ML20234E147
| ML20234E147 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/17/1987 |
| From: | Beck J, Patterson A TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20234E089 | List: |
| References | |
| TAC-R00284, TAC-R284, NUDOCS 8801070442 | |
| Download: ML20234E147 (197) | |
Text
gOMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 l
COMANCHE PEAK RESPONSE TEAM RESULTS REPORT FOR ISAP - Vll.C OCONSTRUCTION REINSPECTION / DOCUMENTATION REVIEW e VOLUME IV-A
SUMMARY
TEXAS UTILITIES GENERATING COMPANY p A DIVISION OF lO TEXAS UTILITIES ELECTRIC COMPANY
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_ _ - - _ _ _ - _ _ _ _ _ _ _ _ _ _ __ _ _ _ - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ - _ _ _ - = _ _ _ _ _ _ - _ - . _ _ _ _ _ - . _ _ ___
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COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: VII.c
Title:
Construction Reinspection / Documentation Review Plan REVISION 1 s
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Johp. Beck,ChairmanCPRT-SRT
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Page i of ix
!['N (j -TABLE OF CONTENTS RESULTS REPORT a
ISAP VII.c PAGE
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY'NRC 'l 2.0 ' ACTION IDENTIFIED BY NRC - 1
3.0 BACKGROUND
1 4.0 CPRT ACTION PLAN 4.1 Objective. 2 4.2 Scope 3 4.3 Methodology 4.3.1 Establishment of Populations 3 4.3.2 Selection of Samples 4 4.3.3 Development of Checklists and Inspection Instructions 6 4.3.4 Preparation of Verification Packages 7 4.3.5 Performance of Reinspection and
-Documentation Reviews 8 j 4.3.6 Deviation Reports 8 4.3.7 Evaluation of Deviations Determined to be Safety Significant 10 4.3.8 Evaluation of Deviations for Adverse Trends 10 4.3.9 Evaluation of Sample Results 10 4.4 . Procedures 11
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4.5 Participant's Roles and Responsibility
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4.5.1 CPRT - QA/QC Review Team 11 l
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Revision: 1 Page 11 of ix TABLE OF CONTENTS RESULTS REPORT (Cont'd)
ISAP VII.c .
(Cont'd)
PAGE 4.5.2 CPRT - Other Review Team Leaders 12 4.5.3 CPSES Project 12 4.6 Qualifications of Personnel 13 4.7 Sampling Plan 13 4.8 Standards / Acceptance Criteria 13 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Implementation of Action Plan 13 lh 5.1.1 Discussion of Objective 14 5.1.2 Method of Approach 17 5.2 Discussion of Results 5.2.1 General 36 5.2.2 Summaries of Corrective Action 38 5.2.3 Electrical - Details 43 Conduit . 43 Cable Tray 47 Cable 51 Nuclear Instrument System Cable 58 Termination Lighting Cable 59 Electrical Equipment Installation 61 Instrumentation Equipment Installation 67 l
Revision: 1 Page 111 of ix h TABLE OF CONTENTS RESULTS REPORT (Cont'd) !
ISAP VII.c (Cont'd)
PAGE 5.2.4 Mechanical - Details 69 Large-Bore Piping Configuration 69 Small-Bore Piping Configuration 74 Piping Bend Fabrication 77 Piping System Bolted Joints 80 Pipe Welds and Material 80 Tubing Welds and Material 84 Field-Fabricated Tanks 84 ll HVAC Ducts and Plenums 85 HVAC Equipment Installation 87 1
87 Mechanical Equipment Installation 5.2.5 Structural - Details 90 Concrete Placement 90 Structural Steel , 91 Fill and Backfill Placement 100 Cement Grout 100 i Epoxy Grout 100 I
Containment Liners and Stainless Steel 101 Tank Liners Fuel Pool Liner 102 5.2.6 Supports - Details 103 Large-Bore Pipe Supports - Rigid 103
r Revision: 1 Page iv-of ix TABLE OF CONTENTS RESULTS REPORT (Cont'd) l ISAP VII.c.
(Cont'd)
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5.2.6 Supports - Details (Cont'd)
Large-Bore Pipe Supports - Non-Rigid 109 Small-Bore Pipe Supports 114 Instrument Tube Supports 118 Pipe Whip Restraints 121 Equipment Supports; 128 HVAC Duct Supports' 128 Conduit Supports- 131 5.2.7 Other - Details 132 Concrete Inserts 132 Bolting 134 Brown & Root AWS D1.1 Welding 13A
' Inspector Certification- 134 Harassment and Intimidation 135 1
6.0 CONCLUSION
S 6.1 General 136 6.2 Role of VII.c and QOC Review 6.2.1 ISAP VII.c 139 I 6.2.2 Collective Evaluation 140 6.2.3 Previous Work / Future Work 140 6.2.4 Corrective Action Program 140
Revision: 1 Page v of ix TABLE OF CONTENTS RESULTS REPORT (Cont'd)
ISAP VII.c (Cont'd)
PAGE 6.3 Basis for Conclusions 6.3.1 General 141 6.3.2 95/5 Statistical Screen 141 6.3.3 Analysis for the Presence of Trends 142 6.3.4 Root Cause and Generic Implications 143 Analysis 6.4 Summary Statement 144 0
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'Q TABLE OF CONTENTS l RESULTS REPORT (Cont'd)
ISAP VII.c (Cont'd)
List of Tables TABLE NUMBER TIILE 5.2-1 Reinspection Population Results 5.2-2 Reinspection Attribute Results I 5.2-3 Documentation Review Population Results 5.2-4 Documentation Review Attribute Results 5.2-5 Summary of Deviations by Population
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TABLE OF CONTENTS RESULTS REPORT !
(Cont'd)
ISAP VII.c (Cont'd)
List of Acronyms and Abbreviations AC Alternating Current A/E Architect / Engineer AISC American Institute of Steel Construction AISI American Iron and Steel Institute ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASME-NF American Society of Mechanical Engineers - Subsection NF ASTM American Society for Testing and Materials AT Adverse Trend AWG American Wire Gage 9 AWS American Welding Society Brown and Root-American Welding Society B&R-AWS BSC Bahnson Services Company CAR Corrective Action Requests CAT Construction Appraisal Team CBI Chicago Bridge and Iron Company CCL Corporate, Consulting and Development Company, L.T.D.
CD Construction Deficiency ,
CEEG Construction Evaluation Engineering Group CMC Component Modification Cards CMTR Certified Material Test Report l COT Construction Operation Traveler CPRT Comanche Peak Response Team l CPSES Comanche Peak Steam Electric Station CSRG Construction Sample Reinspection Group l CWC Construction Work Categories DAP Design Adequacy Program G DC Direct Current DCA Design Change Authorization
Revision: 1 Page viii of 1x NT' TABLE OF CONTENTS g
RESULTS REPORT (Cont'd).
ISAP VII.c (Cont'd)
List of Acronyms and Abbreviations (Cont'd)
DM. Design Manual DR Deviation Report DSAP Discipline-Specific Action Plan ECP Electrical Construction Procedure ECSA- Electrical Conductor Seal Assembly EEI Edison Electric Institute FSAR Final Safety Analysis Report HP Hanger Package HVAC Heating, Ventilating and Air Conditioning HVP Hardware Validation Program HWA Homogenous Work Activity' IR Inspection Report ISAP Issue Specification Action Plan LP Liquid Penetrant (sometimes PT)
MCP Mechanical Construction Procedures MIL Material Installation Log MRS Manufacturing Record Sheet MT Magnetic Particle Testing MWDC Multiple Weld Data Card.
l N/A Not applicable NCIG Nuclear Construction Issues Group NCR Nonconformance Report..
NDE Non Destructive Examination NEMA National Electric Manufacturers Association NIS Nuclear Instrument System NRC Nuclear Regulatory Commission O PDR Program Deviation Report I
PET Permanent Equipment Transfer I
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TABLE OF CONTENTS
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RESULTS REPORT (Cont'd)
ISAP VII.c (Cont'd)
List of Acronyms and Abbreviations (Cont'd)
PS Pipe Support QAP Quality Assurance Procedures QA/QC Quality Assurance / Quality Control QI Quality Instruction QOC Quality of Construction RTL Review Team Leader SBM Separation Barrier Material SC Special Case SFT Scap Film Test SAVC Structural Assembly Verification Card 7s
(,,/ SOV Solenoid Operated Valve SS Stainless Steel SSEG Safety Significance Evaluation Group SSI Safety Shutdown Impoundment TNE TU Electric Nuclear Engineering x TRT Technical Review Team TU Texas Utilities UT Unclassified Trend ,
UT Ultrasonic Testing VB Vacuum Box VWAC Visual Weld Acceptance Criteria WDC Weld Data Card WMI Welding Material Issue WFML Weld Filler Material Log 4
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Page 1 of 186 r\ RESULTS REPORI s /
l ISAP VII.c Construction Reinspection / Documentation Review l'
1.0 DESCRIPTION
OF ISSUE 1DENTIFIED BY NRC This ac don plan did not result directly from a rpecific issue raised by the NRC. Therefore this section is not applicable.
2.0 ACTION IDENTIFIED BY NRC Not Applicable
3.0 BACKGROUND
This Issue-5pecific Action Plan (ISAP) was self-initiated to enable TU Eleccric management to assure itself sf the safety of the Comanche Peak Steam Electric Station (CPSES) regardless of the extent to which issues might have been raised by External Sources. ,
g3 This ISAP included a reinspection / documentation review of Quality
(' Control (QC)-accepted, safety-related products or construction work activities performed at CPSES. This reinspection / documentation review will ensure, as a matter of additional confidence, that the investigative efforts of the CPRT program are of sufficient depth and breadth to permit conclusive statements regarding the adequacy of the CPSES quality of construction to be extended to the balance of the A/E design scope for the safety-related portions of the plant. This visual reinspection / documentation review effort also provided data useful for the evaluations performed under other i action plans and extends into those areas that have been specifically identified by External Sources.
The primary reason that this self-initiated action plan was a developed and implemented is that it represents tha most direct. l reliable, and achievable method of providing additiora confidence that unidentified concerns related to the quality of construction of the hardware at CPSES would be identified, evaluated, and resolved. It also provides additional confidence that any adverse impacts on the installed hardware that may have occurred as a result of potentially inadequate qualifications of historical QC inspectors have been identified and addressed.
1 This plan consisted of a sample reinspection of accessible l QC-accepted, safety- related construction work products supplemented i 7
by a review of related quality documentation when inspection
(' attributes were generically not recreatable. It covered all Unit 1, 2, and common areas, including those that are not specifically covered by other Comanche Peak Response Team (CPRT) ISAPs.
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RESULTS REPORT (v)
ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Objective The overall objective of this ISAP was to provide the basis for a conclusion that there is reasonable assurance that the QC-accepted, safety-related hardware in CPSES was adequately installed in conformance with the design. This overall objective was achieved through the following specific objectives:
- To evaluate the quality of safety-related hardware construction that had been inspected and accepted by QC at Comanche Peak.
- To investigate, on a proactive basis, additional areas to which the CPRT may have been led in the course of its root cause/ generic implications assessments for External Source issues.
i ()h K.. - To ensure that the investigative efforts of the CPRT program were of sufficient depth and breadth to permit the conclusions reached for the External Source issues to be extended to the remaining safety-significant areas of construction.
To provide data to support the assessment of the adequacy of the QA/QC program.
- To provide data to support the assessment of the issue of potentially inadequate historical QC inspector qualifications. .
To provide data to support an assessment of the assertion that a pervasive pattern of intimidation and harassment of QC inspectors that may have resulted in i hardwarc deficiencies existed.
In order to accomplish these objectives, the f ollowing tasks j were performed: j Established populations Selected samples
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Developed checklists and inspection instructions Prepared verification packages l l
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Page 3 of 186 l ,'g y3TS REPGRT ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
- Performed reinspection-and documentation reviews.
- Identified' deviations and performed reviews for safety significance and adverse trends-
- Evaluated results 4.2 Scope The scope of this action plan included all safety-related construction work that had been inspected and accepted by CPSES QC with the exception of cable tray hangers, which.are being addressed in the Corrective Action Program described in the CPRT Discipline-Specific Action Plan'(DSAP) VIII.
4.3 Methodology The following sectiore describe key activities of' the plan.
Any variations from the methodology described in Sections 4.3 and 5.1 appropriate for specific circumstances are explained and justified in the applicable population working files.
4.3.1 Establishment of Populations
-Installed safety-related hardware was categorized into construction work categories (CWCs) of reasonably homogenous work activities (HWAs) and associated quality attributes. The populations from which random samples were drawn for evaluation were the QC-accepted portions of the CWCs. This process was performed in accordance with Appendix B of the CPRT Program Plan, and as detailed in the QA/QC Review Team procedures.
The final list of CWCs was established after each CWC had been identified, its components, boundaries, and a
specCic interfaces described, and the actendant work I activities evaluated to ensure reasonable homogeneity within each work activity. The CWCs and a brief description of each are given in Section 5.1.2. (See Appendix B of the CPRT Program Plan,Section II.A.2.)
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-U RESULTS REPORT ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
A description was prepared for each CWC. A supporting document for each CWC was also prepared to document the reasonable homogeneity of each associated work activity and to define the attributes about which the statistical inferences were drawn. The physical reinspection covered the attributes (or more detailed characteristics) to ensure that a determination of the quality of safety-related construction for each attribute could be made. These attributes and characteristics were described in the Quality Instruction (QI) for each population.
For each CWC, a list containing all safety-related items that had been completed and accepted by Quality Control Inspectors was prepared. These lists containing population items and a description of how the list of items within each population was e established are retained in the working file.
4.3.2- Selection of Samples General Approach For each population two samples were randomly selected.
The first sample was selected to provide information about the total population sufficient to support statistical inference at the attribute level. The second " Safe Shutdown" sample was selected to ensure that the sample included a minimum number of items from that portion of the total population that.is required for or most directly related to achieving safe shutdown of the plant. Consistent with this objective, " Safe Shutdown" items from the first sample were included in the second sample. In cases where all items or no items in the population make up or support the systems used to safely shutdown the pinnt, no second sample was required (e.g., NIS Cable Termination and Fuel Pool Liner). All samples were selected in accordance with Appendix D nf the CPRT Prugram Plan.
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(
(,) RESULTS REPORT ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Items selected during this process that were inaccessible were discarded and new items randomly selected until the desired sample size was achieved.
" Inaccessible" is defined to mean a condition where dismantling or subsequent repair would have been required to gain access for direct reinspection, such as in the case of reinforcing steel or conduit that was embedded in concrete or items encased in thermolag or fire foam. If portions of an item or some attributer of an item were inaccessible, a documented decision was made whether to consider the item " inaccessible".
If safety-significant attributes of a sample were reinspectable, they were reinspected, and no documentation reviews were required to come to a conclusion about the hardware quality for those attributes. In some CWCs, some of the 7-~)
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safety-significant attributes were either inaccessible or not recreatable. "Not recreatable" 13 defined to mean a condition where a process or event cannot be recreated, such as pipe end preparation for dimensions and shape, interpass weld temperature or receiving inspection. In this case, records relating to these inaccessible or not recreatable attributes for the items randomly selected for reinspection were reviewed for adequacy, while the remaining attributes were visually reinspected. There was also a limited number of hardware categories in which all of the safety-significant attributes were either inaccessible or not recreatable. In these cases, which were the CWCs for cement grout, epoxy grout, fill and backfill placement and nuclear instrument system cable terminations, a records review was used exclusively to evaluate randomly selected items, i Records are maintained that identify the hardware items and attributes determined to be inaccessible.
First Random Sample ;
I A sample of items randomly distributed throughout each j
,_ population was selected in accordance with Appendix D l f ) of the CPRT Program Plan. Initially the minimum number j
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.l ISAP VII.c h (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l of items required per Appendix D for a 95/5 statistical screen (i.e., 60 items for populations of 101 or more items) was selected. If attribute coverage was 1 incomplete, meaning some items did not have all )
attributes or an attribute was inaccessible or l partially inaccessible for some items, additional items were randomly selected and reinspected for at least the applicable attributes until the number of sample items was sufficient to afford a 95/5 statistical screen for each attribute. ,
l Second Random Sample )
i The second random sample was made up of items selected )
from the safe shutdown systems within the CWC, or, for l populations such as concrete that do not directly contain items in the safe shutdown systems, the sample was made up of items that support those systems or are 9 in locations where failures could adversely impact those systems.
Items of the first random sample that fell within the safe shutdown systems were also counted as sample items in the second random sample. In order to attain a minimum sample size of sixty (60) f or populations of one-hundred one (101) or more, additional items were selected randomly from the entire population and then reviewed to identify those falling within the safe shutdown category. The second random sample was considered complete when 60 accessible items were obtained, regardless of the count for individual attributes defined for that population.
4.3.3 Development of Checklists and Inspection Instructions For each population, attributes that have safety significance were determined. A safety-significant attribute encompt.sses one or more characteristics of a component or construction activity that, if not in accordance with applicable design documents, codes, and standards, could impair the ability of the component to perform its safety-related function under design loading conditions.
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ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Relevant design information was reviewed to determine attributes that are safety-significant. Design information included design drawings, specifications, and other required documents (such as codes and standards) incorporated by reference into the specifications. Justification for not including attributes wce documented and retained in the working file. Determination of safety-significant attributes was made by the QA/QC Review Team, and distributed to the DAP Review Team Leader (RTL).
I For each safety-significant attribute identified, detailed instructions were provided for the verification of the attribute, including definitive accept / reject criteria based on the CPSES design applicable at the time of sampling. In some cases, two or more sub-attributes, termed " characteristics", were identified for purposes of reinspection. For example,
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\. - thread engagement, tightness, washers, and edge distance could be characteristics of an attribute,
" bolting". This information was incorporated into a detailed inspection instruction for that population.
The inspection instruction provided detailed instructions to the inspectors for performing the ;
reinspection and/or documentation rev1ews. For each {
inspection instruction, a corresponding inspection l checklist was created. Inspectors were required to document the results of inspection of each attribute on the applicable inspection checklist.
k 4.3.4 Preparation of Verification Packages ]
Verification packages were assembled for each sample item to facilitate the performance and documentation of field reinspection and documentation reviews.
Separate verification packages were generated for each field reinspection and each documentation review ;
performed. j l
The field reinspection verification package contained, I as a minimum, the applicable population checklist, and current design documents pertaining to the item, '
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G including Design Change Authorizations (DCAs),
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/'N RESULTS REPORT ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Component Modification Cards (CMCs), or construction traveller where these were a predominant means of defining construction activities. The documentation review verification packages contained the applicable population checklist. Each verification package contained an index listing the contents of the package.
4.3.5 Performance of Reinspection and Documentation Reviews Certified third-party inspection personnel used the verification packages to perform visual reinspection and documentation reviews, and to document the results.
