ML20199E114

Draft B,Rev 0 to Policy on Testing & Insp Personnel Used in Third Party Verification Activities

ML20199E114
Person / Time
Site:	Comanche Peak
Issue date:	02/28/1985
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
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References
FOIA-86-36 PROC-850228-03, NUDOCS 8606230190
Download: ML20199E114 (22)

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, , Policy on Testing cnd Insp2ction DRAFT: B i

Parsennal Ustd in Third Ravicion: 0 Party Verification Activities 02/28/85, Page 1 of 8 i 1.0 PURPOSE

• Section III.G of the CPRT Program Plan states that inspection, testing (other than preoperational testing) and NDE activities may be conducted by third parties. This Policy governs the selection and certification of third party organizations and the certification of persor.nel to perform these activities.

2.0 INTERFACE WITH TUGC0 PROGRAMS This Policy applies to the certification of personnel used to perform inspection, testing, and examination activities as part of CPRT Action Plans. If inspections, tests or examinationa are performed by third party personnel that are intended also to satisfy TUCCO QA Progrs= requirements (e.g. to replace inspections previously performed or required to have been performed), the third party personnel performing those activities will also require certification under TUGCO's QA program. The requirements for that certification are outside the scope of this policy.

The Program Plan describes two situations with respect to inspections:

All inspections required by an Action Plan are performed by third party personnel.

- Inspections required by an Action Plan are performed by CPSES personnel with an inspection validation program conducted on a sa=pling basis by third party personnel.

This Policy governs the third party personnel in both of the above cases. CPSES personnel performing inspections will be certified in accordance with applicable CPSES requirements and any additional CPRT requirements.

3.0 DEFINITIONS 3.1 Inspection A phase of quality centrol which by means of examination, observation, or measurement determines the conformance of materials, supplies, parts, components, appurtenances, systems, processes, or structures to predetermined quality requirements.

3.2 Examination An element of inspection consisting of investigation of materials, supplies, parts, components, appurtenances, systems, processes or structures to determine conformance to those specified requirements which can be determined by such investigation. Examination is usually non-destructive and includes simply physical manipulation, gaging, and measurement.

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, Policy en Tasting cnd Inspsetion DRAFT: B Parcson21 Lasd in Third Rsvision: 0 Party Verification Activities 02/28/85, Page 2 of 8

( 3.3 Testing

• The determination or verification of the capability of an item to meet npecified requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions.

4.0 POLICY 4.1 General The CPRT Program Plan provides general requirements for the certification of inspection, test and examination personnel.

This procedure governs certification of inspection, test and examination personnel performing third party verifications.

4.2 Responsibilities 4.2.1 Review Team Leaders Review Team Leaders are responsible for identifying in Issue-Specific Action Plans those activities requiring the use of certified inspection, test ur examination personnel and using certified personnel as appropriate.

4.2.2 QA/QC Review Team Leader

.t The QA/QC Review Team Leader is responsible for ensuring certification of inspection, test and examination personnel and organizations performing third party verification activities and verification that background, education and experience requirements are met.

He is also responsible for determining the indoctrination and training requirements, and preparing and conducting the required training programs.

4.2.3 Level III Certifying Agent The Level III Certifying Agents are responsible for administering written examinations.

4.3 Instructions 4.3.1 Requirements All third party personnel performing " hands on" inspections, examinations or tests are to be certified in accordance with USNRC Regulatory Guide 1.58-Rev. 1, 1980 which endorses ANSI.N45.2.6-1978.

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, Policy on Tsseing end Inspretion DR/rT: B Psrasnnal Ussd in Third RIs.sion: 0 Party Verification Activities 02/28/85 Page 3 of 8 i 4.3.1 Requirements - (Cont'd) ~

Qualification of inspection, examination, and testing personnel is performed by discipline as indicated below.

Mechanical (includes hangers, equipment installation, piping instrumentation).

Civil (includes. concrete, structural, soils, laboratory, coatings).

Electrical (includes raceway, terminations, cable pulling, equipment installations).

Welding (pipe, structural and HVAC).

Quality (includes documentation, calibration, receiving, vendor surveillance) .

Special Processes.

The education and experience requirements for each level of inspection, examination and testing personnel are given in Attachment 5.4.

