IR 05000445/1989014
| ML20244A648 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/04/1989 |
| From: | Livermore H, Norkin D, Runyan M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20244A640 | List: |
| References | |
| 50-445-89-14, 50-446-89-14, NUDOCS 8904180117 | |
| Download: ML20244A648 (60) | |
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' U '. S._ NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION l
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NRC Inspection Report: 50-445/89-14 Permits: .CPPR-126 3 50-446/89-14 CPPR-127
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Dockets: 50-445 Category: A2 50-446 Construction Permit
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Expiration Dates:
' Unit'1: August 1, 1991'
Unit 2: August 1,.-1992'
Applicant: TU Electric !
Skyway Tower 400 North Olive Street Lock-Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station-(CPSES),
Units 1 & 2 Inspection At: Comanche Peak Site, Glen ~ Rose, Texas Inspection Conducted: February 27 through March 7, 1989 Inspecto (A44 /4 6 O $~- 3 v1 D. P. Norkin, Team Leader, Fire Protectio 3 Date
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Inspector: .
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>w C d-d"87 I M'. - F'. Rdhyan, Resident Inspector, Date Civil Structural 8904180117 890405 PDR ADOCK 05000445 g PDC
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NRC Consultants: Birmingham, Quality Assurance J. Dale, Heating, Ventilation, Air-conditioning (HVAC)
K. Graham, Mechanical / Piping W. Richins, Civil Structural P. Stanish, Mechanical, Instrumentation and Controls (I&C)
J. L. Taylor, Electrical, I&C Reviewed by: L Y- d H. H. Livermore, Lead Senior Inspector Date Inspection Summary:
Inspection Conducted: February 27 through March 7, 1989 (Report 50-445/89-14; 50-446/89-14)
Areas Inspected: Team inspection of the Commodity / Attribute Matrix (CAM). The CAM provides the listing of attributes that were physically verified, evaluated by a technical disposition, or based on CPRT inspection results were determined to be acceptable during the Post-Construction Hardware Validation Program (PCHVP). The team inspected the CAM and associated documentation to verify that:
(1).the CAM contained necessary. commodities and attributes to validate that the hardware is consistent with the design, (2) accessibility of attributes was appropriately determined, (3) extrapolation of CPRT inspection results is acceptable, and (4) engineering evaluations of attrib'.ites were acceptable or an
! acceptable alternative validation was implemented.
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Results: Within the areas inspected, no violations or deviations were identified. Five open items requiring NRC follow up were l identified. The five open items concern: (1) mechanical coupling t
alignments for rotating equipment, (2) welding attributes for NF equipment supports, (3) epoxy grouting for base plates, (4) tracking of commitments established by technical dispositions j
to be performed in other programs, and (5) reinspection of an l attribute included in an attachment to Field Verification Method (FVM)-090 under the Heading " reference use only." These five open
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items are in paragraphs 3.a, 3.b(9), 4.a(1), 4.c(2), and 6.c(4)
I respectivel For additional summary remarks, see paragraph l l
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l DETAILS . Persons Contacted
!- * W.' Ackley, Jr., Director, CECO 1
- M. Alexander, Manager of Materials' Management, TU Electric- 1'
K.l Baker,-EQ Project Manager, Impell
- Rs P.' Baker, Licensing Support Manager,111 Electri *D. P..Barry, Sr., Manager, Engineering, Stone'and: Webster-Engineering Corporation (SWEC)
R. Boehm, CECO PCHVP Task Lead, SWEC
- H. D. Bruner, Senior Vice President, TU Electric
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- W. .J. Cahill,1 Executive Vice President, Nuclear,'TU Electric
- J. T. Conly, APE-Licensing,'SWEC
- W. G. Counsil, Vice Chairman, Nuclear, TU Electric
- G. G. Davis, Nuclear Operations Inspection Report Item
. Coordinator,.TU Electric
- D. E. Deviney, Deputy Director, Quality Assurance (QA),
TU Electric R. Dible,1 Fire Protection (FP) Lead Engineer, Impell J. Dimare, Responsible Mechanical Engineer, SWEC
- J. C. Finneran, Jr., Acting Manager, Civil Engineering, TU Electric
- C. A. Fonseca, Deputy Director, CECO
- J. L. French, Senior Review Team N. Goldstein,-Responsible PSAS Engineer, SWEC-K. Grayson, Responsible Electrical Engineer, SWEC
- T. L. Heatherly, Licensing Compliance' Engineer, TU Electric G. Heitpas, Cable Tray Engineer, Impell
- J. .C . Hicks, Licensing Compliance Manager, TU Electric
- S. D. Karpyak, Nuclear Engineering, TU Electric A. Kirmani, Responsible Civil / Structural Engineer, SWEC
- J. E. Krechting, Director of Technical Interface, TU Electric J. Lawrence, Responsible Electrical Engineer
- O. W. Lowe, Director of Engineering,_TU Electric i D. Lowry, Senior Engineer, TU Electrici )
D. Mosby, Fire Protection Project Manager
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- E. F. Ottney, Program Manager, CASE j
- A. Pereira, Staff, QA, Ebasco j
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- D. M. Reynerson, Director of Construction, TU Electric R. Scavotto, Responsible Electrical Supervisor, SWEC
- C. E. Scott, Manager, Startup, TU Electric
- J. C. Smith, Plant Operations Staff, TU Electric A. Spada, Responsible Engineering Mechanics Division Engineer, SWEC l
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W. Speyer, Responsible Mechanical Supervisor P. B. Stevens, Manager,. Electrical Engineering, TU Electric
- R. D. Walker, Manager of Nuclear Licensing, TU Electric l
- J. E. Wren, Assistant Director QA for Administration,-
TU Electric l The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the March 7, 1989, exit meetin ! Introduction and Summary Background The PCHVP is the portion of TU Electric's Corrective Action Program (CAP) which validates the final acceptance attributes for safety-related hardware. Procedure ECE 9.04 defines final acceptance attribute as "an attribute that provides the basis, either in part or in ,
whole, for the assurance that the installed hardware has satisfactorily implemented the design."
The input to the PCHVP is contained in the installation specifications which implement the licensing commitments and design criteria of the Design Basis Documents (DBD)
developed during the CAP design validation proces Final acceptance inspection requirements identified in .
the validated installation specifications were used to l develop the PCHVP CAM, a set of firal acceptance attributes identified for installed hardware. The PCHVP, by either physical validations or through an engineering evaluation methodology, assures that each of the y attributes defined in the attribute matrix is validate Physical validation is performed by QC inspection or engineering walkdowns for accessible component '
The decision regarding the need for physical validation is based on whether:
(1) The attribute was recommended for reinspection by the Comanche Peak Response Team (CPR"). J (2) Design validation resulted in a change to design or ,
hardware final acceptance criteria that are more j stringent than the original acceptance criteria used l by the CPRT, or the CPRT did not inspect the I attribut l i
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(3) Design validation resulted in new work, including modification to existing hardwar If the CPRT made no recommendation for reinspection and items 2 or 3 above do not apply, the attribute under consideration is accepted without reinspectio If any of the three statements above are true, a determination is made as to whether the attribute is accessibl If the attribute is accessible, a field validation of the item's acceptability is performed and documented in accordance with an approved FV If the attribute is inaccessible, an engineering evaluation is conducted by technical disposition of available information, Method of Review The NRC' team' inspection focused on attributes that were not physically validated for any of the following reasons:
(1) They were not on the Commodity / Attribute Matri (2) Based on the above three criteria relative to CPRT results and design / hardware changes, validation wa not necessary (N attributes).
(3) Technical disposition was required due to l inaccessibility (N-TD attributes).
The team reviewed installation specifications and.DBDs to l determine wh9ther the Matrix contained all necessary commodities, which sre defined in ECE 9.04 as component types grouped together for the purpose of examining a I specific set of attribute l
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The team reviewed a sample c.f approximately 13% of the N attributes and 22% of the N-TD attributes. The sample {
is broken down as follow )
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I L Total N Ns Reviewed Total N N-TDs Commodity of N by NRC of N-TDs Reviewed by NRC Mechanical 92 20 9 1 Equipment l l Piping and Pipe l
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Supports 73 9 7 3 HVAC 9 2 6 2 I&C 92 12 11 5 l
Civil / Structural 127 12 -33 4 Electrical 80 10 21 2 Fire Protection 0 0 33 9 Electrical Race-ways / Supports 66 6 28 7 Total 539 71 148 33 For the commodities pertaining to each N and N-TD l attribute selected, the. team evaluated DBDs and- !
installation specifications to ensure that all signifi-cant attributes for the commodity were identified on the matrix. For the N attributes, the team evaluated whether CPRT inspected the attribute and identified any adverse I trends and whether the CPRT inspection criteria were equivalent to the current installation specification l acceptance criteri t For the N-TD attributes, the team evaluated whether accessibility reviews were properly conducted and reached l correct decisions and whether the technical dispositions 1 were adequate to validate the attribute without a !
physical validatio In a subsequent inspection, the team plans to evaluate Y attributes; i.e., those that required physical validatio Summary of Results During this inspection, the NRC team raised several questions pertaining to commodities and attributes that were not included in the CAM or were not identified to require physical validatio Those questions resulted in the NRC team identifying five open items for further review and one item documented in NRC Mechanical Inspection Report 50-445/89-12; 50-446/89-12. However, for the majority of the NRC questions, TU Electric provided satisfactory explanations of how the commodity or attribute was covered by another
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l EU Electric program or Wasiencompassedlwithin:another Lcommodity..orfattribute in(theLmatrix.- ]
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In general,Lthe NRC\ team agreed /withithe technical; h
! dispositions or the. extrapolation of1CPRT inspection !
results as the: basis forLacceptance~of each ;
- commodity / attribute.- The NRC team identified: J documentation" errors; however, these errors'didinot adversely affect the ultimate-decision'regarding'the- ;
necessity for a field. verification;or to. include the item )
in another' commodity / attribute already'in'the matri The'NRC'teamLunderstands.that, in regard to open item 1 445/8914-0-041which concerns Attribute :794, Physical l Damage to Piping and'In-line Components', TU Electric 1 4 plans' generic: actio The generic action will involve
. review of.all? technical dispositions'to ensure-that commitments made by the technical dispositions are properly implemente .[ - IMECHANICAL EQUIPMENT (50075, 50050, 55100)
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The team reviewed:the installation specifications; listed below as part of its. background review to ensure that all-commodities.and-attributes were. correctly. identifie J ' Installation Specifications Reviewed l
2323-MS-100 j 2323-SS-30~
The.NRC inspector questioned why.the~ supports / restraints l
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for Nuclear Steam Supply' System (NSSS) equipment were'not identified.as a~ commodity on the CAM for Mechanical Commodities. TU Electric stated that NSSSLequipinentLand i supports'were not-identified as a separate commodity in 'l the matrix since they were' included in both CPRT's and PCHVP's Mechanical Equipment and Mechanical Equipment Support: populations.- The team reviewed Attribute-Evaluation forms for Attributes 619, 634, 637, 1730, ;
1733, 1746,'and 1747 for Mechanical Equipment and ,
Mechanical' Equipment Supports commoditie These ;
identify NSSS equipment as part of the scope definitio l
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The team agrees that NSSS equipment is adequately addressed by PCHV !
l NRC review.of.the. commodity Mechanical Equipment revealed- !
that coupling and alignment requirements (e.g., rim to rim, face to face, coupling gap, and torquing) related to connecting rotating equipment to rotating equipment was
'not identified as an attribute on the CA l
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TU Electric stated that alignment of mechanical equipment was not included in PCHVP since all safety-related
,. equipment will be realigned (and doweled if required)
prior to plant operation by startup and operation The NRC inspector attempted to verify that all safety-related equipment alignments would be performed. Discussions with the Assistant Startup Manager, Preoperational Testing, revealed that all coupling / alignments may not be verified due to some systems being exempt from reperform-ance of preoperational testing. Therefore,' a detailed analysis would be necessary to identify which alignments would not be reverified. This is an open item pending TU Electric's actions to validate this final acceptance attribute (445/8914-0-01; 446/8914-0-01).