Inspectors were certified to a minimum of Level II in accordance with Regulatory Guide 1.58 and ANSI N45.2.6. l Certified personnel inspected the condition of each item for each attribute on the checklist or assured gg that the required documentation existed and was complete, as applicable. If the item differed from
('~') checklist requirements or if the associated documentation did not exist or was improperly completed, as applicable, a Deviation Report (DR) was initiated and processed in accordance with written instructions.
The DR was filled out by the inspector. It identified the item reinspected or the documents reviewed, the l
. condition that differed from requirements, and described the condition in sufficient detail (sketches {
or other pertinent information might have,been attached) to provide subsequent reviewers with a clear understanding of the condition.
I 4.3.6 Deviation Reports )
Each DR was reviewed by the appropriate discipline Level III inspector as a minimum, then the responsible engineer, to establish its validity. l A DR could be deemed invalid for any of four reasons:
- The DR might describe a condition that, in
-s fact, was acceptable in accordance with the 7
- approved desigr or other appropriate data.
\- Each DR was reviewed to ensure that all notes, specification details, approved DCAF, or CMCs were appropriately applied.
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() RESULTS REPORT ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
- The DR might describe a condition that had been previously documented on a controlled deficiency document, such as an existing TU Electric Nonconformance Report (NCR). In these cases a review of the actual condition was conducted to ascure that the deficiency document accurately reported the condition.
- The DR might document a condition that satisfied the requirements that applied at the time of the original inspection.
Instances existed in which items were constructed in accordance with the design applicable at the time of construction, but subsequent design changes had caused the existing construction to deviate from the current design. A DR resulting from such a design change was invalid if documentation O existed exempting the specific item from current requirements.
- The DR might have documented a reinspection that was highly subjective in nature, such as visual weld inspection. The engineer validating the DR may then request a Level III Inspector to determine the acceptability of the item.
If any of the above determined the DR to be invalid, the detailed justification for this determination was documented on the DR and retained as a record in the working files.
If a DR was deemed to be valid, a ccpy was given to TU Electric and processed as an NCR in accordance with site procedures. The DR and NCR were cross referenced l
in accordance with TU Electtic procedure CP-QP-16.3 for l
record purposes. Except for those deviations treated i as Unclassified Deviations
- or Unclassified Trends
- in accordance with the CPRT Program Plan Appendix E, Para.
B.6, and DRs specific to I.d.1, each valid DR was evaluated for safcty significance by the QA/QC Review Team.
- Deviations or trends are designated " Unclassified" when a decision is made not to complete classification; they are then treated as if they were known to be safety-significant.
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( s-RESULTS REPORT ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
No evaluations of deviations for safety significance were assigned to other CPP.T Review Teams.
The evaluations of valia DRs for safety significance were conducted in accordance with the guidance contained in Appendix E of the CPRT Program Plan. The results of the evaluations for safety significance, including references to engineering data or other information used to make the determination, were documented.
4.3.7 Evaluation of Deviations Determined to be Safety Significant For unclassified deviations and those deviations determined to be construction deficiencies (CDs) as well as for identified adverse or unclassified trends, f an evaluation was conducted to determine, if possible, k s'4 the root cause and generic implications within the specific population. Generic implications that may require additional evaluation in other populations were identified in some instances and are evaluated for the Quality of Construction in the collective evaluation report. These evaluations were documented.
4.3.8 Evaluation of Deviations for Adverse Trends The totality of information collected on each population was reviewed to determine if there were any adverse or unclassified trends with potencial safety-significant deviations that would warrant additional l reinspection in the specific population. A statement of the results of this analysis was prepared for each population.
4.3.9 Evaluation of Sample Results The acceptability of each CWC and associated HWAs was established based on the results of the reinspection and documentation reviews conducted on the two samples from each population. If the items from the samples i
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Revision: 1 Page 11 of 186 l () RESULTS REPORT ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (cont'd) contained no CDs, and there were no adverse or unclassified trends, no further reinspection or documentation reviews were required.
If a sample was found to contain one or more CDs, or there was evidence of an adverse or unclassified trend, two alternatives were available for resolution of the deficient attributes. The alternatives were that the sample could be expanded for further evaluation in I accordance with Appendix D of the Program Plan or that corrective action that would identif y and correct any similar deficiencies could be developed.
4.4 Procedures Detailed procedures were prepared for implementation of each major step of this plan.
4.5 Participant's Roles and Responsibilities 4.5.1 CPRT - QA/QC Review Team Scope Provided overall direction of this activity and provided third-party engineering and inspection personnel as required.
Coordinated and conducted evaluations of valid DRs for safety significance. Also responsible for determining whether evaluations were to be conducted by themselves or other GPRT Review Team Leaders.
Personnel Mr. J. L. Hansel QA/QC Review Team Leader Mr. E. J. Brabazon QA/QC Review Team Deputy Director Mr. A. A. Patterson Issue Coordinator Mr. J. M. Schauf CEEG Supervisor
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RESULTS REPORT l
ISAP VII.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l Mr. J. A. Adams SSEG Supervisor (until Jan. 1, 1987)
Mr. R. F. Miller SSEG Supervisor (after Jan. 1, 1987) 4.5.2 CPRT - Other Review Team Leaders Scope Reviewed valid deviations referred to them for information.
Personnel All CPRT Review Team Leaders 4.5.3 CPSES Project Scope Assisted in population definition and description.
Assisted the QA/QC Review Team in the identification of specifications, drawings, procedures and other documentation necessary for execution of this action plan. Provided copies as required.
- Assisted in determining the number of items in each population.
- Provided scaffolding, lighting, etc., as required to support inspections.
- Processed NCRs that were generated as a result of this action plan.
Personnel General Liaison Mr. R. Camp Mr. C. Smaney O Electrical Mr. I. Vogelsang Mechanical Mr. C. Moehlman I
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[%j RESULTS REPORT ISAP VII.c (Cont'd) 4.0 CPR1 ACTION PLAN (Cont'd)
Civil / Structural Mr. R. Hooton Piping / Supports Mr. J. Finneran QA Mr. D. Snow 4.6 Qualifications of Personnel All personnel associated with analysis and avaluation of findings were qualified in accordance with the requirements of the CPRT Program Plan. Where inspections required the use of certified third-party inspectors, their qualifications were evaluated to the requirements of ANSI N45.2.6 and Regulatory Guide 1.58.
4.7 Sampling Plan
/ See Section 4.3.2.
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4.8 Standards / Acceptance Criteria Acceptance criteria for the reinspection were based upon a detailed review of CPSES specifications, design drawings, and other required documents (such as referenced codes and standards incorporated by reference into the specifications) in order to identify and verify safety-significant attributes and to establish definitive accept / reject criteria based on the CPSES design applicable at the time of sampling. These acceptance criteria were contained in the inspection instructions which were issued prior to the star; of inspection for each population.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Implementation of Action Plan The construction reinspection and documentation review conducted under this ISAP were performed in accordance with the action plan described in Section 4.0. Additional specific l details of the action plan implementation are provided in this section.
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.1.1 Discussion of Objective The overall objective of this ISAP was to provide the basis for a conclusion that there is reasonable ar.surance that the QC-accepted safety-related hardware in CPSES is installed in adequate conformance with the design. This overall objective and the six specific objectives stated in Section 4.1 were met by executing the following tasks:
- Reinspecting hardware and/or reviewing documentation related to the hardware l
inspected and accepted by QC to detect l
deviations from safety-related installation requirements obtained from design documents (including applicable construction drevings, specifications, and procedures).
- Evaluating the findings of the above task to determine whether there is reasonable assurance that the hardware in each CWC is adequately installed in conformance with the design.
These two tasks were accomplished by reinspecting and/or reviewing documentation for two random samples of each hardware population. The first was a random l
sample of safety-related items with attributes that characterize the work steps (general populattor sample). Additional information and assurance was provided by the reinspection and/or documentation review of an overlapping second random sample of selected hardware items (safe-shutdown systems sample).
For inaccessible or nonvecreatable attributas, quality documentation that was found to have been completed in apparent accordance with applicable procedures was presumed to provide an accurate record of the previous inspection and acceptance of the hardware for these attributes.
One important test of the presumption that apparently proper documentation provided the desired evidence of hardware quality was a comprehensive review and O verification of the qualification of those individuals who performed the inspections and prepared the applicable QA documentation. During documentation
Revision: 1 Page 15 of 186 RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) reviews, deviations were reported for any QC personnel who signed the documentation that was reviewed when evidence was not found of their certification to do so, based on the then current qualification requirements.
The separate review of the preliminary results of ISAP I.d.1, "QC Inspection Qualifications", and the review of the procedural requirements for testing and certifying QC inspectica personnel conducted under ISAP I.d.2, " Guidelines for Administration of QC Inspector Test", subsequently revealed that the historical qualification requirements alone did not provide a sufficient basis for concluding that the inspectors were fully qualified. Accordingly, a more comprehensive review of qualifications of the inspectors relied upon (i.e., those with and without certification deviations reported) was performed utilizing the methodology developed in ISAP I.d.l. In those instances where inspection personnel were not O. shown to be either certifiable to appropriate requirements or otherwise capable of performing their historical inspection activities, additional evaluations were performed to determine the impact of any inspections perf ormed by the inspector.
The attribute reinspection and/or documentation review for the first sample was designed to provide a 95/5 statistical screen in accordance with Appendix D for construction deficiencies (CDs) related to attributes.
The second sample reinspection and/or dccumentat1on review was designed generally to provide additional assurance to the statistical screen for CDs in systems needed for safe-shutdown. Both the first and second samples were used to identify adverse or unclassified trends of deviations.
The reinspection and/or documentation review program implemented for this ISAP provides a basis for conclusions regarding the quality of the installed QC-accepted, safety-related hardware for the entire plant. Statistical inferences regarding quality of the accessible. QC-accepted, safety-related portions of the plant are a direct result of the. sampling program.
Corrective actions are prescribed to ensure quality whenever findings prevent the desired inferences from being made. The extrapolation of the conclusions developed f rom the inspection of accessible samples to those items that are inaccessible is valid since the
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\wd; RESULTS REPORT I ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) samples are similar, and involve the same or similar attributes in accomplishing the same or similar safety functions. Further, the samples and inaccessible items vare installed by the same or similar work processes and craft, installed with the same or similar procedures, inspected by the same or similar inspector group and inspected to the same or similar criteria.
Based on the principles of the sampling program, those items that are inaccessible are not covered explicitly by statistical statements as they had no chance of being selected from the population. Extrapolation to i these items is justified, however, based on the similarity considerations discussed above and has been )
-made as an engineering judgment. Thus, the specific objectives outlined in Section 4.1 have been accomplished.
/"' The implementation of this ISAP was not conducted'in a ,
(s,/s - manner designed to directly identify cases of !
harassment and intimidation of QC inspectors. However, i dats related to possible QC inspection problems that.
could be related to the issues of inadequate inspector qualification or harassment was assessed'and is described in Section 5.2.7.
Reinspection and/or documentation review results for safety-related attributes that passed the statistical screen for CDs and had no identified adverse or unclassified trends provide the basis for concluding that there is reasonable assurance the work steps characterized by these attributes were adequately performed. Where reinspection and/or documentation review results have identified CDs, adverse or unclassified trends, the analysis for root causes and generic implications provide the basis for corrective action recommendations. Implementation of these
! recommendations will provide reasonable assurance that any additional similar deficiencies that were not identified during this program will be corrected.
Overall, the program will result in reasonable assurance that construction defects that would have prevented the facility from being capable of operation in conformance with NRC Regulations have been detected O. and appropriate corrective actions for such defects have been defined.
Revision: 1 Page 17 of 186 RESULTS REPORT ISAP VII.c (Cont'd) l 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.1.2 Method of Approach Establish Populations Architect / Engineer (A/E) specifications, drawings, and lists, the Final Safety Analysis Report (FSAR), and the construction contractor on-site procedures were reviewed to subdivide the entire range of l safety-related construction work into construction work categories.
l Construction work categories are groups of safety-related hardware items containing similar types of components or constructed using similar processes involving a set of homogeneous work activities. Each homogeneous work activity is a series of work steps characterized by acceptance attributes that may be I
either observable or no longer observable. Thus, a O construction work category is defined by a set of uniquely identifiable elements, such as construction steps or hardware items.
The sampling program provides meaningful information about the installation process for each CWC, to the extent that items of the CWC that were sampled were similar (i.e., homogeneous) in the factors pertinent to consistent process implementation. Acceptable homogeneity for a CWC was established by an evaluation that determined either (1) that the work processes were the same or (2) that the work processes were similar in terms of one or more factors such as:
- Attributes and acceptance criteria Governing codes and standards Organization performing work Craft type performing work Inspection procedures and personnel Thirty-two construction work categories in four disciplines (electrical, mechanical, structural, and supports) were identified in this manner and are listed below.
O L.---.---------__ . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _
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Electrical
- 1. Conduit: Class IE rigid and flexible conduits, fittings, pull boxes, and terminal boxes.
- 2. Cable Tray: Class 1E ladder and solid bottom trays and fittings.
- 3. Cables: Class 1E power, control, instrumentation cables, separation barrier material, cable grip installation and field installed jumpers.
l
- 4. Nuclear Instrument System (NIS) Cable Terminations: Class 1E Nuclear Instrumentation System triaxial cable terminations.
_(
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- 5. Lighting Cable: Class 1E emergency and essential lighcing cables and terminations. j
- 6. Electrical Equipment Installation:
Installation and modification of all safety-related electrical equipment such as switchgear, substations, motor control centers, control panels and racks, 125 VDC batteries, chargers and distribution panels, 120 V inverters, transformers and l distribution panels, electrical. penetration assemblies, and electrical conductor seal
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assemblies.
- 7. Instrumentation Equipment Installation: l Safety-related transmitters, indicators, switches, controllers, radiation monitors, (
and instrument piping and tubing.
I Mechanical
- 8. Large-Bore Piping Configuration:
Orientation, location, size, connections, clearances, valve types, and other j r3 configuration aspects for safety-related
( ,) piping 2-1/2 inches and larger.
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- 9. Small-Bore Piping Configuration:
Orientation, location, size, connections, clearances, valve types,'and other configuration aspects for safety-related piping 2 inches and smaller.
- 10. Piping Bend Fabrication: Bends on piping 2 inches and smaller.
- 11. Piping System Bolted Joints: Flanges, bolting, nuts, cap screws, and gaskets for assembly of piping mechanical joints.
- 12. Pipe Welds and Material: Site-made welds,-
weld materials, and base material'for the welding of piping to_other piping, fittings, and components.
- 13. Tubing Welds and Material: _ Site-made welds, weld material, and base' material for'the welding of tubing to other tubing, fittings and components.
- 14. Field-Fabricated Tanks: Field-erected tanks for diesel fuel oil storage, recycle holdup, and boric acid storage.
- 15. HVAC Ducts and Plenums: Installation of Seismic Category I sheet metal duct sections, ;
with accessories, for all safety-related HVAC duct systems installed by the HVAC j contractor.
i
- 16. HVAC Equipment Installation: Installation and setting of in-line vane-axial and propeller fans, dampers, air measuring stations, and other HVAC equipment that was installed by the HVAC installation I
contractor.
- 17. Mechanical Equipment Installation:
Installation, repair and modification of mechanical equipment such as heat exchangers.
O~- pumps, chillers, compressors, filters, shop-fabricated tanks and fuel transfer tubes. Includes large HVAC equipment set on foundations or structural steel. I
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ISAP VII.c l (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Structural
- 18. Concrete Placement: Comprised of all safety-related concrete pours such as walls, slabs, beams, columns, piers, pedestals and curbs.
- 19. Structural Steel: Category I structural steel members including their connections to structural steel and to concrete.
- 20. Fill and Backfill Placement: Fill and backfill associated with the SSI dam, service water piping, Category I electrical duct banks and manholes, the service water intake structure, the safeguards pipe tunnel, the diesel fuel oil storage tanks, and the refueling and condensate storage tanks.
- 21. Cement Grout: Grouting of base plates, bearing plates, equipment bases, core bores and other items noted on design drawings requiring cement grout. It includes both fluid and dry pack types.
- 22. Epoxy Grout: Pressure grouting of base 1 plates, bearing plates, equipment bases, and other items using Ceilcote 658-N or Escoweld 7502 epoxy grout.
- 23. Containment Liners and Stainless Steel Tank Liners: Containment liner and reactor water storage and refueling water storage tank liner panels.
- 24. Fuel Pool Liner: Weld seams for the 3/16 inch stainless steel plates that comprise the fuel pool liner.
Supports j t
- 25. Large-Bore Pipe Supports - Rigid:
7g Safety-related anchor, guide, rigid, and
( ) rigid-seismic pipe supports for piping 2-1/2 inches and larger.
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- 26. Large-Bore Pipe Supports - Non-Rigid:
Safety-related mechanical snubber and constant or variable supports for piping 2-1/2 inches and larger.
- 27. Small-Bore Pipe Supports: Safety-related pipe supports (rigid and non-rigid) for piping 2 inches and smaller, except those for instrument pipes or tubes.
- 28. Instrument Tube Supporcs: Supports carrying safety-related instrument tube, instrument gages and related instrument fittings.
- 29. Pipe Whip Restraints: The moment restraints, pipe whip restraints (including those associated with the main reactor coolant loop), and restraint support structures for O the large and small bore piping systems.
- 30. Equipment Supports: Installation of all safety-related supports for electrical, mechanical and heating and ventilating equipment.
- 31. HVAC Duct Supports: Duct hangers and associated longitudinal bracing and auxiliary steel.
- 32. Conduit Supports: Category 1 hangers supporting conduits.
Each population consisted of those items of the construction work category that were completed and QC-accepted at the time the population items list was completed.
Note that the found condition of the hardware from each population covered by the reinspection program is the result of work by one or more organizations, which might have included testing and operations as well as Construction.
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ISAP VII.c
-(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Selection of Samples The number of items selected for the first random sample was based on providing a 95/5 statistical screen (per Appendix D of the CPRT Program Plan) on each attribute defined for the population.
Items for the second random sample were selected from the structures, components, and equipment that comprise, support, or enclose the safe shutdown systems, or portions thereof, identified as follows:
- Feedwater - Auxiliary Feedwater Connection to Steam Generators
- Atmospheric Steam Relief I
Chemical and Volume Control
- Residual Heat Removal Pressurizer Pressure Control Station Service Water
- Component Cooling Water
- Reactor Coolant System Piping ,
- On-site Power Systems Control Room Ventilation
- Ventilation System related to Engineered Safety Features
. - Safety Chilled Water
- Ventilation System related to Uninterruptible Power Supply
() - Monitoring Indicators in the Steam Generator, Reactor Coolant System, Condensate Storage Tank, and Boric Acid Tank
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l RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The number of items selected for the second random sample was sufficient to provide a 95/5 statistical screen (per Appendix D of the CPRT Program Plan) on the safe-shutdown population hardware items. Safe-shutdown items in the first sample also were included as part of the required second sample items.