1 4.3.2 Certification Levels Within each discipline, inspection, examination, and testing personnel will be qualified to one of the levels listed below.

4.3.2.1 Level III Personnel A Level III person will have all of the capabilities of a Level II person for the inspection, examination or test category or class in question. Additionally, the individual shall be capable cf evaluating the adequacy of specific programs used to train and test persennel performing inspections,

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I tests, or examinations. The individual shall be capable of reviewing and approving inspection, examination and test procedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination and test objectives.

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Policy en Testing and Insptction DRAFT: B Personn31 U::d in Third Revision: 0 Party Verification Activities 02/28/85 Page 4 of 8 4.3.2.2 Level II Personnel

• A Level II person will have all of the capabilities of a Level I person for the insp.ctica, examination or test category or class in question. Additionally, a Level II person shall have demonstrated capabilities in planning inspections, examinations, and tests; in setting up tests including preparation and set-up of related equipment, as appropriate; in supervising or maintaining surveillance over the inspections, examinations, and tests; in supervising and certifying lower level personnel; in reporting inspection, examination, and testing results; and in evaluating the validity and acceptability of inspection, examination, and test results.

4.3.2.3 Level I Personnel A Level I person will be capable of performing inspections, examinations, and tests and recording related results. The individual shall be familiar with the tools and equipment to be employed and shall have demonstrated proficiency in their use. The individual shall also be capable of determining that the calibration status of inspection and measuring equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examination, and test procedures are approved.

.3.3 Inspection, Test or Examination Agency Selection The responsible Review Team Leader may elect to contract with a third party agency to perform inspection, test or examination activities. Prior to the award of a contract to a third party agency the responsible Review Team Leader shall notify the QA/QC Review Team Leader and request QA qualification of the proposed Agent. The QA/QC Review Team Leader shall conduct an audit to verify that the Agent meets the requirements of this policy for the certification of inspection, test and examination personnel. If a third party agency has been previously approved by TUCCO for similar inspection, test, or examination activities, the QA/QC Review Team Leader may limit the audit to a review of TUEC documentation. These audits shall be performed by qualified Lead Auditors, documented and filed in accordance with the Program Plan. If the QA/QC Review Team Leader determines that a third party

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Policy on Testing End Insp2ction DRAFT: B Parsonnal Ucad in Third Revision: 0 Party Verification Activities 02/28/85 Page 5 of 8 4.3.3 Inspection, Test or Examination Agency Selectich -

(Cont'd) agency meets the requirements of this policy, the third party agency may use its own procedures for certification of inspections, test, and examination personnel.

4.3.4 Inspection. Test and Examination Individual Selection The recuirements of this section apply to personnel other - an those associated with a third party agency approved in accordance with Section 4.3.3 cf this policy. Personnel from approved third party agencies are subject to the agency's procedures.

The responsible Review Team Leader shall provide each candidate with a Qualification Questionnaire form (Attachment 5.1) and an Eye Test Certification form (Attachment 5.2).

The candidate will complete the Qualifications Questionnaire. The Eye Test Certification form will be completed in accordance with Attachment 5.2. The Qualification Questionnaire and the Eye Test Certification form are to be forwarded to the QA/QC Review Team Leader.

The QA/QC Review Team Leader will evaluate the candidate's education, experience and qualifications to determine which level the candidate m..y be certified to, based on the requirements contained in Attachment 5.4. The results of his evaluation shall be entered on the Qualification Questionnaire.

4.3.5 Training The QA/QC Review Team Leader or his designee will determine the site specific and on-job training requirements for each-individual, schedule and monitor the training program implementation. A record of each individual's training and examinations shall be maintained. '

4.3.6 Examination All candidates for certification to ANSI N45.2.6 are to demonstrate their capabilities by satisfactorily completing a written specific examination.

Specific examinations may be conducted in accordance with the procedures of an approved third party agency.

Policy en Tsating and Insp cticn DRAFT: B

'. Parsonnal Uccd in Third Ravicion: 0 Party Verification Activities 02/28/85, Page 6 of 8 4.3.6 Examination - (Cont'd)

• The Specific Examination shall cover those subjects applicable to the activities that the candidate may encounter in his specific assignment.