In the Mechanical Equipment commodities there were 92 N attributes and 9 N-TD attributes. The team selected 20 N attributes and 1 N-TD attribute which represented a cross section of all commodities reviewed by the appli-can Technical Audit Program (TAP) has reviewed 38 of the N attributes and 6 of the N-TD attributes. The NRC has inspected TAP performance and has found the TAP to be effectively implemente (NRC Inspection Reports 50-445/88-55; 50-445/88-51 and 50-445/88-75; 50-446/88-71.)
b. 'N Attribute Review (1) Attribute Number: 446 (N)
{ Commodity: Mechanical Equipment - Tanks I Attribute Description: Butt Weld Offset CPRT addressed this attribute in the ISAP VII.c, Appendix 14, Results-Repcrt. Physical inspection was l i
performed on a total of 14 butt weld installations
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and 3 deviations for excessive offset were recorde The specific deviations were reviewed and found to i
be less than Code allowables; therefore, all the I installations were deemed to be acceptable. Current TU Electric inspection requirements are equivalent to those used for the CPRT reinspection. The NRC l inspection team concurs with the assessment of this attribut I
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(2).' Attribute Number: '450 (N)
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Commodity:
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Mechanical Equipment-Tanks:
Attribute' Description: .W elding: ; Fusion
'CPRT: reviewed thie' attribute as.part of the ISAP VII.c,. Appendix 14,1Results Report.:. CPRTL H reinspectionsfof.1100 inspectinnLpoints for thi attribute revealed'two deviations for lack-of. .,
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fusion,Jone on a. seismic: support bracket weldrandL '
.the other on an-anchor-bolt chair weld.' Analysis o the.two' conditions concluded that, while there was it reductionnin the design' margin, Lit was not eroded;to the point where an adverse trend was established.-
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Therefore, there was no' recommendation to perform a 4 generallreinspection of'the attribute. Duecto:
engineering (review of design requirements, the present imspection criteria are less conservative-than those used!by CPRT. The'NRC inspection' team a concurs with the assessment performed'for'thi attribut (3) Attribute Number: '478 (N)'
Commodity: ~ Mechanical' Equipment = Supports'.
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LAttribute Description: LWelding - Fusion The-basis for acceptance ofEthe attribute was the ISAP VII.c review documented in Appendix 130 of the Results Report._. Reinspection'were performed:on 1238 inspection-points-for the attribute ~with one deviation' identified, which was'later determined to be; insignificant. Therefore,-since no construction deficiency was identified, no requirement for reinspection'of the attribute was deemed'necessar The NRC inspection team concurs with the assessment of this attribute in light of the above and the1 fact that inspection requirements are unchange ,
(4) Attribute Number: 480 (N)
Commodity: Mechanical Equipment Supports Attribute Description: Welding - Undercut The results of CPRT's reinspection efforts for this l- welding attribute were contained in Appendix 30 of the ISAP VII.c Results Report. This report documented that this welding attribute was reviewed for 2476 inspection points and 4 deviations were note None of these deviations were deemed to be
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i was identified. Based on the above and the fact that the current inspection requirements are consistent with CPRT criteria, the NRC inspection team concurs with the applicant's assessmen (5) Attribute Number: 624 (N)
Commodity: Mechanical Equipment Attribute Description: Tank - Nozzle Type and Reinforcement CPRT addressed this attribute in their population
" Field Fabricated Tanks," as documented in the Results Report for ISAP VII.c, Appendix 14. The reinspection of this attribute identified no deviations and were determined to be acceptable to CPRT. The installation specification requirements I for this attribute have not been revised as a result of the Design Validation Program. Therefore no reinspection were deemed necessary. The NRC inspection team concurs with this assessmen (6) Attribute Number: 627 (N)
Commodity: Mechanical Equipment Attribute Description: Overpressure Device - Relief Valve, Vacuum Breakers, Rupture Disk The CPRT reinspection identified no safety significant construction deficiencies related to this attribute. These results were documented in the ISAP VII.c Results Report, Appendices 8, 9, and 1 The NRC inspector concurs with the engineering evaluation of this attribute which concluded that reinspection is not require (7) Attribute Number: 631 (N)
Commodity: Mechanical Equipment l Attribute Description: Foundation Bolts - Hardware Based on the CPRT inspection results, all of the 338 deviations identified for this attribute were determined to be insignificant and no adverse trends were identified. The CPRT concluded if similar types of deviations were to exist in the uninspected portion of the population, it is unlikely they would result in construction deficiencies. Based on the above analyses, no mandatory recommendations were L_.________._.___
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, = . hardware-would satisfactorily perform.its safetyf '
'j functio In addition to'theiabove, the CPRT also offeredifort; l
. TU Electric' consideration'a; recommendation ~for i d improvement'to. verify that the: anchor bolt hardware, !
' !* =as: required on the' design' drawings, is correctly: installe TU. Electric's review:of this recommenda-
-tion determined that,'in general,c rotating /recipro- 1 cating.' equipment would be more! susceptible:to l
' problems caused by the. installation of inappropriat , , J
' anchor. bolt . hardware, such as missing - j am nuts,Lthan -
to.the normal vibration ofLrotating. equipment during 5 operation. As.a result, , reinspection of foundation
' bolt hardware is addressed by various.attributesE (825, 804,.810, 805, 807,l811,Hetc.).ini,the-mechani-cal rotating / reciprocating equipment' anchorage:.
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TheLNRC # inspector concurs.with TU Electric's-conclusion-that reinspection is not. required =for= q this. attribute,.and concludes that TU' Electric's implementation of the.CPRT recommendation-for
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improvement by means of;the~above attributes.shouldo
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lfied by.CPRT.- 1 y (8)- Attribut'e Number:' 637'(N):
Commodity: Mechanical Equipment
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-Attribute Description: l Foundation Bolt-Configuration; I
The CPRT reinspection identified no safety -
ye significant construction deficiencies related-to foundation bolt configuration. These results were documented inithe ISAP VII.c Results Report, Appendices'.14 and 17.- ,
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evaluation of this attribute which concludes that e reinspection is not required.
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-(9) ~ Attribute Numbers: 1281,-1282,1283, 1285, 1286, 1289
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and 1828 (N)
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Commodity: NF Equipment Supports (Welding !
. Attributes) i Attribute Descriptions: Welding-Porosity, Cracks, Fusion, Length, Size, Surface Conditioning, and Undercu SWEC and Comanche Peak Engineering-(CPE) determined that these attributes were acceptable based on CPRT reinspection results. The results of this popula-l tion's inspections are identified in CPRT~Results Report ISAP VII.c, Appendix 30; no adverse. trends or construction deficiencies were identified. NF Equipment Supports were included'in the CPRT Equip-ment Support. population. The total population of equipment supports is 1439 (which includes 9 NF supports). Of this population, 300 equipment supports were selected for inspections under'QI-066; however, no NF equipment supports were inspecte CPRT felt that the population of equipment supports-was homogeneous enough to support a conclusion about )
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all equipment supports from this sample. CPR document QA/QC-RT-9060 states that the work process in the equipment support population.was determined
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by CPRT-to be homogeneous in that it has been per- !
formed to similar requirements for all items in this l population. The general requirements upon which the j reinspection and/or documentation attributes were i based-were derived from common specifications, pro-cedures and quality instruction l'
TU Electric stated that all fabrication installation activities were performed by Brown & Root (B&R)
structural ironworkers.who received training to the construction procedures. Each operation of support ;
fabrication / installation (i.e., bolting, welding, j etc.) was of an equal complexity such that it j required the same type of work, equal training and skills to achieve the desired installation Inspections were performed in accordance with the requirements of B&R Instruction QI-QAP-11.1-28 and QI-QP-11.14-1 for those activities which required witnessing by QC inspectors. All inspections were performed by B&R inspectors, who were trained to the t above inspection instructions. Therefore, QC accepted items are representative of the entire population, including non-QC accepted items in that the uniformity of inspection procedures will ensure l
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L performe NRC review of CPRT.reinspectionLrequ'irement',.ERC s LQuality Instruction (QI)-066, revealed that HVAC and
. electrical equipment supports were-inspected lto,
' LVisual Weld ~ Acceptance Criteria. ,(VWAC) which is' not similar'to with NF equipment support? inspection; E T requirements. For' example,LASME NFicode requires
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that: weld size must. meet-or exceedidrawin requirements while AWS' welding- inspected to' VWAC -
criteria is permitted;to-beLundersize11/16" X 1/4"
- of the length. VWAC criteria-also-permits-underlength welding and lack offfusion'which;are~
prohibited by NF criteria'.- Additionally, NF allows a maximum of 1/32~ undercut while 'VWAC permits -
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1/16"' deep undercut'. Therefore, engineering's- .
conclusion thatireinspection is not required, whiche
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was baced:upon-CPRT reinspection results,, .
-ISAP VII.c, Appendix 50,.is not appropriate.- This NRC inspection finding isEan open item (445/8914-0-02;'446/8914-0-02).
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-(10)? Attribute Number: 1265 (N) j
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' Attribute Description: Welding - Location
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. f CPRT inspected this' attribute by verifying that the l welds were located as'specified on the design j
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drawing.- They' inspected.the attributes'for I 1238 inspection' points and identified a' total of 1 25tdeviations. NoLadverse trends'were. identified as j a result:of the deviations identified. .This was !
described in the.Results Report for ISAP VII.c, ]
Appendix 30. 'CPRT inspection criteria are consis-tent with current' installation specification ~
criteria. The NRC inspection team concurs with the l
assessment that this attribute need not b reinspecte (11) Attribute Number: 1347 (N)
Commodity: Mechanical Remote Valve Operators J l
Attribute Description: Concrete Anchorage - Hilti Kwik Bolt Marking l This attribute was addressed by CPRT in a number of populations, and the results of these inspections were summarized in the Results Report for ISAP VII b.4 (Section 5.3.1 addresses this specific attribute)#. In the. inspections for these l
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populations a total of 18 deviations were identified and subsequently determined to be insignifican Therefore, this attribute was considered to be acceptable. The current inspection criteria are the same as those used by CPRT. The NRC inspection team concurs with the assessment.-
(12) Attribute Number: 1618 (N)
Commodity: Mechanical Equipment Attribute Description: Accessories - Configuration The CPRT reinspected mechanical equipment to verify that the overall configuration of equipment was as specified in the applicable design documents or construction operation travelers. Reinspection for this attribute were sorted into three general categories: bolt tightness, welding, and miscellaneou As a result of reinspection for bolt tightness, two significant construction deficiencies were identi-fle Broken hold-down bolts on a control room !
air-conditioning compressor resulted in the issuance of Corrective Action Request (CAR)87-028 which provides corrective and preventive action for the construction deficiency. Twenty deviations regarding bolt tightness on the safety injection accumulator and pressurizer man-way covers resulted in the issuance of CAR 87-046 which provides corrective and preventive actions for the ;
construction deficienc :
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For the inspection categories welding and miscellaneous no significant deviations were
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identifie In summary, since CARS87-028 and 87-046 provide corrective and preventive actions for the two CPRT j
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identified construction deficiencies and the CPRT ISAP VII.c Results Report, Apendix 17, concluded that reinspection was not required for other aspects of this attribute, the NRC inspector concurs with the engineering evaluation of this attribut (13) Attribute Number: 1740 (N)
Commodity: NF Equipment Supports Attribute Description: Concrete Anchorage Hilti Bolt Size and Type
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g 15 This attribute.was also addressed in the general Hilti. bolt inspection effort of ISAP VII.b.4. The reinspection efforts performed for this :ISAP identified no safety significant deviations or-adverse trends. The requirements for the size and type of Hilti bolts, from an inspection standpoint, are unchanged from the CPRT inspections. Based o the above, the NRC inspection. team concurs with the applicant's assessment for this attribut (14) Attribute Number: 1775 (N)
Commodity:. NF Equipment Supports Attribute Description: Bolts . Material conclusions relative to the adequacy of the attribute were drawn based on the results of the inspections. performed in CPRT, ISAP VII.c, Appendix'34 which was for AISC bolting. While.the j bolting for NF equipment supports has different j material specifications, the CPRT conclusions relative to material control and the identified deviations are' applicable to both case The team considers that the conclusions drawn by CPRT-from J this closely'related commodity are valid for the !
commodity of NF Equipment Supports. The current k inspection requirements are consistent with those j applicable at the time of CPRT's inspection.- 1 Therefore, the NRC inspection team concurs with the ]
assessment for the attribut c. N-TD Attribute Reviews
Attributo Number: -484 (N-TD) , j Commodity: Mechanical Equipment Supports Attribute Description: Arc Strikes (Welding)-
CPRT did not specifically address this attribute in their I review of the Quality of Construction. However, it was addressed in a general study performed by SWEC. The results of this study were presented in Report STIR-SWEC-M-002, Revision 1, which identified no defects for the '
attribute. Also, inspection requirements for the attribute are currently less conservative than those that would have been used at the time of initial installation and-QC inspection of mechanical equipment support Therefore, it was concluded that there was no need to reinspect for this attribute. The NRC inspection team finds that this attribute has been adequately addresse _ - _ _ _ - _ - - _ - - _ _ _ _ _ - _ _ _ _ - _ _ _ .