An item and attribute accessibility determination was made for each item randomly selected to determine whether the item would be reinspected.
- If the item and attributes were totally.
accessible, the item was reinspected.
Generally, if a major portion of the item or the attributes of interest.were accessible, the item was reinspected and counted as a
/N sample item. In a few populations, the item.
iq_,) was replaced with another randomly selected item if any portion of the item or any attribute was inaccessible. As necessary, additional items were randomly selected to ensure that the first random sample contained the required minimum reinspection to implement a 95/5 statistical screen for each reinspection attribute.
- If an appreciable portion of the item or an appreciable number of attributes were inaccessible, the item was replsced with another randomly selected item. In some populations the accessible portion and accessible attributes of a replaced item were reinspected and the resu]ts of the reinspection evaluated. However, such a reinspection was not counted'toward fulfilling the minimum required reinspection.
- If the item and attributes were totally inaccessible, the item was replaced with another randomly selected item.
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Proportional sampling across the populations with a similar work process for a particular attribute was permitted and used when a determination was made that this would be a more efficient means of testing the underlying work process. In these cases, the minimum number of items to be randomly selected from each of the populations was proportional to the estimated number of items in each population with that particular attribute. The sum of these proportional shares, included from each population in which the common work process was used, would satisfy the required total number of samples for the 95/5 statistical screen in accordance with Appendix D. Example attributes for which proportional sampling was used include concrete inserts, concrete expansion anchors, bolting, and Brown
& Root American Welding Society (B&R AWS) welding.
The method of sample item selection for some i
O populations resulted in reinspection of more physical items than the number of sample items, e.g., for pipe bends the sample item was a drawing that could contain one or more bends (physical items) to be reinspected.
Sometimes items in addition to those comprising the first and second random samples or those partially accessible items discussed above were reinspected and/or had documentation reviewed. These additional l
items resulted from circumstances that negated their l initial selection as a random sample item. Typical of the circumstances were cases where the item was later found not to be fully QC-accepted, construction work was found to be in progress, or an error was found in the random sample selection. When such circumstances were discovered during or subsequent to the item reinspection and/or documentation review, the valid reinspection and documentation results were retained and evaluated, providing additional information on the quality of construction.
Develop Checklists and Inspection Instructions Separate population-specific checklists and corresponding instructions were prepared for the reinspection and the reviews of documentation to
() implement Section 4.3.3 requirements. The attributes
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAR AND DISCUSSION OF RESULTS (Cont'd) identified on a population checklist for documentation review were generally only those attributes that were not recreatable or were inaccessible for the population items, e.g., inspector qualifications, welder qualification and placement of reinforcing steel. All other attributes were reinspected.
Acceptance criteria for inspection of pressure boundary welds were developed from the visual inspection criteria of ASME III-NB, NC, ND or NE, as applicable.
For the non-pressure boundary welds (ASME-NF and AWS),
L acceptance criteria for inspection of the production welds were developed from ASME-NF visual weld acceptance criteria for the ASME-NF welds and Visual Weld Acceptance Criteria (VWAC), NCIG-01, Revision 2, for the AWS welds. NCIG-01 (Nuclear Construction Issue Group) provides NRC-accepted visual weld acceptance
. (h criteria for structural welds that havo been previously
(__) . inspected and accepted. These criteria are applicable for inspection of welds through coatings, subsequent to the original acceptance inspection, for characteristics such as presence, location, length and size.
Prepare Verification Packages Packages were prepared for each sample item to implement Section 4.3.4 requirements. These packages provide or reference the necessary information to conduct the reinspection and/or documentation review properly and document the results. Each package included a copy of the inspection checklist, suitably marked to be applicable to the particular sample item, when considering all of the required attributes. The l
documents required to perform the reinspection / review might have included drawings and change documents, as i
indicated within the verification packages.
Each verification package had a unique identifying number. These unique numbers were used in a computer-based tracking system to ensure the complete processing of each package.
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.ry G j. RESULTS REPORT LV ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Perform Reinspection and Documentati>on Reviews l'
The checklist and detailed inspection instructions, i.e., quality instructions (QIs), were reviewed with the applicable inspectors prior to performing inspections or reviews.
L The inspectors and documentation reviewers verified that the condition of the installed equipment conformed to the acceptance criteria of the inspection instructions or that the required documentation existed and was complete for each attribute on the appropriate checklist. Accept or reject decisions for each applicable attribute it many cases required reinspection or review of multiple points on the hardware or documentation, and multiple checks for
, different aspects.of each attribute. For example, a bolting reinspection for one CWC required the inspector
/
' to make numerous checks against inspection requirements
( for characteristics such as bolt size and material, thread engagement, presence of washers, and torque / tightness; a sample item could include many bolted connections. Each of the multiple inspection checks or review checks made on an attribute to determine acceptability or resectability was termed an
" inspection point" or " review point". Thus, inspection i of each sample item usually required multiple inspection or review points.
A deviation report (DR) prepared to document conditions that differed from requirements could document the nonconformance of one or more inspection or review points. Each nonconforming inspection or review point is termed a " deviation". Such a deviation is a
" construction deviation" as defined in Appendix E of the CPRT Program Plan.
Welding inspections, governed by the applicable criteria documented in the inspection instructions, were performed without removing existing protective coatings. Inspectsrs were trained to applicable ;
criteria. The suitability of this inspection approach j in supporting the Program objectives will be assessed '
l
/~N in the quality of construction section of the
-(_,) _ Collective Evaluation Report. Any outstanding concerns identified will be addressed either by third-party evaluation or recommendations for corrective action to be performed by the Project.
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Deviation Repo,its Deviation Reports were first reviewed, as a minimum, by the lead discipline inspector for clarity, completeness, and accuracy prior to processing further.
Occasionally, multiple items reinspected or documents l
reviewed consistently had similar deviations from the inspection or review requirements within a. population, i thus identifying a plant condition that would affect many items in the CWC. When it became obvious that such a situation existed throughout the population, a common DR was issued, reviewed for validity and evaluated for safety significance instead of processing separate DRs. For such a situation, reinspection or document review continued. Subsequent deviations found, however, were noted on the checklist and added to the common DR through the revision process.
A QA/QC Program Deviation Report (PDR) was prepared when it was determined that an inspection area had' potentially not been reviewed by the TU Electric QA/QC' program even though it should have been in order to meet stated regulatory requirements or licensing commitments. For each PDR, a review was conducted to verify that the potential omission in the TU Electric QA/QC program did exist and to determine if the verified omissions were TU Electric QA/QC program deficiencies. Recommendations for corrective action were to be included for any identified program deficiencies. Program Deviation Reports were then transmitted to TU Electric for further evaluation. No further documentation review was performed on the affected attribute or characteristic once the omission was verified. since there was no documentation to review for an inspection activity that had not been i
performed.
Deviation Reports associated with Inspector Certifications were referred to the ISAP I.d.1 Issue Coordinator for evaluation of inspector qualifications.
However, the results of the ISAP I.d.1 evaluations indicated that such deviations do not necessarily
.O, relate directly to actual inspector qualifications.
Evaluation results are include ( 'he ISAP 1.d.1 Results Report. Deviation Rep- 6. . . tiated with
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V RESULIS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) concrete anchor bolt installation were evaluated by SSEG prior to being referred to the ISAP VII.b.4 Issue Coordinator for reporting. Results of these evaluations are included in the ISAP VII.b.4 Results Report.
A process was developed (TU Electric procedures CP-QP-16.0, -16.3, and -15.0) whereby physical work by TU Electric on a sample item, including any work required to correct a deviation, was restricted after the DR was issued until an evaluation was made of the safety significance of the deviation (s).
Evaluation of Reinspection Deviations Valid reinspection deviations were submitted to tha SSEG for evaluation of safety-significance as defined f~s, in the Program Plan. This evaluation determined
(_,) (unless the SSEG decided the deviation should be unclassified) the extent to which a deviation affected the capability of the item to perform its intended safety-related function.
Reinspection deviations were evalu ted by first identifying what safety-related aspect of the item was affected. An evaluation was then perf ormed to determine if the item could perform its intended safety-related function. Both qualitative and quantitative evaluation methods were used, depending on the nature of the deviation and the amount and type of engineering information available for the' item.
The majority of the deviations required straightforward analyses to show that the deviations had a negligible effect on the ability of the item to perform its safety-related design function. Others required more extensive quantitative analysis to determine the magnitude of the detrimental effect or reduction in capacity, Qualitative analysis was used to evaluate deviations that did not affect a load transfer path (or other
- functional parameter such as electrical current), and
(') was also used to evaluate most deviations that only affected the load path (or other functional parameter)
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to a minor extent. Examples of these types are certain deviations for welds, concrete surface cosmetic deviations, equipment identification or color coding, gaskets, washers, and locking devices.
Quantitative analysis was used to evaluate deviations that directly affected load transfer paths or other li functional parameters. The quantitative analysis could be done for the portion of the item containing the deviation (e.g., certain veld size devfations, member size deviations, bolt deviations, and steel connection deviations) or the entire item. Types of quantitative analyses included direct calculations of as-found capacities, reductions in design margins, and bounding calculations for the minimum configuration conditions required and/or the maximum deviation allowed to i maintain functional capability. The bounding calculations were used when there was a sufficient
\ number of deviations of the same type to make it more practical than item-specific calculations.
The ext'ent to which the calculated capacity reduction affected the safety-related function of the item was then evaluated. For each sample item, multiple deviations for a single attribute that affected the capacity of the item were combined in determining the capacity reduction. . For evaluations in which the functional capacity in the found condition was calculated, the severity of the deviation was determined from the capacity reduction and the-design-margin reduction. The capacity reBuction was generally calculated to be the reduction in load capacity (or other functional parameter such as electrical current) due to the physical deviation, without reference to the load on the item. The design-margin reduction was the reduction in.the unused capacity. The deviations were categorized based on the magnitude of the reduction in capacity or design margin and the effect on safety-related function.
Reinspection deviations were not given individual safety significance evaluations in the following situations:
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(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
When a number of deviations (f rom DRs) were the same, a single common DR, listing each individual DR (deviation) that it incorporates, was submitted to the SSEG for evaluation. A safety significance evaluation was performed to cover all such deviations and a single result was reported. The types of deviations that were handled in this manner were those with a piece missing, for example, rather than an inadequate condition that could vary from sample to sample.
- Deviations had no additional evaluations for safety significance, root cause, and generic implication if they were the same as one that had been determined to be a CD and if a common corrective action recommendation was f'-] appropriate for them and the CD. In these
( ,/ cases a determination was made that the deviations were sufficiently similar to the CD that they could be covered by a common corrective action recommendation. Also, no safety-significance evaluation was performed if it had been already determined that corrective action was necessary for that type of deviation; this may apply when an adverse trend or unclassified trend had already resulted in a corrective action being recommended. Reference to the common corrective action was made to complete these saf ety significance evaluations'. The deviations were denoted as unclassified deviations.
In this ISAP Results Report, reinspection deviations are categorized and defined as follows:
Insignificant: Deviations that had a negligible change (generally less than 10 percent reduction) in the characteristic of interest or had a negligible effect on the ability of the item to perform its intended design function (this may be a qualitative evaluation).
- Examples of insignificant deviations include minor
(' connection component configuration deviations on structural steel, minor piping linear dimension discrepancies, or missing color coding.
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Notable: Deviations that had a non-negligible change in the characteristic of interest or had a non-negligible ef fect on the ability of the item to perform its intended design function (this may be a qualitative evaluation). Deviations of this type may include incorrect member size, missing or loose bolting in pipe whip restraints, undersized welds, inadequate pipe clearances, or excessive' instrument tube spans.
Construction Deficiency: Deviations that, if uncorrected, would result in the loss (as defined in the Program Plan) of the capability of the item to perform its intended safety function.
Unclassified Deviations: Those deviations for which a i determination was made to proceed directly to analysis of root cause and generic implications and to specification of corrective actions without performing Oi a safety significance evaluation. Such unclassified deviations were treated as construction deficiencies for the purposes of root cause and generic implications analysis and of corrective action recommendations.
When a sample item had multiple deviations involving more than one attribute, a cumulative impact evaluation was performed to determine their combined effect on the item's ability to perform its intended function and to identify combinations of attributes that could result in safety significance. With regard to duct section discrepancies, for example, cases occurred in which both welding and bolting discrepancies were present on ;
a single sample item. Accordingly, a cumulative impact i evaluation was performed. Cumulative impact evaluations were considered, where applicable, during the trend analysis.
In accordance with the Program Plan, apparent defects I and discrepancies that were outside the scope of any ISAP or that affected an item or area that was not part of the randomly selected sample were noted by the inspectors and reported as Out-of-Scope Observations.
Out-of-scope Observations dated prior to April 30, 1987, were reviewed by the appropriate discipline O engineer who determined the significance of the noted condition (s) by comparison, if possible, with in-scope deviations. If the observation described a condition l
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( (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) similar to deviations that had been evaluated for safety significance and addressed in this report for the affected CWC, no further action was necessary. If the observation was more appropriately related to another ISAP (i.e. , non VII.c), then the observation was referred to the appropriate issue cootJvaator for evaluation. If the discipline engineer was unable to determine the safety significance of the observation, the Safety Significance Evaluation Group provided an evaluation. The evaluation results and the significance and applicability determinations for each of the applicable observations were then documented in the files. Any safety-significant observation that was not an additional instance of a finding previously reported was identified as a new finding for the appropriate CWC in this Results Report.
Evaluation of Documentation Review Deviations
- An evaluation was performed of documentation review deviations to determine the extent to which the documentation, possibly supplemented by further investigation, provides supporting evidenca of the quality of construction work.
Since the overall objective of this ISAP was to assess the quality of the installed hardware, a deviation resulting from missing or incomplete documentation meant that the desired evidence was not available to verify the quality of the not recreatable or inaccessible physical attribute being checked. The absence of evidence did not, in itself, support any conclusion regarding the quality of the physical attribute and the evaluation of safety significance was, at this point, indeterminate.
Further evaluation of the missing or incomplete documentation deviations was therefore performed for each type of deviation identified. These further evaluations collected and considered alternative documentation for evidence of the quality of the hardware and other direct evidence of hardware quality O
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cent'd) such as reinspection.* . Generally, destructive examinations of the hardware were not performed.
Where this further evaluation revealed physical evidence of a nonconiormance, a deviation was processed as per reinspection deviations. However, evaluation of the additional information' collected, in most cases, led to a conclusion that the hardware was adequately installed for the safety-related characteristics addressed by the attribute.
For documentation review deviations where insufficient information was found overall, the evaluation determined that no conclusion was possible concerning the capability of the hardware to perform its intended safety-related function. Such a determination does not mean that the hardware was unable to perform its function; nevertheless, an unclassified trend was r~w identified in such cases. For each unclassified trend
(, ) identified, a root cause and generic implications evaluation was performed and corrective action was recommended to verify hardware quality.
In this ISAP Results Report, documentation review deviations are categorized and defined as follows:
Insignificant: Deviations for which evaluation of additional related documents, of existing information from reviewed documents, or of supplementary evidence, in the case of an incomplete document, provided reasonable assurance that the safety-related hardware characteristics addressed by the attriburb being reviewed were of acceptable quality.
Notable: Deviations for which (1) either the documentation typically required or alternative documentation could not be located or it does not exist to provide supporting evidence of the quality of construction work for the safety-related attribute or
- Reinspection supporting evaluation of attributes previously considered inaccessible or not recreatable were possible at times
- for a limited scope (e.g., examination of exposed surface only, use of special NDE techniques, etc.).
(s)
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NJ ISAP VII.c i (Cont'd) !
5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) characteristic being reviawed for the specific item, or (2) the documentation indicates acceptance of an out-of-specification condition (these deviations were insignificant if they were evaluated to be clearly the result of a recording error).
An exception to the deviation categorization process was made for documentation review deviations concerning QC inspector qualification. The ISAP I.d.1 evaluations of inspector qualification for the inspectors whose work was relied upon during Action Plan activities (i.e., those with and without certification deviations reported) determined that such deviations do not necessarily relate directly to actual inspector qualifications. however, the ISAP I.d.1 Results Report does provide a characterization of their impact on the applicable CWCs.
O) s, Analysis for the Presence of Trends For reinspection deviations determined to be not safety-significant, an analysis was performed to identify trends that had safety significance (e.g.,
adverse trends per Appendix E of the CPRT Program Plan). This analysis for the presence of trends was made by assessing the severity of insignificant and notable reinspection deviations, grouped by deviation
" types", along with the frequency at which they were present in the sample and the pertinent characteristics of the uninspected portion of the CWC to determine whether an undetected CD was likely in the CWC. The potential severity of similar deviations in the uninspected portion of the CWC was thus assessed by the evaluating engineers considering the severity, frequency and nature of the deviations reported as well as the margins that were judged to exist throughout the CWC between the hardware application requirements and >
the code-allowable capability.
If, after the assessment of severity, frequency, and potential for undetected CDs, it was determined that it was likely that an undetected CD(s) could exist, then an adverse trend was identified. If the likelihood of 7-( an undetected CD was indeterminate, an unclassified
Revision: 1 Page 35 of 186 g-- RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) trend was identified. Otherwise, such deviation trends were determined not to be adverse. When an adverse or unclassified trend was identified, a root cause and generic implication analysis was performed and corrective action was recommended. Each trend analysis was d'ocumented with a summary of the evaluation logic and a statement of the conclusion in the Results Report.
For trend analysis of some reinspection deviation types, it was determined that a more practical or expeditious approach was to proceed directly te analysis of root cause and generic implications and to recommend corrective action. For cases in which such a determination was made, an " Unclassified Trend" was identified, in accordance with Appendix E to the Program Plan.
'() If investigation of the documentation review deviations uncovered direct evidence demonstrating impaired hardware quality, a similar analysis for the presence of trends might be performed for reported documentation review deviations.
Quality Assurance Measures The activities performed during implementation of ISAP VII.c were controlled by a Quality Assurance Program under which measures were taken to ensure completeness, validity and proper documentation of action plan activities.
This extensive QA Program included provisions for use of appropriately qualified / certified individuals, definition of work activities by specific procedures and instructions, overview inspections to verify the accuracy of QA/QC Review Team reinspection and documentation reviews, planned periodic audits, and an independent engineering assurance review of QA/QC Review Team documentation to assure correctness, completeness and compliance with procedures. In addition, safety significance evaluations and trend 7,s analyses of the found deviations were reviewed by technical personnel for validity and confirmation that
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Revision: 1 P cn 36 of 186 rN RESULTS REPORT, ISAP VII.c (Cont'd) 5.0 IMI' LAMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) no unidentified adverse or unclassified trends exist.
