP1-EC-PRCB-02: Containment Spray System Cable No. Train Related Instrument EG139373 B (green) Undetermined E0139010 A (orange) Undetermined
- 2. Control Panel CP1-EC-PRCB-07: Reactor Control Cable No. Train Related Instrument EG139383 B (green) Reacter manual trip switch E0139311 A (orange) Undetermined E0139310 A (orange) Undetermined EG139348 B (green) Undetermined 7,,, . . . - . _ , _ _ _ . . . . . . . . _ . . .
., Table 1, continued
- 3. Control Panel CP1-EC-PRCB-06: Chemical & Volume Control System Cable No. Train Related Instrument EG139335 8 (green) LCV-112C E0139301 A (orange) Undetermined E0139305 A (orange) LCV-112B NK139605 Nonsafety CSALB-LAB (in bundle)
- 4. Control Panel CP1-EC-PRCB-09: Auxiliary Feedwater Control System Cable No. Train Related Instrument E0139753 A (orange) FK-2453A E0139754 A (orange) FR-2453B EG139756 8 (green) FK-2454A EG139288 8 (green) FK-24548 EG145780 B (green) FK-2454A EG145781 8 (green) FK-2460A A0138622 A (orange Assoc.) HS-2452a/H NK139647 Nonsafety HS-2383
- 5. Control Panel CP1-EC-PRCB-08: Feedwater Control Cable No. Train Related Instrument EG140309 B (green) PK-2324 EG139757 8 (green) PK-2328 NK13957 Nonsafety HS-211A The TRT discussed with TUEC and G&H representatives the apparent violation of the required 1-inch separation between separate flexible conduits and 6-inch separation between separate cables and cables within flexible con-duits inside the panels. TUEC and G&H representatives indicated that l
. . . . . . . . - . . . . - . . . . . . - - . . - - - - . ~ ~ . . - . ---- - -~
, redundant flexible conduits in contact with each other are permitted, as indicated in the cable and raceway separation typical details drawings, but cables in contact with cables within flexible conduit are not per-mitted. However, the TRT brought to the attention of the TUEC and G&H j
representatives that this type of conduit installation is permitted by ' Section 5.6.2 of IEEE Standard 384 if such installation can be substan- X tiated by analysis. The TRT considers the apparent discrepancies described above to be a deviation from the engineering drawings and
~
/
inconsistent with regulatory requirements. Cable Screadino Room. The criteria governing the separation of redundant safety-related cable trays and conduits in the cable spreading room are stated in Section 5.1.3 of IEEE Standard 384-1974, as augmented by RG 1.75. IEEE Standard 384 states, in part, that the minimum separation distance between redundant Class 1E cable trays in the cable spreading area can be determined by analysis of the proposed cable installation or, where the conditions of Section 5.1.1.3 are met (which defines an accep. table tray system), there shall be 1 foot between trays separated horizontally and 3 feet between trays separated vertically. Where the minimum separation distance cannot be met, the redundant circuits shall be run in enclosed raceways that qualify as barriers, or other barriers shall be provided between redundant circuits. The minimum distance between these redundant enclosed raceways and between barriers and raceways shall be 1 inch. The TRT compared these criteria to the requirements set forth in G&H electrical erection specifications and engineering drawings, concerning cable tray and conduit separation in the cable spreading rocm, and identified no deviations. The TRT also examined DCAs, work packages, and other documents pertinent to this issue. In addition, the TRT directly inspected the installation of numerous cable raceways and five termination cabinets in the cable spreading room. The TRT found no deviations from separation requirements i in the cable raceways and termination cabinets inspected. 1 i ,. . . . . . . . . . . . . . . . - - . - . - - - . - - - - - - - - - - - . . ~ - - - - - - - - -
.- Fuel Buildino Area. The TRT inspected-the cable separation installation in the fuel building area and found that most of the cable trays and con-duits were designated as nonsafety-related. The only safety-related l, electrical equipment installation in the fuel building area that needed to satisfy separation requirements was associated with the spent fuel system. The TRT found that redundant spent fuel system equipment was located in separate adjacent rooms, except for a common control panel.
i After examining the separation of cable rac'e ways in the fuel building } area and terminations, cables, wires and devices inside the common l control panel, the TRT found no deviations from separation requirements. Potential Harsh Environment Areas. The TRT examined cable separation I installations in those areas of the plant where a high-energy line break could compromise the independence of redundant safety-related equipment. TUEC's damage study group performed studies to determine the need to pro-tect equipment, including cable raceways, that could be affected by a high-energy line break. Jet shields were installed to protect safety-related raceways, as required. In the areas where the installation of jet shields was not possible, the affected cable raceways were to be rerouted. The TRT inspected two typical jet shield installations located in the chemical and volume control system (CVCS) piping and valve area and steam generator blowdown area and found that cable separation in these two areas was in accordance with IEEE Standard 384-1974, as augmented by RG 1.75. Remote Shutdown and Transfer Switch Panel Areas. The TRT reviewed engineering drawings and electrical erection specifications pertinent to the separation of the safety-related equipment located inside the remote
)
shutdown and transfer switch panels. The TRT also inspected the cables, ( wires, and devices (including their cables and wire connections) inside ' these two panels, and cables entering the top of the panels to determine that this equipment was installed in accordance with established separa-tion requirements. The TRT found no deviations from separation require-ments in these two panels.
.... . . ..... ......_ ._. ... -..-. .. _ .-.... ...- ~. _ . - .- .
a . j . l 8. l
. In regard to NCR E-84-007095, concerning the separation between two specific conduits located in the Unit 1 safeguard area, which was established by bending the concuits with unapproved bending equipment, j
the TRT determined that both conduits were nonsafety-related and the NCR I was dispositioned "use as is."
}
Electrical Erection ~oecification for Seoaration Criteria. The criteria set forth in IEEE Standadr 384-1974, as augmented by R. G. 1.75 and Sec-tions 7.1.2.2 and 8.3.1.4 of the FSAR have been evpressed in specific
'{ terms in the G&H specification 2323-ES-100, " Electrical Erection l Specification."
t i It is alleged that the requirements set forth in this specification governing the separation between independent trays and rigid conduits is inconsistent with the criteria stated in IEEE Standard 384-1974, as avg-mented by R. G.1.75, par cicularly, when ladder type trays and conduits were used as barriers to maintain 1-inch minimum separation between separate trays and conduits routed under the trays. During its assessment of tnis allegation, the TRT found a requirement in the electrical erection specification that permitted nonsafety-related rigid conduits to have a minimum separation of 1-inch from the top of open safety-related trays. This requirement also appeared to be inconsistent with the aforementioned standard and guide. The TRT determined that no information was included in the FSAR that sub-stantiated these two apparent inconsistencies in the electrical specifica-tions with respect to the IEEE Standard 384-1974 and RG 1.75. However, the TRT found, and performed a cursory review of, a G&H analysis including test results for establishing the requirements set forth in specification 2323-ES-100 for separation between conduits and trays (G&H memorandum EE-863, January 17, 1984, " Cable Tray Conduit Separations"). In essence, the analysis concluded that the characteristics of rigid conduits are such that it constituted an acceptable barrier by itself between the cables inside the conduit and cables inside ladder or open-type trays.
. . . . . . . . . . - . . . . . - - . . - . . . . - - - ~ - - - ~ - - - - - - - - - - -
.. Based on the review of electrical specifications, engineering drawings and analyses, inspection reports, precedures, and other pertinent docu-ments, and direct inspection of the installation of cables, conduits, cable trays, terminations and panels in the main control room, cable I , spreadirg room, fuel building area, potential harsh environment areas, l and remote shutdo.<n and transfer switch panel areas, the TRT determined j that in general the requirements set forth in IEEE Stancard 384, as avg-j mented by RG 1.75 and Chapters 7.and 8 of the FSAR, have been satisfied in the areas inspected except for the following items:
i The TRT could find no evidence that an analysis was performed to l support the practice that allows certain suparate safety and nonsafety related flexible conduits inside control room panels to be in direct contact with each other or be separated by less than 1 inch, as required by Section 5.6.2 of IEEE Standard 384. The TRT determined that the installation of certain safety or nonsafety-related cables inside control room panels, which were in direct contact with safety related flexible conduits associated with the other redundant trains (see Table 1), was inconsistent with the engineering drawings and regulatory requirements. Because the acceptability of the flexible conduit as a barrier had not been established by analysis, as required by Section 5.6.2 of IEEE Standard 384, the cables must be separated frcm the conduits inside 3 the panels by a minimum distance of 6 inches, as required by Scction 5.6.2 of IEEE Standard 384. The TRT considers the missing barrier (used to separate redundant devices in the auxiliary feedwater panel CP1-EC-PRCB-09) and the field wiring not being separated by the required 6 inches (inside panel CP1-EC-PRCB-03) to be isolated cases of nonconformance requiring corrective action but having no generic implications.
i The TRT could find no evidence that the G&H analysis for establishing the criteria for separation between rigid conduits and cable-trays, stated in the G&H Electrical Erection Specification 2323-ES-100, had been evaluated by the NRC staff for Comanche Peak Steam Electric Station (CPSES).
- 5. Conclusions and Staff Positions: The TRT concludes that the installations meet established separation requirements, except for certain safety and nonsafety-related cables and flexible conduits inside control room panels which did not meet minimum separation. requirements. The TRT could find p s no evidence that the lack of separation was justified by analysis. The L. ,
TRT also concludes that in the absence of analysis to substantiate the W 'j ' lack of minimum separation between separate feixible conduits inside the s
,Y #
a'in control room panels, the existing design arrangement is in violation '
,of regulatory requirements. Furthermore, the lac,k of separatior. in the n[' /g? '& installation of certain cables and flexible conduits is also inconsistent g( with TUEC's engineering drawings, and documents. Accordingly, both y, concerns have safety significance.
,/
The TRT also concludes that installation of cables and flexible conduit.s inside the panels that do not meet minimum separation requirements and have not been justified has potential generic implications. TUEC shall coiidUIditTieili'est.o determine if this practice was followed in other . areas of the plant. ,- - ' ', ;._
},.. ,
A " / Y.gi,e xm . e:. .: . - 6' lb.<- .w. d** ' In regard to the crit'eria for separation between rigid conduits' ar.d cable g...' trays stated in G&H specification 2323-ES-100, the TRT concludes that
, ,) w arialyses had been performed by G&H to substantiate the acceptability of *~
thesa criteria. TUEC must submit these analyes to the NRC so an indepen-dent assessment of how these criteria were established can be made.
- 6. Actions Required:
TUEC shall accoropibh the following actions prior to fuel load:
. . . -. . . . . - ~ , - - . . . , - - . - - . . - - - - . . . - . ~ - - . . ~ . . - -
7% (.a)(Reinspect)allpanelsatComanchePeak,inadditiontothoseinthe r - main control rocm, Units 1 and 2, that contain (1) redundant safety-related conduits, or (R) safety and nonsafcty related conduits. TUCC onali either correct each vio'lation of the separation criteria, i or demonstrate by analysis the acceptability of the conduit as a ' barrier for each case wnere the minimum separation is not met. This analysis shall be accomplished in accordance with the requirements specified in Section 5.6 2 of IEEE Standard 384-1974. Furthermore, I in the event that the acceptability of the conduit as a barrier l cannot be demonstrated, TUEC shall correct the engineering drawings and relateti documents to indicate the revised minimum separation of conduits inside the panel for each case. (b) Either correct each of the violations of separation criteria con-cerning separate cables and cables within flexible conduits found in
- contact with each other inside main control room panels (Table 1) ,
i or demonstrate by analysis the adequacy of the flexible conduit as a barrier. TUEC shall also 1 remaining panels containing # 4 separate cablei and cables wil6fH~fTeif ble~ cd'nduit~and'shall' take" the same corrective actions as those outlined for the cases listed 1 in Table 1. This analysis shall be accomplished in accorcance with Section 5.6.2
- of IEEE Standard 3S4-1974. In the event that the acceptability of t
the conduit as a barrier cannot be demonstrated, TUEC shall separate cables and cables within flexible conduits by a minimum distance of - 6 inches, as required by Section 5.6.2 of IEEE Standard 384. Fur- , thermore, TUEC shall correct all appropriate drawings and documents to indicate the revised minimum separation. (c) Take corrective measures to secure the barrier in the auxiliary feedwater panel cpl-EC-PRCB-09 separating redundant flow and pressure instruments. i l
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i '* j t* l ( N,) , w ' W< l V~ - m :., d c c T .Gd.!. O ~~'! J ' : i (d) Take corrective action to ensure that the required minimum separation I r
, of the redundant field wiring identified inside panel CP1-EC-PRCB-03 is maintained either by distance or by an acceptable barrier.