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4. PIPING AND PIPE SUPPORTS (49065, 50090, 50075)
ECE 9.04, Revision 2, " Control of the Post-Construction Hardware Validation Program Manual," of which the CAM is a part, defines a Final Acceptance Attribute (FAA) as "An attribute that provides the basis, either in part or in whole, for the assurance that the installed hardware has satisfacto-rily implemented the design." Installation Specifications Reviewed
The NRC inspector performed a detailed _ review of portions of Specification 2323-MS-100, Revision'9, " Piping Erection Specification," and questioned TU Electric l
personnel as to why the following attributes were not l identified as final acceptance attributes on the CAM: :
(1) Attribute Description: Pipe Supports - Cement Grouting of Base Plates TU Electric stated that cement grouting for base I plates will be validated by Attribute 474, Maximum j Grout Thickness. However, a revision to the 1 Attribute Evaluation Form (AEF) is necessary to l indicate that the attribute is applicable to cement grouting. At the time of the NRC inspection, the j AEF was applicable to epoxy grouting only l (445/8914-0-03). 1 (2) Attribute Description: Pipe Supports - Distortion of Material Due to Welding No quantitative criteria for allowable distortion are provided by the installation specification or quality control inspection procedure CPRT reinspection procedures did not identify welding distortion as an attribute and did not identify any conclusions regarding welding distortion in the ISAP VII.c Results Report. NRC review of 2323-MS-100,Section VI, paragraph 6.2.3, identified that welding distortion is prohibited if the func-tion of the pipe support is altered. TU Electric stated that no attribute is specifically required by j Specification MS-100 or any other weld inspection procedures to inspect for distortion of support members due to welding. As such, no specific attribute was included in the matrix. However, within the Pipe Support-General Commodity population there are several attributes which would contribute j to ensure there were not any unacceptable distor- I tions to pipe support members due to welding.
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Attribute 9821- Support Configuration
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Attribute 990 - Member Location
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Attribute 979:- Physical Damage Attribute'995 - Pipe Clearance - Box Type Frame Support'
Attribute 994 - All Other Dimensions Not on Component Support Structural Inspection. Report-The team agrees that inspection of the above-attributes would have the effect of identifying distortion of pipe supports'due to weldin (3) Attribute Description: Welding. Quality Attributes for-II/I_ Pipe Supports-TU Electric stated that~this attribute is addressed; by FVM-PS-082, Attribute'676, Welding Configuration, which requires reinspection of welding.. The NRC inspector concludes that TU Electric has properly addressed'this attribut (4) Attribute Description: Piping and'In-line Components - Post. Welding Heat Treatment-TU Electric stated ~that the' purpose of performing!
post welding heat-treatment, when applicable, is to
. relieve. weld stresses to; prevent welding crack The final' acceptance attributelis therefore addressed by Attribute 745, Pipe Welding - Cracks, which was validated based upon acceptable CPRT reinspection results. The NRC inspector concurs with TU Electric's exclusion of thisLattribute from the CA (5). Attribute Description: Piping and In-line Components - Hydrostatic Test ,
TU Electric stated that, in general, it was not the intent of the PCHVP to include aspects of the testing and startup program as final acceptance attributes because PCHVP was developed with the knowledge that separate procedures would govern required testing activities needed for licensin Pressure testing was not considered a final acceptance attribute that substantiated hardware was installed in agreement with the validated desig Any portion of the ASME III piping that was
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originally code stamped and subsequently revised is-required tc be retested in accordance with Procedures ECC-10.03 and ACP 1 In addition to any required retests above, an inspection'for leaks is to be conducted during hot functional and .
functional testing in'accordance with Procedures- !
1CP-PT-55-02 System Functional. Test (SFT) and STA-72 The team agreed with the above logic for not including hydrostatic' test as an attribut I For the Piping and Pipe Support Commodities,'there were a j total of 73 N attributes and 7 N-TD attributes. . TAP' "
reviewed 30 of the N attributes and 3 of the N-TD attribute The NRC inspection team reviewed nine N attributes, three N-TD attributes, and two attributes which were-deleted from the CAM. These are discussed belo Attributes Reviewed (N)
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(1) Attribute Number: 766 (N) I Commodity: Piping and In-line Components Attribute Description: Flange / Fittings Type,.
Pressure Rating, Gasket
. The CPRT reinspection ~'results reveal that no deviations for flange /tittings type, pressure rating, and gasket were identified. These results were documented in the ISAP VII.c Results Report, Appendices 8, 9, 11 and 12. The NRC inspector concurs with the engineering evaluation of this attribute which concluded that reinspection is not require (2) Attribute Number: 694 (N)
Commodity: Pipe Supports - Variable / Constant Springs Attribute' Description: Beam Attachment - Thread Engagement The CPRT reinspection results reveal that no safety significant construction deficiencies related to thread engagement were identified. These results were documented in the ISAP VII.c Results Report, l
Appendices 25, 26, and 27. The NRC inspector
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concurs with the engineering evaluation of this
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attribute which concludes that reinspection is not require (3) Attribute Number: 927 (N)
Commodity: Pipe Support Concrete Anchorage - ,
Embedded Dolts !
Attribute Description: Locking Devices l SWEC and CPE reviewed this attribute and determined it to be acceptable without reinspection based upon CPRT results. NRC review of the supporting documen-tation attached to the AEF determined that it was applicable to Richmond inserts only.. Engineering i surveillance' Report ES-88-45 had a similar finding related to Attribute 927 which was documented in Deficiency Report (DR) C-89-001 TU Electric stated that Attribute 927 had previously been revised to eliminate reinspection. This J change, however,:was incorrectly based upon the results of the structural steel' population of ;
ISAP VII.c, Appendix 19. This' inappropriate application was due to a misinterpretation.of the
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results of this population =to include the pipe support population.- The ASME. code boundary for' pipe
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, supports has been established at CPSES to exclade-the attachments to concrete and the associated hardware (other than through bolts), in accordance with 2323-MS-100, Revision 9, Appendix F, Figure 6.1.20-1. This exempts embedded bolts and Richmond insert bolting hardware from the ASME III, Subsection NF requirement for locking devices on non-high strength connections, and, therefore, because of this definition of the NF boundary these locking devices are not required and could not be a final acceptance attribute. A revision to the documentation for Attribute 927 will be completed by March 24, 1989, to correctly document the basis for j this attribute'. dispositio '
(4) Attribute Number: 786 (N) .
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Commodity: Piping and In-line Components Attribute Description: Containment Spray Nozzle Type This attribute was determined to be acceptable based on CPRT reinspection results. ISAP VII.c, Appendices 8, 9, and 12, document reinspection results for this attribut CPRT identified no ,
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deviation'for containment spray nozzle type. The NRC inspector concurs with the engineering evalua-L tion of this attribute which concludes that rein-spection is not require (5) Attribute Number: 940 (N)
Commodity: Pipe Support - Hilti Bolts <
Attribute Description: Anchor Marking Visible Denoting Length and Type This attribute was determined to be acceptable based on CPRT reinspection result ISAP VII.b.4, "Hilti 1 Anchor Bolt Installation," did not identify any j significant deviations related to the identification markings which are required to be present on the !
installed Hilti anchors. The NRC inspector concurs with the technical acceptability of this attribut (6) Attribute Number: 988 (N)
Commodity: Pipe Supports - General Attribute Description: Bolt Hole Location Other Than Base Plates CPRT evaluated the configuration of pipe support assembly and concluded that the quality of construction related to bolt-hole location is acceptable. The ISAP VII.c Results Report, j Appendices 25, 26, and 27 document the CPRT !
conclusions. NRC review of supporting documentation l concludes that the attribute is acceptabl !
During the February NRC mechanical inspection, it was identified that an attribute for bolt-hole ,
location had not been addressed by PCHVP. The l specific attribute is the bolt-hole location in ,
snubber and sway strut clamps in relation to i distance from the edge-of the clamp. Dislocation of i the hole could cause a restriction in the available i'
swing angle to less than the amount required by the specification. This finding is documented in NRC Notice of Violation 445/8912-V-0 (7) Attribute Number: 1803 (N)
Commodity: Pipe Support Concrete Anchorage -
Embedded Bolts Attribute Description: Material Type i
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SWEC and CPE determined that the attribute is acceptable without reinspection. NRC review of the supporting documentation attached to the AEF deter-mined that it incorrectly referenced ISAP VII.c, Appendix 19, which was applicable to Richmond inserts, not embedded bolts. TU Electric agreed that this reference is to the incorrect ISAP and stated that Attribute 1803 is redundant with Attribute 1579 under the commodity Structural Steel General, which addressed all concrete anchors throughout the plant. The documentation for Attribute 1579 correctly references ISAP VII.c, Appendix 18. Therefore, a revision to the Initial Acceptability Review for Attribute _1803 will be made no later than March.24, 1989, to delete that attribut (8) Attribute Number: 764 (N)
Commodity: Piping and In-line Components Attribute Description: Branch Connection Type The CPRT reinspection results reveal that no deviations for branch connection type were
--identified. These results were documented in the ISAP VII.c Results Report, Appendices 8 and 9. The NRC inspector concurs with the engineering evaluation of this attribute which concluded that reinspection is not require ,
I (9) Attribute Number: 742 (N)
Commodity: Piping and In-line Components l Attribute Description: Welding - Seal Welds for ,
Threaded Connections i J
This attribute was determined to be acceptable based )
on a review of CPRT reinspection results. The CPRT j reinspection found no adverse trends. These results i were documented in the ISAP VII.c Results Report, l
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Appendix 1 TU Electric stated that CPRT evaluated the welding attributes associated with threaded connection seal welds, and used validated design drawings when performing reinspection. The NRC inspector concurs with the engineering evaluation of this attribute which concluded that reinspection is not require l l
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22 N-TD Attribute Review
'(1) : Attribute Number: 765 (N-TD)
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Commodity: piping and In-line Components Attribute Description: Screwed Joint Thread Engagement A technical disposition for this attribute was required due to generic inaccessibility and because
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CPRT did not address the attribute. Adequate thread engagement of piping screwed-joints is required to assure leak tightness and mechanical strength of the joint.-
It is extremely unlikely that pipe threads on
. purchased items such.as pipe fittings, valves, strainers, traps', and pipe nipples would have any significant deviations from ANSI requirements because these items are generally mass produced using highly automated machines with very' good product quality repeatability. Male pipe threads cut on site using pipe' threading machines also are not likely to.have'significant deviationsffrom ANSI requirements because thread depth and length ar . machine functions and are thereforeLvery repeatable. l A piping. threaded-joint in which both.the male and ,
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female threads conform to ANSI requirements will have adequate. thread engagement when it is tightened. Tightness of piping threaded joints is 4 assured by pressure test of the syste ]
l The high level of confidence that' pipe threads I conform to ANSI requirements and the consistency of field procedures related'to threaded joints are the basis for accepting the attribute without ,
reinspection. The NRC inspector concurs with the i technical disposition of this attribut (2) Attribute Number: 794 (N-TD)
Commodity: Piping and In-line Components Attribute Description: Physical Damage All safety-related piping and in-line components are required to be free of physical damage by the applicable section of Specification 2323-MS-100,-
Revision 9. Although the attribute for physical damage is generically accessible, a technical disposition was provided since TU Electric has committed to the implementation of procedures to
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perform walkdown inspections for final area accep-tance. The NRC inspector reviewed the procedures that implement final area acceptance and determined that current revisions of the procedures do not provide an adequate technical basis for validation of the attribute. Physical damage is not listed as an attribute for' verification in procedure ECC 9.11, Revision 3, Room / Area Completion Walkdown which is required to implement the turnover from construction to operations controlled by Procedure EC-9.1 TU Electric stated that EC-9.11 had, in fact, been i revised to delete specific wording regarding damage, yet reference to the procedure within the Technical Disposition for Attribute 794 is still appropriat EC-9.11 references Operations Procedure STA-810 (" Acceptance of Rooms, Areas,'and Structures") whdah requires that Operations perform a walkdown for damage. EC-9.11 also requires that Construction perform a completion review of the room / areas in accordance with ECC-9.11. This procedure discusses in general terms a review for damage. ECC-9.11 gives guideline criteria of items to be looked at during the walkdow Additional NRC questions were raised on the attribute because the Technical Disposition was worded such that it appeared to base acceptance of Attribute 794 solely upon the room closure proces TU Electric stated that the body of the Technical Disposition also included reference to other programs which contribute to the acceptance of Attribute 794. The Technical Disposition will be revised by March 17, 1989, in order to clarify that the basis for this attribute's acceptability relies on a combination of activities and not solely'on EC-9.1 In some cases, Technical Disposition took credit for verifications that were going to occur in other procedures. Since those other procedures are subject to change, a notification needs to be made to the responsible individual for that procedure identifying the commitment made in the Technical Disposition. TU Electric stated that, in such cases, a commitment will be put into the commitment tracking system to verify that it was completed. A backfit review of technical dispositions to identify these procedures will be completed by March 17, 1989, and the necessary commitments will be entered into the appropriate system (445/8914-0-04).