Also, a separate self-initiated review program was conducted to provide additional assurance that the evaluations accurately analyzed the deviating plant construction conditions.
These QA measures provide assurar.ee that the work performed was properly controlled and of high quality.
5.2 Discussion of Results 5.2.1 General The self-initiated sample reinspection / documentation review resulted in a total of approximately 3,800 sample items being evaluated for quality of construction either directly, by reinspection, or indirectly, by documentation review.
-)
(._) This reinspection / documentation review included approximately 2.1 percent of the population of QC-accepted items and 1.4 percent of the total safety-related items in the plant.
A total of approximately 631,000 reinspection / review points were covered by this program. Of these, approximately 53,000 involved concrete expansion anchors, the reinspection / review points and corresponding deviations of which were referred to the ISAP VII.b.4 report for evaluation and conclusions. Of the approximately 578,000 remaining reinspection / review points, 97.9 percent were found to be acceptable. If insignificant deviations are also " included" as being acceptable (i.e. excluding only notable deviations and safety-significant deviations), then 99.6 percent of reinspection / review points were determined to be
" acceptable." (Note: reinspection / review points and associated deviations for lighting cable and HVAC duct support construction work categories, and for inspector certifications, are not included.)
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T RESULTS REPORT (Y ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
There are 32 construction work categories and three attributes analyzed by proportional sampling. Below is listed the number of CWCs with and without " findings" (i.e., deficiencies, adverse trends, and unclassified trends):
10 CWCs with no findings 20 CWCs with findings 2 CWCs with a finding for the entire population In addition, one of the three attributes analyzed by proportional sampling resulted in a finding (concrete inserts).
The breakdown is as follows:
CWCs with No Findings
(~'T V
NIS Cable Terminations Field-Fabricated Tanks Tubing Welds and Materials Piping System Bolted Joints HVAC Equipment Installation Fill and Backfill Placement Fuel Pool Liner Cement Grout Epoxy Grout Conduit Supports ,
CWCs with Findings
- Conduit Cable Tray Cable Instrumentation Equipment Installation Electrical Equipment Installation Mechanical Equipment Installation Piping Bend Fabricat1on Large-Bore Piping Configuration Small-Bore Piping Configuration !
1 Pipe Welds and Material g HVAC Ducts and Plenums
( Containment Liners and Stainless Steel Tank l
Liners Equipment Supports j
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(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS'(Cont'd)
Concrete Placement Structural Steel Large-Bore Pipe Supports - Rigid Large-Bore Pipe Supports - Non-rigid Small-Bore Pipe Supports Pipe Whip Restraints Instrument and Tube Supports L
CWCs with a Finding for the Entire Population l
Lighting Cable HVAC Duct Supports The reinspection / documentation review resulted in 274 of 329 attributes having no findings.
Tables 5.2-1 through 5.2-5 provide information at the population and attribute level, including attributes or hardware that were proportionally sampled. These tables identify the specific number of findings.
, Several findings are similar in nature and were
- l. combined resulting in the following number of finding types:-
23 Construction Deficiencies 11 Adverse Trends
_1_9 Unclassified Trends All of the above findings resulted in recommendations for corrective action. Each recommendation for r
corrective action is applicable to the population in which the finding was identified unless otherwise noted. In addition, there were seven special cases with associated recommendations and eight Program Deviation Reports, of which four were determined to be QA/QC program deficiencies. Of the four deficiencies, there is one with an associated recommendation that is not included in the findings identified above.
5.2.2 Summaries of Corrective Action Electrical ,
() The results of the reinspection for electrical construction work categories determined that for 37 of 51 electrical attributes reinspected, no corrective actions are required.
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The results of the documentation review for electrical construction work categories determined that for 20 of the 21 electrical attributes reviewed, no corrective actions are required.
The findings related to missing welds, missing bushings in lighting conduit, terminations not per drawings, loose connections in terminal blocks, twist in flexible metal hose, installation of cable tie downs, power cable spacing, and incorrect relay type were determined to be specific to the applicable CWC. The recommended corrective action involves only identification and correction of any similar discrepancies.
The special cases related to cable tray attachments and rung spacing will not require further corrective action if ongoing test program results show that the present conditions are acceptable; otherwise, the recommended 9 corrective action involves identification and correction of unacceptable deviations for these attributes.
The findings related to loose unions, slack of flexible conduit, damaged flexible conduit, loose Weidmuller terminals, cable separation barrier material installation, slack of cable in free air, cable bend radius, electrical equipment damage, and electrical equipment assembly or modification were caused, in p.2rt , by deficiencies in the procedural aspects of the engineering and construction and in training of personnel for this work. The recommended corrective action includes revisions to appropriate procedures and training, as well as identification and correction of any similar discrepancies.
The finding related to electrical separation between conduits and cable trays were caused, in part, by the practice of deferring separation considerations until after construction was complete, and in part by inadequate implementation of the separation walkdown program. The recommended corrective action includes identification and correction of any similar discrepancies.
The finding for the Lighting Cable CWC was caused, in part, by less-than-adequate construction procedures, QC Procedures, and supervision. The recommended
Revision: 1 Paga 40 of 186
,, RESULTS REPORT
(' '/ ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) corrective action includes revisions to appropriate procedures, training and cable manufacturers' recommended tests, as well as reinspection of recreatable safety-significant attributes of Class 1E lighting cables.
The documentation review deviations for the 6.9 kV cable terminations in the cable CWC resulted in an unclassified trend. The recommended corrective action includes an evaluation of the requirements for objective evidence of 6.9 kV jacket and insulation removal and clarification of the inspection procedure.
Mechanical The results of the reinspection for mechanical construction work categories determined that for 69 of
()
f, the 77 mechanical attributes reinspected, no corrective actions are required.
The results of the documentation review for mechanical construction work categories determined that for 33 of the 34 mechanical attributes reviewed, no corrective actions are required.
l The finding and special cases related to mechanical ;
equipment broken bolts, mechanical equipment manway covers and pipe radial weld shrinkage and base material reduction were determined to be specific to the applicable CWC. The recommended corrective action involves identification and correction of.any similar discrepancies. i The findings and special cases related to large-bore ;
and small-bore piping configurations were caused, in part, by deficiencies in the procedural aspects of engineering, construction, and QA for this work. The recommended corrective action includes additional craft training and revisions to appropriate procedures and specifications, as well as identification and j correction of any similar discrepancies.
The finding related to pipe bend fabrication was caused ;
,,s '
e i by deficiencies in the procedural aspects of
\--l engineering, construction and QC for this work. The recommended corrective action includes verification by
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RESULTS REPORT L t
( ISAP VII.c l
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) )
ultrasonic testing that installed site-fabricated pipe bends on 2 inch and smaller piping meet the manuf acturer's minimum wall thickness, as well as revisions to appropriate procedures.
The finding related to ductwork hardware installed without approved design details was caused by deficiencies in the procedural aspects of construction, engineering and QA for this type of work. The recommended corrective action includes retraining the contractor's construction and QC inspection personnel,.
a walkdown inspection of ductwork to identify similar situations, analysis, updating of procedures and rework of. unacceptable installations.
Structural The results of the reinspection for structural f-s construction work categories determined that for 10 of.
the 16 structural attributes reinspected no corrective actions are required.
The results of the documentation review for structural construction work categories determined that for 41 of the 46 structural.attrilutes reviewed, no corrective actions are' required.
The findings related to structural steel member configuration and welding were determined to be specific to the applicable CWC. The required corrective action involves only identification and correction of'any similar discrepancies.
The finding related to concrete surface condition requires the development and it, lamentation of a separate program to evaluate.tba' quality of mortar placement at construction joints.
The findings and special case related to structural steel bolting and the potentially safety-significant trend related to stainless steel tank weld seam surface condition were caused, in part, by deficiencies in the procedural aspects of the engineering, construction, and QA for this work. The required corrective action i ~O' will include revisions to appropriate procedures, as well as identification and correction of any similar discrepancies.
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. \s / l ISAP VII.c l (Cont'd) I 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The missing documentation for the structural steel CWC resulted in a special case which requires review of this CWC's documentation to identify where additional reinspection is necessary to provide a record of construction adequacy. For other CWCs, documentation problems were primarily with the retrieval and clarity of documentation rather than lack of documentation.
Supports The results of the reinspection for supenrt construction work categories determined that for 32 of 52 support attributes reinspected no corrective actions are required.
The results of the documentation review for support construction work categories determined that for all of fg the 32 support attributes reviewed, no corrective y/ actions are required.
The findings related to instrument tube clamps and pipe I whip restraint AWS welding were determined to be specific to the applicable CWC. The required corrective action involves identification and correction of any similar discrepancies. 1 The findings related to large-bore pipe support (rigid) vendor-supplied jam nuts, small-bore pipe support installation of vendor components, instrument tube clamps, and large-bore pipe support (non-rigid) ;
configuration and vendor-supplied components were caused, in part, by deficiencies in the procedural aspects for startup, preoperational testing, and quality control. The recommended corrective actions include review and revision to appropriate procedures, as well as identification and correction of any similar discrepancies.
The findings related to large-bore pipe support (rigid) configuration, bolting, and installation of vendor components, large-bore pipe supports (non-rigid) bolting and installation of vendor components, small-bore pipe support bolting and support configuration, pipe whip restraints configuration, cold
[ )'
'-- gap, structural bolting, and instrument tube support bolting were caused, in part, by deficiencies in the
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! )
ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) procedural aspects of the engineering, construction, and QC and in QC training for this work. The recommended corrective actions include revisions to appropriate procedures, design documents, and training, as well as identification and correction of any similar discrepancies.
The findings related to the HVAC duct support CWC were caused by less-than-adequate procedures for construction, documentation and inspection of HVAC duct supports as well as less-than-adequate training of craft and QC personnel in this area. The recommended corrective actions include testing and design document revisions, as well as actions taken to provide reasonable assurance that the hardware is adequately installed.
,-s, The documentation review deviations for the HVAC duct
- ] support CWC resulted in an unclassified trend. The recommended corrective actions include additional ,
evaluations for fit-up and material traceability adequacy and reconciliation of detail drawing to reflect the as-installed condition.
5.2.3 Electrical - Details Conduit Reinspection For 98.1 percent of the approximately 3,000 inspection points the hardware condition was found to be in accordance with design requirements. For an additional 1.8 percent of the inspections points the deviations were insignificant. 'For the remaining 0.1 percent of the inspection points, the deviations were notable.
There were one CD, four adverse trends and no unclassified trends.
For nine reinspection attributes, six had no findings.
The attribute of installation of fittings had adverse trends for missing bushings on lighting conduit and loose unions. The attribute of installation of
- expansion fittings and flexible conduit had a CD for
( incidental damage to flexible conduit and an adverse trend for insufficient slack in flexible conduit used l
Ravision: 1 Page 44 of 186 rx RESULTS REPORT f I wi ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) in shake spaces. The attribute of electrical separation had an adverse trend for electrical separation violations. This CD and these adverse trends with their root causes and recommended corrective actions are as follows:
Missing Bushings
- The deviations of missing bushings were determined to constitute an adverse trend that was limited to lighting conduits. The deviations themselves are classified as insignificant. However, the bare edge of the conduit end, without a bushing, could cause damage to the cable jacket and insulation during cable pulling and could lead to cable failure. All the missing-bushing deviations were on lighting conduit.
(f-~)s
'- - Primary root cause: less-than-adequate attention to detail by construction personnel during the installation of lighting conduits.
Secondary root cause: lack of adequate acceptance criteria for the presence of bushings in the lighting inspection procedure.
Recommended corrective action: Inspect safety-related lighting conduit ends for the presence of bushings, and correct as necessary. No additional recommendations for lighting conduits are required, as inspection procedures have been appropriately revised.
Loose Unions ThedeviationsofI)ooseunionswere determined to constitute an adverse trend.
The deviations themselves are classified as insignificant. However, a loose union in an area subject to vibration could result in union disengagement. Excessive displacement of the disconnected conduit ends during a
(,.s seismic event would damage the cable and
\ cause cable failure.
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- Primary root cause: less-than-adequate construction installation procedure that did not explicitly address union tightness, a workmanship practice that should have been inspected.
Secondary root cause: less-than-adequate inspection procedure that does not have a checklist attribute for tightness of unions.
- Recommended corrective action: Revisc the electrical construction procedure and the conduit inspection procedure to require that unions be wrench-tightened.
Inspect and wrench-tighten unions on safety-related conduits, as necessary.
Insufficient Slack in Flexible Conduit Used in Shake 7-~g Spaces N.Y - The deviation of a flexible conduit with less than the required 1-inch slack across a shake space between two buildings was determined to constitute an adverse trend. This deviation is classif1ed as notable beca se the available slack was equal to the calculated seismic displacement. However, the same amount of slack in some other flexible conduit installation, across a shake space with greater seismic displacement, would adversely affect its ability to perform its intended function. This conduit was installed prior to June 1984.
l - Primary root cause: less-than-adequate j engineering instruction for installation l prior to June 1984. Prior to June 1984 the detail for the installation of flexible conduit used in shake spaces did not show how slack was to be measured.
Secondary root cause: either less-than-adequate QC training concerning the measurement of slack in flexible conduit to the revised detail or less-than-adequate f-attention to detail by the inspector.
(s) Further specificity of the root cause cannot
Revision: 1 Paga 46 of 186
/N RESULTS REPORT V ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) be determined.
Contributing cause: less-than-adequate instruction from engineering for the disposition of the NCR written against this i installation in March 1985.
Recommended corrective action: Inspect flexible conduit installations traversing shake spaces for the 1-inch slack requirement. Those not meeting the requirement should be confirmed to have adequate slack or corrected as necessary.
Damaged Flexible Conduit ,
- A deviation was reported where damaged flexible conduit had been pulled from the
()
's_,1 fitting that had connected it to an instrument. This deviation was determined to be a CD because the sharp edge of the conduit would cause failure of the conductors contained in the conduit.
- Primary root cause: incidental damage caused by unrelated construction work in the area.
- Recommended corrective action: Perform walkdowns of areas prior to turnover or final acceptance to identify any damage ir. curred during construction activities. Ensure that appropriate inspection procedures are in effect for construction and operations and that emphasis is placed on components susceptible to damage, such as flexible conduit.
Electrical Separation Violation The deviations of conduit installations violeting the electrical separation criteria were determined rs constitute an adverse trend. The deviations themselves are
- classified as insignificant; however, a similar deviation occurring elsewhere in the (s) population could result in damage to a cable if a cable fault is postulated in an adjacent redundant raceway. l I
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(~S RESULTS REPORT ISAP VII.c '
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Primary root cause: The practic e of deferring electrical separation considerations until after construction was complete in an area adversely affected the craft's ability to establish and maintain electrical separation as work was performed.
Secondary root cause: less-than-adequate implementation of the QC walkdown program for i electrical separation.
Contributing cause: Less-than-adequate coordination between engineering, construction, and QC resulted in incorrect j '
interpretation of separation criteria by QC.
Recommended corrective action: Inspect conduits for separation adequacy, and correct as necessary.
No additional recommendation is required as O,
i the inspection procedures for conduit have been appropriately revised to include verification of separation during each conduit inspection.
Documentation Review No documentation review was performed for this construction work category.
Cable Tray Reinspection -
For 99.6 percent of the approximately 20,000 inspection points the hardware condition was found to be in accordance with design requirements. For an additional 0.3 percent of the inspection points the deviations were insignificant. For the remaining 0.1 percent of the inspection points, the deviations were notable.
There were two adverse trends and two special cases. l' There were no unclassified trends or CDs.
For 10 reinspection attributes, eight had no findings.
Additionally, the attribute of attachments had a (g
\
special case for improper installation of splice plates and the attribute of rung spacing had a special case for excessive rung spacing. The attribute of welding .
Revision: 1 Page 48 of 186 RESULTS REPORT ISAP VII.c
- (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) had an adverse trend for missing welds. The attribute ,
of electrical separation had an adverse trend for I electrical separation violations. The deficiencies with their root causes and recommended corrective actions are as follows:
Improper Installation of Splice Plates _
- The deviation of improper installation of splice plates was determined to constitote a special case. The deviation was notable, reporting two of four bolts missing on the side of the tray next to a wall. Analysis determined that this condition is adequate for tray loadings of less than 65 percent.
Due to the small numbers of trays loaded greater than 65 percent and the small percentage of deviations reported, it is unlikely that a construction deficiency would ll occur in the uninspected portion of the population. A cable tray test program incorporating the condition of two bolts in one half of a splice plate is currently underway.
Primary root cause: None determined Recommended corrective action: Review test results of the cable tray test program to determine failure threshald for this deviation type. Results of the+ review should be available for overview by the QOC Review Ta a.m. In the event that the test fails to confirm the analysis performed to determine safety significance, further corrective action may be required.
Missing Welds
- The deviations of missing welds were determined to constitute an adverse trend.
The deviations were insignificant. However, they all result from not backfitting revised design requirements to completed construction 9 and such a lack of backfit for other welds could adversely affect a cable tray's ability to perform its design function.
y Revision:. 'l Page 49'of.186
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'5.0 INTLEMENTATION OF ACTION PLAN ' AND DISCUSSION OF RESULTS (Cont'd) ,
-~ Primary root cause: failure to backfit in
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that construction did.not implement revised designLrequirements that affected'the cable tray installation.
Recommended corrective action: Evaluate design changes that have been made to the generic _ details'for cable tray fittings to determine whether they need to be backfitted, and correct as necessary.
No additional recommendations are required as a procedure-to ensure design change review
'for bacKficting has.been issued. .
Excessive Rung Spacing
-- The deviations of excessive: rung spacing were determined'to' constitute'a special case. The.
deviations _were insignificant and none
= O- exceeded a' spacing of 11 inches. Evaluation determined that rung spacing of up to 15 inches'is acceptable based on extrapolation of data from previous tray qualification testing. It is unlikely that rung spacing would exceed the 15 inches, which represents the maximum allowable rung spacing plus one rung missing. The trays are' currently being retested.
Primary root cause: None determined Recommended corrective action: Review test results of the cable tray test program to determine failure threshold for this' deviation type. Results of the review will be available for overview by the QOC Review Team. In the event that the test fails to confirm the analysis performed to determine safety significance, further corrective action may be required.
Electrical Separation Violation
- The deviations of electrical separation violations were determined to constitute an adverse trend. The deviations themselves are I
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/" RESULTS REP 0FT t
ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) either insignificant or notable. A similar deviation occurring elsewhere in the population could result in damage to a cable if a cable fault is postulated in an adjacent redundant raceway.