I (e) Submit to the NRC the analyses substantiating the acceptability of l the criteria stated in G&H electrical erection specification govern- l i ing the separation between separate conduits and cable trays. These analyses shall be supported with the necessary documentation in I i sufficient detail to perform an independent evaluation of how these { criteria were established based on the analyses.
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- 8. Attachments: None. i l
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- 9. Reference Documents:
I I 1. Regulatory Guide 1.75, Revision 2 " Physical Independence of Electric
. Systems"
- 2. IEEE-384-1974 "IEEE Trial- Use Standard Criteria for Separation of i Class IE Equipment and Circuits"
- 3. Comanche Peak, Units 1 and 2 FSAR, Section 7.1.2.2, " Independence of Redundant Safety-Related Systems" and Section 8.3.1.4, " Independence of Redundant Systems" i
- 4. G&H Specification No. 2323-ES-100, Revision 2 " Electrical Erection
! Specification" t
- 5. G&H Drawing No. 2323-El-1702-02, Revision 2, " Cable and Raceway Separation Typical Details" i
- 6. Drawing No. 2323-El-1701, Revision 11, " Conduit Cable Tray Legend,
, General Notes and Typical Details"
- 7. G&H Specification 2323-MS-38H, " Fire-Retardant Barriers and Materials"
- 8. Nonconformance Report No. E-84-007095
- 9. Design Change Authorization No. 8830, October 22, 1983,
" Specification 2323-ES-100, Revision 4" 10 Design Change Authorization No. 13,435, Revision 2, " Specification 2323-ES-100, Revision 1"
- 11. G&H Memorandum EE-863, January 17, 1984, " Cable Tray Conduit Separation" _
r i
- 12. NRC Inveatigative. Report 50-445/81-04 and 50-446/S1-04, May 5, 1981.
- 13. Depositio; of GA,p-Witness H (in Camera) TUEC's Discovery Deposition, I
Volume II, Ju]y 20,1984, Page 419; Page 10 and 12 of Affidavit. j 14. Deposition of SRT r.tness A-5, July 17,1984, Pages 55G32-55033. ' I I .
- 15. GAP Notes of April 1984 (confidential), Paragraph 7, GAP Witness H.
- 16. Confidential Affidavit of GAP Witness H, July 15, 1984, Pages 10-11. !
l 17. Pre-file.d Testimony before KSLB, May 24, 1982, Page 80.
- i
{ 18. Enclosure to NRC OI Report, 4-54-006, March 7, 1984, Pages 57-59. Ceposition of A-1. l 19. NRC Special Review Team Repcrt, July 13, 1984.
- 2J. Initial Deposition, Telephone Conversation with GAP Witness M, i
July 31, 1984. -
- 21. TUGC0 Office Metacrandum # TUG-2134, ' Transmittal of Final Report on t
~
Jssues Resulting From Interviews with Electrical Inspe.ctors" May 22, 1984.
- 22. NRC Inspection Report 50-445/@4-10, June 21, 1984.
- 23. Decosition of GAP Anonymous Witness, July 25, 1984, Pages ,
58503-58591.
- 24. TUGCO, et al, Hearing before the ASLB, GAP Witness F, September 9, 1984 (In Camera), Pages 14719-14722.
+
I
_ , n_. . - 15 -
- 25. NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18, 50-146/83-12, April 11, 1983.
- 26. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; (June 13, 1983, Pages 7733-7755; June 15, 1983, Pages 8358, 8367, 8368-8373.
- 27. T'JGC0 Procedars No. QI-QD-31.5-29, Revf ston 15, January 18, 1984,
" Electrical Separation."
- 28. TOGC0 Pricadure No. QI-QP-11.3-29.1, Revision 15, Februarj 15, 1934,
" Verify E'lectrical Separation."
29 T11CCD Frecedure No. QI-QF-11 3-40, Rcvision 18, Mey 18, 1984, "Fostconstruction Inspection Of Electrical Equipment and laceways."
- 30. NRC Jnterview with SRT A11eger A43, September 6, 1984, Pages $3-56, '
C2-64, 83.
- 10. Ti.: sta+.et.ent prepared by. ;
Ailen R. Johnson Date TCT Peviewer Hulbert C. Li Date TRT Reviewer Reviewed by: l Jose A. Calvo Group Leader Date Approved by: Vincent S. Noonan Project Director Date
.. Document Name:
SSER AE-17
. Requestor's ID:
JEAN Author's Name: A. Vietti/kb Document Ccements: 11/21/34 Redraft Electrical 4 (REVISED 9/29 HQ)
i . i 1. Allegation Group: Electrical / Instrumentation Category No. 4 - Control j Room Ceiling Fixture Supports
- 2. Allegation Number: AE-17
{
- 3. Characterization: It is alleged that the field run conduit, drywall [
and lighting installed in the area above the equipment panels in the control room were classified as nonseismic, and as such were'only : supported by wires.
- 4. Assessment of Significance: The central concern of this allegation is whether Texas Utilities Electric Company (TUEC) considered the positions
- of Regulatory Guide (RG) 1.29, " Seismic Design Classification," as augmented by the Final Safety Analysis Report (FSAR) Section 3.2.1.2,
" Seismic Category II," during the design of the support systems in the control room for the nonsafety-related field run conduit, for the suspended i drywall ceiling, and for the lighting fixtures.
,l Regulatory Guide 1.29 states that nonsafety related structures, systems, j or components whose failures could reduce the functioning of any plant feature to an unacceptable safety level, or could result in incapacitating , injury to occupants of the control room, should be designed and constructed so that the safe shutdown earthquake (SSE) would not cause such failure. ' FSAR Section 3.2.1.2 provides TUEC's commitments to these positions, and designates as seismic Category II the nonsafety related equipment that ' will be encompassed by the positions of RG 1.29. I Field Run Conduit. The Technical Review Team (TRT) examined conduit seismic installation notes and detail drawings, design change author-izations (DCAs), work packages, physical configuration drawings and other documents pertinent to this issue. The TRT also inspected conduit ' installation in the area above the control room ceiling and determined ! that the safety-related conduit was fastened by seismic Category I
]
supports typical of those used in other areas of the facility. The l I J l I
.._...-............-___._.._....... l
. . . l
i ! i ! I a' nonsafety-related conduit was secured by supports which were of a dif-ferent design than those for safety-related conduit. None of the non- i
, safety-related conduits examined by tne TRT were greater than 2 inches in I diameter, were not supported by seismic Category I supports, nor did ;
j they have seismic Category II cable restraints. The TRT determined that engineering drawing 2323-5-0910, " Conduit and Junction Box Supports," did i not require seismic Category II cable restrasnts for nonsafety-related l i conduits less than or equal to 2 inches in dianeter, but required it for conduits greater than 2 inches in diameter. The TRT also examined similar nen. safety-related conduit installations in other seismic Category I areas cf Unit I and found that seismic {! } Category II stainless steel cable restraints were used as backup to the i nonseismic dead weight supports for the conduits greater than 2 inches 1 in diameter. The TRT staff also found that the installation of nonsafety- , related conduit less than or equal to 2 inches in diame'te" in the control ! room was consistent with that used throughout the plant. jj Suspended Drywall Ceiling. The TRT found that the suspended ceiling
- 4 l above the central part of the centrol room was mace of drywall sheets q- l 1
arranged to form a sleping wall around that area. These drywall sheets e
- } were fastened to a metal framework (metal batten) supported by thin-I i walled channels (1-1/2-inch by 1/2-inch) attached to the primary building i concrete. The metal framework was also attached to the concrete by a
,I t t systen of 1/8-inch stainless steel cables such that if the tnin walled ; I channel supports failed during a seismic event, the weight of the framing [ s and drywall would be assumed by the cabling. t Lighting Fixtures. The TRT reviewed the installation of the lighting ; fixtures over the control panels and central part of the centrol rcom I i and found that they were supported frem an intermediate substructure I of "unistrut" by light-weight conduit. The substructure was likewise supported by light-weight conduit frem the prinary building ceiling. { The conduit used is typical of that supporting the light fixtures in { _ . . . . . . .. . - . ... _ ... . . . _ . . . . . . . . . . _ . . . . . . ~ . . . . . . . - . . ~ . . . . . ... . . . -
.. suspended ceiling applications.
i Parallel with each lighting support i conduit are two 1/8-inch stainless steel cables which would assume the load if the support conduit or its attachment were to fail. Other f individual light and reflector assembly fixtures, separate frca those j supported by the intermediate "unistrut" substructure, were secured by l a similar type of conduit and backup cable design arrangement with the j cable attached to the edge of the light reflector assembly. , Based on the review of engineering drawings and direct inspection of the installation, the TRT determined that the positions of RG 1.29, as augmented by FSAR Section 3.2.1.2, applied to the installation of the ' I fixtures located in the area above the panels and central part of the F' > control room. - _~fn I l 4. 'W.
,{ The nonsafety-related conduit in the area above the control room suspendI3 .,.u' '
]' ceiling was not fastened by seismic Category I supports and/or seismic b, '
- j Category II cable restraints. With regard to the suspended drywall t
;i ceiling and lighting supports, it appeared that the installation m6t the I l ,1
]j TUEC commitments to the positions of RG 1.29. However, the final resoluj) !l tion of this technical issue, including the nonsafety-related conduit i support system, will depend on the review and approval by the TRT of an *
- analysis to be provided by TUEC concerning the adequacy of the seismic l- support system installation in the control room.
l The TRT inspected selected seismic Category I areas of the plant, reviewed associated engineering drawings, and determined that the applicable itens-
- highlighted by this allegation appeared to be installed in accordance with seismic design requirements, except for the lack of saismic Category -
II cable restraints on nonsafety-related conduits of less than or equal to 2 inches in diameter. i
- 5. Conclusions and Staff positions: The TRT concludes that the installation of the nonsafety-related conduit in the control roca appears to be !
I inconsistent with the positions of RG 1.29. Accordingly, this part of _. _ _ _ ~ J I
- r. +
l 4- I l the allegation 1s of safety significance. With regard to the susponced l ceiling and lighting supports, the acceptability of the installaticn will dependontheapprovalbytheTRToftheanalysisto$cprovidedbyTUEC concerning the adequacy of the seismic Category II restraints in the control room. This technical issue, including the noftsafety-related conduit support system, will be resolved after the review of TUEC's , seismic analysis substantiating the adequacy of the overall seismic support system installation in the control room. The results of the TRT review of TUEC's analysis will be reported in a supplement to this S.05R. ) l l Based on the review of other seismic Category I areas of the plant, l the TRT concludes that the acceptabiif ty of the installation will 1 J depend on TRT approval of TUEC's analysis of the adequacy of the seismic support installation for nonsafety-related conduits in areas l of the plant other than the control room.