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(3) Attribute Number: 943 (N-TD)
Commodity: Pipe Support Lubrite Plates
, Attribute Description: Plate Type This attribute received a technical disposition due to the generic inaccessibility of Lubrite plate The physical features which would identify the plate type are hidden by the mating surface. CPRT review of installation documentation did not identify any deviations. The NRC inspector reviewed the technical disposition documentation attached to the AEF and concurs that TU Electric's evaluation of the attribute is technically acceptabl (4) Attribute Number: 1003 (Deleted) (N-TD)
Commodity- Pipe Supports - General Attribute Description: Temporary Attachment - Base
. Metal After Removal This attribute concerns the' local grindoff of material at temporary support attachment point The attribute has been deleted based upon a review of 23 nonconformance reports (NCRs) which were acceptably dispositioned and a SWEC analysis that found that the minimum wall reduction resulting from corrosion was acceptable. The NRC inspector concurs with the deletion of the attribut (5) Attribute Number: 705 (Deleted) (N-TD)
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Commodity: Pipe Supports (Category II/I)
Attribute Description: Integral Attachment Adequacy This attribute was deleted due to a redefinition and consolidation (clustering) of attributes for Category II/I pipe supports. The net effect was the deletion of 35 attributes and the addition of 11 attributes which are sufficient to validate the ]'
commodity. Construction adequacy for Category II/I integral attachments is now being validated by Attribute 1799, Configuration / Orientation / Material j Deviations. The NRC inspector concurs with the consolidation of Attribute 705 into attribute 179 PCHVP reinspection is required for Attribute 1799, {
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l 25 5. HVAC (50100) Installation-Specifications Reviewed The team reviewedLSpecifications 2323-SS-30, Revision 3, dated August 3, 1987, and 2323-MS-85, Revision 6, dated February 12, 1988, as part of its background review to ensure tnat all necessary. commodities and final acceptance attributes were identified on the CAM. The HVAC attribute population consisted of nine N attributes and six N-TD attributes, of which TAP reviewed four and three, respectively. The team reviewed two N and two N-TD attributes which represented three of the four HVAC-commodities. Two of the four attributes in the NRC sample were also reviewed by TA N-Attributes Reviewed (1) Attribute Number: 1788 (N)
Commodity: HVAC Air Handling Units / Plenums Attribute Description: Hilti Kwik Bolt - Nut Not Bottomed Out Specification 2323-SS-30, Revision 3, dated August 3, 1987, identifies QC. inspection attributes i pertaining to the installation of Hilti Kwik bolts in HVAC air units and plenums. All significant attributes identified in the specification are included in the PCHVP for this commodit CPRT did not address the specific attribute of " Nut i Not Bottomed Out." However, this' attribute would have been encompassed-in the CPRT inspection attribute "embedment"; i.e., if the embedment is correct the nut cannot bottom out. Further, if embedment was not correct, QC initiated a DR and engineering then evaluated the condition including nut bottoming out. The NRC inspector concluded that reinspection of this specific attribute is not require (2) Attribute Number: 1102 (N)_
Commodity: HVAC Ducts Supports Attribute Description: Bolting Bearing 1:20 Specification 2323-MS-85, Revision 6, dated February 12, 1988, identifies QC inspection attributes pertaining to the installation of HVAC
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< duct supports. All significant attributes identified in the. specification are included in the-
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PCHVP for this commodit CPRT did not identify any bolted connections on HVAC
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duct support members.' Therefore this uttribute has,
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I not been included-in the PCHVP_rei'nspection effort.- l The NRC' inspector reviewed the~Results Report for:
ISAP VII.c, Appendix 31, and FVM CPE-EB-FVM-CS-029, Revision 6, and agrees that reinspection of thi '
specific attribute is not required.- N-TD Attributes Reviewed (1) 1098 (N-TD)
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Attribute Number: l t l Commodity: HVAC Ducts supports Attribute Description: Bolting - Hardened Washers for High Strength Bolts; Hardened washers are. required for friction type connections but are not required for bearing type connections.. This attribute will not be validated under PCHVP because there are.'no known friction typ connections for this commodity. Within the scope o PCHVP HVAC duct support walkdowns, all connections' ,
are' considered bearing connections. If a friction !
connection is required, it will be detailed as such-on a-Design Change Authorization (DCA) for a modification. This DCA will be implemented as new work and inspected in accordance with Appendix K of MS-85. The NRC inspector agrees with this approac .
(2) Attribute Number: 1766 (N-TD)
Commodity: HVAC Equipment Supports Attribute Description: Bolting Bearing 1:20 Project Procedure NQI-3-09-M-006 requires that " Bolt heads and nut shall rest against the outer face of I the bolted part(s), within a slope of 1:20 or less."
Further, CPE-EB-FVM-CS-066 also requires that "any washer condition which prevents full bearing of the nut or bolt head shall be recorded on the RMF." The NRC inspection team's discussions with TU Electric .i identified that these inspections are in fact being j performed and.that the attribute matrix apparently has a typographical error (indicating N-TD) which will be corrected. It is TU Electric's opinion that this attribute is within the scope of the PCHV The NRC inspector agree i
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l 6. INSTRUMENTATION AND CONTROLS (52055)
The team reviewed the installation specifications and DBDs listed below as part of its background review to ensure that all commodities and attributes were correctly identified. The l NRC identified no commodities or attributes in addit. ton to !
I those identified by TU Electric in the PCHVP CAM that the NRC
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felt needed to be addresse Installation Specifications and DBDs Reviewed:
CPES-I-1018, Revision 2, " Installation of Piping / Tubing and Instrument" 2323-MS-100, Revision 9, " Piping Erection Specification,"
dated July 1, 1987 2323-SS-30, Revision'3, dated August 3, 1987 i
DBD-CS-089, Revision 1, " Instrument Tubing Support- .{
Design" j DBD-EE-035, Revision 1, " Instrument Installation and Separation" l
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For the I&C commodities, there were 92 N attributes and l 11 N-TD attributes. The team selected 12 N attributes and 5 N-TD attributes which represented all the
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commodities reviewed by the applicant. TAP has reviewed 33 of the N attributes and 8 of the N-TD attribute N Attribute Review l (1) Attribute Number: 514 (N) (Deleted)
Commodity: Instrument Flow Elements l Attribute Description: Tap Location The NRC team review of the documentation of the attribute revealed that the attribute inspection is covered in the Piping and In-Line commodity by Attributes 753, 755, 769, and 77 Therefore, this I attribute was deleted from the matrix for the Instrument Flow Elements commodity. The NRC l inspection team review concluded that this deletion is appropriat (2) Attribute Number: 573 (N)
Commodity: Instrumentation Control Valve Accessory Supports I
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28 Attribute Description: Baseplate-Hole Centerline to )
Edge Distance d l
CPRT addressed this attribute in the ISAP VII.c, 1 Appendix 28, Results Report, Section 2.2.5. CPRT i reviewed the attribute at 480: inspection ~' point l Twenty-six deviations from specification? j requirements were noted. The analysis for each j
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deviation determined that the supports as installed were still adequate to sustain the maximum applic-able loading condition. Therefore, CPRT concluded (
that it was unlikely that a construction deficiency l exists and did not recommend reinspection. The ,
inspection criteria for this attribute are l unchanged. The NRC inspection team concurred that I this attribute was adequately addresse J l
(3) Attribute Number: 603 (N) j
Commodity: Instrument and Tubing Supports l Attribute Description: Welding-Size This welding attribute (size) was addressed by CPRT in ISAP VII.c, Appendix 28. One-thousand sixty j
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inspection points were reviewed with a total of 206 deviations noted. Analysis of the deviations indicated that none was substantial enough to affect the function of the instrument tubes or the supports adversely; therefore, no reinspection was recommended. Also, the attribute acceptance criteria used for this commodity by PCHVP are the same as those used for the CPRT inspections. The NRC inspection team concurs that the attribute has been adequately addresse (4) Attribute Number: 1260 (N)
Commodity: Instrument and Tubing Supports Attribute Description: Welding Length This attribute was addressed by CPRT in ISAP VII.c, Appendix 28. CPRT reviewed 1060 inspection points and found 11 deviations. These were determined by ana'?9>.s nc^ to affect the function of the tubing or supports. Therefore no adverse trend was identi-fle The acceptance criteria for this attribute are the same as those for the CPRT inspection Based on the above, the NRC inspection team concurs with the applicant's assessment.
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L 29 (5)' Attribute Number: 1607 (N)
Commodity: Instrument Tubing, Valves, and Fitting Attribute Description: Tubing' Size l
This attribute.was inspected by CPRT and reported in ISAP VII.c, Appendix 7. Based on the fact that no
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deviations were noted in 107 inspections of this attribute, no recommendation for reinspection was !
.made. The NRC inspection team concurs'with this attribute evaluatio ,
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(6) Attribute Number: 1708 (N) '!
Commodity: Instrument Control; Valve Accessory Supports Attribute Description: 'Hilti Bolt Diameter l CPRT, ISAP VII.b.4, "Hilti-Bolt Installation,"
reported on the reinspection results for size, type and. quantity, and states that the deviations found; were determined not to be safety significant and no adverse trend was identified. Further, the current
' inspection criteria for this attribute are the same as.those used in the CPRT inspections. The NRC inspection team is-satisfied that this attribute has .;
been evaluated correctl !
(7) Attribute Number: 1830 (N)
Commodity: Incore Instrument Tubing l
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Attribute Description: Material-Wall Thickness-CPRT inspected this. attribute as Attribute 8 and 10 in ISAP VII.c, Appendix 13. Attribute 10 verified that the original tubing was. supplied with a nominal wall thickness that satisfied-the original specifi-catio CPRT inspected 200 items for this attribute identifying three deviations which were determined .
to be insignificant. Attribute 8 verified that the j tubing did not contain base metal defects. Two-hundred two inspections were performed and no -
adverse trends were identified. The CPRT inspection criteria are the same as current requirements. The i I
NRC inspection team concurs with the conclusion that further reinspection is not require . - _ _ _ . _ _ _ _ - - . _ _ _ _ _ _ _ _ . . _ _ _ . _ -
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- (8) Attribute Nhmber: 1475 (N)
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Commodity: Instrument Tubing,[Valvss_and Fitting .
_ Attribute Descript' ion: Welding-Perfonn ? Required -
Nondestructive' Examination ((NDE) 1 ISAPiVII.c,: Appendix 13, indicades-that CPRT'
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Lperformed 500 reviews fortthisjattributeland found'
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no: deviation Therefore, there was no recommenda- E tion for reinspection.- Also the validated instal--
, lation specification criteria are consistent;with1 the CPRT criteria. The NRC inspection team. concurs k that thisKCPRT' assessment is-. adequate ~for.the 1 attribute.- !