Primary root cause: The practice of deferring electrical separation considerations until after construction was complete in an area adversely affected the craft's ability to establish and maintain electrical separation as work was performed.
Secondary root cause: less-than-adequata ,
implementation of the QC walkdown program for !
electrical separation. i Contributing cause: Less-than-adequate ;
coordination between engineering, construction, and QC resulted in incorrect
.) interpretation of separation criteria by QC.
Recommended corrective action: Inspect cables and raceways for separation adequacy, and correct as necessary.
No additional recommendation is required as the inspection instruction for conduit has been appropriately revised to include a verification of separation during each conduit inspection.
Documentation Review For 78.5 percent of the approximately 260 review points the documentation was found to be as required. Of the 21.5 percent reported deviations, 21.1 percent represent deviations that were determined to be insignificant because documentation that could not be found in the cable tray documentation files was not required by the QC program in effect to be retrievable. ,
For the remaining 0.4 percent of the review points the deviations were also insignificant. The four documentation review attributes had no findings.
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(_,
- ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Cable Reinspection For 97.7 percent of the approximately 8,700 inspection points the hardware condition was found to be in accordance with the design requirements. For an additional 2.0 percent of the inspection points the deviations were insignificant. For the remaining 0.3 percent of the inspection points, the deviations were notable. There were three CDs, two adverse trends, and three unclassified trends.
For 13 reinspection attributes, seven had no findings.
The attribute of power cable spacing had an unclassified trend for spacing less than the specified minimum. The attribute of slack had an adverse trend for insufficient cable slack. The attribute of bend radius had an unclassified trend for bend radius less Os the the specified minimum. The attribute of separation barrier material installation had an adverse trend for incorrectly installed separation barrier material. The attribute of tie down installation had an unclassified trend for incorrect power cable tie down spacing. The attribute of terminations had three CDs: loose connections on Weidmuller terminal blocks, cables not terminated in accordance with drawings, and loose connections on terminal blocks. The deficiencies with their root causes and recommended corrective actions are as follows:
Power Cable Spacing Violations
- The deviations of power cable spacing less than the specified minimum were determined to constitute an unclassified trend. The deviations themselves were notable. However, a bounding analysis to determine the conditions under which any cable would be adversely impacted by less-than-specified spacing of the cables would be difficult to perform. The elastic memory of the reinstallation coiled condition of the cable, coupled with cable thermal cycling, can cause displacement of the cable if the Oi initial installation is installed usin6
R2 vision: 1 Page 52 of 186 RESULTS REPORT m
1 SAP VII.c (Cont'd) 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) inadequate criteria. These deviations represent cables that were QC-accepted as having minimum spacing but that, upon subsequent reinspection, were found not to be in accordance with specified requirements.
- Primary root cause: less-than-adequate installation criteria for construction's use; installation criteria should have ensured that when the spaced cables were installed, minimum spacing would be maintained with time.
Contributing cause: tie-down spacing greater than the specified maximum.
- Recommended corrective action: Review, by engineering, to determine those cable trays where cable spacing is required.
Reinspection of cable trays for spacing where j/} (_ required and correction as necessary.
Review by engineering of the present criteria f or minimum spacing between power cables and maximum spacing between cable tie-downs.
Insufficient Cable Slack
- The deviations of slack less than the specified minimum in free air cable transitions between tray and conduit were determined to constitute an adverse trend.
The deviations themselves are classified as insignificant. However, a similar lack of sufficient cable slack at other locations could adversely affect the ability of the cable to perform its intended function after a seismic event.
- Primary toot cause: less-than-adequate clarity in the definition of slack in the engineering specification, installation instructions, QC procedures, and applicable detail drawings, as the criterion of 2 inches of cable movement specified does not necessarily result in 2 inches of excess cable measured between its two secured ends; O- also, the specified criterion was interpreted
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RESULTS REPORT
(~}/
\ms ISAP VII.c (Cont'd) 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) and applied differently by the installers.
Contributing cause: lack of necessary instruction-. and acceptance criteria regarding slack in the termination installation and termination inspection procedures. Slack could be reduced during the terminating process, but these procedures had no requirement to ensure that slack existed after cable termination.
- Recommended corrective action: Revise erection specification, installation instruction, and inspection procedures to include an adequate definition of slack and to ensure adequate slack after terminations.
Inspect cables at all free air cable transitions for specified slack, and where 7-~3 slack requirements are not met, engineering should evaluate for adequacy. If adequate
( / slack does not exist, correct as necessary.
Bend Radios Violations
- The deviations of cables having a bend radius less than the minimum specified were determined to constitute an unclassified trend. One deviation was insignificant, and one was notable. The likelihood of a CD in the CWC cannot be determined from the existing data as there are many types of cable, and the cable manufacturers ara relied upon for determination of allowable limits.
Primary root cause: less-than-adequate cable installation instructions that did not specify bend radius acceptance criteria for this type of cable and had no instructions for bend radius to be maintained during the terminating process.
Secondary root cause: less-than-adequate attention to detail by the inspector.
Further specifics of the cause cannot be determined.
4 i
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-- RESULTS REPORT
# ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- Recommended corrective action: Revise engineering instructions for cable termination to include instructions for maintaining minimum bend radius during and after terminating cables.
Review and revise engineering instruction for cable installation to include those cable types now missing minimum bend radius acceptance criteria. The QC procedure should then be revised to agree with engineering instruction.
Inspect those installations of cable types now missing minimum bend radius acceptance criteria in the cable installation instructions, and correct as necessary.
Incorrectly-installed Separation Barrier Material The deviations of incorrect installation of
[)
\-
separation barrier material (SBM) were determined to constitute an adverse trend.
The deviations themselves are classified as insignificant, because for a postulated cable fault, temperature of the cables in the sample were acceptable. However, similar deviations occurring on other cables and raceways could result in a violation of the electrical separation requirements and could cause cable damage from elevated temperature, thus adversely affecting the cable's ability to perform its intended function. The types of deviations encountered were spacing between bands securing the SBM to the raceways or cables and inadequate covering of the cables in cable tray, resulting in separatian violations.
- Primary root cause: less-than-adequate program for SBM installation.
Recommended corrective action: Inspect the existing SBM installations for compliance with the applicable travelers and procedures, and correct as necessary.
((_/} Review and change those aspects of the SBM program necessary to achieve an acceptable
Revision: 1 Page 55 of 186 RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) level of performance, and incorporate the changes into future program requirements.
Incorrect Power Cable Tie-down Spacing
- The deviations of cable tie-down spacing greater than specified were determined to constitute an unclassified trend. Proper spacing of the tie-downs is necessary to maintain proper spacing of cables. Power cable spacing deviations were reported in conjunction with tie-down spacing deviations.
- Primary root cause: The primary root cause could not be determined.
Secondary root cause: The secondary root cause could not be determined.
Recommended corrective action: Inspect tie-O down installations in conjunction with any reinspection conducted for power cable spacing, and correct as necessary.
Loose Connections on Weidmuller Terminal Blocks
- Deviations ware reported where wires were found loose in Weilmuller terminal blocks because the terminal screws were loose.
These deviations were determined to be a CD because thermal cycling or other forces on the conductors would cause f ailure of the cables to perform their intended function.
Primary root cause: less-than-adequate installation instructions.
Secondary root cause: less-than adequate l inspection procedures.
l
- Recommended corrective action: Terminations on Weidmuller terminal blocks completed prior to June 13, 1985 (the effective date of Revision 5 of EEI-8, which contains adequate installation instructions for Weidmuller terminal blocks), should be reinspected.
O Inspections should be performed in accordance with the latest procedures.
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Cables Not Terminated in Accordance with Drawings 1
- Deviations were reported where wires were not landed at terminal points in accordance with design drawings. These deviations were determined to be a CD because the circuit in which they were connected would not have performed its intended function.
- Primary root cause: less-than-adequate design control in that design changes requiring field work after completion of construction and startup testing were issued to the field by way of a drawing revision rather than a DCA.
Contributing cause: less-than-adequate configuration control in that the revised document was not adequately reviewed to G determine if all required changes were incorporated into the plant.
Recommended corrective action: Review design changes to aasure implementation. Evaluate the design control process for design change control and work tracking for configuration control.
Loose Connections on Terminal Blocks
- A deviation was reported where a wire was found loose on a terminal block.because the terminal screw was loose. This deviation was determined to be a CD because the connection could have deteriorated until the circuit in which wire was connected would fail to perform its intended function.
- Primary root cause: No root cause could be determined; however, based on the very large number of similar terminations directly inspected and indirectly observed during implementation of various CPRT ISAPs, this one case is considered to be either an isolated case or indicative of an extremely 9 low percentage of such deviations.
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Recommended corrective action: Perform an evaluation to address concerns regarding the adequacy of the tightness of field connections on screw-type terminal blocks, and implement any further actirns deemed to be necessary.
Documentation Review For 99.0 percent of the approximately 2,700 review points the documentation was found to be as required.
For an additional 0.8 percent of the review points the deviations were insignificant. For the remaining 0.2 percent of the review points, the deviations were notable. There was one unclassified trend.
For 12 documentation review attributes, 11 had no
,s findings. The attribute of QC acceptance of cable
( jacket and insulation removal had an unclassified trend related to 6.9kV cable. The unclassified trend with its root cause analysis and recommended corrective action is as follows:
QC Acceptance of Cable Jacket and Insulation Removal
- Unverified 6.9kV cable jacket and insulation removal was determined to constitute an unclassified trend. The deviations themselves were classified as notable. The evaluation of these deviations determined that no conclusion about the condition of the cable is possible, as the attribute was marked N/A on the QC inspection report, and no supplementary documentation could be found.
Primary root cause: less-than-adequate inspection procedure in that it does not clearly indicate that the cable jacket and j insulation removal attribute should be i verified for every 6.9kV cable termination; yet the same procedure clearly requires every 6.9kV cable terminations to be witnessed.
p].
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- Recommended corrective action: Evaluate, by engineering, the need to have objective evidence that 6.9kV cable jacket and insulation removal was performed adequately, with any further corrective action to be specified by engineering.
Clarify 6.9kV cable termination requirements in the QC inspection procedure.
Additional Recommendation
- One additional corrective action recommendation was made to complete the generic implications evaluation for the findings in both reinspection and documentation review.
- Recommended corrective action: Review Specification ES-100 for correctness of
(-)
installation criteria for all attributes not previously addressed in the findings.
Similarly review installations instructions EEI-7 and EEI-8 the complete restatement of ES-100 installation criteria in the form of practical instructions that include manufacturer's data and installation criteria as well as the requirements from any pertinent codes and standards.
Following that review, revise each document and the corresponding inspection procedures (QI-QP-11.3-26 and QI-QP-11.3-28) as necessary. Evaluate those revisions to identify any that raise concerns regarding the quality of existing hardware. Resolve any such concerns, performing reinspection where appropriate.
Nuclear Instrument System Cable Termination Documentation Review For 99.7 percent of the approximately 3,300 review points the documentation was found to be as required.
O For the remaining 0.3 percent of the review points tre deviations were insignificant. The four documentation review attributes had no findings.
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Lighting Cable Reinspection The need-for corrective action was apparent after the reinspection of 24 sample items;.therefore, the reinspection of lighting cable was terminated at that' time. The basis for the decision _was the frequency and apparent severity of deviations for the attributes of damage, wire joint installation, bare conductor length,,
and maximum number of conductors in a box. From this set of identified deviations, a determination was made to proceed directly to an analysis for root cause and generic implications. .No safety-significance evaluations were performed, and all reinspection deviations are unclassified.
It was determined that a single unclassified trend O
5 exists for all attributes of the lighting cable CWC, both reinspection and documentation review. The unclassified trend with its root cause and recommended corrective actions are as follows:
All Attributes
- The 24 inspections identified deviations of wire insulation and wire joint damage, loose and improper wire joints, excessive bare conductor at terminations and too many conductors in a box. The deviations were frequent and widespread and involved several attributes.
Primary root cause: less-than-adequate management of construction' personnel, in that management did not select ' personnel with appropriate skill level and experience, and less-than-adequate supervision of construction personnel, in that supervision did not effectively monitor the performance of the work. Construction personnel whose primary work activity had been installing conduit were utilized to pull and terminate f- lighting cable rather than personnel whose primary work activities had been pulling or
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1 RESULTS REPORT ISAP VII.c (Cont'd) l 1
l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) terminating all other Class 1E cables.
Training in pulling and terminating cable was
)
given the personnel used; however, supervisory guidance to ensure correct application of the principles learned was not evident from the work observed. The most frequent types of deviations reported would have been readily observable to construction supervision had a critical examination been performed.
Secondary root cause: less-than-adequate inspection procedures in that the periodic surveillance specified was not effective in identifying the unacceptable workmanship.
The QC inspection procedure did not require inspection at a frequency that would detect trends of deviations, nor did it require inspection of wire joints for attributes that G would verify proper installation.
Contributing cause: less-than-adequate installation procedures for the work activity including less-than-adequate acceptance criteria for the work. The procedure did not contain explicit directions in the depth and detail necessary for adequate Class 1E cable installation and termination. This is evident when the procedure is compared with those for other Class 1E cable installations and terminations.
Recommended corrective action: . Revise installation procedures for Class 1E lighting cables to include the depth and detail appropriate for a Class 1E system, including acceptance criteria, or optionally include lighting cable criteria in the procedures for all other Class 1E cable.
Select construction personnel to perform the installation who have the necessary skill level and experience.
Train appropriate construction personnel to the revised procedures prior to any rework or new installation, and train construction 9 supervisors in techniques of in-process monitoring.
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Inspect recreatable safety significant attributes of accessible portions of the Class 1E lighting cables and perform appropriate tests in accordance with lighting-cable manufacturer's recommendations on lighting cables to detect any damage on-the inaccessible pcrtions of the cable.and correct as necessary.
Revise QC inspection procedures to assure that verification to requirements will be adequate to control the work activities and train inspection personnel to the revised procedures prior to_further inspection.
Consider an evaluation of the electrical non-Class 1E systems for fire protection, communications and heat trace for the effects of less-than-adequate supervision similar to that identified for lighting cables.
Documentation Review Reinspection deviations on lighting cables are unclassified, and no' safety significance evaluations were made for documentation review deviations. They are categorized as unclassified and an unclassified trend exists for all documentation review attributes of ,
the CWC, except QC inspector certification which was i evaluated separately. The documentation review ]
deviations were included in the reinspection root cause analysis. The root causes and recommended corrective action are included in the reinspection section, above.
Additional documentation will be developed as part of the recommended corrective action.
Electrical Equipment Installation Reinspection For 99.5 percent of the approximately 17,000 inspection points the hardware condition was found to be in accordance with design documents. For an additional 0.3 percent of the inspection points the deviations were insignificant. For the remaining 0.2 percent of the inspection points, the deviations were notable.
\- There were five construction deficiencies, one adverse trend and one unclassified trend. l 1
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For four reinspection attributes, two had no findings.
The attribute of damage had a CD for damaged porcelain bus insulator, a CD for damaged solenoid operated valve, an adverse trend for damaged electrical conductor seal assembly, and an unclassified trend for damaged equipment door and access panels and associated hardware. The attribute of assembly or modification had a CD for incorrect relay type, two CDs for incorrect fuse size, and deviations of incorrectly reassembled door and access panels that were included in the unc.lassified trend under the attribute of damage. "he deficiencies with their root causes and recommended corrective actions are as follows:
Damaged Porcelain Bus Insulator
- A damaged porcelain bus insulator in the f-~s transformer compartment of a loa 4 center was determined to be a CD. The damage
(\-') consisted of a small crack in the insulator and the inability to tighten the bolt holding the insulator, bus, and incoming feeder cable together. If the insulator were to fail to provide electrical insulation resulting from crack propagation or to maintain its structural integrity resulting from the loose bolt, it would result in the inability of the transformer to perform its function. The damage resulted from overstressing (overtorquing) the bolt during a transformer modification. -
- Primary root cause: An incorrect torque value was specified in the traveler that instructed construction personnel to perform a field modification. The incorrect torque value was specified and was appropriate for 1/2-inch bolts instead of the actual 3/8-inch bolts installed. The error was not detected in the traveler review and approval cycle.
Recommended corrective action: Replace insulators subject to overtorquing.
Evaluate travelers for similar misapplication c
of design data. Evaluate the practice of
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
I using travelers that provide design information directly in their instructions, including the review and approval cycle for such travelers.
Damaged Electrical Conductor Seal Assembly
- The deviation of a ruptured flexible conduit that was part of an electrical conductor seal assembly (ECSA) connected to a solenoid-operated valve (SOV) was determined to constitute an adverse trend. The damage caused the environmental seal to be lost, and an evaluation to determine the probable failure mode, should failure occur under severe environmental conditions, concluded that the SOV could fail, causing the f-'s air-operated valve to go to its fail-safe
( ,) position. This deviation was therefore notable. Other ECSA configurations could exist whereby the protected equipment would not be fail-safe, and this type of damage could adversely affect the ability of the equipment to perform its safety-related function.
- Primary root cause: damage caused by unrelated construction work in an area. Such damage could be caused by accidental contact with an object or person.
- Recommend corrective action: Inspect for damage to equipment and components susceptible to incidental damage. Particular emphasis should be given to flexible conduit and equipment that must maintain an environmental seal because incidental damage could cause loss of the seal. Inspection should be on an area-by-area, post-construction closeout basis. Establish quality assurance program, and provide procedures to accomplish the inspections.
Evaluate design, location, and configuration
() of flexible conduit connected between ECSAs and components, with particular attention to susceptibility to damage.
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Damaged Solenoid Operated Valve
- A deviation was reported where the solenoid housing of a solenoid-operated valve was found to be excessively loose. This deviation was determined to be a CD because the loose housing could allow moisture l intrusion of the valve assembly, thereby I adversely affecting its operation. l
- Primary root cause: incidental damage caused by unrelated construction work in the area. ,
Such damage could be caused by accidental I contact with an object or person.
Recommended corrective action: Inspect for damage to equipment and components susceptible to incidental damage.
e Particular emphasis should be given to flexible conduit and equipment that must maintain an l environmental seal because incidental damage could cause loss of the seal such as solenoid-operated valves. Inspection should be on an area-by-area, post-construction closeout basis. Establish quality assurance program, and provide procedures to accomplish the inspections.
Damaged and Incorrectly Reassembled Equipment Doors and Access Panels
- The deviations for damaged and incorrectly reassembled equipment doors and access panels and damaged associated hardware were determined to constitute an unclassified trend. The effect of the deviations on the ability of the equipment to perform its safety function would be significant if the affected equipment required a tight seal and might also be significant if components such as relays were mounted on the door or panel.
The likelihood of a CD would be difficult to determine as each piece of equipment's O components and qualification parameters would have to be determined as well as any variations allowed by the manufacturer.
