ML20203D412

Forwards Trip Rept 2236 Re 860428-0501 Safety Significance Evaluation Audit at Comanche Peak

ML20203D412
Person / Time
Site:	Comanche Peak
Issue date:	07/01/1986
From:	Landers D TELEDYNE ENGINEERING SERVICES
To:	Barnes I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
6410-66, NUDOCS 8607210204
Download: ML20203D412 (29)

Text

..J l PTFI CDYNE ENGINEERING SERVICES r ss:: .:i.swe

,/ .a-e, v:ssic.,osrs :ns'9195 4'* ?:.335: *?.x .?t : 224-7505 July 1, 19SQ 6410-66 gc l f(l .

Mr. Ian Barnes M United States Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 l Arlington, TX, 76011 l l

Subject:

Trip Report No. 2236 j

Dear Mr. Barnes,

Attached please find the subject trip report which summarizes the )

efforts of TES personnel involved in the safety significance evaluation ,

audit at CPSES from April 28, 1986 through May 1,1986. j If you have any questions, please do not hesitate to contact Messrs.

Bob Hookway, Jim Rivard or the writer. .

l Very truly yours, ,

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TELEDYNE ENGINEERING SERVICES Y TA L Donald F. Landers President DFL:mid attachment cc: V. Noonan (NRC)

C. Tramell (NRC)

A. Vietti-Cook (NRC)

D. Jtng (NRC)

G. Bagchi (NRC)

R. D. Hookway (TES)

J. J. Rivard (TES) 6410 File 9607210204 e60701 PDR ADOCK 0D00044S

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TN ENG3EERNG SERVICES TRIP REPORT NO. 2236 AUDIT REPORT SAFETY SIGNIFICANCE EVALUATION AUDIT AT CPSES SITE 4/28-5/1/86 Audit Team / Company Responsibility R.D. Hookway/TES Piping & Supports -

J.J. Rivard/TES Civil / Structural L. Stanley /Zytor Elec./I&C ,

• The purpose' of this audit was to gain an understanding of the process used by ERC to perform the Safety Significance Evaluations of the Deviation Reports.so that: ,

1. The extent of audit required on this task could be determined.

and

. 2. The most efficient method of audit could be determined.

To do this, the audit team reviewed the evaluations of over 100 deviation reports.'for safety significance. Coments for those evaluations where con-cerns exist, are presented later in this report.

The team looked at evaluations from 22 different populations. There are approximately 33 total populations.

It is expected that there will be over 5000 deviation reports filed when all inspection work is completed by ERC.

A sumary of the populations investigated and the deviation report eval-uations reviewed is shown in the following Table I.

Attachment I (9 pgs.) lists the reviewers notes and comments for each deviation report reviewed in the piping populations.

Attachment II (9 pgs) lists those for the Civil / Structural populations.

Attachment III (6 pgs) describes the work performed in the electrical and instrumentation and control area.

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TF M ENGNEERING SENICES l l

Concerns /Conments i l

A. General I

1. There seems to be a problem with the definition of " Safety Significance". The process to determine safety significance is irreversible. The determination of safety significance is dependent upon the population you are investigating. That is, the same support evaluated in a piping configuration popula-tion may be deemed non safety significant whereby, if it were in a supports population it would be safety significant.

2. There is also a concern, as expressed in the past in meetings, with the use of "cid" design data to perform the safety sig-nificance evaluations. New design data is being generated, for example, for piping, pipe supports, and cable trays as a minimum. Evaluations made using "old" data must be revisited when the new data is available.

B. Piping (related) Populations *

. The review of the 29 S.S. Reports indicated thoroughness, complete-ness and general compliance with the procedures except:

1. R-S-LBSR-016-DR2

, Deviation is lack of material traceability. In the process of evaluation the analyses package was reviewed and found tc be incomplete. This evaluation completed the analyses package in addition to tracking the material.

This evaluation is thorough and okay. However, since this evaluation (for material traceability) uncovered a document deviation in the analyses package of the support. The ques-tion is; with the system in place, will this type of document deviation be found if it e .ists for other supports or com-ponents? Note: A QI review may resolve this.

2. 1-5-PWRE-006-DR-4

• Deviations include two pipe whip restraints located outside the tolerance for the dimension shown on the drawing. The evalustfon discovered a letter to TUGC0 from G&H allowing the relocation. Therefore, the evaluation is okay and concludes non-safety significance.

My concern is why wasn't the information in the letter incorporated onto a revision to the drawing!! And why didn't this become a document deviation report?

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TTHlD(hE EBCAEERNG SERVICES C. Civil Structural Populat.jonj

1. Concrete - Cast-in-place anchor bolts were installed out of tolerance. The evaluation states that the analysis of the anchor bolts and attachment uses the as-installed locations.

This should be verified by a review of project procedures and specific calculations.

2. Similar deviations identified in a number of the populations, including weld deficiencies, support locations, brace con-figurations, may be safety significant if occurring at other locations. The adverse trending should be reviewed to deter-mine how this will be addressed.

3. Equipment Supports - The torque of Unistrut bolts holding an Electric Control Box was determined to be 100 in-lbs instead of 228 in-lbs as required by the installation procedure. The evaluation demonstrated that 100 in-lbs were adequate to sup-port the control box. However, during the reinspection of the torque, it was noted that the mounting lugs began to bend at 100 in-lbs. The concern is that, if in fact 228 in-lbs was used at similar applications, the control box may be damaged.