- (9)- Attribute Number: 05 (N)
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. Commodity: Balance offPlant (BOP) Analog Controls '
Attribute Description: ID-Tag Number 7300 Cabinet '
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This. attribute addresses proper equipmen ..
identification tagging of BOP analog-equipment racks
, (type;7300. cabinets)-in accordance with!ES-100, Section 1.4.2.2 A and.B. CPRT addressed:the attribute in Results Report ISAP VII.c,; Appendix'6, SectionL2.2.1, Revision 1; with criteria equivalent to the current criteria-in ES-100, Appendix K.. _ The'
CPRT ' identified 11 discrepancies of 137 inspectioli point The 11 discrepancies involved missing' metal
- tags on electrica1' conductor. seal assemblies.(ECSAs)-
and were considered' insignificant. "CPRT determined-that the attribute did not require reinspectio The NRC team agrees with'this dispositio (10). Attribute Number: 1686 (N) (Deleted)
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. Commodity: Instrument Flexible Hoses Attribute Description: Serial Number The attribute was deleted as not meeting the ec
definition of a FAA; i.e., "An attribute that provides the basis, either in part or whole, for the assurance that the installed hardware has satisfac-torily implemented the design." Considering that E serial numbers will be recorded under other reinspection requirements and documentation
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programs, the team agreed with this deletion.
r The team questioned why the commodity did not ;
include as attributes weld splatter ama caparation
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of braid. However, the NRC inspection team's review of Attributes 502, " Frayed Braiding," and 503, " Arc Strikes," determined that weld splatter and
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separation of braid-were inspected by FVM-69, which l'
l references the appropriate specification (I-1018).
Also, QC inspection reports for these attributes require adherence to the specification. The NRC inspector had'also previously attended a training class on flex hose installation (forLcraft, engineering, and QC personnel) which thoroughly addressed specification requirement (11) Attribute' Number: 798 (N)
Connodity: ' Instruments Attribute Description: High, Pressure / Low Pressure Tap Identification The attribute was=at one time deleted based on the judgement that it-was encompassed by Attribute 767, Component Name Plate. Data, of the Piping and In-Line Components commodity. .The team reviewed Attribute 767 and FVM-89'and Mechanical Specification MS-100, Appendix'Z, Section 3.2.3.4, and noted.that a o previous revision of the attribute evaluation referred to FVM-IC-069 which contained data sheets ;
for recording. root valve numbers. The applicant !
explained that the root valve was considered as part of the piping whereon the tap was attached and that i tubing downstream of the valve was. instrumentatio Recording root valve numbers effectively addressed tap identification. Therefore, the encompassing by j '
a piping commodity was considered' appropriat ,
The applicant subsequently informed the team that it I was reopening Attribute 798 to clarify.the attribute definition. The AEF, approved by CPE on March 17, 1989, concludes that the attribute is acceptable i based on the Results Report for ISAP VII.c, Appendix 7 and deleted reference to other li attributes /FVMs. The team agrees with this assessmen (12) Attribute Number: 356 (11) (Deleted)
Commodity: Control Valves Attribute Description: Identification - Tag Number The attributes pertaining to this commodity are included in Specifications MS-100, Appendix Z, and I-1018, Appendix D. The attribute was deleted since i
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Lit was.' encompassed by Attribute'767, ComponentLName'
Plate 1 Data, of the Piping and In'Line Components-
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The team's review of. Attribute 767
' determined that it didl encompass this. attribut EAttribute 356-was audited by: TAP, butLthe TAP report, ATP-88-117, only' indirectly; addressed.the commodity by a. sampling of-four.FVM-089 PCHVP-engineering walkdown packages for'the-containment:
spray,7 fuel =poolLcooling,aand component coolin water systems. The team agrees with this' deletio '
c. N-TD Attributet-Review ll
'1 (1)- Attribute Number: -613 (N-TD) 1 3 0
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Commodity: Instrument Tubing '
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Attribute Description: Welding N- Size i'
, CPRT identified a. concern associated withs socket welds.-(size) con 11/2"!diametercand smalleritubin The concern involved theilnabilityxto determine the j edge of:the base. material 1by, visual inspection'after- H-completion of thefweld, thereby:leavingithe' weld :l size indeterminate. ;The technical disposition 1 addresses:the concern as, documented on?DRs .
-C-87-05213 and C-87-05251. lIn response, Engineering Report ER-IC-002, Revision 0, dated; April 29, 1988, '
was issued, which evaluated this CPRT concern.-. The evaluation included radiographic testing.(RT) an was performed on a sample of tubing welds. " Based-o '
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these radiographs it was determined that the weld-sizes were acceptable in allicases. The applicant-
.also perfonned. destructive' examination (DT) of these-weld This examination included sectioning and j acid etching of the weld to_ quantify weld'penetra-tion which also proved to be adequate. Als presented was a discussion of the installation-process and, requirements for in process (fit-up)
inspection and nondestructive. examination (VT.&1PT).
Therefore, based on the testing performed and review ,
of installation methods, TU Electric concluded that: d the socket welds in tubing 1/2" in diameter ands smaller need not be reinspected. The NRC inspection team reviewed the documentation provided and concurs with the applicant's assessmen (2) Attribute Number: 592 (N-TD)
Commodity: Instrument Racks Attribute Description: Installation - Hole Diameter Within Tolerance
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F l This attribute was not addressed during the CPRT i reinspection effort. The applicant's technical disposition for the attribute stated that the original Installation Specification 2323-MS-628 had !
tolerances equivalent to-the current Specification CPES-I-101 i A DCA had revised the current' specification to make it consistent with the older ~ requirement Also provided'as part of.this technical disposition were copies of the inspection reports for all the safety related instrument racks which all indicate that the final configuration was satisfactorily inspected by l QC personnel. Based on the satisfactory inspections and its review of installation specifications and the DCA, the NRC inspection team finds the attribute assessment adequat (3) Attribute Number: 1614 (N-TD)
Commodity: Instruments Attribute Description: Cable Installation Splicing and Terminations For Selected Non 1E Instruments (Regulatory Guide 1.97 " Post Accident Monitoring").
The attribute was technically dispositioned as not requiring reinspection due to complete rework directed by DMRC-87-1-178. Installation will be in accordance with the current criteria of Procedure EEI-8 and QC Procedure QI-QP 11.3-28. TAP Report ES-88-48 indicated that a deficiency in the attribute was properly identified and tracked by Deficiency ES-88-48-01. The team concurs that the technical disposition provides an adequate basis for no PCHVP reinspectio (4) Attribute Number: 359 (N-TD)
Commodity: Control Valves Attribute Description: Accessories - Configuratio ,
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Remote mounted accessories for air operated valves, such as transducers, air filter regulators, and solenoid valves, which are safety related and/or Seismic Category I or II must be configured in accordance with design drawings. This attribute was not addressed by CPRT. The initial technical disposition indicated reinspection would not be required due to coverage by Startup Department testing and Maintenance Department operations. The team's review of the referenced applicable l
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procedures raised questions as to whether'configu-ration would actually be verified by this coverag 'A' subsequent evaluation form was submitted to the team which indicated that the above questions-had already been considered by.the applicant. The revised evaluation indicated reinspection for configuration will be. accomplished under FVM-09 NRC review of'FVM-090 showed-this attribute to be'in an attachment. The heading of this attachment i stated " reference use'only." The NRC team is-concerned that this attribute may not be covered by the FVM (445/8914-05).
The team reviewed QA surveillance Report'ES-88-46 which noted a discrepancy between the evaluation. .
package and.the' commodity / attribute matrix. One of the required two actions has not been completed; i.e., to revise the matrix reinspection requirement to "Y-Q."
(5) Attribute Number: '1603 (N-TD)
Commodity: Instrument Main Control Board and Panel Attribute Description: Control Equipment Mounting The attributes pertaining to this commodity are'-
included in Specification I-1018, Appendix Z. This attribute was evaluated as not requiring reinspec-tion due to the envelopment by Attribute 1483 which covers mounting for electrical equipment in genera The team's review of FVM-CPE-IM-EQ-057, Revision 4,
. " Equipment Qualification Walkdowns," determined that the FVM appeared adequate.for reviewing both Attri-butes 1483 and 160 . CIVIL / STRUCTURAL (45051, 46055, 48055)
The team reviewed the installation specifications and design -l
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basis documents listed below as part of a background review to ensure that all commodities and attributes were correctly identified. No commodities or attributes in addition to those listed on the PCHVP CAM were identified by the NRC inspecto I
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l Installation Specifications and DBDs Reviewed j 2323-SS-6, Excavation and Backfill for Plant Structure i
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2323-SS-8, Excavation and' Backfill for Buried Pip SS-9, Concret l 2323-SS-14, Containment Steel Line SS-16B, Structural Steel / Miscellaneous Steel (Category I & II)
.2323-SS-18, Erection of Stainless Steel Liner DBD-CS-015, The Qualification of Embedments in j Concret !
l In.the civil / structural area, PCEVP listed.127 N attributes and 33 N-TD attributes. . The team selected 12 N attributes (including-one deleted attribute) and 4 N-TD attributes for review. At leart one attribute was sampled from each commodit N Attribute Reviewed'
(1) Attribute Number: 176 (N)
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Commodity: Concrete Anchorage.Hilti. Bolts Attribute Description: Final Minbnum Embedment j j
CPRT inspected this attribute using Quality j Instruction QI-045,. Revision 4.. The criteria j specified in QI-045 are equivalent to the current j Installation Specification 2323-SS-30 with the exception of maximum embedment limitations for 1/2-inch and 3/4-inch Hilti bolts. These criteria are addressed by SDAR CP-86-51 and CECO letter 0158 dated February 13, 1989. FVM-CS-075 identified 594
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of these bol.cs with deep embedments and concluded that 100% of these bolts have sufficient capacity to support the design loads. .The NRC inspector concluded that this issue is adequately addresse The CPRT Results Report ISAP VII.b.4 concludes that '
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the Hilti bolts are adequately installed to perform the safety-related function and did not recommend reinspection. No adverse trends or safety signifi- i
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cant deviations were identified by CPRT. The NRC inspector concurred that reinspection of this attribute is not require _----_____-__-____-_____:__________
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'36 (2) Attribute Number: 347 (N)
Commodity: Containment Liner Floor,.Shell, Dome, and Insert i
Attribute Description: Fittings Alignment CPRT inspected this attribute using Quality Instruction QI-31, Revision 0. The criteria specified in QI-31:are equivalent to the. current-Installation Specification 2313-SS-14. The CPRT Results Report ISAP VII.c, Appendix 23 concludes I that the containment liner is adequately installed to perform the safety-related function and did not recommend reinspection. No adverse trends or safety significant deviations were identified by CPRT; The NRC inspector concurred that reinspection of this attribute is not require (3) Attribute Number: 564 (N)_
Commodity: Stainicss Steel Liner - Fuel Pool Attribute Description: Welding - Weld Surface
CPRT inspected this attribute using Quality J Instruction QI-033, Revision 1. The criteria specified in QI-033 are equivalent to the current Installation Specification 2323-SS-18. The CPRT Results Report ISAP VII.c, Appendix 24 concludes a
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that the fuel pool stainless steel liners are adequately installed to perform the safety-related function and did not recommend reinspection. No adverse trends or safety significant deviations were identified by CPRT. The NRC inspector concurred that reinspection of this attribute is not require (4) Attribute Number: 723 (N) j Commodity: Pipe Whip Restraints Attribute Description: Dimensions Within Tolerance For the attribute Dimensions Within Tolerance, the CPRT inspection criteria are equivalent to the current installation specification acceptance criteri CPRT inspected this attribute and determined that all identified deviations were insignifican CPRT did not recommend reinspection of this attribute. The NRC inspector concurred that l reinspection of this attribute is not require j l
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(5) Attribute Number: 741 (N) (Deleted)
i Commodity: Pipe Whip Restraints Attribute Description: Hot Functional Gap This attribute was deleted from the attribute matrix since hot functional gap measurements will be taken during the Hot Functional Testing Program. The NRC inspector verified that the Hot Functional Testing Program procedures include provisions to make these measurement (6) Attribute Number: 1461 (N)
Commodity: Stainless Steel Liner - Tanks Attribute Description: Welding - Undercut CPRT inspected this attribute using Quality Instruction QI-031, Revision 2. The criteria specified in QI-031 are equivalent to the current Installation Specification 2323-SS-16B. The CPRT Results Report ISAP VII.c, Appendix 23 concludes that the tank stainless steel liners are adequately installed to perform the safety-related function and did not recommend reinspection. No adverse trends-or safety significant deviations were identified by CPR The NRC inspector concurred that reinspection of this attribute is not require (7) Attribute Number: 1553 (N)
Co.nmodity: Backfill i
Atcribute Description: Material ,
CPRT performed a document review of this attribute using Quality Instruction QI-057, Revision 7. The criteria specified in QI-057 are equivalent to the current Installation Specification 2323-SS-6. The CPRT Results Report ISAP VII.c, Appendix 20 concludes that the backfill is adequately installed -
to perform its safety-related function and did not j recommend reinspection. No adverse trends or safety {
significant deviations were identified by CPRT. The ]
NRC inspector concurred that reinspection of this j attribute is not require i
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(8) -Attribute Number: 1557 (N)
Commodity: Bedding Attribute-Description: Placement
'CPRT performed a document review of this attribute using Quality In struction QI-057, Revision 7. The:
criteria specified in QI-057 are. equivalent to the current Installation Specification 2323-SS-8. The CPRT Results Report ISAP VII.c, Appendix 20 concludes that the bedding is adequately installed-.