- 6. Action Recuired: Prior to fuel load, TUEC shall provide to the TRT those cnalyses that substantiate (1) the adequacy of the overall seismic l support system installation for all the items located above the ceiling )
I in the centrol recm, including nonsafety-related conduit, suspended I ceiling, and lighting and (2) the adequacy of the seismic support system installation for nonsafety-related conduit in seismic Category I areas of the plant other than the centrcl ro m. This action shculd be coordir.ated as appropriate with cther actions addressed under Civil /5tructural Category No.14 " Seismic Design of Control Room Ceiling Elemer.ts," - R).s. ~.u m Q Q }.sc- w . . $h bcl. !(X Jh & ! j' k .NcWy
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; 8. Attachments: None. ! 9. Reference Documents:
1
- 1. Regulatory Guide 1.29, " Seismic Designs Classification."
- 2. Comanche Peak, Units 1 & 2 FSAR, Section 3.2.1.2, " Seismic Category II."
- 3. DCA No. 4693, Revision 10.
- 4. TUSI Drawing 2323-5-0910 " Conduit and Junction Box Supports."
- 5. CASE letter of May 11, 1983 to NRC IE and OELD.
- 6. NRC Inspection Report 50-445/83-24 and 50-446/83-15, August 19, 1983.
- 7. NRC Inspection Report 50-445/82-26, 50-446/82-14, February 15, 1983.
- 8. NRC RIV Summary of Comanche Peak Open Issues Tracking System, July 13, 1984.
, 9. NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18, l 50-446/83-12, April 11, 1983. ,
- 10. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT, June 16, 1983, Pages 8358, 8367, 8368-8373.
- 10. This statement prepared by:
George Myers Date TRT Reviewer - I Reviewed by: < Jose A. Calvo Group Leader Date Approved by: Vincent S. Noonan Project Director Date
.- 1 4
i .. Document Name:
- 1 ELECTRICAL NO. 5 t
i /- Requestor's ID: \ *
; l
,_ JEAN '
)
1 i. -
; Author's Name:
l A. Vietti/kb
! s Document Ccmments: '
s . - . 11/16/84 Redraft 1l space 4 . -i n /u/n- * = l
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- 1. Allegation Group: E ptr.ica4Au;rumentation Category No. 5 - Electrical Nonconformancepport-TWCR) Activities
- 2. Allegation Numbers: AQE-1, AQE-2, AQE-3, AQE-4, AQE-5, AQE-25, AQE-33, AQE-34, AQE-35, AQE-37, AQE-38, AQE-40, AQE-41, AQE-42, AQE-45, AQE-47, AQE-48, AE-24, and Parts of AE-22, AE-27, AQE-12, AQE-36, and AE-50.
- 3. Characterization: It is alleged that the validity of the generation and disposition of electrical nonconformance reports (NCRs) was suspect.
- 4. Assessment of Safety Significance: The implied safety significance of
- - these allegations concerns the quality of construction, inspection and rework.
These allegations pertain to various concerns involving the NCR program, which include: The prevalence of the "use-as-is i disposition of NCRs with respect to x hibbs'~&~ Hill-(G&H)' EleEt'rica1' fraction Specification 2323-ES-100. (AQE-33, AQE-47, Part of AE-27). Inaccurate evaluation in the generation of an NCR (workmanship verses t'echnical acceptance) (AQE-48). The closing out of NCRs by unqualified inspectors (either intentionally or because they were forced to) (AQE-4). Pressure not to generate NCRs (AQE-42). The traceabiiity of "Q" (safety-related) items (AQE-35). Restraint cable (mechnical) crimp gage calibration (AQE-41). l l l I
/
. .2... . . . . . . - - . . . . . . . ~ - - . - , ,
Failure to follow procedures, specifications and drawings (AQE-25, AQE-40, Part of AQE-12). Splicing of safety-related electrical cables in raceways (Part of AE-50). Electrical cables in trays with regard to cable damage (AEQ-45). Electrical cable tray attachments (AE-24). No documentation of butt splices in panels (Part of AE-22). Dispositioning of conduit replacement (AQE-3). The NRC Special Review Team (SRT) also had concerns with respect to the Texas Utilities Generating Company (TUGCO) management response to the so called "T shirt" incident because of its potential affect on the morale of
'QC electrical inspectors, which in turn, could have affected their work-manship. (Special Review Team Report (SRT-10), July 13,1984.)
In addition to these general concerns, several allegations contained specific information about questionable NCR dispositions, which include: Electrical cables in trays with regards to cable damage, removal, and improper documentation (AQE-1, AQE-2, AQE-5, AQE-34). Terminal block rework (AQE-37). Bent terminal lugs in motor control centers (AQE-36). Unauthorized solenoid repair (AQE-38). Loose elbow termination fittings (Part of AE-27).
a i j ..
.- _u n-The Final Safety Analysis Report (FSAR), Section 17.1 " Quality Assurance During Design and Construction," commits TUGC0 to a quality assurance (QA) program, as required by 10 CFR 50, Appendix B. FSAR Section 17.1.10
" Inspection," outlines the inspection planning means which will ensure that construction tasks conform to procedures, drawings, specifications, codes, standards, and other documentation. These inspection means are augmented by TUGC0 procedure CP-QP-16.0, which establishes the methods for generating and dispositioning reported items of nonconformance. The Technical Review Team (TRT) reviewed pertinent TUGC0 documentation to determine that the procedures and instructions for generating and dispositioning reported items of nonconformance were adequate.
The TRT reviewed a random sample of 75 electrical NCRs and conducted r, Wl/ / e, numerous interviews with QA/QC and engineering personnel to determine ->
~~ -%
_ the adequacy of tftq_t[C.R g ogram. (See also Electrical / Instrumentation w Category No. 6, " Electrical GC Inspector Training / Qualifications.") The .. TRT reviewed 25 of the 75 electrical NCRs to determine if the QC inspector j~ l ..' who " closed out" the NCR was qualified to do so. The TRT found that in ~ ['& > all 2T, cases the QC electrical inspectors were qualified and their [v* Q., r/ i
'h certification files were current.
p N h v Equipment installation matters raised by these allegations are addressed t Y(/ '* under:
/ ,, Electrical / Instrumentation Category No.1, " Electrical Cable Termina-
\ tions," for the alleged butt splices in panels without authorization
/,/
s, ,k,L, L.
/ /. - and being documented on drawings.
Electrical / Instrumentation Category No. 2, " Electrical Cable Tray and Conduit Installation," for the alleged improper cable tray attachments. Electrical / Instrumentation Category No. 7, " Electrical Cable Installa-1 tien," for the alleged splicing of safety-related cables in raceways I and cable damage where trays contained trash and hazardous debris. 1
4
- j .- ~ . .
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j The TRT interviewea both a Texas Utilities Electric Company (TUEC) electrical engineer and a lead quality engineer (QE) about the "use-as-is" , i disposition of electrical NCRs. The TRT determined that for an NCR to i i receive a "use-as-is" disposition, an independent verification inspection l by an electrical engineer had to be made to evaluate the reported item of I nonconformance. Based on that inspection, and on an evaluation with regard i i to procedures, specifications, drawings, including applicable codes and { standards, and other related documentation, a "use-as-is" disposition could f be applied. Final approval of any disposition required two QE signatures. l The TRT also reviewed the 75 NCRs to determine if there were he disposition "use-as-is," with the explanation "not addressed in ES-100,7 as j alleged. The TUEC engineer also indicated that should an NCR Wbe received
! with this type of disposition, it would be " kicked back" and would require more justification.
t The TRT determined that if the nonconfermance is indeed not addressed in f ES-100, then the document such as a procedure or other specification, that h does address this nonconformance item would be required to be referenced i t in the NCR. Of the 75 NCRs examined, the TRT could identify no "use-as-is" dispositions which raised a question of safety, except for the isolated cases identified in Electrical / Instrumentation Category No. 1, " Electrical Cable Terminations," and Electrical / Instrumentation Category No. 2,
" Electrical Cable Tray and Conduit Installation," regarding NCRs identi-fying bent terminal lugs in motor control centers, and reporting two loose conduit elbow fittings, respectively.
The TRT also interviewed a TUEC electrical engineer about NCR dispositions with respect to " replace versus repair" and " workmanship versus technical acceptance." The TRT determined that replacing a reported item instead of repairing it as originally dispositioned would require a revision to the original NCR. The disposition of the NCR for replacement would be based on an engineering evaluation. The TRT determined that on a case-by~ case basis where workmanship versus technical acceptance was compromised, the
' inspecting engineer would apply engineering judgment to determine that the 1 l
~ l
a
- l 5-quality of workmanship did not jeopardize safety. (See also Electrical /
Instrumentation Cagetory No. 8, " Electrical Procedures," regarding NCR for terminal block rework using TUGCO's procedure CP-SAP-6). The TRT interviewed the quality control (QC) supervisor for the calibration lab and reviewed pertinent procedures to determine their adequacy to ensure that construction tools which required periodic calibration were being main- , tained. TheTRTfoundthatlabcontrols, procedures,andtooltraceabili[ty , en:ured that tool calibration was maintained. Adequate procedures also existed to ensure that corrective actions were taken shculd a tool not meet calibration specifications and tolerances. The TRT reviewed NCR docu-mentation on tool calibration and found it to have been dispositioned in accordance with procedures which ensured the integrity of the construction task. The TRT interviewed QC and purchasing personnel and an electrical general foreman for construction, and reviewed pertinent documentation to determine the adequacy of traceability of safety-related (noted as "Q") items. The TRT determined that procedures and controls were adequate to ensure the traceability of "Q" items and that they would preclude the possibility of substituting "non-Q" for "Q" items. The TRT reviewed installation docu-mentation and found all the required traceability documentation. The TRT searched th'e records for the number of NCRs and inspection reports written and for the amount of cable pulled for a 57-day period prior to and following the so-called "T shirt" incident. This search was conducted to determine if the incident had any affect on the workmanship of the electrical QC inspectors. The TRT could find no evidence that inspectors were affected by the incident as a result of management reaction to it. To address the specific technical concerns raised in these allegations, the TRT examined the NCR log books and selected a random sample of NCRs pertaining to specific items of concern and determined that:
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,/ The allegation for the excessive bending of compression lugs Amp in
! ITT Gould-Brown Boveri switchgear has safety significance. This issue
! is being addressed in Electrical / Instrumentation Category NO. 1,
" Electrical. Cable Terminations." -- --
*~
, The allegations for the rework of terminal blocks, the repairing of
, a solenoid, the unauthorized pulling of cables without paperwork,~
replacement of flex conduit, and cable damage (frcm the removal of
\
f bisco foam seal fire retardant material) in the Auxiliary Building
)'
.s.- ,_------ has no safety significance since in its review of a random sample of M4 .s . jp 15; NCRs on these specific issues, the TRT g d.not identify any -g ' s c W >tffcoiisTsEnctirs or~eeficencies that would entail a safety question. l 6e TRT contacted the NRC senior resident inspector, who had no h >'gg :~ additional information on these specific items. The allegation for the loose elbow termination fittings (LBs) in the diesel generator rooms for Unit I has nerit. The TRT examined the NCR log book and found the specific NCRs for this item. The TRT also inspected the diesel generator rooms of Unit I and found two loose __ LB fittings. This issue is being addressed in Electrical /. ' Instrumentation Category No. 2, " Electrical Cable Tray and Conduit Installation."
- 5. Conclusions and Staff positions: Based on the reviews of the pertinent documentation, examination of NCRs, and the information obtained from the intery.iews % TRT conc Edes that adequate procedures, controls, and pro-ce'ss checks for the generation and disposition of reported items of non-conformance exist. Thus, ttERT7eli'cludes that these electrical-related
-w / -
allegations have neither safety significance nor generic implications, except for those previously mentioned which are being addressed in other
\ ,i, Electrical / Instrumentation categories. However, the results of this p' '. ,
/
evaluation will be further assessed as part of the overall programma' tic N review of all NCRs addressed under QA/QC Category No. 5, " Construction, Installation, Fabrication." Therefore, the final acceptability of th sc am v. .L . m s ~ 1 s a. t.. . w. n *vba=c. b
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i, i evaluation will be predicated on the satisfactory result of the overall programmatic review on this subject. Any adjustments to these conclusions will be reported in a supplement to this SSER.