This attribute should be reviewed in the Elec. Equipment Pop-ulation. This may be sianificant.

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TM ENGNEERNG SERVICES TABLE I No. of S.S. Eval Deviation Reports Avail. No. Evaluations Population Reports (1) for Review (2) Reviewed / Reviewer GENERAL 4 4 4/JJR LBC0 58 16 10/RDH LBSN 266 5 5/RDH LBSR 198 7 6/RDH PWRE 116 2 2/RDH SBPS 85 2 2/RDH SBC0 63 11 3/RDH Conc 58 12 10/JJR Cond. Spts 428 75 6/JJR Eq'T Spts 100 31 3/JJR Fuel Pool Liners 19 3 3/JJR.

Instr. Spts 549 40 1/JJR Liners 88 81 3/JJR Steel 230 42 4/JJR HVAC Spts 249 93 6/JJR Cable Tray 1/JJR Back Fill 610 78 0/JJR Electric Cable (CABL) 75 11/L.S.

Cable Tray (CATY) 62 16/L.S.

Conduit (CDUT) 36 5/L.S.

Electric Equip. (EEIN) 59 12/L.S.

Instrumentation Control (ININ) 72 15/L.S.

Nuclear Instru. (NTST) 2 2/L.S.

Total 123

1. As of this Audit date.

2. This includes only those that have been completed since 3/1/86 using a "new" report format.

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TN ENGINEERING SERVICES Attachment I Page 1 of 9 I. Large Bore Configuration Population (LBC0) o There are 58 Deviation Reports (DR's) for this population, o Only 16 SSE reports have been completed since 3/1/86, 10 were re-viewed during this audit.

I-M-LBC0-039-003

. Six deviations on the CCW system isometric dealing with clearances. The evaluation considers pipe motion based on G&H analyses to justify the small (less than tolerance) clearance. Okay.

I-M-LBC0-063-001 This deviation is a 3" M.S. pipe not centered in a wall penetration. The evaluation looks carefully at the predicted (based on G&H computer analyeses) movements. These movements are smaller than the gaps existing. This eval-uation is okay. (Note: the new write-ups, since 3/1/86 uses 20 pages to do what a 9/85 write-up did in about 4).

I-M-LB C0-069-001 Deviations (4 of them) are clearance problems, o All of these are evaluated by the use of simple hand calculations (e.g. L= ) with no apparent regard for restraints on the system.

(Without a thorough understanding of the restraints and their lo-cations, this type of analysis should not be used.) .

o This (hand calc) is not necessarily wrong but it is terribly incon-sistent with the evaluation of 1-M-LBC0-063-001.

o Calculations have not been checked.

o The S.S. Eval. takes exception to the findings of the inspection team (specifically on the penetration clearances where inspectors found the insulation cracking and S.S. evaluater found a gao?!! I don't know what this means!!

a Consider these (above coments) together with others after going through more reports.

I-M-LBCO-079-DR1 The two deviations are clearance problems. They have been evaluated with );

Sand calcs. This time, however, the evaluation does consider restraints and there locations. It looks okay.

. 1 TN ENG3EERNG SERVICES Page 2 of 9 I-M-LBC0-098-DRI Clearance violations are deviations. The evaluation considers movements as predicted oy G&H. Evaluation looks okay.

Tuesday 4/29/86 I-M-LB CO-102-002 This OR indicates the piping is located outside of tolerance. The dimensions used are those on the isometric. It was found that the isometric dimension is in error. The piping is not affected. This evaluation is okay.

I-M-LBCO-103-002 This deviation is an interference (Rx Coolant Spray Line) with the steam generator upper support. .

The evaluation is very difficult to follow with the information in the evaluation report. Discussion with the evaluation eliminated any concerns.

The evaluation is Ok.

I-M-LBC0-104-DR3 The' deviation is with respect to pipe run lengths. The discrepancy is minimal. The evaluation is Ok.

I-M-LBCO-118-DRI The deviations are interferences with other pipe and supports. ,

For concern #1, the evaluation used the maximum displacements listed on the support detail. The concern is two horizontal pipes with a potential vertical interference when operating. The evaluation assumes both systems operate at the same time. Can one operate while the other doesn't? The evaluation doesn't consider this and the evaluation report does not provide enough information to make that decision.

This evaluation report needs more work, at least for presentation. If all operating conditions were not considered, then other work is definitely required.

General Question: What would have been done if this evaluation did indicate that interferences would exist for the other pipes?

I-M-LBCO-119-002 Concern is valve was installed with stem downward instead of upward.

Evaluation looks okay.

WM ENGNEERNG SERVICES Page 3 of 9 II. Large Bore Supports - Non Rigid Population Of the approximate 266 DR's listed on the SSEG Status Report (dated 4/5/S6) only 5 have been completed since 3/1/86. Therefore only these five will be looked at.

R-S-LBSN-046-004 The deviation is a document deviation. The Hilti Bolt Inspection Report could not be retrieved.

The evaluation found that the bolts were torqued and okay as shown in the Hilti Bolt Torque Reinspection Program. The S.S. evaluation is okay.

I-S-LBSN-239-DR2 The deviation is an irregular shaped fillet weld. .

Evaluation includes weld sizing cales. Evaluation is okay.