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5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- Primary root cause: Inadequate control of maintenance, testing, or inspection operations in that the equipment was damaged or not properly reassembled during or at the completion of such work.
Recommended corrective action: Evaluate plant operating and maintenance programs to ensure that these prograr.s include adequate administrative controls to require restoration of equipment and component supports, doors and covers including bolts, latches, gaskets and vapor barriers.
Inspect the enclosures of electrical equipment and components and mechanical equipment with electrical components for damage to doors, covers, gaskets, vapor barriers and associated hardware, and for proper reassembly /reclosure of components, supports, covers and doors.
Incorrect Relay Type The deviation of installation of an incorrect type of relay in an auxiliary relay rack was determined to be a CD. The installation of an AC relay in place of the required DC relay would result in premature failure of the installed relay. The installed incorrect relay was not detected because it can be expected to pass startup functional testing as it is normally de-energized. Also receipt inspection does not inspect incoming assemblies to this level of component detail.
- Primary root cause: The primary root cause could not be determined.
Recommended corrective action: Inspect all equipment for configuration in accordance with latest approved drawings.
Incorrect Fuse Size
- - The deviations of installation of incorrect fuse sizes (smaller than required by the internal wiring diagram) resulted in two
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'^} RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
CDs. In both cases, the rating of the fuse was less than the calculated peak load and could cause loss of two load-shedding circuits for the emergency diesel generator.
Thus unscheduled load would remain connected to the diesel during emergency conditions rath'c than being disconnected as intended.
Modifications requiring larger fuse sizes were made on both circuits after initial installation. The fuse size is shown on three types of drawings: schematics, internal wiring diagrams, and fuse schedules.
Information that should be duplicated on the three drawings did not agree.
Primary root cause: less-than-adequate design control in that all related drawings were not updated in the same time frame. The
(Ns_,) drawings were inconsistent for a two-year period and were still partially inconsistent as of October 1986. During the period between initial installation and the VII.c reinspection of the fuses, the correct fuses had been installed, then removed by operations when the equipment was tagged out of service, and then replaced with incorrect fuses using drawings that had not been updated.
Less-than-adequate work tracking aspect of configuration control for fuses subject to routine removal and replacement during plant operation and governed by multiple sets of drawings.
Less-than-adequate design control in that a fuse size change was not indicated as revised on one reissued drawing.
When fuses were removed there was no systematic means to ensure replacement of the original fuse in the circuit or to record the size of the fuse removed.
- Recommended corrective action: Evaluate and
-- revise the design control program with respect to the issuance of duplicate design (s) information on different design drawings and the configuration control with respect to the review of issued design
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(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) changes and work tracking for incorporation into the plant hardware.
Revise the tagging procedures with respect to proper replacement of removed fuses.
Inspect all equipment for correct fuse size in accordance with latest design drawings.
Additional Recommendation
- Based on the findings associated with Attribute 3, damage, specifically the deviation for wear of plating on battery intercell copper connectors, it is recommended that consideration be given to revising the maintenance procedure for station batteries to ensure compliance with all requirements of the vendor maintenance manual.
O Documentation Review For 99.9 percent of the approximately 4,700 review points the documentation was found to be as required.
For the remaining 0.1 percent of the review points the documentation review deviations were insignificant.
The documentation review attribute had no findings.
Instrumentation Equipment Installation Reinspection For 97.7 percent of the approximately 7,100 inspection points the hardware condition wee found to be in accordance with design requirements. For an additional 2.0 percent of the inspection points the deviations were insignificant. For the remaining 0.3 percent the deviations were notable. There was one CD and no adverse or unclassified trends.
For 15 reinspection attributes, 14 had no findings.
The attribute of flexible hose installation had a CD for installation with excessive twist. There was one QA/QC program deficiency resulting from a PDR on unapproved thread sealant. The deficiencies with their O root causes and recommended corrective actions are as follows:
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Flexible Hose Installed with Excessive Twist
- Deviations were reported where flexible metal instrument hose assemblies were installed with twist in excess of that allowed,by the specification. These deviations were determined to be a CD because any installation with twist is subject to failure and will not be in accordance with the equipment qualification.
- Primary root cause: No, root cause could be determined.
- Recommended corrective action: Reinspect flexible metal hoses to assure that their installation is in accordance with the manufacturer's requirements, and correct as 7-~ necessary.
tsjm Unapproved Thread Sealant
- The PDR on unapproved thread sealant was determined to constitute a QA/QC Program Deficiency. Rectorscal was an approved thread sealant at CPSES prior to January 30, 1981. When its use was prohibited, instrument installations in which Rectorseal was known to have been used should have been replaced using an approved sealant. However, no documentation was found to verify the backfitting activity. There is a possibility that installations still exist in which Rectorseal was used and not removed.
Primary root cause: less-than-adequate backfit program that provided no documented record of whether backfitting had been completed.
Recommended corrective action: Evaluate installations using Rectorseal to determine what actions were taken in 1981 to ensure the removal of it. If conclusive evidence of
[)
A/ Rectorseal removal cannot be produced,
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ISAP VII.c I
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) engineering should perform an evaluation to determine the effect of its continued presence and perform corrective action as necessary.
Documentation Review There were no documentation review deviations for the approximately 240 review points. Thus. the two documentation review attributes had no findings.
1 5.2.4 Mechanical - Details Large-Bore Piping Configuration Reinspection ff- - For 98 percent of the approximately 6,000 inspection points the hardware condition was found to be in i accordance with design requirements. For an additional 1.9 percent of the inspection points the deviations-were insignificant. For the remaining 0.1 percent of inspection points, the deviations were notable or significant. There was one unclassified trend, one special case, and one CD. There were no adverse trends.
For the five reinspection attributes, three had no findings. The attribute of piping clearances had an unclassified trend for inadequate piping clearances.
The attribute of expansion joint installation had a CD for loose tie rods. Additionally, the attribute of .j orientation of piping and conponents had a special case for incorrect flow element direction. These deficiencies with their root cause and recommended corrective action are as follows:
Incorrect Flow Element Direction The deviation for the installation of a flow element opposite to the flow di,rection. u specified by the piping isometric drawing was determined to constitute a special case. The incorrect orientation of the flow element E - results in an inaccurate flow measurement that is less than the actual flow. The
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(Cont'd) s.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) single deviation itself was notable and !
.i L
affected a non-safety-related function.
However, a similar deviation serving a- .)
safety-related system could have the /
I potential for adversely'affecting.the-system's ability'to perform its intended function.
- Primary root cause: less-than-adequate construction procedure that.did not specifically address the direction of flow installation criterion for flow elements.
Secondary root cause: less-than-adequate inspection procedure that did'not specifically address the requirement to verify that flow elements are installed in the correct flow direction.
'3 Contributing cause: less-than-adequate i rework / installation control on turnover systems, where startup did not detect an incorrect installation that was installed under.their cognizance.
Less-than-adequate construction workmanship or supervision that did not install a clearly-marked. flow element in the correct flow direction.
Less-than-adequate QC inspection workmanship that did not verify that a clearly-marked flow element was' installed in the correct flow direction.
- Recommended corrective action: Reinspect flow elements and other direction-sensitive piping components performing a- safety-relate'd function in large- and-small-bore piping to verify that they are oriented in the proper direction and correct as necessary.
Review the appropriate construction-procedures to verify that instructions are provided to ensure that the flow elements and any other flow-sensitive components are installed in the proper flow directions.
Review the appropriate QC inspection procedures to verify that inspections are O- provided to ensure proper installation of 1
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) flow elements and any other flow-sensitive components.
Review appropriate startup procedures to verify that instructions are provided to ensure that flow elements and any other direction-sensitive components installed under startup cognizance are verified by startup for proper orientation.
Inadequate Piping Clearances
- The deviations for pipe-to-pipe and piping-to-component clearances were determined to constitute an unclassified trend. All the deviations were insignificant except a single deviation that was notable.
However, due to the number of deviations
-s s encountered and because it could not be 7
determined that a similar reduction in
-}
6 clearance distance between pipe and/or components would not exist that would result in overstress in the piping, components, or pipe supports, thus adversely affecting their ability to perform their intended function.
Most of the deviations involved situations in which at least one pipe was insulated. The deviations were localized in nature. In all but one case with insulation, the notable one, the insulation was sufficiently compressible to accommodate the movement with no significant effect on pipe stress or support loads.
Primary root cause: inconsistent and incomplete clearance criteria between various piping and component erection specifications during the time of major construction activities Prior to March 1983, less-than-adequate interface between engineering, construction and QC in that insulation thickness was allowed to exceed the specified value in the O)
L
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\, I ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) insulation specification without engineering's being informed if a less efficient material was used.
Lack of criteria in the construction' piping procedure for clearances with components other than piping and lack of instructions relative to notching of insulation for clearance, prior to November 1984.
Secondary root cause: lack of QC requirement to verify final piping clearances subsequent to insulation installation.
Contributing cause: lack of criteria for insulation thickness in the construction procedure used when estimating clearances, l prior to November 1984.
- Recommended corrective action: Verify that existing pipe clearance criteria in
.O applicable specifications (e.g., Piping Erection Specification, 2323-MS-100, etc.)
and procedures are consistent and complete, that criteria among disciplines are provided and that types-of plant hardware requiring clearance from piping are identified.
Review and revise as necessary the insulation specification to include instructions relative to notching of insulation and to specify maximum insulation thickness.
Walkdown of all large-bore piping with insulation installed to verify necessary clearances after all pipes and components are in their final locations.
Retrain piping craft to the requirements of the construction procedure with regard to notifying Engineering when clearance is not adequate.
Revise the QC inspection procedure to require verification of final piping clearances subsequent to insulation installation.
O
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v RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Loose Expansion Joint Tie Rods The deviations for the loose tie rods with missing jam nuts on an expansion joint installation was determined to be a CD. This installation, had only one of four tie rods hand tight and only one nut on each end of the four tie rods, rather than the required two. This created the potential for overstress of the expansion joint. To perform their function the tie rods are required to be uniformly tight and both nuts are required to be installed so that initial setting of the expansion joint length is maintained. In addition the calculated design load for each tie rod is above the safe load, g,
( -
Primary root cause: less-than- adequa te preparation and review of operation travelers, less-than-adequate configuration control.
Secondary root cause: less-than-adequate construction supervision or workmanship associated with contr'olling the installation of non-permanent materials in accordance with established site procedures.
Contributing cause: insufficient identification of the tie rod safety classification on installation drawings in that the drawings that are identified as non-ASME III do not specifically identify the tic rods as safety-related.
Less-than-adequate construction procedures in that the piping erection, pipe support installation, and mechanical equipment installation procedures did not specifically address the installation of expansion joint tie rods or responsibility for such installation.
Less-than-adequate inspection procedures in that the piping, pipe support, and mechanical s equipment QC inspection procedures did not
() state specific criteria for the inspection of expansion joint tie rods.
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's s/ ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Recommended corrective action: Reinspect safety-related piping system expansion joints and correct as necessary.
Review and supplement, as necessary, the appropriate construction and QC inspection procedures to specifically include the installation of expansion joints and associated hardware, as well as any other hardware not addressed by procedure. Verify that any other specialty hardware not addressed by procedure has been properly _
installed in the field. As an alternative to explicitly identifying each type of specialty hardware, appropriate generic provisions may be made in the procedure.
Verify that safety-related components are clearly identified as such on construction
,_, drawings. Where such identification is not
( clear, verify that appropriate installation
's and inspection procedures were followed.
Ensure, as applicable, that all previously-installed temporary installations have been replaced by permanent design installations.
Evaluate, develop and implement, as required, a method of tracking the installation and removal of all temporary piping hardware to verify that temporary installations have been replaced by permanent design installations.
Documentation Review No documentation review was performed for this construction work category.
Small-Bore Piping Configuration Reinspection For 95.5 percent of the approximately 3,700 inspection points the hardware condition was found to be in accordance with design requirements. For an additional 4.4 percent of the inspection points the deviations were insignificant. For the remaining 0.1 percent of
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inspection points, the deviations were notable. There was one unclassified trend and one special case. There were no adverse trends and no CDs.
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For the four reinspection attributes, three had no findings. The attribute of piping and component clearances had an unclassified trend for piping clearances. Additionally, the attribute of orientation of piping and components had a special case for valve flow direction. These deficiencies with their root causes and recommended corrective actions are as follows:
Incorrect Valve Flow Direction
- The deviation for a metal diaphragm type globe valve installed with the flow arrow on the valve opposite to the system flow direction was determined to be a special case. There was no flow direction arrow on the piping isometric used for installation of this 7s valve. The deviation itself was
() insignificant. This deviation type could affect the functional capability of other piping systems; however, the number of isometrics with missing flow arrows resulting in disoriented components cannot be determined without extensive avaluation.
- Primary root cause: less-than-adequate engineering drawing that did not contain a flow direction arrow.
Secondary root cause: less-than-adequate QC inspection checklist, without a requirement for verification of correct valve orientation.
Recommended corrective action: Review safety-related piping isometric drawings to identify any that do not contain the required flow direction arrows, and correct as necessary.
Inspect safety-related piping components the flow orientation of which is essential for system functional operability; correct as necessary.
Revise the QC inspection checklist to address
[T
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the orientation of flow-sensitive components.
During training reemphasize to construction and QC inspection personnel those components that are required to be installed in a specific orientation, l
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Inadequate Piping Clearances l
- The devia:1ons for pipe-to-pipe and piping-to-component clearances were determine.d to constitute an unclassified trend. all the deviations were insignificant except a single deviation that was notable.
However, it could not be determined that a similar reduct5on in clearance distance between other pipes and/or component.s would not result in overstress in the piping, cgsponents, or pipe cupports, thus adversely
'affecting their ability to perform their intended function. Most of the deviations involved situatione in which at least one pipe was insulated. The deviations were localized in nature: In all but one case f-~s the insulation was sufficiently compressible
('~,) or adequate clearance was available to accommodate the movement with no significant effect on pipe stress or support loads.
- Primary root causes: inconsistent and incomplete clearance criteria between various piping and component erection specifications during the time of mejor construction activities Prior to March 1983 less-than-adequate interface between engineering, construction and QC in that insulation thickness was allowed to exceed the specified.value in the insulation specification, if a less efficient material was used without engineering's being inf o rmed .
Lack of criteria in the construction piping procedure for clearances with components other than piping and lack of instructions relative to notching of insulation for clearance, prior to November 1984.
Secondary root cause: lack of QC requirement to verify final piping clearances subsequent to insulation installation.
Contributing cause: Lack of criteria for 7-s,
- ) ,
insulation thickness in the construction procedure used when estimating clearances prior to November 1984.
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- Recommended corrective action: Verify that existing pipe. clearance criteria in applicable specifications (e.g., Piping Erection Specification, 2323-MS-100, etc.)
and procedures are consistent and complete, that criteria among disciplines are provided and that types of plant hardware requiring l clearance from piping are identified.
Review and revise as necessary the insulation specification relative to instructions for notching of insulation and relative to actual insulation thickness.
- Walk down all small-bore piping with I- insulation installed to verify necessary clearances after all pipes and components are in their final locations.
Retrain piping craft to the requirements of the construction procedure with regard to
' -O. notifying Engineering when clearance is not adequate.
Revise the QC inspection procedure to require verification of final piping clearances subsequent to' insulation installation.
Documentation Review No documentation review was performed for this construction work category.
Piping Bend Fabrication Reinspection For 99.7 percent of the approximately 630 inspection points showed the hardware condition was found to be in accordance with design requirements. For the remaining 0.3 percent of the inspection points the deviations were insignificant. There were no adverse or unclassified trends and no CDs. Thus, the three reinspection attributes had no findings.
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(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Documentation Keview For 86.1 percent of th's approximately-230 review points the' documentation was found to.be as required. For the remaining 13.9 percent of.the review points the deviations were notable. The notable deviations resulted in one generic deviation report'related to minimum wall thickness verification. There was one unclassified trend.
For the' two documentation review attributes, one had. no findings.. The attribute of minimum wall thickness verification had an unclassified trend'for lack of documentation. The unclassified trend with its root causes and recommended corrective action is as follows:
Lack of Documentation for Minimum Wall Thickness The deviations for lack of documentation-for the determination that pipe bend wall
' thicknesses after bending meet manufacturer's' minimum wall thickness were determined to constitute an unclassified trend. The deviations were notable, and present'
.information does not provide a sufficient basis for projection into the uninspected-population.
Review of the pipe bending qualification tests for the two bending machines showed that the wall thinning effect from bending ranged from 0.0 to 12.3 percent of the original pipe wall thickness and that this percentage differed significantly between the two benders for the same pipe diameter, schedule, and material type combinations.
Available documentation on minimum wall thickness verification during the bending process does not support a conclusion relative to the remainder of the population.
In addition, ultrasonic testing'(UT) of pipe bend wall thickness on a portion of the sample items indicated that manufacturer's minimum wall thickness was not met in all
'O cases.
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- Primary root.cause: less-than-adequate I construction procedure for the qualification of pipe benders and for the selection of pipe used for the fabrication of pipe bends.
Secondary root cause: less-than-adequate QC
- 1. inspection procedure that did not require QC to verify that construction personnel record the pipe wall thickness prior to bending Contributing cause: less-than-adequate engineering specification that did not provide clear direction to ensure that the mar.ufacturer's minimum wall thickness would.
be met after bending, if the requirement priar to bending was satisfied.
Lt than-adequate construction supervision to .nsure that construction personnel follow the construction procedure to record the pipe g-ss - wall thickness prior to bending
& Less-than-adequate construction training in that construction personnel did not follow the construction procedure requirement to record the pipe wall thickness prior to bending.
Less-than-adequate construction procedure for not specifying in sufficient detail where on the MRS form the pipe wall thickness prior to bending should be recorded.
- Recommended corrective action: Verify by UT that installed site-fabricated pipe bends on 2-inch and smaller piping meet the manufacturer's minimum wall thickness requirement.
Revine construction procedure CP-CPM-6.9E to add the requirement that manufacturer's minimum wall thickness be met after bending and to provide an appropriate space on the MRS form for recording the pipe wall thickness prior to bending.
Revise QC procedure QI-QAP-11.1-26 to require that wall thickness after future bending be verified by UT and recorded.
Retrain construction personnel to the
() requirements of the construction procedure,
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RESULTS REPORT ISAP VII.c (Cont'd) l l- 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) with regard to recording the wall thickness prior to bending.
Revise engineering specificat. ion MS-43B to include, in the pipe bending section, a reference to the applicable requirements for-wall thickness after fabrication.
1 Piping System Bolted Joints Reinspf.ction For 99.7 percent of the approximately 7,700 inspection points the hardware condition was found to be in accordance with design requirements. For an additional 0.2 percent of the inspection points, the deviations were insignificant. For the remaining 0.1 percent of the inspection points the deviations were notable.