- 6. Action Recuired: None.
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- 8. Attachments: None.
- 9. Reference Documents:
- 1. Comanche Peak, Units 1 and 2 FSAR, Section 17.1.10, " Inspection."
- 2. TUGC0 QA Plan Manual for CPSES.
1
- 3. TUGC0 Quality Procedure Manual.
l I 4. Brown and Root Quality Assurance Manual. I*
- 5. Brown and Root Quality Assurance Procedures Manual.
- 6. TUGC0 Office Memorandum, TUQ-2134, dated.May 22, 1984.
- 7. SRT .:inal Report (SRT-10), July 13,1984.
i 8. NRC OI Report 4-83-013, November 3, 1983, Page 8, Paragraph 1, 2, 3, t 4, and 5.
- 9. NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5, 1981.
- 10. GAP Notes of April 1984 (Confidential), Paragraph 16, GAP Witness H.
- 11. GAP Notes of April 1984 (Confidential), Paragraph 33, GAP Witness Anonymous.
- 12. Limited Appearance of Anonymous GAP Witness before the ASLB, l September 16, 1982, Pages 5551-5552, and 5556-5557.
- 13. NRC RIV Inspection Report 50-445/83-03, 50-446/83-01, March 28, 1983.
- 14. Comments of Anonymous GAP Witness, Meeting with NRC and Sent to CASE, December 13 and 20, 1982.
- 15. Deposition of SRT Witness A-5, July 17,1984, Pages 55,102-55,103.
- 16. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on Issues Resulting From Interviews with Electrical Inspectors," May 22, 1984.
- w-
- 17. Deposition of GAP Anonymous Witness, July 25, 1984,
; Pages 58,503-58,591.
- 18. Deposition of GAP Witness, July 16, 1984, Pages 53,003-53,263.
- ' 19. NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18,
', 50-446/83-12, April 11, 1983.
- 20. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; (June 13,1983, Pages 7733-7755; June 15,1983,
- ! Pages 8160, 8231, 8251-8263, 8291; June 16,1983, Page 8358.
- 21. NRC Interview with SRT A11eger A-3, September 6, 1984, Pages 30-37, 39-40, 42-44, 63-72, 75-79.
t . l 10. This statement prepared by: TRT Reviewer Reviewed By:
- Jose A. Calvo Date Group Leader Approved By:
Vincent S. Noonan Date Project Director l y., ..L . _.. . _ _ _ _ . _ . _ . _ _ . . . _ _ _ . . . .. . . l
Document Name: SSER - ELECTRICAL 6 Requestor's ID: . LINDA i Author's Name: , A. Vietti/kb i. Document Comments: AQE-8,ETC.(WAS SSER-Electrical 10-NEWNAME) (REVISED 9/29 HQ) . 1ll16 l f ' t
. . . - . . . . . - . . - . - - - . + - - - -
- 1. Alleaation Grouo: Electrical / Instrumentation Category No. 6 - Electrical Quality Control (QC) Inspector Training / Qualifications
- 2. Allegation Numbers: AQE-8, Parts of AQE-4, AQE-6, and AQE-12.
- 3. Characterization: It is alleged that some electrical QC inspectors were inadequately qualified, that they received help in passing certification tests, and that\ their experience requirements were " pencil whipped."
- 4. Assessment of Safety Significance: The implied safety significance of, those allegations is that the lack of training or qualification of electrical QC inspectors could result in inadequate inspections of safety-related components.
The allegations question whether the positions of American National Standards Institute (ANSI) Standard N45.2.6-1978, " Qualifications of Inspection, Examination, and Test Personnel for tne Construction Phase of Nuclear Power Plants," as augmented in the Final Safety Analysis report (FSAR) Section 17.1.2, " Quality Assurance Program," were con-sidered by Texas Utility Electric Company (TUEC) in the development of the quality assurance (QA) program at the Comanche Peak Steam Electric Station (CPSES). Regulatory Guida (RG) 1.58, Revision 1, " Qualification cf Nuclear Power Plant Inspection, Examination, and Testin; Personnel" endorses the positions of ANSI N45.2.6-1978.
. . . . . . . , . . . . , - . - - = = . - - - -
****--~*-"*******'*****e*** * * " * * * * * * " * * * ' " * * ~ * '*
RG 1.58, Revision 1, and ANSI N45.2.6-1978 set forth positions stating the education and experience requirements for the various capability levels of inspectors (I, II, and III). Both documents, however, state that these requirements are not absolute when other factors may provide reasonable assurance that a person can competently perform a particular task. They require that all records or qualifications shall be maintained' by TUEC in an individual's personnel file.
- C.'
In assessing these allegations, the Technical Review Team (TRT) examined C;. Texas Utilities Generating Compan (TUGCO) procedures, QC inspector I+n/ li training and certification files, Jesting program requirements, on-the-
/. ~
,[ job training (0JT) requirements, and recertification program requirements.
The TRT also conducted interviews with the training coordinator, two Level I QC electrical tecnnicians, four Level II QC electrical inspectors, one Level III quality engineer (QE), one Level II lead QC electrical inspector, e' as one lead QE, and the QE Supervisor. / 4r ' l
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fr u. Procedures. The TRT found that TUGC0 Procedure CP-QP-2.1, " Training of Inspection Personnel," commencing with Revision 8 (July 1981), contained the education and experience requirements consistent with RG 1.58, Revision 1, and ANSI N45.2.6-1978. Revision 7 (June 1981) of the aoove procedure, Section 3.1.d, " Technical Training" contained the statement: Minimum training, education, and experience requirements will be dafined in technical training outlines prepared for specific inspection activities (civil, electrical, etc.).
.. .. ....... . ....-.---..~.-. . - - ~.-.-- - . .
After a discussion with the training coordinator and an examination of the technical training outlines, the TRT discovered that the education and experience requirements were never defined, and that only the training requirements had been defined. After examining other related procedures, the TRT could not find any deficiencies or inconsistencies, except as noted below. Trainino and Certification Files. The TRT examined in detail six elec-trical QC inspector's training and certification files (two Level I and four Level II). The examination revealed two instances where TUGC0 Procedure CP-QP-2.1, Revisions 8 through 15, RG 1.58, Revision 1, and ANSI N45.2.6-1978 requirements for qualification were not being met. Specific-ally, they included: (a) No documentation of a high school diploma or General Equivalency Diploma (GED) for one of the inspectors selected. The file on this inspector contained only a telephone conference note that a call had been made in 1982 requesting information from a high school. (b) No documentation to waive the remaining two months of the required one year of experience for a Level I technician before the individual became a Level II inspector after successfully passing the required examinations. g . .. . . . -. - .. - _ . _ - _ . . . . . - - . . . _ . . . . . - . .. . .
~
l.
- 7. - t
_s. p-The TRT also found one case where'a Level I QC technician had not passed the required color vision examination to be administered by an independent professional eye specialist. f A makeup test using co*lored pencils was administered by a QC supervisor, was passed, and then a waiver was given. A TUGC0 procedure allowed for a waiver on a case-by-case basis. In addi-tion to the above, the TRT staff also found two cases where the experience requirements to become a level I technician were met only marginally. In one case no documentation was found in the training and certification files substantiating that the person met the experience requirements or providing the basis for determining that the person could, with reasonable assurance, competently perform the particular task without having the required related experience. Testing Program Recuirements. The TRT examined the testi..g, retesting and scoring methods applicable to Level II qualification and found scme guide-line inconsistencies and procedural deficiencies. Specifically, they included: (a) No time limit or additional training requirements between a failed test and a retest. In practice the time varied from a few days to months. (b) No controls to assure that the same test would not be given if the taker previously failed it. y3 . _ _ _ _ _ 7. __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
(c) No consistency in scoring. Two different scoring techniques were used to average the results when two tests were taken. Combined test scores could vary slightly, depending on which technique was used. These slight variations could make the difference between passing or failing the tests - a condition resulting solely from the scoring technique used. Seven out of 25 tests used one test scoring technique instead of the other. (d) No guidelines or procedures to control the disqualification of ques-tions from the test. In one instance a question was disqualified c after the test was administered, thus allowing two people to pass the exam that they would have otherwise failed. (e) No program for establishing new tests (except when procedures changed). The same tests had been utilized for the last two years. On-The-Job (0JT) Training Requirements. The TRT examined the OJT train-ing for QC electrical inspectors and found sufficient documentation in the training and certification files that adequate OJT was being obtained. Numerous cases were found where a portion (10%-20%) of the required OJT was being waived only after applicants successfully passed the Level II examinations. S
f .- Recertification Program Requirements. The TRT examined the recertification program and found that there was no required documentation to assure that recertification requirements were being met. The present system only requires a simple "yes" or "no" answer from an inspector's lead QC inspec-tor that the individual had been active in the area in the last 6 to 12 months and was knowledgeable about current procedure requirements. The lead QC inspectors did not maintain any written record of a subordinate inspector's activity. 9
/
Interviews. TheTRTinterviewed'llpeople,/includingthetrainingcoordi-
/
nator and Level I QC technicians-on-up'to the QE supervisor. The TRT determined that QC supervisor favoritism, craft harassment, and production pressures implied in the allegations were at a minimum. The consensus of those interviewed was that the training program'was ade-quate and had improved over the last couple of years. Some thought addi-tional OJT would have been more beneficial in lieu of " book time." Based on reviews of the QC inspector training and qualification aspects of the electrical QA program, the TRT determined that current procedures in effect beginning with Revision 8 of the CP-QP-2.1 meet the requirements of ANSI N45.2.6-1978, as augmented in the FSAR and endorsed by RG 1.58, Revi-sion 1. Prior to Revision 8, TOGC0 procedures did not define the education g7 . - . - ~ . . . _ , . . . . . , - . - . - . . -. .. -
d
~
and experience recommended in the above regulatory documents since TUGC0 was not committed to these requirements until April 30, 1981. The TRT review of the training and certification files determined that some supportive documentation as required by procedures and regulatory positions was lacking.
. ..s The TRT determined that the testing program lacks guidelines and procedural requirements covering, but not limited to, such items as test question dis-qualifications, scoring, retests, and the prolonged use of the same tests.
The TRT also determined that the inspector recertification program lacks programmatic controls to assure that the recertification requirements in i
/ 3@st the different electrical quality instructions are being met.
!fv'p
- 5. Conclusions and Staff Positions: Based on its review of the pertinent
[d documentation and its interviews, the TRT concludes that there is evidence MD5, to indicate that the electrical QC inspector qualification program lacks programmatic controls which may be indicative that the required level of qualification was not obtained for some electrical QC inspectors. Spe-cifically, the lack of programmatic controls to assure that suitable proficiency is achieved and maintained (as' required by 10 CFR 50, Appen-dix B) was found in:
The supportive documentation of qualifications, as required by pro-cadures and regulatory recuirements in the training and certification. 6 The testing program for Level II qualification. The recertification program requiroments in electrical quality instructions. The TRT concludes that the lack of these programmatic controls in the electrical QC inspector qualification program does have safety significance.
~ ~ ~ ~
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L*e-on . ; n .. h,p'"J/Sincethed,trainingandcertificationprogramisthesameforalldisci-1
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. . . plines (except ASME), the TRT concludes that the deficiencies in procedural y)...-- requirements and guidelines in the testing program and the lack of documen-tation in isolated cases have generic implicaticns to the other construc-
/
.~tion disciplines./The-implications s
of the TRT's findings concerning the V'p electrical QC inspector training and qualification will be further assessed p.r@as part of the overall programmatic review of QC inspector training and
- / p,o
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qualification, which is addressed under QA/QC Category No. 4, " Training and ualification."