Examination questions will be increasingly more difficult for higher levels of certification to assure a comprehensive understanding of the subject material.

Written examinations shall be administered without access to reference material (closed book) except that necessary data may be provided as attachments.

Test question banks will be safeguarded to eliminate access to personnel other than the Level III Certifying Agent or QA/QC Review Team Leader.

4.3.7 Grading of Examinations Where an approved third party agency conducts the examination, its procedures shall govern grading of examinations, otherwise the follcwing will apply.

The Level III Certifying Agent or his designee shall be responsible for administering and grading examinations of all Level I and Level II individuals.

ExaminationsohcandidatesforLevelIIIcertification shall be admiaihtered and graded by the Level III certifying agen't and reviewed by the QA/QC Review Team Leader.

A minimum grade of 80% is required for passing of sny i examination. The examinations need only be taken once for each Level of Certification and a person satisfactorily passing an examination for one level does not have to pass the equivalent examination for a lower level provided he meets the education and experience requirements of that level.

Candidates failing to attain the required grades shall be given additional reading assignments, as determined by the Level III Certifying Agent, before re-examination.

9 Perscnnel shall be allowed one (1) retest for each certification test failed. Retests shall be a diffarent test from the initial test.

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Policy on Testing and In2pretion DRAFT: 3

. Parsonnsi Usad in Third , Revision: 0 Party Verification Activities 02/28/85, Page 7 of 8 4.3.8 Certification

• The Level III Certifying Agent shall review the documentation and certify the candidate to the app;ropriate level for a discipline by completing the P.ersonnel Certification Form (Attachment 5.3), with the approval of the QA/QC Review Team Leader or the procedures of an approved third party agency shall be used.

The QA/QC Review Team Leader shall certify all Level III's other than those certified by an approved third party agency.

4.3.9 Recertification All levels of inspection, test and examination personnel shall be recertified at least once every three years by re-examination or evidence of continuing satisfactory performance. Evidence of recertification shall be provided by issuance of an updated Personnel Certification Form (Attachment 5.3).

Each individual shall be requalified when he has not performed inspection, examination, testing or procurement activities in the specific discipline for a period of twelve months.

4.3.10 Revoking Certifications t The Level III Certifying Agent, QA/QC Review Team Leader, or those designated by the approved third party agency shall. revoke or suspend certifications, at any time, for the following reasons:

Failure to pass annual vision examination or

, for other physical impairment.

Gross or repetitive noncompliance with applicable requirements.

Termination of employment.

When maintenance of certification is no longer needed.

The reason (s) for revocation shall be documented in a memorandum to the inspector's certification file, and action shall be taken to prevent utilization of the person in the applicable inspection activities.

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Policy on Testing and Inspection DRAFT: B

, Personnal Ussd in Third Revision: 0 Party Verification Activities 02/28/85 Page 8'of 8 4.3.11 Files -

The following information shall be documented and retained in the CPRT Project and Working Files as required by the Program Plan:

Audit reports and completed checklists of audits conducted to qualify Inspection, Test or Examination Agencies.

Qualification Questionnaire.

Eye Test Certificate.

Record of individuals training program.

Written examinations and grading.

Personnel Certification Forms.

(Certification and recertification).

Certification revocation memorandums.

5.0 ATTACHMENTS The following accachments are typical forms that may be modified as appropriate by the QA/QC Review Team Leader. Third party agencies approved in accordance with Section 4.3.3 of this policy may use their own forms.

5.1 Inspection / Test Personnel Qualification Questionnaire.

5.2 Eye Test Certification.

5.3 Personnel Certification.

5.4 Education and Experience Requirements.

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k OFFICE MEMORANDLH TO: Review Team Leaders FROM: ,

Senior Review Team DATE: February 14, 1985

SUBJECT:

Policy on Testing and Inspection Personnel used in Third Party Verification Activities The attached is a policy statement by the SRT that governs the qualifications and use of third party personnel used for inspection and testing activities covered by the CPRT Program Plan.