There were no adverse or unclassified trends and no CDs. Thus, the eight reinspection attributes had no findings.
Documentation Review For 97.2 percent of the approximately 400 review points the documentation was found to be as required. For the remaining 2.8 percent of the review points the deviations were insignificant. The two documentation review attributes had no findings.
Pipe Welds and Material Reinspection For 99.7 percent of the approximately 3,000 inspection points the hardware condition was found to be in accordance with design requirements. For an additional 0.2 percent of the inspection points the deviations were insignificant. For the remaining 0.1 percent of inspection points, the deviations were notable. There was one special case and one unclassified trend. There were no adverse trends, and no CDs.
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ISAP VII.c l
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
For 10 reinspection attributes, nir.e had no finding.
The attribute of base metal defects had an unclassified trend for base material reduction. The attribute of radial weld shrinkage had a special case for excessive radial weld shrinkage. This unclassified trend and special case with their root causes and recommended corrective actions .are as follows:
Excessive Radial Weld Shrintage
- The deviation for radial weld shrinkage was determined to constitute a special case. The deviation itself was insignificant. However, j for welds in the CWC inspected prior to December 1982, there could potentially be scre instances of radial weld shrinkage, and it is difficult to determine if such
,s deviations could have an adverse effect on the piping. The deviation occurred at a weld
(\--} on a schedule 40 stainless steel butt-welded joint that had been replaced entirely once and repaired twice in the area of tne deviation. This type of deviation was primarily the result of excessive cycles of high heat input from rewelding and reworking of the metal, particularly on thin-wall i stainless steel pipe. Therefore, radial weld shrinkage can be expected most likely to occur during the replacement or repair of full penetration butt-welds of thin-wall stainless steel piping. .
Pricary root cause; less-than-adequate piping erection specification that did not provide quantitative acceptance criteria for radial weld shrinkage (criteria were subsequently provided in May 1982) or limit the number of times that extensive weld repairs would be made or otherwise address shrinkage that can occur due to replacement and repair of a weld.
Secondary root cause: less-than-adequate QC inspection procedure in that it lacked a
/T requirement to detect excessive radial weld b
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) shrinkage (requirement was subsequently provided in December 1982).
Contributing causc: Failure of engineering to require (or evaluate the need for) backfit of the radial weld shrinkage criteria added in December 1982 to welds made prior to then.
- Recommended corrective action: Reinspect butt-welds in schedule 80 or thinner f stainless steel piping that are replacement welds and/or have received extensive repairs, and correct as necessary. The reinspection is limited to welds inspected prior to December 1982.
Evaluate adding criteria to piping erection specification MS-100 and to site piping fabrication specification MS-43B to limit the nuteber of extensive weld repairs or replacements to avoid excessive radial weld (U-) shrinkage.
Review changes to the welding and material requirements in Spec. MS-100 and Spec. MS-43B to ensure consideration of backfit.
Add quantitative criteria for acceptable radial weld shrinkage to Spec. MS-43B.
Base Material Reduction
- The deviation for base material reduction was identified as an unclassified trend based on the occurrence of an excessive evergrind that violated the manufacturer's minimum wall thickness and was determined to be notable.
The overgrind occurred around a reinforced branch connection weld of a small-bore fitting to a 4-inch diameter pipe. The overgrind condition was approximately 3/64 of an inch in depth. Further evaluation determined that, given a set of conservative assumptions, a similar 3/64-inch overgrind could violate the ASME Section III Code minimum design wall thickness of other pipe lines.
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! (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
This deviation resulted from the craft attempting to make a smooth transition between the weld and base material, in accordance with the requirements of the construction procedure. Therefore, base material reduction could occur on other piping with weld joints that require a transition into the base metal (e.g.,
reinforced branch connections, stanchions, uneven thicknesses of materials).
- Primary root cause: less-than-adequate construction workmanship during transition grinding of piping welds.
- Recommended corrective action: Perform an evaluation to determine those pipe lines that are most likely to be adversely affected by 9 as much as a 3/64-inch-deep transition grind.
Perform a walkdown to determine whether or not base material reduction exists on those pipelines determined to be susceptible to an overgrind condition of this magnitude and that could violate the ASME Section III Code minimum design wall thickness.
Reemphasize to QC inspection, by retraining and/or modification to QC procedures QI-QAP-11.1-26 and CP-QAP-12.1, those pipe weld / joint configurations that are most susceptible to overgrinding.
Documentation Review For 99.8 percent of the approximately 2,500 review points the documentation was found to be as required.
For the remaining 0.2 percent of the review points time deviations were insignificant. The seven documentation review attributes had no findings.
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Tubing Welds and Material Reinspection For 99.8 percent of the approximately 1,500 inspection points the hardware condition was found to be in accordance with design requirements. For 0.1 percent of the inspection points the deviations were insignificant. For the remaining 0.1 percent of the inspection points the deviations were notable. There were no adverse or unclassified trends and no CDs.
Thus, the nine reinspection attributes had no findings.
Documentation Review i For 98.9 percent of the approximately 1,200 review points the documentation was found to be as required.
For 0.3 percent of the review point the deviations were O insignificant. For the remaining 0.8 percent of the review points, the deviations were notable. The seven documentation review attributes had no findings.
Field-Fabricated Tanks Reinspection For 95.9 percent of the approximately 10,000 inspection points the hardware conditions was found to be in accordance with design requirements. For 3.3 percent of the inspection points the deviations were insignificant. The remaining 0.8 percent of the inspection points were notable. There were no adverse or unclassified trends and no CDs. Thus, the 12 reinspection attributes had no findings.
Documentation Review For 99.6 percent of the approximately 6,200 review points the documentation was found to be as required.
For the remaining 0.4 percent of the review points the deviations were insignificant. The nine documentation review attributes had no findings.
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RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
.HVAC Ducts and Plenums Reinspection For 98.6 percent of the approximately 100,000 inspection points the hardware condition was found to be in accordance with the design requirements. For an j additional 1.3 percent of the inspection points the deviations were insignificant. For the remaining 0.1 percent of the inspection points, the deviations were notable. There were no adverse trends and no CDs.
Three of the seven reinspection attributes resulted in one unclassified trend with a recommendation for l corrective action related to hardware installed without I approved design details.
The one unclassified trend with recommendations for corrective action is as follows:
Hardware Installed without Approved Design Details
- Deviations were reported where ducts were connected to ducts without ap' roved connection details, diffusers were bolted to j air supply ducts without bolting details and I portions of plenums contained welding !
configurations that did not have defined l welding requirements. An evaluation of this '
situation concluded that construction proceeded with the fabrication and installation of components wichtn the duct l systems without having approved design i details. Since the required installation q
- 1 details were lacking, an analysis was not .
performed and no conclusions precluding a construction deficiency could be reached.
These deviations have therefore been determined to constitute an unclassified '
trend.
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YJ ISAP VII.c (Cont'd)-
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- Primary root cause: _Less-than-adequate l construction supervision allowed construction to proceed with the installation of hardware without approved installation details.
Another primary root cause is less-than-adequate procedures. The contractor's procedures lacked sufficient detail to control all necessary installations.
Secondary root cause: less-than-adequate QC inspection that accepted installed duct components without having approved installation details for these components.
- Recommended corrective action: A walkdown inepection of the safety-related HVAC duct-systems should be performed to verify that
.A fabrication and installation details exist
(,) for all installed work. For details that are missing, the as-built conditions should be analyzed to determine if they will prevent the items from performing their intended function. If the as-builts are acceptable then revise appropriate construction documents to include these as-built conditions. If any of the as-built conditions are not acceptable, then acceptable design details should be developed and included in the appropriate construction documents; all deviating items should be reworked to the approved designs It is also recommended that the HVAC contractor's construction and QC inspection personnel undergo additional training to ensure that work and inspection of completed work do'not proceed unless approved drawings are available or details of work are included in fabrication installation or inspection procedures.
Documentation Review
() For 88.5 percent of the approximately 1,200 review points the documentation was found to be as required.
For an additional 8.4 percent of the review points the
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vl ISAP VII.c 1
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l deviations were insignificant and for 3.1 percent the deviations were notable. The seven documentation review attributes had no findings.
HVAC Equipment Installation Reinspection For 96.6 percent of the approximately 50,500 inspection points the hardware condition was found to be in accor: dance with design requirements. For an additional
- 3. percent of the inspection points the deviations were insignificant. For the remaining 0.1 percent of l
the inspection points, the deviations were notable.
l There were no adverse or unclassified trends and no CDa, Thus, the nine reinspection attributes had no findings.
m k,) Documentation Review No documentation review was performed for this construction work category.
Mechanical Equipment Installation Reinspection Of the approximately 15,400 inspection points, approximately 360 involved concrete expansion anchors.
The reinspection results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions. For the approximately 15,040 remaining hardware inspection points, 94.2 percent were f ound to be in accordance with design requirements. For an additional 5.4 percent of these inspection points the deviations were insignificant. For the remaining 0.4 percent of these inspection points, the deviations were notable. There were no adverse'or unclassified trends. There was one CD and one special case.
For the 10 reinspection attributes evaluated, nine had no findings. The attribute of configuration had a CD
( for broken bolts. Additionally, the attribute of configuration had a special case for manway covers.
These deficiencies with their root causes and recommended corrective action are as follows:
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Broken Bolts
- The deviations for two broken hold-down bolts for a control room air conditioning unit compressor were determined to be a CD. The stress in the remaining bolts of the compressor would exceed AISC code allowables during seismic loadings. Modifications were made to this equipment in late 1984 to reduce excessive vibration problems, which had been apparent since its installation in 1979. The original hold-down bolts were reused during the modification. The modification, which stiffened the compressor support frame, may have only masked the vibration problem by transferring the vibrations to the floor and may have left excessive vibrational stresses in the hold-down bolts. The broken bolts O exhibit characteristics typical of fatigue failure.
Primary root cause: Less-than-adequate engineering evaluation in failure to anticipate the ef fect of excessive vibration j resulting in fatigue failure. Engineering l
should have specified replacement of the hold down bolts during the modification.
Possibly, the modification was not an adequate solution to the vibration problems.
- Recommended corrective action: . Replace all l
compressor hold down bolts for the control room air conditioning units with bolts of a size and material determined to be appropriate for existing conditions.
To determine the effect of vibration-induced fatigue on components, including electrical connections in on-skid control cabinets, evaluate all rotating equipment (including HVAC rotating equipment) that has experienced a vibration problem requiring engineered modification. Upon completion of the evaluation, any necessary corrections should
() be implemented.
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Manway Covers Approximately one-half of the manway cover bolts or nuts on a pressurizer and a safety injection system secumulator manway cover j
failed to meet the minimum tightness l criterion. The manway covers had been installed using the procedure specified by Westinghouse. Although the deviations were l not safety-significant, they were determined to be a special case because of the importance of the affected components and because the potential reduction in the design margin of these bolted connections was substantial.
Primary root cauce: less-than-adequate vendor procedures that failed to provide
()N
(_ sufficient detail to ensure uniform tightness of the manway cover bolts / nuts. A contributing cause was less-than-adequate vendor engineering evaluation because of the failure to specify the use of washers under the manway cover bolts / nuts.
Recommended corrective action: Revise procedures for installing manway covers and similar closures on vessels and accumulators supplied by the NSSS vendor, particularly those that are part of the primary system pressure boundary, to incorporate, as appropriate, the guidance and recommendations in Westinghouse Technical Bulletin 87-01.
Inspect the above-described manway covers and similar closures to ensure that the cover flange internal threads and the bolt or stud and nut threads are clean and undamaged, and then retighten using the revised procedures to the torque values specified in the appl 1 cable design documents.
Documentation Review.
) A documentation review was not performed f or this construction work category.
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.5 Structural - Details Concrete Placement Reinspection For 98.5 percent of the approximately 4,400 inspection points the hardware condition was found to be in accordance with design requirements. An additional 1.4 percent of the inspection points had insignificant deviations. For the remaining 0.1 percent of the inspection points, the deviations were notable. There were no adverse trends and no CDs; however, one condition was determined to be an unclassified trend requiring further investigation.
For four reinspection attribute's, three had no s findings . The attribute of surface conditions had an
( ,)
'~
unclassified trend for unsound concrete mortar. The unclassified trend with its root cause analysis and recommended corrective action is as follows:
Unsound Concrete Mortar
- TU Electric chipped two columns to determine if surface debr!.s identified during reinspection extended beyond the surface.
During this cetivity the existence of unsound concrete mortar was noted. The amount of foreign material was slight and scattered, and the deviations were determined to be insignificant. The discovered unsound concrete mortar is considered notable. The unsound mortar extended beyond the j reinforcing steel, and its full extent could not be determined by any non-destructive inspection method utilized by the VII.c program. This condition was determined to be an unclassified trend.
- Primary root cause: indeterminate, as enough I information was not available.
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- Recommended corrective action: Implement a l more comprehensive program to evaluate the l . quality of concrete mortar placement at construction joints. This program should include: (1) determination of root cause and any possible generic implications, (2) safety i
significance evaluations of two reported cases, (3) examination of additional selected ;
construction joints for quality of- mortar, and (4) determination of whether additional mortar inspections are required.
Documentation Review For 94.7 percent of the approximately 2,900 review points the documentation was found to be as required.
An additional 5.2 percent of the review points had insignificant deviations. lor the remaining 0.1 percent of the review points, the deviations were
- O notable. The nine documentation' review attributes had no findings.
, Structural Steel l
Reinspection Of the approximately 37,500 inspection points, approximately 1,900 involved concrete expansion anchors. The reinspection results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions.
For the approximately 35,600 remaining hardware inspection points, 97.7 percent were found to be in accordance with design requirements. For an additional 1.9 percent of these inspection points, the deviations were insignificant. For the remaining 0.4 percent of these inspection points, the deviations were notable. There were two unclassified trends, one adverse trend, four CDs, and one special case.
Additionally, an unclassified trend was identified for the attribute of concrete inserts in Appendix 33,
" Concrete Insert Thread Engagement."
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(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
For six reinspection attributes evaluated, two had no findings. .The attribute of member configuration had an unclassified trend for substitution of smaller. members.
The attribute of welding had an adverse trend for missing welds and an unclassified trend for undersized welds.- The attribute of bolting had CDs for lack of jam nuts and for gaps. Additionally, the attribute of bolting had a special case for substitution of smaller-diameter bolts. These discrepancies with'their root-causes and recommended corrective actions are as
.follows:
Substitution of Smaller Members
- The installation of a smaller member size for one structural steel item was determined to constitute an unclassified trend. The single deviation itself is classified as notable.
O- A similar reduction in capacity could have the potential for impairing the ability of highly-stressed members, were they to exist in the CWC, to perform-their intended function. It was' observed' chat similar undersized members were present on the same structure. The inspection documentation could not be located for this structure. The substitution of smaller members was determined to be isolated to that portion of the CWC for which documentation could not be located. This determination was made by ensuring that a minimum of 60 samples that had inspection documentation was reinspected.
This type of deviation did not occur in reinspected structures with inspection documentation. It could not be determined whether the deviation resulted from an incorrect shipment by the vendor or substitution by construction personnel.
- Primary root cause: less-than-adequate construction supervision, as construction personnel should have installed the correct
.- size of members even if the vendor supplied r smaller-size members. Construction procedures have subsequently been revised to
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ISAP VII.c
-(Cont'd) 5.0' IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS,(Cont'd) control the substitution of members.
Secondary root cause: less-than-adequate inspection procedure at the time of installation, as it did not require member size verification. (The present procedure is adequate.)
- Recommended corrective action: Refer to the finding on missing documentation.
Missing Welds
- The missing weld deviations were for the same weld detail on a reactor cavity platform installation and are considered to constitute an adverse trend. The deviations themselves are classified as notable; however, similar deviations on other structural steel members
.() have the potential for adversely.affecting their ability to perform their intended function. The missing welds were determined to be isolated to that portion of the CWC for which documentation could not be located.
This determination was made by ensuring that a minimum of 60 samples that had inspection documentation was reinspected. This type of deviation did not occur in the reinspected' structures with inspection documentation.
- Primary root cause: less-than-adequate construction supervision, as the weld was consistently omitted throughout the operation.
Secondary root cause: less-than-adequate inspection procedures at the time of installation, as they did not require documentation of inspections (present procedure is adequate).
- Recommended corrective action: Refer to the finding on missing documentation.
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ISAP VII.c-(Cont'd) ,
1 5.0 -IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Undersized Welds
- The weld configurations encompassing the undersized welds or welds with unacceptable profiles were determined to constitute an unclassified trend. The deviations-themselves were classified as either insignificant or notable. Analysis of the stress distribution and capacity reductions for these weld configurations with deviations indicated that there is a possibility that similar undersizing could adversely affect the ability of the weld to perform its intended function; however,) the data are nct broad enough to permit accurate conclusions to be drawn.
fr~3 - Primary root cause: less-than-adequate
_( ,) construction workmanship or supervision, as the undersized welds do not occur with any discernible pattern.
Secondary root cause: less-than-adequate inspection, as the procedure in effect required only a single sign-off for all the welds on a' structure.
Contributing cause: lack of inspection documentation, as no inspection documentation could be located for some of the items.
- Recommended corrective action: Develop and implement program to select and. inspect additional field welds for weld size and profile; compile capacity reduction.and stress distribution data for welds found to have undersize deviations, and' determine if additional inspections are required.
Modify method of documenting the weld inspections to accurately log the inspection of each weld detail. Improve training methods of welding inspection to ensure requirements of AWS welding.
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Substitution of Smaller Diameter Bolts The deviations were for the use of bolts with
! diameters 1/8 inch less than the diameter i I
specified on the design drawings. These deviations from design requirements were determined to be notable but did not constitute an adverse trend, as the bolted connection capacity is rarely the governing design parameter for structural steel i designs. However, this type of deviation is considered a special case requiring a root cause analysis and corrective action. The >
structural steel vendor's detail drawings specify the as-found smaller-diameter bolts.
- Primary root cause: The substitution by engineering was not detected, as the vendor e drawings indicating smaller bolts were approved, but the change was not annotated on the vendor drawings.
Contributing cause: Substitution was made by the structural steel fabricator without formally notifying the engineer.
Recommended corrective action: Review the vendor drawings for compliance of the bolt diameters with the design drawings.
Require that vendors obtain written approval from the engineer prior to any bolt diameter substitution. .
Lack of Jam Nuts - Uu1t 1 Rotating Platform
- The deviations for the lack of jam nuts or other acceptable locking devices for the Unit I rotating platform were determined to constitute a CD. This condition creates the potential for disengagement of an installed nut from its bolt and subsequent inability of the structural steel item to perform its intended function. The rotating platform was installed and inspected prior to the addition of the locking device requirement in the G structural steel specification and inspection procedures.