I-S-LBSN-210-DR2 Deviations consist of three catalog items on this support are not within dimensional tolerances. All variations were evaluated properly. Evaluation is okay.-

I-S-L BS N.-249-DR1 Deviation in Tube steel is 2" shorter than the 22" dimension called for on the drawing. Evaluation is okay. ,

I-S-LBSN-260-2 Deviation is support member length is long. Evaluation performed with STRUDL - Evaluation is okay.

I-S-L BS N-260-3 The deviation is ungrouted base plates for a snubber support frame.

The evaluation included re-inspection of the baseplates to verify bear-ing surf aces for the plates in addition a "BAP' reanalysis to qualify the plates for less than intended bearin'g area. The evaluation is okay.

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TM ENGNEERING SEFNICES Page 4 of 9 III. Large Bore Supports - Rigid Population Of the approximate 198 DR's listed on the 4/15/86 SSEG Status Report, only 7 have been completed since 3/1/86. Six of these will be looked at.

R-S-LBSR-016-DR2 Deviation is lack of material traceability. In the process of evalua-tion, the analysis package was reviewed and found to be incomplete. This evaluation completed the analysis package in addition to tracking the material.

This evaluation is thorough and okay. However, since this evaluation (for material traceability) uncovered a document deviation in the analyses package of the support, the following question is raised: With the system in place, will this type of document deviation (i.e., incomplete analysis pack-age) be found if it exists for other supports or components? Note: .A QI review may resolve this.

I-S-LBSR-069-DR4 This deviation includes MPT tag missing and base plate anchor bolt holes located out of tolerance. The evaluation shows that the NPT tag is not needed and a reanalysis of the base plate indicates all loads and stresses to be within code allowables. Okay.

I-S-LBSR 069-DR6 Daviation is damaged concrete in the vicinity of other base plate anchor bolts. Evaluation is thorough ar: complete. Okay. .

T-S-LBSR-202-DR6 Deviation is an out of tolerance angle (6 )0 between strut and clamp.

Analysis considers the effect of the change in axial and transverse load in the clamp etc. Evaluation is okay. In addition, I believe an NCR wil1 be written for this DR and a construction modification will be made to correct it.

I-S-LBSR-217-DR1 This deviation includes dimensions not shown on dwg and proper signature are not provided on the Materials Info List (MIL). The evaluation is complete and okay.

I-S-LBSR-204-DR-5 This deviation is the inability to verify thread engagement The evaluation verified there is sufficient thread engagement. The evaluation is okay.

- T ENGNEERNG SERVICES Page 5 of 9 IV. Pipe Whip Restraint Population Of the approximate 116 deviation reports listed in the 4/15/86 SSEG status report only 2 safety significant evaluations have been completed since 3/1/86.

I-S-PWRE-006-DR-4 Deviation includes two pipe whip restraints located outside the toler-ances for the dimension shown on the drawing. The evaluation discovered a letter to TUGC0 from G&H allowing the relocation. Therefore, the evaluation is OK and concludes non-safety significance.

My concern is why wasn't the info in the letter incorporated onto a revision to the drawing!!! And why didn't this become a document deviation report?? -

I-S-PWRE-507-DR1 The deviation is that washers do not completely cover the bolt holes.

The evaluation relies on the f act that these connections are Bearing Type connections (Type X) and the washers do not play a role in the transfer of loads. ,The evaluation does not present enough info to verify the above contentions. It appears like some tension loading would probably exist in these locations.

V. Sm'll a Bore Pipe Supports Population Of the approxmiate 85 deviation reports listed in the 4/15/86 SSEG status report, only 2 safety significant evaluations have been completed since 3/1/86.

I-S-SBPS-249-003 This deviation is paint on the spherical bearing of a strut support.

Field inspection in the evaluation assured that the bearings are free to move.

Evaluation is okay.

I-S-SSPS-272-1 Deviation is box-frame gaps. The evaluations considered raJial growth due to temp. and pressure. The growth is still less than tFe gap. The evaluation is okay.

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- TN ENGNEERING SERVICES Page 6 of 9 VI. Small Bore Piping Configuration Sample Of the approximate 63 deviation reports listed in the 4/1/86 SSEG status report, 11 SSEG reports have been issued since 3/1/86. Three will be reviewed in this audit.

I-M-SBC0-004-DR-1 These deviation reports are run of pipe evaluation out of tolerance by 1/16". The evaluation assured that nothing more significant than that existed on the piping and wrote this deviation off as insignificant with respect to stress and loads. The evaluation is okay.

I-M-SBC0-22-2 The deviation is a clearance violation with other piping. (Notei the clearances noted are to insulation). The clearances of concern are <ertical direction. Rigid vertical supports exist on all of the lines effected here.

Therefore, the minimal clearance will have no impact on stress or support loads. The evaluation is okay.

I-M-SBC0-024-DR1 The deviation is interference with another line. The evaluation considers the analytical displacement prediction (which are very small) and concludes that resulting loads and stress will be insignificant. The evalua-tion is okay.

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. ENGINEERING SERVICES Page 7 of 9 DR's Found to be Safety Significant Five Generic Evaluation reports applicable to all support samples (i.e.

LBSN,LBSR,SBPS)

In addition I-S-LBSR-019-DR2

-069-DR2 I-S-LBSN-259-DR5

-252-DR4 1

-261-DR1 I-S-SBPS-054-DR2

-044-DR1 .