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g COMANCHE PEAK RESPONSE TEAM ACTION PLAN b '

Item Number: I.t

Title:

Electrical Conduit Supports Revision No. 0 1 2

Description Original Issue Revised to Reflect Incorporates NRC Coments SSER WY$ w

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r Prepared and Recomended by:

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Revision: 2 Page 1 of 12 ITEM NUMBER I.c Electrical Conduit Supports

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT examined the non-safety related conduit support installation in selected seismic Category I areas of the plant.

The support installation for non-safety related conduits less than or equal to 2 inches was inconsistent with seismic requirements and no evidence could be found that substantiated the adequacy of the installatian for non-safety related conduit of any size. According to Regulatory Guide 1.29 and FSAR Section 3.7B.2.8, the Seismic Category II and non-seismic items should be designed in such a way that their failure would not adversely affect the function of safety related components or cause injury to plant personnel.

2.0 ACTION IDENTIFIED BY NRC Accordingly TUEC shall propose a program that assures the adequacy of the seismic support system installation for non-safety related conduit in all seismic Category I areas of the plant as follows:

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Provid the results of seismic analysis which demonstrates

• g g g /p gy d that all non-safety related conduits and their support J systems, satisfy the provisions of Regulatory Guide 1.29 and ,

F -[k edb5 ,3/FSARSection3.7B.2.8.

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verify that non-safety related conduit less than or equal to 2 inches in diameter, not installed in accordance with the ff ccm)

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]7g/ ,rT)L,requirements design of Regulatory Guide 1.29, satisfy applicable f

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3.0 BACKGROUND

3.1 Information Supplementing NRC Descripcion of Issue The issue pert.ains to non-safety related conduits (Trairt C, non-Class IE) which, consistent with FSAR criteria, have not been seismically supported by design based upon the significance to safety. This issue was addressed generically throughout the plant by the TRT with specific interest in documentation justifying the non-seismic installation requirements for the non-nuclear safety related conduit less than or equal to 2 inches in diameter.

' The generic issue of non-seismic support of Train C hardware has been addressed during the construction of CPSES through the CPSES Damage Study Program. This systematic study was performed for the interaction of all non-seismic piping and conduit greater than two inches in diameter, equipment, and

Revision: 2 Page 2 of 12 I

\. ITEM NUMBER I.c (Cont'd)

3.0 BACKGROUND

(Cont'd) structures vf.th safety-related components in Category I buildings for Unit I and common areas. The support of conduit less than or equal to'2 inches in diameter was assumed to be adequate to assure that the conduit would not result in an adverse interaction during a seismic event. Accordingly, this interaction was not considered by the Damage Study. This assumption was bas.ed upon industry practice which recognized the inherent capacity of the anchorage and supports for these relatively lightly loaded installations. Uncontrolled calculations were generated in support of this assumption.

Design document DCA-4693 delineates support classification requirements and DCA-5106 delineates typical support details for Train C conduit two inches in diameter or under.

In accordance with Regulatory Guide 1.29 the CPSES Damage j, b cr. f cI. y C Study was performed to demonstrate that the failure of CW 7 adjacent non-seismic items due to an SSE would not reduce the tw/ g fo d functioning of Seismic Category I systems and components, as defined in position C.1.a. through C.1.q. of the Regulatory

(' )ce*f v w4.4 l Guide and FSAR Section 3.7B.2.8.

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The saismic/non-seismic interactica study, which was performed ND V

c/ in 1983, involved the walkdown of 287 rooms. The walkdown of 0,

a room was performed in accordance with Engineering D[

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4 Instruction CP_-EI-4.0-36_ (Control of Seismic and non-seismic e[CPte7 ],O~ j' Component Interaction Evaluations) with all potential i ^, interactions eva12sted to the accepeance criteria deve1oped g- T' .L%f for the study. Methods for resolution of potential k I A# finteractions of a falling source impacting a nuclear related I

t' M , gO 7 7 ,n i. class carget consisted of analysis, evaluation, use of iN ".

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l / ln barriers, administrative controls, or addition of seismic

@g# I d -%4d ,-7* ,/ [ .k supports or restraints. Each of these activities includes pertinent requirements of the CPSES QA program. Maintenance of this evaluation is performed in accordance with Engineering  :

hl Instruction CP_EI-4.0-53 (Maintenance of Damage Study Analysis).