- 6. j Action Recuired: TUEC shall accomplish the following prior to fuel load:
g,..._.- __
.. - . - - - - - - - ~ . . . . - . . . . - . . . . . , . - .
.m _ .. .
,A 4 R
(1) Evaluate the testing program for QC electrical inspector qualifica-tions and develop a testing program which optimizes administrative guidelines, procedural requirements, and test flexibility (e.g., computer generated tests) to assure that suitable proficiency is achieved and maintained. These guidelines and/or procedures shall include such items as scoring, retests, and question disqualification. (2) Review 'all electrical QC inspector training, qualification, certifi-
,U 9[- l' cation and recertification files against the project requirements
. ~
y p and provide the information in such a form that each requirement is V l',' {J (P,),clearlyshowntohavebeenmetbyeachinspector. e k If an inspector
.3 ..
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( is found to not meet the training, qualification, certification, or ( V (l ' certification requirements, TUEC shall then review the records to
- determine the adequacy of inspections made by the unqualified indi-J' 4,j- / ,
p.. - v f,y- >
.# '7 viduals and provide a statement on the impact of the deficiencies
/
b.f # , noted on the safety of the project.
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7' (3) These actions should be coordinated, as appropriate, with other actions addressed under QA/QC Category No. 4, " Training and Qualification." V. ?,E*t**Ml n f .: r-h,M *'s*W:#fc'
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- 8. Attachments: Ncne.
- 9. Reference Documents:
(1) Comanche Peak, Units 1 and 2 FSAR, Section 17.1.2, " Quality Assurance Program." l t, (2) ANSI N45.2.6-1978, " Qualifications of Inspection, Examination, and ! Testing Personnel for the Construction Phase of Nuclear Pcwer Plants." , (3) RG 1.58, Revision 1,1960, " Qualification of Nuclear Pcwer Plant Inspection, Examination, and Testing Personnel." (4) TUGC0 Procedure CP-QP-2.1, Revisions 7, 8, and 15, " Training of Inspection Personnel." ! (5) TUGC0 Procedure CP-QP-2.3, Revision 4, " Documentation Within QA/QC Personnel Qualification File."
(6) TUGC0 Procedure QI-QP-2.3, Revision 8, " Qualification of Electrical Inspa tion and Test Personnel." (7) Inspection Report 82-11. (8) NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5,1981. (9) Pre-filed Testimony before ASLB, May 24, 1982, Page 80. ; (10) NP.C OI Report 4-83-013, November 3, 1983, Page 8, Paragraph 4. (11) NRC Special Review Team Report, July 13, 1984 (12) TUGC0 Office Memorandum #TUC-2134, " Transmittal of Final Report on Issues Resulting from Interviews with Electrical Inspectors," May 22, 1984. (13) Deposition of GAP Witness, July 16,1984, Pages 53,003-53,263. (14) NRC RIV Summary of Comanche Peak Cpen Issues Tracking System, July 13, 1984, t 4 e y. 2 s __ ., . . . . . . . . . . . . . . . . . . . . . . . - .
~ _ . . , .
e L 12 -
- 10. This Statement Prepared by:
James C. Selan Date TRT Reviewer Reviewed By: Jose A. Calvo Date Group Leader Approved By: _ Vincent S. Noonan Date Project Leader
- y. . . . . . . . . . - . . , . . - . . . ~ - - - - - - - - - - - - - - ~ ~ - - . - . ~ . . - - - - - -
a I l 1 l l Document Name: SSER-EIICTRICAL 7 Requestor's ID: JANE Author's Name: A. Vietti/kb Document Coments: AE-19 etc. (REi, 10/03 HQ) Ilf2.4ff4 1Lm3 ..
. . . - -~ ~ .
- 1. Allegation Grouo: Electrical / Instrumentation Category No. 7 - Electrical Cable Installation
- 2. Allegation Numbers: AE-19, AE-28, AE-30, AE-50, Parts of AQE-5 and AE-29, ;
4 and Special Review Team (SRT)-10. 4
- 3. Charseterization: It is alleged that:
Cable trays were overloaded (AE-19). Cables were not " trained" in a workmanlike manner in the cable spread-ing room and in junction boxes 1058 and.1059 (AE-28). ' j Higher siderails were added to cable trays due to tray overfill con-ditions (Part of AE-29). - Cable density / compaction problems existed due to tray overfill condi-tions (AE-30). Cables were spliced in cable trays in the cable spreading rocm in violation of regulatory requirements (AE-50). A noncenformance report pertaining to trash in cable trays, d6maged cable, and improperly trained cable was improperly closed (Part of AQE-5). The Special Review Team Report on July 23, 1984 identified the issue of over-loaded cabie trays due to the installation of "thermolag" material (SRT-10). i I
... . . - - . . . . - ~ . - . - - - - ~ ~ ~ - - . - . . . . . - - . . . . . . . - .- . ..-
, , ~. __ - __. - . . . . _ , _ -.
-g-
- 4. Assessment of Safety Sicnificance:
Cable Solices in Raceways. Allegation AE-50 involved the alleged splicing of safety-related cables in raceways in violation of regulatory require-ments. The Technical Review Team (TRT) reviewed i:RC Region IV (RIV) inspection report 83-03 (November 8, 1982) anc found that the RIV irvesti-gation of the two cables specifically identified by the alleger adequately addressed this. allegation. The .RIV investigation deterzined that one cable (
, t ,gliolongerperformsasafety-relatedfunction,andtheothercablehasbeen ,_ ,
..s,$ I'" spared"andremovedfremtheraceway. RiV also determined that cable ~
,c W 1; p . >
<Q solicing in racew' ays is not explici,tly forbidden by regulatory requirements, k*o $4* \ industry stand'ards, or site procedures, and that similar-appearing items in t he same area were not splices, but were, in fact , acceptable methods of repairing minor cable jacket damage. The TRT concurs with the RIV determination.' However, the TRT notes that regulatory requirements discour-
.. - _/
age the use of splices in raceways, as stated in position 9 of Regulatory Guide (RG) 1.75, " Physical Independence of Electric Systems." If splices are made
%j ------, the resulting design shculd be justified by analysis.
/
The TRT then examined the cable spreading room, selected two cables, installed in raceway, which to the untrained eye could appear to have been spliced, and inspected them in their as-installed condition. The l, 1 TRT also reviewed the applicable installation / inspection records. This inspection and review revealed that there were cable jacket repairs and
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that they were properly identified, repaired, and documented in
, accordance with applicable procedures.
Poor Workmanship. Allegations AE-28 and Part of AQE-5 involved instances of improper cable " training" (or dressing), poor workmanship in cable installation, and cables installed in raceways containing trash and hazard-ous debris. The issues of improper " training" of cables and poor workman-4 ship in function boxes 1058 and 1059 were inspected by the TRT. The TRT 1 findings agree with the previous NRC RIV determination that these cables, which are nonsafety-related, were properly trained and that they exhibited an acceptable degree of workmanship. These findings were discussed with ( the alleger who indicated that the junction box numbers may not be correct 4 , and provided additional information concerning the location of the boxes in the plant. The TRT is currently evaluating this new information and will report the results in a supplement to this SSER. The alleger did not identify which trays contained trash and hazardous debris at the time of cable installation, so the TRT a randomly inspected approximately 2,000 feet of cable trays containing safety-related canles and found no instances of improper training, trash, hazardous debris, or poor workmanship. Tray Overfill. Allegations AE-19, and AE-30 involved various concerns related to cable trays possibly being overfilled. The alleger specifically identified tray T130CC007 in the cable spreading room. The TRT inspection , of this tray revealed the following: E _ EIE22I-- E I I " II ~ " ~
* ~
4 l , (a) Siderails were installed on this tray, adding approximately 2 inches , to its height and, when inspected, no cables extended abo'e v the. level of the siderails. - (b) Per nonconformance report (NCR) E-82-1073R1, eight spare cables were removed from this tray in January 1983 in conjunction with the removal of 42 spare cables from tray T130ECCS2 due to an identified , physical tray overload condition. , (c) Calculation of the actual weight of cables currently installed in , this tray indicated loading of approximately 22 pounds per square foot, compared with the maximum allowable value of 35 pounds per square foot, as specified in seismic supporting requirements. (d) Calculation of the square area fill of cables currently installed in this tray indicates an actual fill of 28%, compared with the maximum recommended value of 40%, as stated in IEEE Standard 422, " Guide for the Design and Installation of Cable Systems in Power Generating Stations." The TRT selected nine additional sections of tray con-taining large quantities of cables. These quantities ranged from 57 to 300 cables per tray section. The square area fill and weight per square foot values for these trays were reviewed for conformance with the stated maximum values. The results of this review were as follows:
- y. .. .. . ....--.--_. ..--. --- - _ -.----..-. .... --.. . ..
.' (1) All nine trays were loaded at less than 28 pounds per square fcot.
(2) Seven of the trays had square area fill less than 40%. (3) The two remaining trays had square area fills of 41% and 42%; novever., Section 8.3.3.1 of the Final Safety Analysis Report (FSAR) justifies exceeding the 40% value if cables do not extend above the siderails of the tray, and do not violate seismic supporting requirements. The NRC staff considers this justificationacceptable. This reyf ew revealed that all trays sampled comply with seismic supporting r3quirenents and, becauce no cables extended above the tray side-rails, that ho deficientfes existed within the sample selected. Added Leeds on 'Trats. Allegetion AE-29 and concern SRT-10 involved the addition cf highe?'siderails had "thermolag" material to existing cable trays, cor.ditipns which could cause trays to become physically overloaded. Regarding the higher siderails, tne TRT discovered that siderails were 4 fatiicated using 6-inch high by 15 gauge galvanized sheet metal. As such, the addition of ttis maturial would increase tray loading by approximately 2\ pounds per foot. Using the above sample of cable trays, which the TRT considers representative of some of the most highly loaded trays at Comanche Peak Steam Electric Station (CPSES), Unit 1, this added height would bring g ,. .---...--.a. _ - . . - . . . . _ . - ~ - , - - - -
. . - - = - - . -
~ ,. t 4
the most highly loaded tray to approxImately 30.5 pounds per square' foot, compared with the maximum allowable value of 35' pounds per square foot.
. m.c s
.L en Regarding the "thermolag" material, the TRT reviewed procedure CP-EI-4.0.-49l Revision 1, " Evaluation of Thermolag (TSI) Fire Barrier. Material on Class IE Electrical Raceways." From this review the TRT determined that the -
4 -e procedure is adequate to assure that, should overl'oading occur due to the
~
addition of thermolag material, these instances will/bv ibar.tified, eval- ,
? '
uated, and -if necessary, corrected prior to the installation of the / i thermolag. The TRT then selected two raceways (one cable tray and one s k' conduit) with thermolag installed and reviewed the evaluations performed' t in accordance with the above procedure. TheTRTfoundthatthereghiraq. x. ,
\,
ments of the procedure had been met, and therefore, determined that the ' addition of tray siderails and thermolag material poses no hazard to the ' structural integrity of the raceway system. c. . s
- 5. Conclusions and Staff Positions: Based'en the inspection of the cable installationsforcablesplicesincabletrays[ workmanship,cabla tray fill, added load on cable ' trays by thermolag material, and feview of .
I., ,.( 5 g pertinentcriteria, procedures,RIVinspectionreports, installation s [, inspection' reports,andnonconformancereports,iheTRT conc}ude:: that the various aspects of the cable installation on raceway fill meet estab-lished installation requirements. Therefore, the TRT concludes 3that these allegations have neither safety significance nor generic implications. l y3 . . . . . . . . . - . - . - . . . - - - _ _ l _
g* D d /
~
M s T
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s s The results of the TRT review of new information concerning allegation AE-28 will be reported in a supplement to this SSER. Y
- 6. Actions Reouired: None.
t
- 8. Attachments: None.