I-S-LBSR-019-DR2 Deviation is Safety Significant. The deviation is the jam nut and strut barrels on a rigid strut turn simultaneously. "In this situation the eval- 1 uation claims that a displacement will be imposed on the pipe." Since (1) this is a support population and (2) the rigid support will not act strictly as a rigid support, the deviation is deemed safety significant.

I-S-LBSR.-069-DR2 Deviation in pipe clamp halves installed out of parallel.

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y ENGMEERNGSBMCES Fage 8 of 9 Look at Number of Dimensional Discrepancies Discovered to Date (i.e., the 2nd day of this audit)

LBSN 21 of 160 in " dim out of Tol" category.

LBSR 20 of 119 in " dim out of Tol" category.

PWRE 20 of 101 in " dim out of Tol" category.

SBPS 5 of 50 in " dim out of Tol" category.

INSP 33 of 250 in " dim out of Tol" category.

Instrument Pipe / Tube Sup.

HVDS 44 of 232 in " dim out of Tol" category.

HVAC Duct Supports -

Sub Total 143 of 920 in " dim out of Tol" category.

exceeds 15% of the DR's These 143 were found on total population of 655 supports! = 25%

(i.e. 25% of 655 supports looked at were found to have dimensions out of tolerance). This must be looked at in the trending evaluation.

LBSN 82 LBSR 89 PWRE 135 SBPS 76 INSP 130 HVDS 143 655 l

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TN ENGSEERING SERVICES Page 9 of 9 Sumary as of 4:30 PM 4/29/86 Piping & Supports Of the 6 population to be reviewed, two have been completed and the third is in process. These populations include:

Sample Size DR's SSE Rpts Avail. Looked At LBC0 101 58 16 10 LBSN 82 266 5 5 .

LBSR 89 198 7 7 Others PWRE 135 116 2 2 SBPS 76 85 2 2 SBC0 88 63 11 3 Notes:

For LBC0 most deviations looked at are clearance.

For LBSN most deviations are dimensional.

. "RTA m(NE a ENGNEERNG SERVICES Page 1 of 9 ATTACHMENT II Concrete Placement (CONC)

I-S-CONC-79-DR1 A 5/8" diameter hole with a depth greater than the required concrete cover.

The evaluation assumed a 5/8" diameter x 12" deep void in a 12" (wide) x 4' (thick) wall. The section is reduced 1.3% and rebar was not exposed. Note: Agree with evaluation.

I-S-CONC-79-DR2 ,

Deviation: Cast-in-place anchor bolts installed out of tolerance.

The evaluation stated that the actual loading on cast-in-place anchor bolts is determined as part of the design of the specific attachment '

loading and is based on the actual installed locations.

Agree with the evaluation. The procedure for cast-in-place anchor bolts should be reviewed to confirm evaluation.

I-S-CONC-90-DR1 The deviation is a 21/2" deep void in the concrete in an area where the required cover is 4". The evaluation states that a 'small localized reduction in cover will not adversely affect the protection of rebar. Agree v:!th the evaluation.

1 I-S-CONC-90-DR2 An area of the thickened portion of the concrete at the equipment hatch is 2'-113/8" instead of 3'-0" as shown on the concrete draw- l ings. The evaluation states that this localized deviation will not l adversely affect the structural capacity of the concrete. Evaluation l okay.

I-S-CONC-071-DR1 Similar comment as I-S-CONC-079-DR2.

I-S-CONC-123-DR2 Two cast-in-place anchor bolts were cut and the elevation of the top of the bolts did not conform to the design drawings. The bolts were cut per a DCA for the equipment setting. Evaluation okay.

. "#P F W NE ENGNEERNG SERVICES Page 2 of 9 I-S-CONC-091-DR1 Three cored holes were drilled in a concrete wall which were not shown on either design drawings and DCA's. Evaluation accounted for reduc-tion in concr-2te and rebars. The design margin is adequate. Evalu-ation okay.

I-S-CONC-108-DR1 Similar to I-S-CONC-079-DR2.

I-S-CONC-115-DR1 A cared hole was not shown on design drawings. However, this cored hole was authorized per a DCA. Evaluation okay.

I-S-CONC-113-DR1 The deviation consists of the identification of a 5/8" diameter, 2 1/2" deep hole in a 3' x 3' column. The evaluation states that this is an 0.12% section reduction and that 2 1/2" is less than the required cover. Evaluation okay.

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ENGNEERING SEiWICES Page 3 of 9 Conduit Supports (C0SP)

I-S-COSP-090-DR1 The deviation was undersized welds - 5/32" compared to 3/16" required.

The structural capacity of the support is controlled by Hilti allow-ables and the as-found weld capacity is adequate. Evaluation okay.

I-S-COSP-086-DR1 There is a gap between conduit clamp and strut. The required torque of the bolts on this support was okay. Therefore, the desired clamp-ing force was obtained. Evaluation okay.

I-S-COSP-039-DR1 .

Same as I-S-COSP-086-DR1.

I-S-COSP-038-DR1 The connection nuts were misaligned and one nut was damaged. Since the threads in question are not damaged and the required torque was obtained, the evaluation demonstrates that the connections will func-tion as intended and will develop sufficient capacity. Evaluation okay.