3.2 Preliminary Determination of Root Cause and Generic Implications The prelizinary reviews conducted to date have not identified a root cause for this item. Implementation of the action plan is necessary before a root cause determination can be made.

The generic aspects of this item are being considered through 3 inclusion of all Train C conduit within the scope of the N

I 7. action plan as described below. Ceneric implications will be I gs evaluated based on the results of the implementation of the

\tc action plan and the results of the root cause determinagion.

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Revision: 2 Page 3 of 12

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s ITDi NUMBER I.c (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology This action plan is designed to document the basis for t'he CPSES Damage Study assumption that Train C, non-seismic conduit two inches in diameter or less would not fall and have a potential for interacting with safety related components.

4.1.1 , Conduit of Diamet'er Greater than 2' Inches 7 -

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)- Qg 3 J As partial responsa co item 1 of-the Action Identified FI Tb by NRC, a'1hird-party' review is' Eo' be performed as part gc b T of Action Plan Item Number II.d, Seismic Design of D { Control Room Ceiling Elements, which will focus on the philosophy and implementation of the Damage Study

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V Program.

The Damage Study program identified 500 non-seismic conduits greater than 2 inches in diameter of which 391

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hadbe vill interactions.

reviewed by The theresolution of these interactions third-party.

4.1.2 Conduit of'Dismeter IAss than or Equal to 2 Inches In response to Items 1 and 2 of.the " Action Identified by NRC", a seismic analysis will be provided that

,! verifies stability and/or acceptable interaction during an earthquake. Two separate samples of 2 inch and under diameter, Train C/non-seismic conduit will be

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determined from the Unit I and common areas. One v l f .

sample will be randomly selected and the other sample will be derived on an engineering basis using a profile of selected conduit against prescribed attributes that are physically important to seismic behavior. A discussion of the conduit sample selection and evaluation process is provided below.

4.1.2.1 Population and Sample The population of 2 inches and under diameter, Train C/non-seismic conduit is represented by approximately 13,500 conduit runs where a rua is defined as a single conduit running between origin and destination (e.g. junction boxes, panels, etc.). Each run has a unique identifying conduit number. The percentage distribution u?

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i Revision: 2 i Page 4 of 12

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ITEM NUMBER I.c .

(Cont'd) 4.0 CPRT ACTION PI.AN (Cont'd) 1 of the population by conduit size breaks down approximately as follows:

3/4"9 -

55%

1" 9 -

17%

1 1/2" 9 -

19%

2" 9 -

9%

The random sample is selected from the 1 1/2 and 2 inch diameter populations, representing a total of approximately 3,738 runs. Sample

< selection has been restricted to this segment of the population because it is most significant from an engineering point of view due to its greater inertia. This is evident from the loaded Neights of the conduit by size:

3/4"9 -

1 pound / foot g' 1" 9 -

2 pounds / foot 1 1/2" 9 -

4 pounds / foot 2" 9 -

5 pounds / foot Supports fall into three ganeral categories:

generic (specified on design document DCA-5106), specials, and seismic S-0910, i representing approximately a 2/1/0.2 split

' respectively. The generic supports hava several predetermined configurations r h recommended dimension tolerances spe e f ed.

The special supports are configured in c.e field, usually consisting of the generic support configuration with a variation to permit ficup under congested circumstances.

The seismic S-0910 supports are seismically qualified for use on Class IE, Train A or B, conduit; however, these have been utilized on Train C, non-seismic conduit under limited circumstances. Individual supports may provide restraint for multiple conduit runs.

i t The Sample Plan is designed to provide 95 percent confidence that the sample will detect a defective race of 5 percent or greater, where a defective is defined as a l

run which fails to meet specified performance N. requirements outlined in Sections 4.1.2.3, f

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I Revision: 2 Page *5 of 12

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ITEN NUMBER I.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.4 and 4.1.2.5. A random sample of 126 conduit runs from the 2 inch and 1 1/2 inch g' g ) J#"

V diameter populations will be evaluated, with an acceptance number of 2 rejects.