- 9. Reference Documents:
- 1. Region IV Inspection Report 50-445/83-03, 50-446/83-01, March 28, 1983.
- 2. Nonconformance Report E-82-1073, RI.
- 3. IEEE Standard 422, " Guide for the Design and Installation of Cable Systems in Power Generating Stations."
t l
- 4. Regulatory Guide 1.75, " Physical Independence cf Electric Systems." i i
- 5. CPSES FSAR, Section 8.
o g.........-.~ .
. . . . . . . - - . - --;.-~..-...-._... ._____.n_, ._. g .- - -
+_ ,
, l -
8-I
- 6. Procedure CP-EI-4.0-49, Revision 1, " Evaluation of Thermolag (TSI)
Fire Barrier Material on Class 1E Electrical Raceways."
- 7. NRC Special Review Team Report (SRT-10), July 13, 1984.
- 8. GAP Notes of April 1984 (Confidential), Paragraph 5, GAP Witness A and H.
- 9. NRC OI Report 4-83-013, November 3, 1983, Pages 8-9.
- 10. Limited Appearance of Anonymous GAP 3 Witness before the ASLB, September 16, 1982, Pages 5551-5552, and 5556-5557.
)
- 11. Comments of Anonymous GAP Witnes , 'eting with NRC and Sent to CASE, December 13 and 20, 1982.
- 12. NRC Inspection Report 82-01.
- 13. TUGC0 Office Memorandum #TUC-2134, " Transmittal of Final Report on Issues Resulting from Interviews with Electrical Inspectors," May 22, 1984.
- 14. Deposition of Anonymous GAP Witness, July 25, 1984, Pages 58,503-58,591.
_gg . . . . . . . . . . . . . . . - .~.-.-.---n~. - . . . - - . . . .-:--- . .
- 15. NRC RIV Summary of Comanche Peak Open Issues Tracking System, July 13, 1984.
- 16. NRC Constructio praisal Team (CAT) Inspection Report 50-445/83-18, 50-446/83-12, April 11, 1983.
- 17. TUGCO, et al., Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; June 13, 1983, Pages 7733-7755; June 15, 1983, Pages 8160, 8231, 8261-8263.
- 18. NRC Interview with SRT Alleger A-3, September 6, 1984, Pages 27-30.
- 10. This statement prepared by:
William S. Marini Date TRT Reviewer Reviewed by: Jose A. Calvo Date Group Leader Approved by: Vincent S. Noonan Date Project Director l i i
.- Document Name:
SSER - ELECTRICAL 8 Requestor's ID: JEN1 1 Author's Name: A. Vietti/kb i
- Document Comments
l
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i 5 O e e 4 l 7 .. . . . . .-- - .. .. . .. - . .-- ... - . .. .
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- 1. Allegation Group: Electrical / Instrumentation Category No. 8 - Electrical Procedures .
l
- l 2. Allegation numbers: AQE-23, AQE-32, AQE-39, AQE-44, AQE-46, AQE-52 and Parts of AQE-6, AE-18, AE-20, and AQE-37.
l l 3. Characterization: It is alleged that:
! Requirements were extensively omitted in the procedural revision , for post-construction inspection of electrical equipment and raceways. (AQE-23 and Part of AQE-6.)
The number of required inspections were reduced in the procedure for reverification of seismic electrical equipment mounting l details. (AQE-32.) Revisions to the procedure for post-construction inspection of electrical equipment and raceways were made to accommodate numerous problems with loose terminations found in the lighting system termi-j nal boxes during past inspections. (AQE-39 and AQE-46.) Revision 15 to the procedure for post-construction inspection of electrical equipment and raceways omitted requirements for inspections of large pieces of equipment, such as 6.9 kilovolts (KV) motors. (AQE-52.) i i g- . _ _ _ _ . .-- _ . . . - - - . _ . _ . _ ,... . . . _. . ..
i Post-construction deficiencies identified in the fuel building and dispositioned "use-as-is" were contrary to procedure. l (AQE-44.) i Paper flow problems existed involving rework and modification to
?
, terminal blocks with respect to the procedures to control work on station components after release from Brown & Root, Inc. (B&R) construction to Texas Utilities Generating Company (TUGCO).
'j
, (Part of AQE-37.)
i Insulated butt splices were being used contrary to the in process j inspection procedure for cable terminations. (Part of AE-18.) i Separation criteria between redundant cable trays and conduits in the cable spreading room were not consistent with the require-ments of the in process inspection procedures for verifying electrical separation. (Part of AE-20.)
- 4. Assessment of Safety Sienificance:
The Technical Review Team (TRT) examined nine in process inspection procedures used during plant construc-tion, one post-construction inspection and walkdown procedure, and four turnover inspection procedures for final acceptance of station systems, structures, and equipment by TUEC startup and operations. The TRT reviewed in place procedures, historical procedure files, inspection reports (irs), IR deficiency logs, post-construction deficiency lists, 1
. . _ . . . . _ . ~ . . . . . . . . . . . _
1 electrical equipment punch lists, and electrical separation deficiency reports, test release / return to contractor custody /startup release to operations forms, construction operation travelers, startup work authori-zations, and systems / area testing, drawing, walkdown results/ review fo rms . The TRT also interviewed QC management personnel and selected allegers. The TRT examined the above documents for programmatic weak-nesses in the electrical procedures which may have negated quality 1 assurance / qual'ity control (QA/QC) inspection activities during construc-tion of the plant. procedures for post-Construction Insoection of Electrical Eouioment and Raceways. The TRT review of procedure QI-QP-11.3-40, " Post-Construction Inspection of Electrical Equipment and Raceways," revealed that numerous deficiencies were identified by QA/QC personnel during the post-construction and walkdown inspections of electrical equipment and raceways based on this procedure. The TRT found that this post-construction walkdown procedure had been revised 18 times and was used extensively by management ~ to maintain tight
. . . . .~_
control of construction deficiencies. Before Revision 15, QC inspectors
.<___ - = :. _ - - - ~
were using this procedure extensively to reinspect in process inspection activities, (f{g., Sections 3.1.1thru3.1.4ofRevision14, requiring verification of cable, cable tray, conduit, and equipment installation, were rewritten under Sections 3.1.1 and 3.1.2 of Revision 15 entitled,
h ' s 1 4-
" Raceway Inspection" and " Equipment Inspection.") Before Revision 16, large pieces of equipment were not specifically addressed in this proce-i dure; however, this equipment was covered in Revision 15 of QI-QP-11.3-4.0 procedure ection 3.1.2 entitled, " Equipment Inspections." Because ! -6.9 KV motors are not considered to be Class IE, requirements for inspec-i I
tion of this equipment did not need to be covered by this procedure.
; Some of the reyisions of this procedure came as a result of the many test
; deficiency change requests (TDCRs) based on TUGC0 procedure CP-SAP-3, (
; " Custody Transfer of Station Components." These deficiencies evolved from the startup performance testing of components and systems that B&R l and other contractors had turned over to TUGCO. Other revisions were made to include the experience gained during the reinspection of the I in process inspection activities. The TRT found that during the revamp-ing and issuance of Revision 15 of the procedure, excessive and repetitive inspections
/
were eliminated. Wf After a review of QI-QP-11.3-40 and CP-SAP-3, as well as other pertinent electrical in process inspection and startup administrative procedures, the TRT did not find any omissions in requirements for inspection of electrical equipment and raceways. t
! Procedures for Lightino Termination and Wirino.
t The TRT found that
'( safety-related lighting terminations and wiring were required to be
\
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inspected under TUGC0 in process procedures QI-QP-11.3-23, " Class IE Conduit Raceway Inspections," QI-QP-11.3-26, " Electrical Cable Installa-tion Inspections," QI-QP-11.3-28, " Class 1E Cable Terminations," and QI-QP-11.3-40, " Post-Construction Inspection of Electrical Equipment and Raceways." Nonsafety-related lighting terminations and wiring did not require inspec-tions under TUGC0 procedure QI-Qp-11.3-40 or under the TUGC0 in process inspection procedures. The TRT found that the inspections of emergency lighting and associated terminations were being performed under Revision 15 or earlier revisions of procedure QI-QP-11.3-40; even so, the procedure was not specifically addressing the emergency lighting inspections. Revision 16 of this pro-cedure was made specifically to address raceway lighting inspections (Section 3.3.1). The TRT found that the loose terminations within the lighting termination boxes occurred as a result of an installation deficiency by craft involvin .l the Thomas and Betts RP-12 crimp-type insulated connectors. A document N d'/ change noti e (DCN) was issued changing the engineering instruction used by the craft (EE-8) and thereafter the number of deficiency reports in lighting termination boxes was greatly reduced.
s . The TRT found that the revisions to procedure QI-QP-11.3-40 regarding i emergency lighting inspections were justified to eliminate repetitive inspections of a craft installation deficiency which had already been I corrected. l I i Other Electrical procedures. After a review of procedure QI-QP-11.14-12, j " Reverification of Seismic Electrical Equipment Mounting Details," the TRT could find no requirements in Revision 0 through 4 that established a fixed frequency for reverification of inspections concerning bolt tightening of seismic electrical equipment mountings. However, the procedure provided for reverification of inspections on a " case-by-case" basis. The TRT also reviewed the following in process inspection procedures with respect to electrical equipment separation and the use of butt splices in panels: (a) Procedure QI-QP-11.3-29, " Electrical Separation" (b) Procedure QI-QP-11.3-29.1, " Verify Electrical Separatien" (c) Procedure QI-QP-11.3-23, " Class 1E Cable Termi. nations" The TRT determined that in process inspection procedures QI-QP-11.3-29 and QI-QP-11.3-29.1, and post-construction procedure QI-QP-11.3-40, were used to identify deficiencies in the fuel building and that these. procedures allow the "use as-is" disposition of nonconformance reports
~
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~7-b (NCRs). The s 'ect of "use-as-is" disposition of NCRs is discussed l in Electric 1 I strumentation Category No. 5, " Electrical Nonconformance i
- Report (NCR) Activities."
'l l The separation of electrical equipment and installation of terminations l in accordance ith procedures, drawings, and specifications is discussed inElectricifIistrumenttionCategoryNo.1,"ElectricalCableTermina-tions," and Electri strumentation Category No. 3, " Electrical Equio-t ment Separation." t
, In a TRT review of other electrical procedures, the TRT found no omissions in requirements for inspection of electrical equipment.
- 5. Conclusions and Staff positions: Based on its review of procedures for i
in process irspections, post-construction, and turnover inspections, the TRT concludes that no significant concerns existed with electrical proce-dures. The TRT, therefore, concludes that these electrical-related allegations have neither safety significance nor generic implications. ' ~
--' '~ '
~~~~~~'-
f [ Howe v ethe'res r , % tsulof,,,__. .. ~.-. this evaluation will be further assessed as part f of the overall programmatic review concerning procedures addressed under_ ( QA/QC Category No. 6, "QC Inspection." Therefore, the final acceptability j of tnfi evilDitToTW111-be predicate'd on the satisfactory results of the
/
overall programmatic review on 'his subject. Any adjustments to these conclusions will be reported in a supplement to this SSER.
,p* T e. ., J - - - hv OOV4' i afd*'f' % s
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- 6. Actions Recuired: None.
l
. 1 N.u.%%@k.:b[$k 6~. ws n w:x$,#23[n.fg4fMR$
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$ $ dl5 E $ $ $ Nf M M, n .$$5$[$ $2 N :
- 8. Attachments: None. ,
f i i
- 9. Reference Documents:
- 1. TUGC0 Procedure No. CP-QP-11.3, Revision 4, August 12, 1983,
" Electrical Inspection Activities."