I-S-COSP-027-1 The spacing between supports is greater than that shown en the' design drawingt. The evaluation shows that this condition is okay. Evalu-ation okt.y.

I-S-C0SP-071 The deviation states that the 1/2" diameter Hilti has bottomed on its ,

thread length. The length of exposed thread was measured from the end i of the bolt and should have been measured from the first thread cut. l This demonstrates that the nut is actually not bottomed out. Evalu-ation okay.

"WTA STVNE ENGNEERNG SEiNICES Page 4 of 9 Equipment Supports (EQSP)

I-S-EQSP-045-DR4 The torque was found to be 100 in-lbs instead of 228 in-lbs as required. It was noted during the reinspection that at 100 in-lbs the control box moJnting lugs began to bend. .The evaluation demonstrates that the existing torque is adequate to support the control box.

Concern: Since the mounting lugs began to bend at 100 in-lbs, the lugs and/or the component may have been damaged by applying the required installation torque of 228 in-lbs. This attribute should be checked in the equipment population.

I-S-EQSP-045-DR1 ,

The deviation was that a Unistrut connection angle was not installed correctly. The installation configuration does not affect the capacity of the connection. Evaluation okay.

I-S-EQSP-002-0R1 A . member location shown on the design drwings as 13/4" i 1/8" is actually 1 1/2". Support was evaluated for this condition and shown to be adequate. Evaluation okay.

"MTA mYNE ENGNEERING SERVICES Page 5 of 9 Fuel Pool Liner (FPLR)

I-S-FPLR-180-DR1 I-S-FPLR-006-0Rf I-S-FPLR-149-0R1 Rust-colored corrosion noted on weld seams. A chemical test was con-ducted and the results were that the condition was not active cor-rosion.

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ENGNEERING SERVICES Page 6 of 9 Liners (LINR)

R-S-LINR-59-DR3 One polar crane support bracket was not listed on the Receipt Inspec-tion Report (RIR) which covered all the other brackets. It was covered in another RIR. Evaluation okay.

R-S-LINR-038-DR3 There was no record of a weld joint being radiographed - one foot to be RT'd for every 50' of weld. The weld was incorectly identified and after further investigation the correct identification was determined and the weld was found to be covered by the testing program. Evalu-ation okay. .

R-S-LINR-013-DR2 The piece number for a part of an assembly could not be determined. A more extensive review was done and the piece was identified. Okay.

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. WTA m(NE ENGINEERING SERVICES Page 7 of 9 HVAC Duct Supports (HVDS)

I-S-HVDS-046-DR-12 The dimension locating the point where a diagonal brace mounts to the concrete ceiling was found to be 581/8" instead of 91", as shown on the design drawing. Since the design calculations were based on 91",

the as-found condition will result in higher stress in the support members as well as the Hilti bolts. The evaluation of the as-found condition shows that the increased member stresses and anchor-bolt loads are acceptable. Evaluation okay.

I-S-HVDS-057-DR1 Undersized welds were identified. Six 1/2" fillet welds undersiz.ed up to 1/8". In addition, the duct was found to be attached to the sup-port with 1/8" fillet welds, 2" long and approximately 6" 0.C. The evaluation of the undersized support welds demonstrated that the as-found condition is acceptable and is okay. The evaluation does not address the fact that the duct-to-support welds are normally used on an axial duct support. It is noted, however, that it is doubtful that this support could support an axial load since there is no axial br. ace .

The evaluation should further address the duct-to-support weld.

I-S-HVDS-064-DR1 A number of deviations were identified with support welds, inclu' ding undersized, underlength, excessive undercut, incomplete fusion, and questionable profile. Evaluation demonstrates that the as-found con-dition is acceptable. Evaluation okay.

I-S-HVDS-013-DR5 I-S-HVDS-055-DR1 The weld of the support angle to the concrete mounting angle was not shown on the design drawing. A number of other suoport weids were undersized. Evaluation demonstrates that the as-fcuna condition is acceptable. Evaluation okay.

I-S-HVDS-023-DR1 The identified deviations include member orientation and length. The deviations are minor and the evaluation is okay.

Note: The' project is readdressing the HVAC supports, whicn will cover  ;

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W TF1enYNE ENGNEERING SERVICES Page 8 of 9 Structural Steel (STEL) .

I-S-STEL-146-DR2 The deviation is undersized welds. The design drawing calls for a 3/8" fillet weld. A number of locations were identified as undersized by 1/16" and one area was 1/8" undersized.. The evaluation shows that this condition is acceptable. Evaluation okay.

I-S-STEL-066-DR2 This deviation deals with member location. The design drawing iden-tifies the evaluation of the member as being 828'-0" i 1/8". Actual evaluation is 828'-0 3/16". Evaluation okay.

I-S-STEL-090-DR2 The design drawing identifies a member as being located 17'-5" from a building column. The dimension is actually 17'-3 15/16". Evaluation is okay.

I-S-STEL-519-DR1 Similar to I-S-STEL-090-DR2.

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. 'A'TA mYNE ENGNEERING SERVICES Page 9 of 9 Instrumentation Supports (INSP)

I-S-INSP-020-DR7 Undersizd weld. The design drawing calls a 5/16" weld. The total length of the weld is undersized by 1/16". The evaluation shows that this condition is acceptable. Evaluation okay.