The random sample is selected from the

' population of approximately 3,738 runs of 1 1/2 and 2 fach diameter conduit using a table of random numbers, thus, providing an equal chance that any single conduit run may be selected, regardless of its identity, physical attributes or quality. Runs, so selected, that are found in the field to be inaccessible for as-builting, will be excluded from the sample for practicality reasons. ,

Subsequent to the definition of the f population of approximately 3,738 runs of 1

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1/2 and 2 inch diameter conduit, it was determined that a small number of runs were inadvertently omitted from the population during the drawing takeoff process. All of

. these runs will be evaluated in accordance with the provisions of this acti:n plan.

,O The " engineering" sample of 126 conduit runs will be selected for evaluation based upon l engineering judgement. The intent of this

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selection process is to define a subset of the population of conduit runs which is representative of an expected lower bound seismic performance behavior. An individual conduit run is a candidate for selection

1. hh' based upon its profile against specified attributes. As such, if 5 of the following 9 criteria are met, a run may be selected:

l Attribute Selection Criteria l

' 1. Significance to Safety Installed in Areas Containing Equip-ment Required for l

Hot Shutdown

2. Conduit Size g11/2"8 N.

3. Total Length g 20'

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Revision: 2 Page 6 of 12 e

ITEM NUMBER I.c '

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

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L Attribute Selection Criteria

,,- 4. Span Length OneSpan18'

5. Unrestrained Length in g 15' Longitudinal Direction

6. Number of Conduit / >3 Supports ~

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7. Number of Special 2 25% of Supports Supports on Run 8.' Congestion Unrelated Hardware Item within 6 Inches of Run

9. Elevation Upper Half of Building The statistically based, random

• sampling approach represents a singularly effective means of resolving the issue. It provides a clear statistical representation of the behavior of the total population; however, the bias afforded by the engineering sample is judged to provide a more rigorous test of installed hardware. Thus, the engineering sample provides defense-in-depth evidence supporting conclusions to be reached.

\. 4.1.2.2 As-built Physical Configuration Documentation s

[O The subject conduit have been field run.

Isometric drawings or support details are not 8 D, generally available for use in support of the Q. conduit analytical efforts. Field A{

r verification of the installed conduit will be performed by CPPE Engineering in accordance f

with engineering instruction CP-EI-4.0-64, Q A Field Verification of 2" Diameter and Smaller f

Train C Conduit Support Systems. A Third-Party will overview selected portions of this process.

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• Revision: 2 Page .7 of 12 ITEN NUMBER I.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.3 Seismic Analysis and Acceptance Criteria The intent of the seismic analysis is to provide quantitative evidence that the

. conduit support system will perform its intended performance requirements. This simply requires the support system to provide adequate anchorage and support for the conduit such that the conduit does not fall or sway in a mannar to cause an intolerable interaction with a safety related item.

Hardware will be initially screened using acceptance criteria that are consistent with that applied to Seismic Category II support hardware. (Seismic Category II hardware must remain physically intact; however, not necessarily functional as with Category I hardware.) Stress _in the support members it .

will be compared with 0.9 Fy (where Fy is the

's specified minf=n= v f = 9] meranath of the

i g ma't M Anchar'ha1* f=aear= af ==fek ID will be compared to 3.0.

A pseudo dynamic analysis accouncing for important modes of behavior will be performed for each selected run. Each support will be considered independently in the vertical and

~g s transverse directions. Deflection will also

1. /- # be computed to serve as input into a field

- I "valkdown which will verify that unacceptable

f interactions do not exist.

Later screening may be considered if it is t

required to verify a:ceptable performance of runs which do not pass the initial screening criteria. Analytical techniques may be refined and/or limited ductility considered, consistent with the intended performance requirements.

The seismic analysis will be subject to a design review by the third-party.

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Revision: 2 Page E of 12 ITEM NUMBER I.c (Cont'd) 4.0 CPRT ACTIO PLAN (Cont'd)

, 4.1.2.4 Damage Analysis a All selected runs will be considered for E

g [g l interaction with safety related targets due gD p U j to sway or possible fall in circumstances, if U

h p;g i any, where a run fails to meet anchorage and g , aupport performance requirements. This

' ceview will be accomplished through a walkdown by engineering and overview by the third-party.