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to perform its safety-related function and did'no recommend reinspection. No adverse trends or safety significant deviations were identified by CPRT. The
'NRC inspector concurred that reinspection of this _;
attribute is not require (9) Attribute Number: 1580 (N)
Commodity: Concrete Anchorage Embedded Steel
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Attribute Description: Plate Type and Location CPRT inspected this attribute using Quality-Instruction QI-043, Revision 2. The criteria specified in QI-043 are equivalent to the current Installation Specification 2323-SS-9. The CPRT Results Report ISAP VII.c, Appendix 18 concludes that the embedded plates are adequately installed to perform the safety-related function and did not recommend reinspection. No adverse trends or safety
- significant deviations were identified by CPRT. The l NRC inspector concurred that reinspection of this 4
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(10) Attribute Number: 1638 (N)
I Commodity: Reinforced Concrete Attribute Description: Concrete Strength CPRT performed a document review of this attribute using Quality Instruction QI-044, Revision 3. The criteria specified in QI-044 are equivalent to the'
current Installation Specification-2323-SS-9. The :
CPRT Results Report'ISAP VII.c, Appendix 8 concludes j that the concrete is. adequately installed to perform i its safety-related function and did not recommend reinspection. No adverse trends or safety signifi-cant deviations were identified by CPRT. The NRC i inspector concurred that reinspection of this I attribute is not require l l
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(11) Attribute Number: 1642 (N1-Commodity: Reinforcing Steel Attribute Description: . Adequacy of Cadweld Splices CPRT performed a document review of this attribute using Quality Instruction QI-044, Revision 3. The criteria specified in QI-044 are equivalent to the current Installation Specification 2323-SS-1 The CPRT Results Report ISAP VII.c, Appendix 18 concludes that the cadweld splices are adequately installed to perform the safety-related function and did not recommend reinspection. No adverse trends or safety significant deviations were identified by CPR In addition, the technical adequacy of nonconformance and design deficiency reports regarding cadwelds was reviewed in accordance with Project Procedure PP-041, Revision 3, "Noncon-formance Evaluation Procedure." No problems with the dispositions were identified by this progra '
The NRC inspector concurred that reinspection of this attribute is not require '
(12) Attribute Number: 1656 (N)
Commodity: Epoxy / Cement Grout Attribute Description: Grout Strength CPRT performed a document review of this attribute using Quality Instruction QI-69, Revision 2. The criteria specified in QI-69 are equivalent.to the current Installation Specification 2323-SS-9. The CPRT Results Report ISAP VII.c, Appendix 21 concludes that the epoxy / cement grout is adequately installed to perform its safety related function and did not recommend reinspection. No adverse trends or safety significant deviations were identified by CPR The NRC inspector concurred that reinspection of this attribute is not require c. N-TD Attributes Reviewed (1) Attribute Number: 352 (N-TD)
Commodity: Containment Liner Overlay Plates and Attachments Attribute Description: Weld Location L___-_____-__
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. Quality Instructions QI-31 and QI-32, and. concluded i
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that the liner welds are adequately installed to perform the safety-related function. 'Since the welding of the overlay plates and attachments i performed by CB&I was performed using the same procedures, personnel, etc., as the containment . j liner, PCHVP concluded that the overlay plates and ;
attachments installed by CB&I were also adequately 1 installe CPRT reached the same conclusion in !
letter CPRT-ll52 dated August 5, 198 !
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-Various commodities such as instrument supports,
.small base pipe supports, Category 1 conduit
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supports, etc., were welded to the liner by !
contractors other than CB&I (primarily B&R). CPRT, in letter CPRT-ll52, accepted the attachment of these commodities based on reinspection of simila construction work. . CPRT selected samples for i reinspection from: numerous populations that included "
these' commodities.- Items attached to the' liner were .i eligible'for sample selection by CPRT-and the items ~ l r reinspected were representative of the total . '! l populatio In addition, letters SWTU-1654 and SWTU-3823 document reviews of all traveler packages for the containment liner attachments and the-corresponding weld procedures. The weld procedures were reviewed for compliance with applicable welding code ,
The NRC inspector reviewed the PCHVP package fo this. attribute, discussed the technical disposition with the applicant, and concluded that reinspection of this attribute was not require (2) Attribute Number: 554 (N-TD)
Commodity: Stainless Steel Liner - Fuel Pool-
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Attribute Description: Welding --Arc Strikes CPRT did not address the' attribute of welding - arc strikes. This attribute was not inspected by PCHVP based on the conclusion that the reduction of base
! metal does not adversely affect the functional capability of the fuel pool liners. The NRC inspec-tor agreed with that conclusio !
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[ (3)..' Attribute Number:' -lb48-(N-TD)'
Commodity: Excavation
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' Attribut'el Description:- Blast Vibrations
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CPRT"did not address'the attribute of; blast' i vibrations. PCHVP did not. inspect..for.this: .
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attribute 1as blast vibrations'are transient'and n<xt inaccessible.- Also, the excavated. surfaces of
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concrete and backfill.that2 could have been affecte :by-the blast vibrations are nowl inaccessible.- PCHVP 1
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d validated .the attribute to be : acceptable based;on - a review.of blast. records. . The NRC inspecto concludedithat. reinspection of thisfattribute'was: ,
not1 require '
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'(4) IAttribute: Number: -1563 (N-TD) !)
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Commodityi Safe Shutdown Impoundmen ..
(SSI)-Excavation !
A Attribute Description: ' Structural. Concrete lj
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CPRT did not address the.Attribdte of' structural-concrete for-the. commodity SSI-Excavation.. This-
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' attribute was not inspected by PCHVP since;th I 5' single placement _of structural concrete is' embedded'
in the rock excavation.and the top surface is covered with water. Thus, the placement /is inaccessible. PCHVP-validated 1the. attribute to be-
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acceptable based on documented' approvals on the ~
structural concrete placement card.and documented concrete compressive strength. .The NRC inspector concluded that' reinspection of this attribute was not require . ELECTRICAL (51055, 51065) ..
%' Installation Specifications Reviewed The team reviewed electrical installationLspecification, ES-100 to ensure that: all commodities and - attributes were ' '" -
correctly identified on the PCHVP-matrix. The NRC did not identify 1any significant commodity or attribute omissions. There were 80 N and 21 N-TD attributes;. TAP reviewed 22 and 13 of'these, respectively.- The-team sampled 10 N and 2'N-TD' attributes. The samples selected bylthe team were based on awareness offproblem. area i Attributes previouslyl reviewed by TAP, CPRT, or EFE were avoided, except where'too few unreviewed attributes were available for the commodity or to check the adequacy of the other reviews. The team's sample for each commodity
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was approximately proportional to the number of attri-butes_for that commodity. The team's review of the attributes is discussed below, b. N-Attributes Reviewed j (1) Attribute Number: 140 (N)
Commodity: Cable-Power, Control and Instrument Attribute Description: Damage - General The cable is required to be free of observable damage, including cuts, gouges, cracks, kinks, or twist CPRT inspected the attribute to the current criteria with.the exception of allowable depth of indentations. The current criteria are less stringent. The CPRT inspection found no damage and,
.j therefore, no reinspection was required. The team concurs that the CPRT results cover the attribute adequately in scope and obviate the need for PCHVP reinspectio (2) Attribute Number: 107 (N) (Deleted)
Commodity: Cable-Power, Control and Instrument Termination Attribute Description: Insulated Splice Connectors (PIES)
This attribute was deleted since all design-related items for the attribute were to be addressed as part of Attribute 1576 which is addressed belo (3) Attribute Number: 119(N)
Commodity: Cable-Power, Control, and Instrument Termination Attribute Description: Connectors-Triaxial The assembly of triaxial connectors is required to meet the vendor / engineering requirements of ES-100, Appendix K, Section 5.6. CPRT inspection consisted of a document review of QC accepted Nuclear Instrumentation System (NIS) cables and identified no trends necessitating PCHVP reinspection. The acceptance criteria of the QC inspections were equivalent to current installation criteria and therefore the determination of no requirement for reinspection was justified.
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'The team noted that Worksheet A of the attribute evaluation package indicated CPRT Results Report, Appendix.3 was used for the evaluation. However, the actual appendix' applicable was Appendix 4 which was used in the evaluation. TAP Surveillance Report-ES-88-48 also documented this discrepanc (4) Attribute Number: 370 (N)'
Commodity: Electrical Equipment - 120 VAC UPS Attribute Description: Field Modification / Rework The Uninterruptible Power Supply-System is designed to supply power without delay or transients during any period when the' normal power supply is incapable'
of performing acceptably. All field-modification require verification of instructions and installa-tion in accordance with ES-100. CPRT inspected the:
attribute according to a revision of ES-100, which is essentially the same as the current revision wit regard'to the attribute. The NRC team's review-of CPRT Results Report ISAP VII.c, Appendix 6, Section 2.2.4, Revision 1, indicatedLthat CPRT identified no-
' negative trends; therefore, the. recommendation not, to require reinspection was justified. However,tthe CPRT did recommend a complete reinspection for
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configuration, and this was accomplished by FVM EE-08 (5) Attribute Number: 379 (N)
Electrical Equipment - l'25'VDC Chargers
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Commodity:
Attribute Description: Ratings The chargers are designed to provide normal DC power and recharge the battery after discharg This attribute confirms that the ratings of installed components are consistent with design requirements. CPRT ISAP VII.a.9, Attachment E, inspected this attribute to requirements equivalent to the current criteria in ES-100 and.found no negative trends. The team concurs that PCHVP
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(6) Attribute Number: 390 (N)'
Commodity: Electrical Equipment-- 480 V MCC Attribute Description: Field Modification / Rework Reinspection was not required and was justified similar to Attribute 370 above. The team concurred with the justification that PCHVP reinspection is not necessar (7) Attribute Number: 393 (N)
Commodity: Electrical Equipment - 480 V Unit Substatio ]
Attribute Description: Ratings This attribute addressed ratings of substations, consisting primarily of one transformer mechanically and electrically connected (and coordinated in design) with a switchgear or motor control assembl Reinspection was not required and was justified similar to Attribute 379 above. The NRC inspection team concurs that reinspection is not require !
(8) Attribute Number: 403 (N)
Commodity: Electrical Equipment - 6.9KV Switchgear Attribute Description: Damag CPRT Results Report ISAP VII.c, Appendix 6, Section 2.1, Revision 1, indicated no negative trends for this attribute and therefore provided justification for not reinspecting this attribut TAP surveillance on the attribute evaluation was documented in Report ES-88-48. Deficiency ES-88-48-03 concerned an incorrect specification reference. Additionally, the TAP report noted that i the results of the redesign review portion of the i attribute evaluation were erroneous. However, the acceptance criteria were verified not to have j changed subsequent to the CPRT review so the ]
attribute evaluation was acceptable. This deficiency is being tracked by the applicant as Deficiency ES-88-48-0 )
The team concurs that this attribute does not I require reinspection on the basis of the CPRT review and the consistency between acceptance criteria before and after the CPRT review.