- 2. TUGC0 Procedure No. QI-QP-11.3-23, Revision 11, March 6,1984,
" Class 1E Conduit Raceway Inspections."
- 3. TUGC0 Procedure No. QI-QP-11.3-26, Revision 22, June 8, 1984,
" Electrical Cable Installation Inspections."
- 4. TUGC0 Procedure No. QI-QP-11.3-28, Revision 21, June 8, 1984,
" Class IE Cable Terminations."
- 5. TUGC0 Procedure No. QI-QP-11.3-29, Revision 15, January 18, 1984,
" Electrical Separation."
- 6. TUGC0 Procedure No. QI-QP-11.3-29.1, Revision 15, February 15, 1984, " Verify Electrical Separation."
i .
~
I j . _g-i
- 7. TUGC0 Procedure No. QI-QP-11.3-38.1, Revision 1, February 21, 1984, " Installation of Class IE Electrical Equipment."
l
- 8. TUGC0 Procedure No. QI-QP-11.3-40, Revision 18, May 18, 1984, i "Postconstruction Inspection of Electrical Equipment and Raceways."
- 9. TUGC0 Procedure No. QI-QP-11.3-50, Revision 10, February 8, 1984, i
" Cable Grip Support Installation Inspection."
i
- 10. TUGC0 Procedure No. QI-QP-11.14-12, Revision 4, July 28, 1983,
" Reverification of Seismic Electrical Equipment Mounting Details."
F
- 11. TUGC0 Startup Administrative Procedure No. CP-SAP-3, Revision 12, June 21, 1983, " Custody Transfer of Station Components."
- 12. TUGC0 Startup Administrative Procedure No. CP-SAP-6, Revision 9, March 10, 1983, " Control of Work on Station Components After Release from Construction to TUGCO."
- 13. TUGC0 Startup Administrative Procedure No. CP-SAP-21, Revision 2, February 29, 1984, " Conduct of Testing."
- 14. CPSES Station Acministration Manual, Procedure No. STA-802, Revision 1, January 10,1984, " Final Acceptance of Station Sys-tem.s, Structures and Equipment."
~ ~ ' ' " ~ ~ ~ ~ ~ ~ ~
E E_--[_E Z -"' ~ El--- l~~E~" - '
_ 10 -
- 15. NRC Investigative Report 50-445/81-04 and 50-446/81-04, May 5, 1981.
- 16. Pre-filed Testimony before ASLB, May 24, 1982, Page 80.
- 17. GAP Notes of April 1984 (Confidential), Paragraph 6, GAP Witness H.
l
, 18. Confidential Affidavit of GAP Witness (Paragraph 6) of June 27, 1984.
- 19. GAP Notes of April 1984 (Confidential), Paragraph 7, GAP Witness H.
- 20. GAP Notes of April 1984 (Confidential), Paragraph 25, GAP Witness I.
1
- 21. Confidential Affidavit of GAP Witness H, July 16, 1984, Pages 10-11.
- 22. NRC Special Review Team Report, July 13, 1984.
- 23. Deposition of SRT Witness A-5, July 17,1984, Pages 55,000-55,164
- 24. TUGC0 Office Memorandum # TUG-2134, " Transmittal of Final Report on Issues Resulting From Interviews with Electrical Inspector j .ay 22, 1984.
- 25. Deposition of GAP Anonymous Witness, July 25, 1984, Pages 58,503-58,591.
5
- 26. Deposition of GAP Witness, July 16, 1984, Page 53]03-53,263.
7,,. . _ . . . _ _ _ . . . ... .._ _.-.. . ,.
- l .
- 27. NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18,
- t
, 50-446/83-12, April 11, 1983.
- s
'i
- 28. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding il l the Findings of CAT; June 13, 1983, Pages 7733-7755; June 15, 1983, il Pages 8160, 8231, 8261-8263; June 16,1983, Pages 8358, 8367, 8368-8373.
- 29. NRC Interview with SRT Alleger A-3, September 6, 1984, Pages 9-12, 17-27, 30-40, 48-83.
- 30. This statement prepared by:
Allen R. Johnson Date TRT Reviewer Hulbert C. Li Date TRT Reviewer Reviewed by: Jose A. Calvo Date Group Leader Approved by: Vincent S. Noonan Date Project Director M l
Document Name: ELECTRfCAL 9
'e Requestor's ID:
JEAN Author's Name: A. Vietti/kb Document Ccements: AQE-7 and AQE-43 frcm CP1 (REVISION 9/29-HQ) Il{z C/J-'l-yy - . - . . . . . . - . ~ . . . . . . . - , . - . . . . . . . . . . . ~ . . . . . . . . . - . .
. s
?-
- 1. _Ailegatfon Grcup: Electri al i strumentation Category Nc. 9 - Electrical Inspection. Reports, Inspection Item Removal Notices and In-Process Inspections.
- 2. Allegation Nonters: AQE-7 and AQE-43
- 3. Characteri:stion: It is alleged that the number of required in process inspectioris per procedure were not being conducted and that inspection reports (irs) were being written without~re-inspections to close out inspection item removal notices (IRNs).
- 4. Assessnent of Safety Sicnificance: The implied safety significance of these .ger.eral allegations is that a reduction of in-process inspections and omissien of re-inspections could compromise the quality of the instaliation of safety-related components.
In-Process Insoections. The Technical Review Team (TRT) examined current and past quality inspection procedures in the electrical di:cipline to determine the number of in process 4nspections required. The TRT found that Texas Utilities Generating Ccmpany (TUGCO) precedure QI-QP-11.3-28,
" Class IE Cable Terminations," was the only electrical quality inspection !
procedure which defined a specific number of required in process inspec-tions. Through Revision 4 (dated July 16,1980), the procedure required a minimum of 10 in process inspections per shift. Revision 5 of the pro-cedure (August 7, 1980) changed the quantity required to "a weekly" in-process inspection.
~
-g-The TRT interviewed quality control (QC) personnel to learn the basis for the revision to the procedure. However, the individuals responsible for this revision were no longer employed at Comanche Peak Steam Electric Station (CPSES) and could not be contacted. Current QC personnel could only speculate that " level of confidence" was the basis for the change.
The TRT interviewed the project engineering manager to determine the Class 1E cable termination activity profile when the procedure was reviewed. From the discussion, the TRT determined that less cable termination activity occurred in early 1980 compared with late 1980 to mid-1981, when cable termination activity was approaching its peak. Comparing cable termination activity for these two years, that is, for the period between Revisi~ o n 4 and 5 of the procedure, with the results of the quality assurance (QA) trend reports for 1980 (third and fourth , V quarters) and 1981 (first and second quarters) on nonconformance report b
"}- ..
(NCR) activity, the TRT determined that adequate QA controls existed in
, y-g .M the inspection process so that an increase in in process inspections was
.y not warranted. Thus,therAbu'ctioninthenumberofinprocessinspections wa tified.
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y)q,[ .-b - f T t " .
.1 1 - .- I O. c . . A d
Inspection Recorts and Inscettien Item Removal Notices. The TRT examined
' ' t 'If ' ' TUGC0 procedure CP-QP-18.0, " Inspected Item Removal Notice Form," for its adequacy to control the inspection process. The TRT determined that this procedure was adequate to assure that reinspections were performed, when required, to verify that the item subject to the IRN was still in conform-ance with the requirements.
I i t #' .
~
The TRT also interviewed two paper flow group (PFG) coordinators, a
, PFG IR clerk, a lead QC electrical inspector, and examined 20 irs and IRNs. The TRT determined that because of the checking and paper pro- ,
cessing involved with irs and IRNs, a PFG coordinator would not be able r to recognize that a signed-off inspection report had been completed without reinspection actually occurring. After discussing this issue , with QC inspectors, the TRT determined that an inspection could be made, but was extremt ly unlikely, without an inspection report in hand. Other-wise, an inspection report could be completed away from the inspection site, from which the inference cculd be made that an inspection had not been made. Although, there are no requ'irements in the procedures to this effect, it is understood within the QC discipline that an inspection will not be performed without all required documentation. The TRT contacted the alleger for specific information, but no additional information was provided by this individual. Further, the alleger acknowledged when making the allegation that this part of the allegation was based on hearsay information.
- 5. Conclusions and Staff Positions: Based on the review of the pertinent 3 . ,,,
i d
/ ocuments and interviews, the TRT concludes that the electrical-related
.. 4 / allegation concerning completion of an inspection report without re
'f
- __ _
, tion has no safety significance. The TRT also concludes that the elec-trical-related allegation of not performing the required 10 per-shift in process inspections has neither safety significance nor generic
([p.\ -_ _ implications. However, the results of this evaluation will be further (; >
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c , <-. assessed as part of the overall programmatic review of irs, IRNs ank'N - in process inspections addressec under QA/QC Category No. 6, "QA/QC Inspection)' Therefore,7he-fina-1-acceptabilitV oft 'his .. . .evaluation
..- will
/
be predicated on the results of the overall prograncatic review on this subject. Any adjustments to the:e conclusions will be reported in a supplement to this SSER. I
- 6. gtiensReauired: None.
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- 8. Ar achments: None.
- 9. Reference Occaments- t
- 1. TUGC0 Frecedure CP-QP-18.0, " Inspection Repert.'
- 2. Brown and Root (BLR) Procedure CP-CFM-6.10, " Inspection Item Removal Notice Fom."
3. i, NRC Investigativa Report 50-445/81-04 and 50-4t6/81-04, Pay 5, 1981. '
- 4. NRC Special Review Team Report, July 13, 1984.
- 5. TUGC0 Office Meme.randum # TUG-2134, "Tean:mittal of Final Report on Issues Resulting From Interviews with Electrical Inspectors" Nay 22 1984. 11 J,
, 6. NRC Construction Appraisal Team (CAT) Inspection Report 50-445/83-18, 50-446/83-12, April 11, 1983. j 1 il t-t i l
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- 7. TUGCO, et al, Hearing before the ASLB, NRC Staff Testimony Regarding the Findings of CAT; June 13, 1983, Pages 7733-7755; June 15, 1983, Pages 8160, 8231, 8261-8263; June 16, 1983, Pages 8358, 8367, 8368-8373.
- 8. NRC Interview with SRT Alleger A-3, September 6,1984. P, ages 8, 21, 42-45, 48-79, 81-83.
- 10. This statement preparec by: ,.
James C. Selan Date TRT Reviewer Reviewed by: ' Jose A. Calvo Date Group Leader Approved by: Vincent S. Noonan Date Proja-t Director 4 i I
r j Document Name: AT-18 TEST PROGRAM CATEGCRY 8 ' s Requestor's ID: ~ l
'4 PAT '
g Author's Name: ,
. A. Vietti/kb Docu=ent Cce:nents :
11/8/34 Final Dra ft, Rey, 1 e j
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, Final Draft, Rev. 1, 11' AT-1S Test Program Catege SSER
- 1. Allegation Category: Te:t Programs No. 8
- 2. Allegation Nun'f_r: AT-18
- 3. Char 4cterization: It is alleged that quality assurance / quality ccatrol (QA/QC) surveillance of test program activities was minimal.
- 4. Assessment of Allecations The implied safety significance of the allega-tion is that QA/QC surveillance may not h:ve been sufficient to ent.ure that the testing progran met its objective, that is, demonstrated that plant structures, systems, and components were capable of performing their intended safety-related furctions.