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4.1.2.5 Population Acceptance Criteria I

'I All identified interactions will be

, evaluated. Any conduit runs predicted to damage safety related targets to failure will (beconsideredasarejectintherandom f sample. All rejected runs will either be

- resupported or restrained as necessary to

' protect safety related equipment. If the number of rejects is greater than 2 for the random sample of 126, two options are available. Option 1 consists of identifying, based on the experience gained in the analysis, the type of connections, supports l

and/or geometries that are prone to exhibit LI- )f *

()j j similar behavior and appropriately evaluate i these or modify them in the whole population g  ; "+ , l including Units 1 and 2. The second Option l

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' random sample utilizing the same 95 percent (f confidence level on the 5 percent defective f * ' ) rate criteria mentioned previously. This option will be selected if the cause for I

/' rejects is either indeterminate or isolated g and without a systematic trend. If the number of rejects is found to be too large {

for even an expanded sample, the entire

' population including Units 1 and 2 will be evaluated. Rejects identified within the

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engineering sample will be dispositioned in a  ;

similar manner as described under Option 1 l for the random sample; however, expansion of '

the enginearing sample is not contemplated.

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Revision: 2 Page .9 of 12 ^

'\' ' ITEM NUMBER I.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2.6 Installation Quality Review The quality of the installed Train C conduit will be addressed as part of the response to 1]ggp/'k NRCs January 8, 1985 letter on QA/QC under

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)i CPRT Action Plans, VII.a.1 " Quality Control s Inspection" and VII.b.4 "Hilti Bolts".

The attached logic diagram identifies tasks and the inter-relationship of tasks for resolution of this action plan.

4.2 Responsibilities The organizations and personnel that will participate in this effort are listed belov vith their respective scopes of work.

4.2.1 Comanche Peak Project Civil Engineering 4.2.1.1 Scope

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sample selection as-built documentation damage analysis assistance in overall evaluation and preparation of Results Report 4.2.1.2 Personnel Mr. R. Hooton Project Civil Engineer Mr. T. Wright Civil Engineer Mr. D. West Field Damage Study Group Supervisor 4.2.2 Gibbs & Hill. Inc.

, 4.2.2.1 Scope seismic analysis acceptance criteria design review

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, ITEM NUMBER I.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Personnel Mr. J. Jan Chief Structural Engineer Mr. P. Huang Principal Structural (g) Engineer

'7 M - 7 Mr. W. Thonguthai Senior Engineer

, 4.2.3 Third-Party Activities 4.2.3.1 Scope review of sample selection oversight of as-built documentation process design review of seismic analysis overview of field walkdovn/ damage study review of overall conclusions overall evaluation and preparation of Results Report 4.2.3.2 Personnel Mr. H. A. Levin TERA CPRT Civil /

Structural Review Team Leader pj% -

fp Dr. C. Mortgat TERA Senior Structural Engineer Dr. F. A. Webster JBA Associate (Engineering Statistics Consultant) 4.3 Personnel Qualification Requirements f

lg' Participants in the implementation of this action plan meet the personnel qualification requirements of the Program Plan or the CPSES Quality Assurance Program as applicable.

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ITEM NUMBER I.c (Cont'd)

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4.0 CPRT ACTION PLAN (Cont'd) 4.4 Procedures The action plan will be conducted in accordance with applicable CPRT guidelines. In addition. instruction.

CP-El-4.0-64. Field Verification of 2" Diameter and Smaller Train C Conduit Support Systems, will be used.

, , 4.5 Standards / Acceptance Criteria f* d I#"

Compliance with FSAR section 3.7B.2.8 and Regulatory Guide

,, 1.29. *

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4.6 Decision Criteria The as-builting effort will provide two samples: one representative of the entire population and the other displaying a lower bound of seismic performance. The analysis of both these samples will determine whether the population of two inch and under meets the requirement of Regulatory Guide q 1.29 and FSAR section 3.7B.2.8. Favorable results of this sampling will verify conformance with acceptable interaction requirements. Unfavorable findings will establish the need for additional review and corrective actions.

5.0 SCHEDULE Sample Selection: Complete As-Built Documentation: Complete Random Sample Analysis: Complete Engineering Sample Analysis: 04/30/85 Refined Analysis: 06/10/85 Damage Analysis: 06/30/85 Results Report: 08/15/85 v.

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