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' (9) Attribute Number: 419'(N) (Deleted)
Commodity: ' Electrical Equipment - Penetration-Assembly
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Attribute Description: . Pigtail Damage Insulations The' attribute was deleted'as'being duplicated by
. Attribute'41 The NRC team agreed that the latter attribute enveloped Attribute 41 NRC review of1 Attribute 417 will be documented.in a subsequent inspectio (10) Attribute Number: 434 (N) (Deleted)
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' Commodity: . Electrical Eqdipment -' Electrical conduit'. Seal Assembly Attribute Description: Cleanliness The attribute was deleted as being an in-process rather than a final acceptance attribute. The justification also stated the attribute would be
' addressed as part of'NQA ~ 3.09-7.0 However,
.NQA 3.09-7.01, " Inspection Packages" was. delete The team understands.that, since it is not-TU Electric's intent to reinspect this attribute as .]
indicated above, the reference to NQA 3.09-7.01 will b'e deleted from the attribute evaluation documenta-tio N-TD Attributes Reviewed (1) Attribute Number: 1573 (N-TD)
Commodity: Cable-Power, Control and Instrument Attribute Description: Effect From Cable Pull Overtensio The possibility exists that cables pulled in excess of maximum allowable pull tension could have.bee damaged. This attribute was not addressed by CPR The technical disposition.that no reinspection was required is based on SWEC.'s Specific Technical Issue Report (STIR)'CPE-E-002, " Cable Tension Evaluation,"
and manufacturer recommendation The NRC inspection team's review of the STIR indicated acceptable sampling methodology and the results do indicate that reinspection is not require '
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(2) Attribute Number: 1576 (N-TD)'
Commodity: Cable-Power, Control and Instrument Termination Attribute Description: PIES Location Preinsulated Environmental Splices (PIES) are electrical connectors,. installed by mechanical pressure. crimping, in panels, termination cabinets or junction boxes where field cables are splice TAP Report ES-88-48 documented a discrepancy (also noted by the NRC inspection team) in the attribute description. While the attribute evaluation form i and the matrix description refer to PIES location, !
page 2 of the Initial Acceptability Review refers to !
PIES in general, and describes the design require-ments of maintaining an electrical current through the splice during normal and abnormal electrical and environmental operating conditions. The team noted several other minor discrepancies in the evaluation which it considered insignifican The justification for not reinspecting the attribute j was primarily based on STIR CPRT-E-001 and
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FVM-EE-022. The team reviewed these documents and a found the justification acceptable. Additionally, the team determined that PIES had been addressed and found acceptable in NRC Inspection Reports 50-445/88-38, paragraph 2.b; and 50-445/88-45, j paragraph 5.a. Butt splices had been accepted by ;
NRC letter dated September 14, 1984'. Therefore, the !
justification was acceptabl . FIRE PROTECTION (64053)
The team reviewed the installation specifications and DBDs listed below as part of its background review to. ensure that j all commodities and attributes weru correctly identified. The l NRC identified no commodities nor final acceptance attributes 1 in addition to those on the PCHVP CAM which the NRC considers !
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to b3 necessary to assure that the design has been satisfacto-rily implemented and that associated components will perform their design function DBDs and Installation Specifications Reviewed DBD-ME-063, Revision 1, October 7, 1988 - Fire Barriers j DBD-ME-225, Revision 1, October 7, 1988 - Fire q Suppression System l
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"DBD-ME-002, Revision 1, October
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6,~ 1988 - Penetration L' 1 Seals DBD-ME-001, Revision 1,' October 7, 1988 - Fire Protection Program ,
2323-SS-16B, Revision 2, April 22,.1988 - Structural: -
Steel / Miscellaneous Steel (Category I & II)
2323-MS-38A, Revision 2, January 7, 1976 - Fire i Protection Equipment !
2323-MS-38B, Revision 8cj0ctober 11, 1976 - Sprinkler Systems and Hose Stations, Administration and Maintenanc Buildings 2323-MS-38C, Revision 5, May 24, 1988 - Fire Protection Equipment, Indoor Hose Stations 2323-MS-38D, Revision 3, November 4, 1983 - Fire Protection Equipment, Portable Fire Extinguishers 2323-MS-38E, Revision'1, February 6, 1980 - Fire Protection Equipment, Halogenated Agent Extinguishing System-2323-MS-38F, Revision 4, January 11, 1989 - Fire Rated, Radiation Shielding, and Pressure Penetration Seals 2323-MS-38H, Re"ision 2, June 23, 1988 - Cable Raceway Fire Barrier Materials 2323-MS-98, Revision 1, September 30,.1983 , Fire Protection Equipment-Design, Fabricationiand Installation of Fire Protection Systems ,
2323-MS-101, Revision 6, October 19, 1988 - Mechanical Erection Specification In-fire protection, there were 33 N-TD attributes and no N attributes. The NRC inspection team selected nine N-TDs for review representing:nine different commoditie Five of these commodities had two or more attributes;
- these five commodities represented 28 of the 33 N-TDs in the population sampled. TAP reviewed four attributes in the 33 N-TD population, all pertaining to one commodit l The NRC team did not review these four attributes, but l instead reviewed another attribute for that commodit ;
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b. N-TD Attributes Reviewed (1) Attribute Number: 488 (N-TD)
Commodity: FP Thermolag Attribute Description: Mechanical Fastener Type DCA 67543 was issued to remove thermolag/ radiant energy shield from raceways, raceway supports and protruding members for all areas of Unit 1 and Commo Therefore, no commodity remains to be l Verified under PCHV (2) Attribute Number: 896 (N-TD)
Commodity: FP Welding Attribute Description: No Surface Slag Inclusion The attributes pertaining to this commodity are in accordance with ANSI B 31.1 and also include weld size, no cracks or pinholes, no excessive undercut, and no craters or cold-lap. Due to extensive piping rework on the sprinkler system, the attribute was considered to require further review regarding i accessibility for reinspection. The review determined that, due to painted surfaces, the weld attributes were not accessible for reinspectio The logic used to validate this attribute without field walkdown was based upon review of (1) instal-lation and inspection documents, (2) turnover packages for weld inspections, (3) turnover packages for final acceptance testing, and (4) failure scenario Grinnell Fire Protection Systems was responsible for the original design and installation of all fire suppression system piping at CPSES, except for termination piping to the Atmospheric Cleanup Units and piping through the Containment Penetration. B&R procedures were used to install.the piping outside the Grinnell scop I Grinnell Procedure PI-CET3, " Control, Examination and Testing of Fire Protection Systems," defines the requirements for weld inspections and identified the necessary documentation for each weld. The attribute, No Surface Slag Inclusion, is specifi-cally addressed as requiring validation. The team reviewed Grinnell inspection reports and determined
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that the slag inclusion.a't tribute, as well as other welding attributes, had inspector sign-off The technical disposition provides reference to B&R welding documentation packages. This documentation ,
was reviewed by Impell in accordance with ECE '
9.04-05 to obtain assurance that the subject attri-bute, No Surface Slag Inclusion, was satisfactorily verified by trained and certified inspectors for each weld performed by B&R personnel within the fire protection system pressure boundar Although there are no explicit line items for weld attribute confirmations in the final visual weld inspection documentation, B&R weld inspectors were trained and certified to quality Inspection Procedure QI-QAP-2.1-5, " Training and Certification of Inspection Personnel." Included as Attachment 4 to that procedure is the " Visual Weld Inspection Training outline," which requires a minimum ofL20 hours of specialized training in visual weld inspection activities, including a separate subject for slag inclusion. The NRC inspection team e.grees that the technical disposition provides assurance that the subject attribute has been validated acceptably and does not need further reinspectio (3) Attribute Number: 915 (N-TD)
Commodity: FP Radia11t Energy Shield Attribute Description: Continuity of System-As indicated above for FP thermolag (Attribute 488),
the radiant energy shield was removed (DCA 67543)
and the PCHVP is no longer applicable to this commodit (4) Attribute Number: 1524 (N-TD)
Commodity: Gypsum Construction in Class I Structure Fire Barriers Attribute Description: Metal Framing / Components Per Design Specification 2323-SS-16B, Revision 2, dated April 22, 1988, and DCA-74249, Revision 6,Section IV, Fire Barriers states'that QC shall inspect gypsum construction for the attributes as specified herein. All but one of the nine attri-butes identified in this specification are identi-
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fled on the PCHVP CAM. The exception is for
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verifying that Hilti bolts are installed per-Specification 2323-SS-30. Impell; stated that,Hilt = bolts for the gypsum board fire barriers will be inspected as part of new construction resulting from NCR 88-15230 (see below).
Steel framed gypsum board fire-barriers consist of gypsum board to provide fire resistance and steel
~ framing for supporting 1the-gypsum. This attribute verifies that the framing (studs, bridging, clips, etc.) is-in accordance with design. NCR 88-15230, Revision 0, was initiated to remove and scrap the gypsum board. The framing will thensbe inspected by QC along with.the reassembly of-the gypsum. . As a result of the NCR, the subject gypsum walls are considered new construction and not within the PCHVP scope, which applies to previously constructed item The team agrees with this Impell assessmen (5) Attribute Number: 1547 (N-TD)
Commodity: Unit Masonry Construction in Class I Structure Fire Barriers
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Attribute Description: Manufacturer's Certificate' i of Compliance l Specification'2323-SS-16B, Revision 2, dated ,
April 22, 1988, identifies QC inspection attributes I pertaining to unit masonry construction. All.those specified in 2323-SS-16B are included in the PCHVP CAM for the subject commodit PCHVP applies to safety-related commodities. Fire j protection commodities are not safety related,.but are included in PCHVPJif they protect a safety- 1 related commodity. Impell's review determined that j there are no concrete masonry walls required to protect safety-related equipment from fire expo- !
sures. The technical disposition identifies two 4 concrete masonry barriers in the Electrical and l Control building which protect high dollar value, nonsafety-related computer In addition, a wall within the' Service Water Intake Structure (SWIS)
- . (Room 276) carries'a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating to protect fire pumps, but the fire pump system is being redesigned and the fire pumps in the SWIS will no longer be use In summary, this attribute will not be validated under PCHVP because there are no fire protection concrete masonry walls protecting safety-related commodities. The team agrees with this assessmen _-_-____ __-_ -
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(6) Attribute Number: 1522 (N-TD)
Commodity: Rolling Steel Doors in Class I Structure Fire Barriers Attribute Description: Manufacturers Certificate of Compliance Specification 2323-SS-16B, Revision 2, dated April 22, 1988, and DCA 74249, Revision 5, identifies seven attributes for this commodity. The team verified that all seven are included in the PCHVP CA '
Impell's review of the Fire Hazards Analysis drawings and the door schedule determined that five doors are within the PCHVP scope. All five doors were purchased under Contract CP-0717. The manufac-turer (North American) issued a letter dated May 23, 1984, which certifies (for three doors) that manu-facture was in compliance with Underwriters Laboratories (U.L.) requirements. However, there is no such letter for doors E-45 and E-45 The technical disposition states that all five doors were required by CP-0717 to comply with Specifica-tion 2323-AS-25 dated September 19, 1975; which required fire doors to have a U.L. label as evidence of rating. Field inspection at doors E-45 and E-45B confirmed these labels. The technical disposition stated that a letter of certification "would provide only a small degree of construction quality beyond that provided by the physical' presence of a label." The NRC inspection team agrees with this assessmen (7) Attribute Number: 1499 (N-TD)
Commodity: Hollow Metal Fire Doors Attribute Description: Manufacturer's Certificate of Compliance Specification 2323-SS-16B, Revision 2, dated !
April 22, 1988, and DCA 74249, Revision 5, {
identifies 12 attributes which the team judged appropriate for inclusion in PCHV All 12 were listed on the PCHVP CAM.