Cable Trays (CATY)

I-E-CATY-011-DR2 Loose bolts in a cable tray splice plate. The evaluation showed that this condition is acceptable. Evaluation okay. .

Generic SSE's I-S-LBSN-GEN-DR2 (Lg Bore Spts - Non-rigid)

I-S-PS7N-GEN-DR2 (Pipe Supports in Rm 77N)

I-S-LBSR-GEN-DR1 (Lg Bore Spts - Rigid)

I-S-SBPS-GEN-DR1 (Sm Bore Spts)

A. total of 213 deviations have been noted in the piping populations.

The deviations have safety significance, the deviation being that there are no locking devices which are required on these two.

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. Draft R= port, Auoit of CPSES Scfsty Significance Evaluations of Electrical and Instrumentation and Control Inspection and Documentation Deviation Reports, 4/28/86 through 5/1/86.

The purpose of thic audit was to review and assess the edequacy of a' sample of completed safety significance evaluations prepared in response to construction and installation deviation reports. The deviation reports were developed from a reinspection of installed equipment and from a review of related construction documentation. An assessment was also desired regarding the adequacy of the implementation process used to prepare ano complete safety significance evaluations.

During the audit, the team reviewed approximately 20 percent of the currently available and completed safety significance evaluations in the electrical an'd instrumentation and control area as shown in the following tabulation:

Inspection Documentation Safety Safety Significance Significance Evaluations Evaluations Population Symbol Completed Revieweo Completed Feviewed

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ __==- ___ ________ _________ ________

Electric Cable CABL 56 6 19 5 ,

Cable Tray- CATY 49 14 l' '

Conduit CDUT 36 5 0 0 Electric Equipment EEIN 59 12 0 0 Instrumentation,Contrcl ININ 62 15 10 0 Nuclear Instrumentation NIST C 0 Total 262 52 44 9 Within the$e six populations, the team reviewed each of the 29 inspection safety significance evaluations completed during the past two months. An additional sample of 23 inspection safety significance evaluati,cos was s' elected for review from those completed prior to March 1986. Nine dccumentation safety significance evaluations were reviewed from the electric cable and nuclear instrumentation populations.

The team was informed that revision 2 of procedure CPP-016. " Safety Significance Evaluations of Deviation Reports, " was issued on January 25, 1986. The technical requirements in the current procedure were compared with those provided in revision 1 dated August 9, 1985. Current versions of tne applicable quality instructions, such as 0I-006, OI-010. OI-012.01-014, and QI-016, were also used during the audit.

Eacn of the 61 safety significance evaluations reviewed by the team hao been individually determined to be not-safety-significant. However, the team did not agree with this determination for deviation report DR-I-E- ,

EEIN-022-DR4 dated January 24, 1986. In this instance, a stainless steel i flexible conduit has been used to provide an environmental barrier from )

containment atmosphere and physical support for an electrical cable {

connecting a Conax seal assembly (ECSA-1-HV-2404A-1) to a steam generator J sucendary side sample solenoid valve (1-HV-2404A). This flexible conduit 1 1

CPSES ILC Safety Significance Evaluation Audit Report Author and Date: L. Stanley, Zytor, Inc., rev. 1, 05-06-86 HSB:TE50001.DR1, page 1

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. was found to hav@ tears at each end such that thG environm;ntal casi from containment atmospheric conditions was broken for both the cable and calenoid valve internal parts. This exposure to containment atmosphere violated tne environmental qualification basis of the solenoid valve whose required safety function was to de-energize (causing the fluid system sample valve to close) upon actuation of the auxilanry feedwater system. Closure of the fluid system sample valve was required in this situation to maintain a sufficient amount of water for steam generator heat removal from the reactor coolant system.

The safety significance evaluation for DR-I-E-EEIN-022-DR4 concluded that the flexible conduit installation ~ defect would not result in the loss of capability of the affected system and component to perform its intended safety function based on:

(1) a predicted safe failure mode for the solenoid valve electrical coil, as described in the environmental qualification report, when it has been exposed to containment atmospheric conditions:

(2) the presence of other electrical interlocks that could cause electrical de-energi:ation of the solenoid valve, and (3) an assessment that the cable was adequately supported by the

- damaged flexible conduit.

This determination for safety significance was not valid because the -

environmental qualification of a safety-related solenoid valve, in  ;

accordance with 10CFR50. 49 ( j ) and IEEE Std. 323-1974, has been violated j by the flexible conduit installation defec . ,

- i The foreword of IEEE Std. 079-1977 stated that in order to obtain i protection from possible common mode failures resulting from external -!

environmental effects, the (safety) system components are designec, a qualified, and installed to be immune to such anticipated challenges.  !