Title 10 of the Cede of Federal Regulations, Part 50 (10 CFR 50) Appendix B, Criterion XI, requires a testing program to be identified that will demon-strate the satisfactory performance of safety related struttures, Systems, and ccmponents, and that the testing be conducted in secondar.c; with written procedures which incorpsrate the requirements and acceptance cri* teria of applicable design docarents. Appendix F, Criterion X, requires an inspection program to be established to ensure that activities affecting quality cuch is testing of safety-related structures, systems, and ccmpc-nents, are carried out preperly. The NRC Technical Review Team (TAT) reviewed the pecgrams that Texat Utilities Electric Company (TCEC) had established and implemented ic order to mee t these NRC require.r.ents. The IRT's review of the prerequisite end preoperational tecting pr: grams is described in Test Program Categories 1 ".hrough d of this SSER. The TRT al. o reviewed TUEC's QA/QC progran fcr inspection of testing activities. The QA/QC inspect:en progran ts described 'n the Cemanche Pe:k Stcan Elect.ric Staticn ( PSES) Fin'l Safet'; analysis I:epart (y3AR), Chapters 14 end 17, and is augmented by the Cf3ES Startup Quality Assur-ance Plan. This plan delineates rcspensibili:les aal .neasures for accom-
; !ishing .nd com r l ' n.; tc Gn;; actit iq es. TCCC's h ger , Qaslii)
Assurance, was responsible for verifying preper implementation of the plan. This responsibility was assigned to the Construction and Startup/ Turnover Surveillance (CSTS) group which was located on the plant site and reported directly to the !!anager, Qual'ity Assurance.
- In order to deteraine the extent of this group's surveillance of testing activities, the TRT reviewed CP-QP-19.6, "Sarveillance of Construction and Startup/ Turnover Activities" and referenced doccments which prescribed the method fer, and frequency of, conducting survetilances (cut of 174) con-ducted during 1982, 1983, and the first half of 1984, as well as 5 un-planned surveillances (out of 37) cenducted during 1983 and the first half of 1984. The TRT found that a surveillance schedale, which was updated s f f'/ monthly to acceemadate changes in the testing. schedule, dictated the fre-quency of the QC surveillances by the CSTS group. The schedule was
< sa
,- I< prepared by the CSTS staff and approved by the CSTS Supervisor es required by CP-QP-19.6. The schedule required surveillance cf certain aspects of each precpecational test scheduled and a minimum of 30 percent cf the peer'equisit e tests associated with each preoperational test.
In interviews with cognizant CSTS personnel, the TRT found that the sampling of the prerequisite tests was such that each test would come
/ .
1 under sur~eillance at least annually. These prerequisite tests are generic and are performed to verify such things as cceplet: installation, functional operability, and cleanliners. Preoperation21 tetts, on the s-other hand, are perforced to verify that structures, systens, and compen-
-d , - ' .' ,
[ ents meet their safety-related design functions. ~herefore, the snaller sample size for prerequisite test survetilance is appropriate because the precperational tests are the NRC-required perforaance proof tests and the TRT fcund that these undergo considerable surveillance.
~
The surveillance schedale also covered reviews of the administrative pro-
, cedures by which the testing personnel cenducted their program. These reviews were scheduled to cover each administrative procedure at least annually.
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( < E The TRT also fcund that a detailed checklist was prepared for each sur-y) .
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- veillance by the assigned CSTS inspector. These checklists referenced u....
applicable drawings, procedures, and regulatory requirements, and included e , . _ . . f (. --uch attributes as the qualifications of testing personnel, ver,ifiq;tt' ion
. - - . - . . . . . . . , . ... s j
N,(tWgc v of equipment results, and d[ rect performance observationscharacteristics, of testing activities proper to verify documentation adherence of tect to procedures, use of correct revisions to applicable testing documents, and proper completion of prerequisite conditions. Additionally, the TRT observed the use of QC " hold points" in their review of preoperational test procedures which was conducted in conjunction with a review of allegaticas in Test Progras Categories 1, 3, and 5 of this SSER. This indicated to the TRT that the CSTS group also performed sgecific reviews of these procedures before the start of a particular test. In addition to the surveillances listed above, the TRT also reviewed five audits (out of seven) conducted by TUEC's Dallas QA group between late 1932 and the first half of 198G to deter =ine the extent of involvement by TUEC Corporate QA in the testing program. These audits were found to be ccmprehensive, and the frequency at which they were conducted was consis-tent with that established by DQP-CS-4, " Procedure to Establish and Apply a System of Pre-Award Evaluations, Audits, and Surveillances." This is also commensurate with the safety significance and pace of the preopera-tional testing activities as described in NRC Regulatory Guide 1. 33.
- 5. Conclusions and Staff Position: The TRT concludes that the frequency and
' degree of TUEC's QA/QC inspection of testing activi. ties was appropriate, commensurate with the safety significance of the specific activity under surveillance, and in compliance with N'RC requirements. Accordingly, this '
allegation has neither safetf significance nor generic implications. r [
- 6. Action Required: None, g (C.k ! O gtt"* \
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- s. A_ttachments: None. hJ c.
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- 9. Reference Docu.ments:
(1) 10 CFR 50 Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,77 (2) Comanche Peak Steam Electric Station Final Safety Analysis Report (FSAR) , Chapters 14 and 17 through Amendnent 50, July 1984. (3) TUGCO-Dallas Quality Procedures / Instructions Muaual, June 23, 1904. g (4) Comanche Peak Steam Electric Station Startup Quality Assurance Pla'n, Revision 1, January 19, 1983. (5) TUGC0 Quality Procedures Manual, Procedure CP-QP-19.6, " Surveillance of Construction and Startup/ Turnover Activities," Revision 5, May 15, 1984; Revisica 6, June 20, 1984. * (6) TUGC0 Quality Procedures Manual, Procedure QI-QP-19.6-1,
" Surveillance Deficiency Reports," Revision 0, May 15, 1984.
(7) TUGC0 quality Procedures Manual, Procedure CP-QP-2.6,
" Certification of CSTS Personnel," Revision 2, May 15, 1984.
(8) DR (Surveillance) Nos. 83-004, 83-012, 83-020, 84-005, and 84-0c9. (9) CSR (Surveillance) Nos. 82-002, 82-003, 82-010, 82-015, 82-023, 82-026, S2-029, 82-033, 82-040, 82-047, 82-063, 32-066, 82-072, 83-001, 83-002, 83-007, 83-010, 83-013, 83-022, 83-024, 82-027, 83-023, 83-035, 83-039, 83-049, 33-053, S4-001; 84-008, 84-032, and 84-036. (10) T'.~2C-Call u QA ' u.';; Nos . T51*-1, TSL'-2, TSU-3. 7?C-4, .u.i TSU-6 (11) NRC Regulatory Guide 1.33, Revision 2. 1975.
5
~* .
(??) TUFC-Dallas Quality Procedures /Ir.structions Manual Frccedure EQP-CS-4, " Procedure t: Establish and Apply a System cf Fre-Award Evaluations, Audits, and Surveillance," Revision 10, June ', 1984 (13) TUEC-Ds11 .' Quality Frecedures/ Instructions Manual, Instruction DQI-CS-4.6, "Cor.dyct cf Internal, Frire, and Subcontractor Audits ," , Revisien 7, April 13, 1984. (14) Har.dwritten notes taken by GAP (Tillie Garde) with witr.ess H.
- 10. This statement prepared by: _
Arthur Mackley Date TET Eeviewer Reviewed by: Richard R. Keimig Date Greup Leader Approved by: Vincent S. Nocnan Date .: ,, Project Director L
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[* .Cocument Name:
.- .' SSER TEST PROGRAM 3 N
Requester's ID: PAT Auther's Name: Chet Poslusny Document Cecments: 11/8/84 Final draf t, rev.1
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Revision 3 CP1 sser at-12 SSER
- 1. A11ecation Catecory: Test Programs No. 3
- 2. Allegation Number: AT-12
- 3. Characterization: It is alleged that unless ordered to do so by the NRC
] Atomic Safety and Licensing Board (ASLB), Texas Utilities Electric Company (TVEC) will not conduct a testing program on Unit 2, but will rely instead on the results of the Unit I testing program to support Unit 2 operation. i
- 4. Assessment of Safety Significance: The implied safety significance of
, this allegation is that safety-related structures, systems, and components associated with Unit 2 would not undergo a testing program to verify that the plant has been properly designed and constructed to assure public health and safety.
1 The NRC Technical Review Team (TRT) reviewed TUEC's preoperational testing program for Comanche Peak, Unit 2. The TRT reviewed TUEC's j Final Safety Analysis Report (FSAR), Chapter 14.0, " Initial Test Pro-gram," and found it to be consistent with NRC Regulatory Guide (RG) 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear' I Power Plants," and RG 1.63, " Initial Test Programs for Water Cooled
' Nuclear Power Plants." TUEC is committed in the FSAR to meeting both \
of these regulatory guidelines. Regulatory Guide 1.68 requires that } all structures, systems, and components that are important to safety be i tested. . The Comanche Peak FSAR Chapter 14.2.1, " Summary of Test Programs and ] Cbjectives," states that the purpose of the startup program for Comanene Fean Steam Electric Station (CPSES) is to assure tnat the instailec i station structures, systems, and components will be subjected to tests to verify th~at the-plant has been properly design;d and constru:ted and is
- ready to operate in a manner that will n'ot endanger the healtn and safety
of the public. The FSAR for Comanche Peak encompasses both Units 1 and 2. Accordingly, this statement does not imply that testing will be conducted only on Unit 1. Figure 14.2-3, " Preop,erational Test Schedule," and Figure 14.2-4," Initial Startup Test Schedule," indicate that the respec-tive schedules are applicable to both Unit 1 and Unit 2. The TRT also reviewed TUEC's "AT/PT' Test Index with Schedule, Unit 2-CPSES," (July 18,1984). This document previded an index of accep-tance &creptagne tests (ATs) and preoperational tests (pts), including .
. test numbers, revision numbers, and procedure titles for the projected Unit 2 testing program. Due to the uncertainty of when Unit 2 construc-tion will be completed, this document does not show a projected schedule.
The TRT compared the Unit 2 index with RG 1.68 and with the Unit 1 index and found them to be consistent. Only systems which were shared by Unit 1 and Unit 2 and were fully and successfully tested during the Unit 1 testing program were not scheduled to be tested d' u ring the Unit 2 testing program. Examples of these " shared" system tests (which were listed on "AT/PTTestIndexwithSchedule,UnitIandCommon,"datedJuly9,1984) included: Waste Gas System Leak Check; Control Rocm Heating and Ventilation System; Telephone and Radio Systems; Primary Plant Ventilation System; Primary Plant Ventilation Supply System Cooling. The control room heating and ventilation system is typical of the commonality of these systems. Units 1 and 2 share the same control rocm, and it has one heating and , ventilation system. Because the heating and ventilation system was tested when Unit I testing cccurred, it need not be tested during the Unit 2 testing cycle. In #=ct, this system will already be in operation when Unit 2 testing takes place. 4
- 5. Conclusion and Staff Pesitions: The TRT concludes that this allegation is without basis. TUEC has consistently indicated to the NRC staff that Unit 2 would uncergo a testing program subject to NRC requirements.
Accordingly, this alleration bas neither sa'a v e4-a4#4-ance no cere _ipplications. I
- t'e s OAcui-ed: N: 2.
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- 8. . Attachments:
AT/PT Test Inds,v with Schedule, Unit II - CPSES, July 18, 1954 l AT/PT Test Index with Schedule, Unit I and Common, July 9,1984
- 9. Reference Occuments:
- 1. 10 CFR 50 f
.g
- 2. CPSES FSAR, Chapter 14 S,
- 3. RG 1.70 k
- 4. RG 1.68
- 5. AT/PT Test Index with Schedule, Unit II - CPSES, July 18, 1984
- 6. AT/PT Test Index with Schedule, Unit I and Common, July 9, 1984
- 7. NRC MC 2513 .
- 8. NRC MC 2514
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- 9. Citizens Association for Sound Energy (CASE) proposed contention $
g No. 26, October 13, 1933 g i1
- 10. This statement prepared by: i Richard R. Keimig Date Group Leader t
Reviewec by: Richard R. Keimig Date Group Leader 4-Approved by: Vincent S. Noonan Date Project Director I
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