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The technical disposition states that the Certificate of Compliance is a document that is supplied to the purchasing / receiving group and is ;
not attached to the doors. Due to the )
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unavailability of such certificates, Impell requested and received confirmatory letters from the companies which had installed CPSES hollow metal fire doors (Mesker and ACME Steel). These letters stated that the doors were constructed in accordance with standard Underwriters Laboratories surveillance procedures for fire labeled products. The letters further stated that it is company policy to provide products which are in complete compliance with applicable codes and standards.and that the fire doors supplied to CPSES were in< compliance with company policy. As additional assurance, Attribute 1494 is intended to verify that-the hollow metal fire doors have'U.L., label The team agrees that the technical disposition p:;ovides assurance that the attribute has been validate (8) lttribute Number: 1504 (N-TD)
Commodity: Bullet / Penetration Resistant Doors Located in Fire Barriers of Class I Structures Attribute Description: Door Manufacturer Certifies Door Construction is Equivalent to Labele Construction Specification 2323-SS-16B, Revision 2, dated April 22, 1988, and DCA 74249, Revision 5, identifies eight attributes which the team judged appropriate for inclusion in PCHVP. All eight were listed on the PCHVP CA The bullet / penetration resistance doors used at CPSES were manufactured by Protective Materials Company and supplied without U.L. fire labels. The manufacturer has since attached a U.L. fire rating for their bullet / penetration resistant doors and is now authorized to label them. The manufacturer's letter dated June 14, 1983, states that the doors manufactured for CPSES are of the same basic construction as the units that the manufacturer is now authorized to labe As additional assurance, Calculation 0210-063-0043, Revision 1, dated October 16, 1987, " Maximum Permissible Fire Loading /Non Rated Features Analysis," evaluates the installation of 10 doors along with their local configurations and concludes that the fire zones in question could experience a i fire severity of up to three hours without breaching the penetration resistant door. The team considers that the manufacturer's letter and the calculation l
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provide an acceptable basis for the technical dispositio (9) Attribute Number: 1540 (N-TD)
Commodity: Fire Proofing of Structural Steel'in Class I Structure Fire Barriers Attribute Description: Manufacturer's Certificate of Compliance Specification 2323-SS-16B, Revision 2, April 22, 1988, and DCA 74249, Revision 5, identifies three attributes for the subject commodity, which are all addressed by the PCHVP CA Specification 2323-SS-38H requires the manufacturer to supply a certification that the supplied material meets the vendor's specification. The only type of fireproofing material used'on CPSES fire barriers in Class I structures is trowel grade Thermo-Lag-330-1 ,
subliming coating. The Thermo-Lag.used at CPSES was '
purchased.under four. purchase orders. The technical disposition contains manufacturer's certificates of conformance for Thermo-Lag shipments pertaining to these purchase orders. The letters certify that materials meet the vendor's manufacturing and written QC specifications. The team considers that the technical disposition validates the subject attribute in an acceptable manne l
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10. ELECTRICAL RACEWAYS / SUPPORTS !
l The team reviewed the installation specifications and DBDs listed below as part of its background review to ensure that all commodities and attributes were correctly identified. The NRC inspection team identified no commodities or attributes in addition to those identified by TU Electric in the PCHVP CAM that the NRC team felt needed to be addresse l Installation Specifications and DBDs reviewed: 1 2323-SS-16B, Revision 2 " Structural Steel / Miscellaneous Steel" 2323-ES-100, Revision 6, " Electrical Installation Specification" w _ _ --
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p DBD-CS-015, Revision 2 DBD-CS-093, Revision 1 DBD-CS-022, Revision 0 ,
DBD-CS-090, Revision 2 In Electrical Raceways / Supports there were 66 N
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attributes and 28 N-TD attributes. Seven N-TDs and six N attributes were selected for review representing four i different commodities. TAP reviewed 39 of the N attributes and 16 of the N-TD attributes pertaining to !
all six commodities. The team reviewed some of the same attributes that TAP reviewe j b. N-Attribute Review ,
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(1) Attribute Number: 186 (N)
Commodity: Conduit Supports Attribute Description: Bolt Installation - Turned !
Element on Correct Face The basis for not reinspecting this attribute was derived from the inspection results reported in the :
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Results Report for ISAP VII.c, Appendix 32, Revision 1. This Results Report discusses bolt inspections and no deviations were noted'for this specific attribute in inspections that covered
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bolting. Also, there were no recommendations for corrective action. The current requirements are the same as those CPRT inspected to. The NRC inspection team concurs with the above assessmen (2) Attribute Number: 208 (N)
Commodity: Conduit Supports Attribute Description: Washer Bearing Contact (Bevel / Flat)
CPRT reviewed this attribute and reported these findings in ISAP VII.c, Appendix 32, Revision They inspected in excess of 100 installations and identified three deviations which were later determined to be insignificant; therefore, no adverse trend was identified for this attribut The current requirements for this attribute are unchanged from those used by CPRT. The NRC
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inspection team concurs with the applicant's assessment that no further inspection of this attribute is require _(3) Attribute Number: 232 (N)
Commodity: Conduit Supports Attribute Description: _ Welding-Visual Inspection for Size / Length This attribute was discussed in ISAP VII.c, Appendices 32 and 3 In Appendix 32, inspection of 4020 inspection points to verify characteristics related to welding are discussed. In this sample, 10 deviations related to weld size were note Analysis was performed on all the deviations which showed that the weld stress did not exceed 55% of the allowable design stress. Therefore, these deviations were deemed inconsequ~.:tial with regard to design capacity and no adverse trend was identified. This attribute was also reviewed in Appendix 35, titled " Brown & Root AWS D Weldings," which addresses weld quality across several commodities including conduit supports, and concludes that there are no adverse trend Further in STIR-SWEC-M-002, Revision 1, site welding was again evaluated and no significant defects were identified for the attribute. Current requirements are the same as those used by CPRT. The NRC i inspection team concurs with the applicant's I assessmen (4) Attribute Number: 266 (N)
Commodity: Conduit System Attribute Description: Bends It was determined by CPRT that the radius of bends in conduit between pull points was not a safety significant item. This review assures that due to the fact that prior to cable pulling all conduits are reviewed to determine that the cable may be safely pulled. And, as long as pull tension, lide bearing pressure, bend radius, etc., will not se '
i adversely affected, the conduit configuration:
(including bends) is acceptable. The NRC inspection team concurs that this is a reasonable assessmen Installation requirements and tolerances for this attribute have not change s l
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56 (5) Attribute Number: 270 (N) r Commodity: Conduit System Attribute Description: Junction Box, Material As part of ISAP VII.c, Appendix 1 Results Report, inspection of junction boxes was addressed. These inspections focused on the National Electrical Manufacturers Association (NEMA) rating of the junction boxes, and as part of this review details
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of junction box uaterial and construction was addressed. There were no deviations identified for ,
this attribute within the 77 inspections performed, and there was no adverse trend associated with junction boxes in general. Requirements for the attribute are unchanged from those used by CPR The NRC inspection team concurs with the applicant's assessment that further inspection is not require (6) Attribute Number: 13 (N) <
Commodity: Cable Tray f Attribute Description: Damage (Cable Tray) ;
i Specification 2323-MS-100, Revision 9 dated July 9, { '
1987, identifies QC inspection attributes pertaining to cable tray damage. However this attribute and the inspection criteria do not extend beyond cable trays, for instance, to supports, connecting ,
conduit, equipment, et i I
The CPRT results in ISAP VII.c, Results Report, l Appendix 2 identified 102 reinspected samples pertaining to this attribute. Of this total,-10
deviations were identified. None of the 10 deviating conditions were severe enough to penetrate the cable jacket and no cable damage was identifie !
Because the CPRT acceptance criteria were as stringent as the current installation criteria, this attribute will not be validated under the PCHV The team agrees with this assessmen c. N-TD Attribute Review (1) Attribute Number: 205 (N-TD)
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Commodity: Conduit Supports Attribute Description: Hilti-Bolts Nut Not Bottomed Out l
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-For this attribute'CPRT identified an unclassified
- F ' trend andzrecommendedianievaluation~of,the then-(f 3 current' inspection procedure. As part'of'the-L Specification).Drawingland Procedure Update)(SPADU)
leffort=both;Ebasco and SWECLevaluated)the inspection.
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requirements for.this attribute-as specifiedlin:
Specification 2323-SS-30 which states'that " Torque-
"E .must be-.obtainedfprior.to the. nut;bottomingiout in the threads .-. ; . "'; Critical dimensions lare l provided as an attachmentito the, specification an ~ '
the; specification further requires verification of
/thislattribute. .TheLevaluation'that.this:attributei need not be readdressed for~ conduit supportsais i based on the fact that the inspection procedures; ~
included the appropriate criteria for inspecting this attribut Further, CPRT concerns with_the
adequacy of installed Hilti' bolts' regarded-only'_ '
,' spacing requirements which is a' separate attribute.:
- The NRC inspection team feels that'this attribute tevaluationLis complete.and concurs with the
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technical disposition:that reinspectionlis not require (2) Attribute Number: 317 (N-TD) '
i: H Commodity: . Conduit Train."C" Attribute Description: Size of Nelson Stud Weld
-> The technical disposition of this attribute i addressed in Impell Report 01-0210-1560, Revision 3. . 3 Paragraph 2.5 addresses stud weld ~ inspection andL describes;that the'onlyLinspection possible in.this type'ofLweld is at the time of installatio Further, it' describes the; testing requirements before and during the production (stud welding).
process as:
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one stud-in-every 100 production studs shall be
. hammer bent to an angle of 15 degrees from'its original ' axis .
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'one threaded stud in every 100 production studs shall bettorque tested with a calibrated torque
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wrench'to a,value shown in Table 1 of Reference If the stud fails-in the weld zone, the procedure shall.be checked and two more of'the existing studs shall.be bent or torque tested. If either.of-these two studs fail, all studs represented by the' tests shall be torque tested, bend tested or rejected. If failure in the stud shank occurs, an investigation
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shall be conducted to ascertain and correct the problem before resumption of welding is allowe Based on these requirements, the conclusion that-this. attribute need not be reinspected appears adequat (3) Attribute Numbar: 1821 (N-TD1 Commodity: Conduit Supports-Cable' Spread Room (CSR)
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' Attribute Description: Conduit Attachment'-
Lockwashers CPRT did not address the need for reinspecting this1 attribute. The technical disposition for'this attribute was derived from-the results of a limited-inspection effort.. :Ebasco reinspected a sample of 255 seismic-restraints under the engineering walkdown program. No deviations were~ identified for this attribute; therefore, it was concluded by the applicant that no further reinspection for this attribute is'necessary and that,there is. reasonable assurance that the existing installations are . .
acceptable. The NRC inspection team concurs that-this technical disposition is adequat (4) Attribute Number: 1831 (N-TD)
Commodity: Conduit System Attribute Description: Electrical Conductor Seal
' Assemblies (ECSA)
The technical disposition for the attribute was based on a' documentation review to identify suspect installations. Each of the suspect cases was walked down and it was determined that no ECSA fittings'
were present on the conduit ends in questio Therefore, there is no need to reinspect. The NRC inspection team concurs that this attribute has been adequately addresse (5) Attribute Number: 1818 (N-TD_1
Commodity: Conduit Supports (CSR's only)
Attribute Description: Concrete Anchorage-Eye _, Nut l Torque Setting CPRT did not inspect this attribute within the CSR !
population. The technical disposition of this
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' attribute is based on'the< fact that other similar attributes were inspected within the support-
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installations ~for-Trains A, B, and C with-no significantifinding or~ recommendation for reinspection. Based'on the fact that the
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installations and inspections for all types of conduit supports (including the.CSR population) were performed under the same program using the same procedures it was concluded that the quality of construction of this attribute would be no different than-other conduit-support attributes which were inspected by CPR The NRC inspection team concurs
,. that this attribute is similar to other attributes within the conduit support population and that it is a reasonable assumption that they have been adequately installe (6) Attribute Number: 30 (N-TD)
Commodity: Cable Tray Attribute Description: Welding, Visual Inspection for Profile This attribute (Number 30) is included with and is being verified under attributes 21 and 1669 for PCHVP. . This information was verified by the NRC L' inspecto (7) Attribute Number: 39 (N-TD)
Commodity: Cable Tray l Attribute Description: Welding, Visual Inspection for Cracks This attribute (Number 39) is included with and is being verified under attributes'21 and 1669 for PCHV This information was verified by the NRC inspector.
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1 Open Items open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both. Five open items disclosed during the inspection are discussed in paragraphs 3.a, 3.b(9), 4.a(1),
4.c(2), and 6.c(4).
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! An exit meeting was conducted March 7, 1989, with,the applicant's representatives identified in PE.ragraph .1 of this .
report. No written material was provided.to the applicant by-the inspectors during this reporting period. 'The applicant did not identify as proprietary any of the materials.provided.
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.to or reviewed by the inspectors-during this inspection.
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During this meeting, the'NRC inspectors summarized the scope
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.1 and findings of the inspectio ,
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