Appendix B of section 7.1 of the NUREG-0800 Standard Review Plan statec j

• that the invalidation or " lack of equipment qualification may serve as a -

j basis to assume failures. After assuming the failures of nonsafety- i grace, nonqualified equipment and those failures caused by a specific event. a random single failure is arbitrarily assumed." In demonstrating compliance with the single failure criterion, one purpose of a failure moce and ef f ects analysis described in section 4.1 of IEEE Std. 352-1975

, l is to ensure that all conceivable f ailure modes and their ef f ects on  ;

operational success of the system have been considered. Table 3 of this latter standard identified typical failure modes of mechanical systems as  !

corrosion, contamination, anc Sinding. The safety significance evaluation did not consider the possibility of mechanical bIncing of I solenoid valve parts that could result from exposure to containment l atmosphere conditions. This postolatea failure mode would prevent the j solenoid valve from venting the fluid system control valve. and thus  !

prevent the performance of its intended safety function. On this basis.

the evaluation determination should have stated that the flexible condut' installation defect was safety-significant. }

CPSES ILC Safety Significance Evaluation Audit Report l Author and Date: L. Stanley, Zytor, Inc., rev. 2, 05-07-86 HSB:TES0001.DR1, page 2

During tha cudit of cafcty cignificanco evaluations, a review s pneform;d of tha adsquacy of procedure CPP-016 cnd its implementation ~ '

process. The team developed the following observations:

(1) Procedure CPP-016 section 5.7.2 (b) stated that "the intended safety function of the item is determined." This should be changed to safety function (s) to reflect the fact that some components have as many as four distinct safety functions that need to be fulfilled, and that some may be mutually e::clusive.

For example, an emergency core cooling discharge valve may have one saf ety f unction to open f or saf ety injection flow, and may also have a second safety function to close for containment isolation. As written, the procedure does not encourage the identification of multiple safety functions for a component.

(2) A format variation was noted in the most recent safety significance evaluations regarding the identification of the required safety functions of a component. A number of instrumentation and control (ININ) evaluations did not clearly state the safety function in that section of the evaluation, but rather described the required safety function in the analysis objective section of the evaluation.

(3) The safety significance evaluation for I-E-ININ-100-DR2 stated that the instrument line function was to transmit pressure to the instrument and to maintain the system pressure boundary. The issue in this deviation was the maintenance of at least 18 inches separation distance between redundant instrument lines. The objective statement did not state this separation requirement in a clear manner.

(4) The safety significance evaluation for I-E-ININ-082-DR2 did n,o t identify maintenance of the reactor coolant pressure boundary as a safety function for the instrument line.

(5) The safety significance evaluation for I-E-ININ-082-DR1 did .

not identify the safety function of pressuricer transmi tter PT-455 even though the objective statement stated that the evaluation would determine if the observed deviation in instrument line slope had any impact on the transmitter.

Two cable tray connector plate bolting aspects were investigated during j this audit. Eight bolt connector plates used to join cable tray sections wure inspected as part of the CPRT program with a criterion that each bolt be finger tight. Gibbs and Hill documentation contained no requirement for the tightness of the bolts, such as a " snug" fit through the use of ordinary hand tools. Where one or more bolts were found to be loose, a minimum of si:: bolts was -determined to be sufficient for structural purposes. This six bolt criterion was ambiguous in that it did not. require three bolts on each side; however, the team observed that such symmetry had been applied in the safety significance evaluation process.

CPSES I&C Safety Significance Evaluation Audit Report Author and Date: L. Stanley, Zytor, Inc., rev. 2. 05-07-86 HSB:TES0001.DR1, page 3 1

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y . . .

PERSONNEL CONTACTED:

G tt 4 Name Title Organi:ation

_____________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - ______ ______ =-=

E.J. Braba:on (title unknown), SSE Group ERC J. Adam (title unknown), SSE Group ERC/CWCC G. Maddo>: (title unknown), SSE Group ERC A. Nevins Instrumentation and Control ERC/SWEC A. Patel Instrumentation and Control ERC/SWEC D. Grewal Electrical ERC/SWEC A. Low Electrical Lead Engineer ERC/SWEC ,

T. Kulaga Cable Tray Population Engineer ERC/PLC A. Tewfik (title unknown) ERC J. Hansel (title unknown) ERC T. Tyler (title unknown) ERC i

l 1

i CPSES I&.C Safety Significance Evaluation Audit' Report '

Author and Date: L. Stanley, Zytor, Inc., rev. 1, 05-07-96 .

^

HSB:TES0001.DR1, page ~A l l

c. ,

App:ndix As I&C Inupsction Sciety Significance Evaluations Reviewad

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_I $S_ _$_ ___ _ $$_________=_ _________________ d[ ,

I-E-CABL-003-DR1, 09/24/85, Cable Minimum Soacing Within Tray.

I-E-CABL-017-DR2, 04/02/86, Cable Minimum Bend Radius.

I-E-CABL-022-DR2, 09/19/85, Cable Floor Sleeve Not Shown on Schedule.

I-E-CABL-043-DR2, 12/24/85, Cable Movement' Slack Tolerance.

I-E-CABL-060-DR2, 09/19/85, Conduit Not Shown on Schedule.

I-E-CABL-091-DR2,.01/07/86, Cable Conductor Insertion Into Barrel Lug.

I-E-CATY-011-DR2, 09/12/85, Cable Tray Plate Bolts Loose.

I-E-CATY-050-DR3, 09/18/85, Cable Tray-Bottom Welding Details.

I-E-CATY-117-DR1, 10/15/85, Cable Tray Hole Plugs Not Installed.

I-E-CATY-125-DR1, 03/25/86, Cable. Tray Plate Bolt Reversed.

I-E-CATY-146-DR1, 04/05/86, Cable Tray Plate Bolt Reversad.

I-E-CATY-172-DR1, 03/25/86, Cable Tray Plate Bolt Loose.

I-E-CATY-195-DR3, 02/17/86, Cable Tray Plate Minimum Width.

I-E-CATY-199-DR1, 03/31/86, Cable Tray Plate Locking Device Missing.

I-E-CATY-265-DR1, 04/xx/86, Cable Tray Plate Bolt Loose.

I-E-CATY-284-DR1, 04/02/86, Cable Tray Welding Inspection Documentation.

I-E-CATY-286-DR1, 04/12/86, Cable Tray Plate Bol ts Loose.

I-E-CATY-287-DR2, 03/26/86, Cable Tray Plate Bolt Loone.

I-E-CATY-314-DR1, 03/20/86, Cable Tray Plate Bolt Loose.

I-E-CATY-315-DR1, 04/12/86, Cable Tray Plate Bolt Missing.

I-E-CDUT-017-DR2, 11/06/85, Conduit Number Marking Error.

I-E-CDUT-017-DR7, 04/02/86, Conduit Color Code Marker Distance'.

I-E-CDUT-040-DR1, 08/27/85, Conduit to Flexible Conduit Connection Gap.

I-E-CDUT-086-DR2, 02/19/86, Conduit to Conduit Separation Distance.

I-E-CDUT-111-DR2, 03/xx/86, Conduit to' Tray Cable Maximum Length.

I-E-EEIN-003-DR2, 10/09/85, Canax ECAS Conduit Maximum Length.

I-E-EEIN-022-DR4, 02/21/86, Conax ECAS Flexible Conduit Torn.

I-E-EEIN-043-DR1, 03/07/86, Transformer Orientation Not on Drawing.

I-E-EEIN-044-DR1, 01/15/86, Battery Rack Connection Nut Loose.

I-E-EEIN-055-DR1, 01/24/86, Lighting Panel Broken Decr Latch.

I-E-EEIN-049-DR1, 03/08/86, Cabinet Orientation Not Stated on Drawing.

I-E-EEIN-069-DR2, 03/25/86, ERF Computer Cabinet Lift Ring, Hinge.

I-E-EEIN-073-DR1, 03/26/86, Conax ECAS Rigid and Flexible Conduit.

J-E-EEIN-074-DR1, 03/10/86, Conax ECAS Rigid and Flexible Conduit. *

• I-E-EEIN-074-DR2, 03/07/86, Canax ECAS Identification Marking.

I-E-EEIN-083-DR2, 01/xx/86, Local Control Station Relocated by ECN.

I-E-EEIN-099-DR2, 01/08/86, Canax ECAS Rigid and Flexible Conduit.

I-E-ININ-002-DR3, 03/xx/86, Instrument Line S1cpe Tolnrance.

I-E-ININ-026-DR1, 01/xx/86, Instrument Marking Tag Missing.  ;

I-E-ININ-050-DR1, 04/12/86, Instrument Line Separation Distance, '

I-E-ININ-051-DR1, 01/xx/86, Instrument Line Slope Tolerance. j I-E-ININ-063-DR2, 04/05/86, Instrument Line Color Code Marking. I l

I-E-ININ-071-DR1, 12/03/85, Instrument Hori: ental Location Tolerance.

I-E-ININ-073-DR1, 04/03/86, Instrument Line Color Code Marking.

I-E-ININ-082-DR1, 04/xx/86, Instrument Line Reverse Slope.

I-E-ININ-082-DR2, 04/05/86, Instru, ment Line Color Code Marking Spacing.

I-E-ININ-082-DR3, 04/04/86. Instrument Horizontal Location Tolerance.

I-E-ININ-084-DR1, 12/03/95, Instrument Line Slope Tolerance.

I-E-ININ-093-DR1, 04/12/86, Instrument Line Color Code Marking.

I-E-ININ-100-DR2, 04/04/86, Instrument Line Separation Distance.

I-E-ININ-111-DR3, 03/14/86, Instrument Connection Drawing Error.

I-E-ININ-111-DR7, 04/12/86. Instrument Line Color Code Marking.

CPSES ILC Saf ety Significance Evaluation Audit. Report Author and Date: L. Stanley, Zytor, Inc., rev. O, 05-06-86 HSB:TE50001.DR1, page 4

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• 'e Appencix B: I&C Documentation Safety Significance Evaluations Review d 6f Deviation Number Date Subject R-E-CABL-023-DR1, 04/03/86, Cable Raceway Pu11 card Engineer Initials.

R-E-CABL-035-DR2, 04/04/86, Cable Raceway Pu11 card Date Missing.

R-E-CABL-052-DR1, 04/05/86, Cable Raceway Pu11 card Date Missing.

R-E-CABL-055-DR2, 04/12/86, Cable Raceway Pu11 card Premature Signoff.

R-E-CA5L-063-DR1, 04/15/86, Cable Raceway Pu11 card Not Re-signed.

R-E-CATY-125-DR1, 03/26/86, Cable Tray Welder Qualification Records.

R-E-CATY-282-DR1, 04/02/86, Cable. Tray Welding Inspection Documentation.

R-E-NIST-016-DR1, 04/xx/86, Cable Connector Installation Sequence.

R-E-NIST-027-DR1, 04/12/86, Cable Connector Inspectiun Report Blanks.

CPSES I&C Safety Significance Evaluation Audit Report.

Author and Date: L. Stanley, Zytor, Inc., rev. O, 05-06-86 HSB:TES0001.DR1, page 5

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