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N RESULTS REPORT (v I ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Primary root cause: lack of a documented review to backfit the hardware on installed structures to revised requirements, as there was no evidence of such a review to determine those areas needing backfit subsequent to the addition of the locking device requirement.
Recommended corrective action: Develop and implement a program that identifies bolted connections that require locking devices; define the inspection requirements for such connections, and inspect and correct the identified connections.
Establish program to review all structural steel design change documents to determine those that have not been inspected or constructed, and take appropriate action for those so identified.
(
e ~)
'~
Develop and implement a procedure to assure that as-required design changes related to structural steel are implemented for future work.
Any additional instructions from engineering should be clearly noted on the design drawings.
Lack of Jam Nuts - Unit 1 Pressurizer Platform
- The deviations for lack of jam nuts or other acceptable locking devices for the Unit 1 pressurizer platform were determined to be notable. These deviations were not given a separate trend classification since a CD in this area had already been identified.
However, a root cause and generic implications analysis was performed, and corrective action recommendations were made.
Primary root cause: lack of a procedure for the review of design changes to determine if additional work is required to complete implementation, as there is no inspection documentation indicating that the design
[J k-T change specifying locking devices was implemented.
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ISAP VII.c (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- Recommended corrective action: Develop and-implement a program that identifies bolted connections that require locking devices;-
define the inspection requirements for such connections, and inspect and correct the identified connections.
I Establish program to review all structural steel design change documents to determine those installations that have not been l inspected ~or constructed, and take appropriate action for those so identified.
Develop and implement a procedure to assure.
~
l l that as-required design changes related.co l structural steel are implemented for future work.
Gaps Between Components Transmitting Seismic Loads f\ The deviations for gaps between bolt nuts and
() -
structural steel angles designed to transfer seismic loads between a concrete wall and a concrete beam were determined to be a CD.
The gaps resulted from inadequate spoiling of the threads, thereby allowing the hand-tight nuts to back off, resulting in a gap. The seismic wall angles rely on the bolts to transfer tension loads, and the gap prevents the wall angles from performing their intended design function.
- Primary root cause: less-than-edequate instructions from engineering to assure adequate spoiling of the threads, since for this connection configuration greater control of the locking device was required than normal.
- Recommended corrective action: Require engineering to identify those connections that require additional instructions for the installation of the locking device, and note the instructions on the design drawing, g Clearly define the inspection requirements;
( reinspect these connections, and rework as required.
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ISAP VII.c (Cont'd) 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Gaps Between Connected Plies
- The deviations for a gap between the connected plies of the support bracket and the Unit I rotating platform and deviations for gaps between the baseplate and embedded plates for the Unit 1 sump structure were determined to be enveloped by two CDs. These gaps, which resulted from the lack of adequate shimming, prevented the transfer of l load by bearing, as the load transfer mechanism relied on contact of the connecting plies.
Primary root cause: less-than-adequate construction procedures in that the procedure did not address the complete closure of gaps s by shimming, as required by the structural q,,) steel specification.
Secondary root cause: less-than-adequate inspection procedures in that the procedures did not address the complete closure of gaps by shimming, ar required by the structural steel specification.
Recommended corrective action: Develop and implement a program to assure that bolted connections that transmit design force via bearing of connected plies are correctly installed, by identifying such bolted connections, detailing their inspection requirements, and inspecting and correcting such connections.
Review and revise construction and inspection procedures to delineate the specification requirements.
Documentation Review Of the approximately 540 review points, approximately 20 involved concrete expansion anchors. The documentation review results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions. For the
[)
' approximately 520 remaining documentation review )
points, 89.6 percent were found to be as required. For !
l
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.l RESULTS REPORT (s .
ISAP VII.c (Cont'd) 5.0- IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l an additional 7.9 percent of these review points, the deviations were insignificant. For the remaining 2.5 l ' percent of these review points, the deviationa.were notable. There was one unclassified trend covering all attributes. Thus,~all five documentation review attributes evaluated had a finding for missing documentation.
The unclassified trend with its root cause analysis and recommended corrective action is as follows:
Missing Documentation l
- The magnitude of the inspection documentation for the structural steel population that-cannot be located or does not exist was considered to constitute an unclassified f-'g trend. No inspection documentation could be (j located for 31' sample items.:which comprise seven installed structures. However, additional sample items were selected to provide at least 60 items with documentation to isolate some of the identified reinspection problems to the undocumented portion of the construction work category.
Primary root cause: No conclusive root cause can be determined.
Contributing cause: Inadequate specification of inspection requirements in early site procedures, lack of correlation.between construction documentation system (construction operation traveler number or construction-assigned equipment number) and the design drawings, and potential inadvertent classification of some areas as seismic Category I.
Recommended corrective action: A program should be established to review structural steel documentation and to identify all items for which inspection documentation cannot be located.
()~ Any item for which inspection documentation cannot be located should be inspected and the
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-(~'} RESULTS REPORT U
ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) inspection documented.
A master list of inspection documentation, cross-referenced to the design drawings, should be prepared.
Make an engineering evaluation to confirm the intended seismic category.
Fill and Backfill Placement Documentation Review For 89.1 percent of approximately 4,500 review points the documentation was found to be as required. An additional 10.3 percent of the review points had insignificant deviations. For the remaining 0.6 percent of review points, the deviations were notable.
The six documentation review attributes had no
-'x findings.
() Cement Grout Documentation Review For 90.3 percent of the approximately 960 review points the documentation was found to be as required. For the remaining 9.7 percent of the review points the documentation review deviations were 1 significant.
Supplemental information obtained during the evaluation of ,Sese deviations provided evidence that cement grout was placed in an acceptable manner. The eight documentation review attributes had no findings.
Epoxy Grout Documentation Review For 60.6 percent of the approximately 720 review points the documentation was found to be as required. For the remaining 39.4 percent of the review points the documentation review deviaticas were insignificant.
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'"y RESULTS REPORT l
[V '
ISAP VII.c (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Supplemental information obtained during the evaluation of these deviations provided evidence that epoxy grout was placed in an acceptable manner. The eight documentation review attributes had no findings.
Containment Liners and Stainless Steel Tank Liners Reinspection For 92.2 percent of the approximately 870 inspection points the hardware condition was found to be in accordance with design requirements. An additional 4.5 percent of the inspection points had. insignificant deviations. For the remaining 3.3 percent of the inspection points, the deviations were notable. There was one unclassified trend and no adversa trends or CDs.
fw 4 For four reinspection attributes, three had no findings. The attribute of stainless steel liner weld seam surface had an unclassified trend for the presence of rust. The unclassified trend with its root cause analysis and recommended corrective action is as follows:
Presence of Rust
- The deviations for presence of iron contamination, resulting in active iron corrosion in the weld seams and base naterial of a stainless steel tank liners were determined to constitute an unclassified trend. The deviations themselves were classified as notable. However, the liner. i i
could continue to corrode if the contamination remained, but there is insufficient data to determine if the corrosion over time would result in leakage.
Primary root cause: lack of control of iron-containing or iron-contaminated grinding wheels used by the subcontractor during
- erection.
Contributing cause: lack of requirements for
\~ -
final cleaning in the engineering i I
Revision: 1 Pags 102 of 186 7-'s. RESULTS REPORT U, ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) specification and lack of appropriate subcontractor QC inspection during the grinding and cleaning processes.
Recommended corrective action: Remove rust in stainless steel tank liners where noted in subsequent tank inspections.
Ensure that a program exists to inspect all stainless steel tanks for Units 1 and 2 periodically, and remove rust when found.
For all future work, including that performed by subcontractors, ensure that a program exists for the control of grinding and cleaning tools in stainless steel applications.
Review specifications, procedures, QC program, and training for such work to
-- determine if additional provisions to prevent
( iron embedment are required.
Documentation Review For 99.4 percent of t.he approximately 1,400 review points the documentation was found to be as required.
For the remaining 0.6 percent of the review points the documentation review deviations were insignificant.
The five documentation review attributes had no findings.
Fuel Pool Liner Reinspection For 96 percent of the approximately 250 inspection points the hardware condition was found to be in accordance with design requirements. For an additional 3.6 percent of the inspection points the deviations were insignificant. For the remaining 0.4 percent of the inspection points, the deviations were notable.
There were no adverse or unclassified trends and no CDs. Thus, the two reinspection attributes had no findings.
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}Ij( RESULTS REPORT ISAP VII.c (Cont'd)'
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd).
-Documentation Review For 96.7 percent of the approximately 1,000 review
. points the documentation was found to.be as required.
An additional 2.6 percent of the review points had-insignificant deviations. For.the remaining 0.7 percent of the review points, the deviations were notable. The five documentation review attributes had no findings.
5.2.6 Supports - Details Large-Bore Pipe Supports - Rigid Reinspection Of the approximately 25,900 inspection points, f'
approximately 4,400 involved concrete expansion.
i anchors. The reinspection results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions.
For the approximately 21,500 remaining hardware-inspection points, 98.4 percent were found to be in accordance with design requirements. For an additional 1 percent of these inspection points the deviations were insignificant. For the remaining 0.6 percent of these inspection points, the deviations were notable.
There were six construction deficiencies and one adverse trend. Additionally an unclassified trend was identified for the attribute of concrete inserts in Appendix 33, " Concrete Insert Thread Engagemenc."
For the seven reinspection attributes evaluated, three had no findings. The attribute of configuration had a CD for incorrect components and an adverse trend for zero gaps. The attribute of bolting'had a CD for inappropriate locking devices. The attribute of vendor-supplied components had CDs for incorrect pipe clamp spacers, loose jam nuts and loose hardware fasteners. These discrepancies with their root causes and recommended corrective actions are as follows:
Incorrect Components A deviation for installation of undersized
! vendor-supplied bolts in a pipe clamp assembly (thus creating the potential for
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. jq RESULTS REPORT l ISAP VII.c l (Cont'd) f 1'
l 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l malfunction of the support) was determined to be a CD. This installation required the use of oversized washers to compensate for the studs' and nuts' being undersized.
Primary root cause: less-than-adequate procedure for QC inspection that stated I
applicable requirements generally.to ensure
- l. effective implementation. As a result, the pipe clamp assembly was issued for installation with the wrong bolting nacerial.
Secondary root cause: less-than-adequate-supervision of construction personnel, allowing issuance and installation of unauthorized oversize washers.
Contributing cause: Vendor supplied incorrect material; vendor documentation confirmed that the wrong bolting material was supplied.
Recommended corrective action: Perform walkdown of pipe supports (ASME Code) I containing vendor-supplied components, and subject nonconforming parts to appropriate i engineering disposition and rework as necessary.
Review training and supervision procedures to ensure that construction persor.nel are j instructed not to make unauthorized J substitutions relative to hardware, especially vendor-supplied hardware.
Quality control inspectors of vendor-supplied hardware in the issuance and final acceptance )
should be given additional training to ensure fulfillment of inspection objectives.
Zero Gaps The deviations relative to zero gap between pipe and the supporting members are considered to constitute an adverse trend.
The deviations were determined to be insignificant. However, for other piping l systems, loads and stresses on the piping I l
l
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/-g RESULTS REPORT U ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) could exceed allowables if.zero gap exists and the. system is subject to. temperature and pressure increases that cause radial expansion and system displacement.
Primary root cause: less-than-adequate training and supervision of construction personnel to. comply with installation requirements for maintenance of gap.between.
pipe and pipe support as clearly specified in the engineering specification and the construction procedure.
Secondary root cause: less-than-adequate training of QC personnel for the inspection requirements of QI-QAP-ll.1-28.~
Recommended corrective action: Inspect all pipe supports (ASME Code) for proper gap, f-- taking into account special cases of
-(j .
deadweight supports and piping welds close to a support. Develop criteria for determining adequate clearance between a piping weld and a support. Additionally, develop criteria to address supports that provide deadweight support.
To address activities that are implicated but not covered by specific recommendations, extend the inspections of ASME Class 1, 2, and 3 piping to include safety-significant attributes with the exception of welding.
4 Inappropriate Locking Devices
- The deviations for inappropriate or missing locking devices for threaded fasteners on vendor-supplied components were combined into one common DR. The inappropriate locking devices create the potential for loosening of the threaded fastener, which constitutes a deviation from ASME Code requirements and was determined to be a CD.
- Primary root cause: less-than-adequate
., engineering specifications and design drawings that failed to indicate types of
Revision: 1 Page 106 of 186 i
RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) bolting materials that required locking devices aad failed to specify consistently the materials for construction on design drawings.
A contributing cause was determined to be the l conclusion, since withdrawn, that paint was a i suitable locking device for Unit 1 and areas l common to both units. Because paint was considered effective as a locking device, complete corrective action was not taken.
Recommended corrective action: Install suitable locking devices on all vendor-supplied components (ASME Code) that do not have high-strength bolting.
Install locking devices on high-strength bolting that is not torqued to an acceptable e preload.
Review procedures and specification to ensure that appropriate code requirements for component supports are incorporated.
Supporting documentation should also be updated to ensure that accurate ~
identificat1on of material type can be made for any high-strength bolting that will not require locking devices.
Incorrect Pipe Clamp Spacers
- A deviation for an incorrect pipe clamp spacer used in the installation.of vendor-supplied components was determined to be a CD. This condition, which increased the span between the pipe clamp ears, resulted in greater-tban-allowable bending stresses on the load pin. Installation of incorrectly-sized pipe clamp spacers resulted from construction personnel's installing spacers other than those supplied by the vendor and issued for construction.
Primary root cause: less-than-adequate e training and supervision of construction personnel in the installation of the correct
i Rov 1sion: 1 i Pcgs 107 of 186
]
l
[~ RESULTS REPORT
'w-]'
ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) pipe clamp spacers. Construction personnel did not recognize the importance of using the proper spacer.
Secondary root cause: less-than-adequate QC procedure for the inspection of pipe clamp spacers. The procedure did not provide specific instruction for the inspection of a pipe clamp for proper spacer installation.
Recommended corrective action: Walk down all pipe supports (ASME Code) having pipa clamps, and replace nonconforming spacers, or confirm that they fall within the limits of a bounding calculation.
Review training and supervision procedures to ensure that instructions given to construction and QC personnel are consistent rN with engineering requirements.
(
Loose Jam Nuts
- The two deviations for eye rod j am nuts used on sway strut assemblies that were not secured were determined to constitute a CD.
The loose j am nuts could result in the loosening of the threaded connection parts !
and create the potential for malfunction of the sway strut assemblies.
Primary root cause: less-than-adequate procedural interface between the startup and construction groups as to which procedure and acceptance criteria (no acceptance criteria mLaced in startup procedures) were in effect at the time of pipe support adjustment.
More specifically, the primary root cause has been determined to include two elements: (1) the lack of documentation (work authorizations) of requests for or instructions to construction personnel regarding the performance of work activities on pipe supports and (2) the performance of
,3_
work by craft without applicable procedures' being involved.
(%-)
E Revision: .1 Pags 108 of 186 RESULTS REPORT
("~ .
~ ' ' ISAP VII.c (Cont'd)
, 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Recommended corrective action: Verify that jam nuts on all' vendor-supplied components (sway struts, snubbers, and spring cans) are verified as snug tight.
Establish detailed procedurcs and instructions to provide a clear line of work-responsibility between startup and construction groups with appropriate training.
Loose Hardware Fasteners
- The deviation for a loose pipe clamp assembly in a sway strut was determined to be a CD.
The loose pipe clamp assembly may not allow the strut to transmit any loads as is is free to rotate.
-h:
v
- Primary root cause: less-than-adequate procedural interface between the startup and construction groups as to which procedure and acceptance criteria (no acceptance criteria stated in the startup procedures) were in effect at the time of pipe support l adjustment.-
More specifically, the primary root cause has been determined to include two elements: (1) the lack of documentation (work authorizations) of requests for or instructions to construction personnel regarding the performance of work activities on pipe supports and (2) the performance of work by craft without applicable procedures' being invoked.
- Recommended corrective action: Walk down all pipe supports (ASME Code) having pipe clamps to establish security of the attachment to the pipe.
Establish detailed procedures and instructions to provide a clear line of work responsibility between startup and construction groups with appropriate training.
(
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- RESULTS REPORT U,s ISAP VII.c l (Cont'd) l l
l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Documentation beview Of the approximately 8,500 review points, approximately 1,500 involved concrete expansion anchors. The documentatica review results and deviations related to concrets expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions. For the approximately 7,000 remaining documentation review points, 99.8 percent were found to be as required. For j the remaining 0.2 percent of these review points the deviations were insignificant. The four documentation review att.ributes evaluated had no findings.
Large-Bore Pipe Supports - Non-Rigid Reinspection
,,_ Of the approximately 36,900 inspection points, approximately 4,900 involved concrete expansion
(- ) anchors. The reinspection results and deviations related to concrete expansion anchors were referred to the 1 SAP VII.b.4 report for evaluation and conclusions.
For the approximately 32,000 remaining hardware inspection points, 98.6 percent were found to be in accordance with design requirements. For an additional 0.9 percent of these inspection points the deviations were insignificant. For the remaining 0.5 percent of these inspc. tion pointo, the deviations were notable.
There were six construction deficiencies. There were no adverse trends. Additionally an unclassified trend was identified for the attribute of concrete inserts in Appendix 33, " Concrete Insert Thread Engagement".
For the seven reinspection attributes evaluated, three had no findings. The attribute of configuration had a CD for incorrectly adjusted components. The attribute of bolting had two CDs for inappropriate locking devices. The attribute of vendor-supplied components had CDs for incorrect angularity and for cotter keys.
These discrepancies with their root causes and recommended corrective actions are as follows:
i
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r~N RESULTS REPORT
(
v) ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Incorrectly Adjusted Components A deviation for an incorrectly-adjusted spring can assembly turnbuckle was determined to be a CD. The incorrect adjustment resulted in the assembly's having one side Icose. In this condition the unloaded spring will be ineffective. Over a long period of time, the preload on the U-bolt may decrease and allow the support assembly to rotate under load. This would render the entire support assembly partially or completely ineffective. Construction personnel ncerectly installed and secured the spring can assembly with verification by QC prior to turnover to TU Electric startup. The deviation resulted from adjustments directed s
gg by startup during system test and set, 4
'%) -
Primary root cause: less-than-adequate procedural interface between startup and construction groups as to which procedure and acceptance criteria (no acceptance criteria were stated in startup procedures) were in effect at the time of pipe support adjustments.
More specifically, the primary root cause has been determined to include two elements: (1) the lack of documentation (work authorizations) of requests for or i instructions to construction personnel )
regarding the performance of work activities !
on pipe supports and (2) the performance of work by construction personnel without ]
i applicable procedures' being invoked.
Recommended corrective action: Reverify vendor-supplied component adjustment during the startup and preoperational phases of the plant. )
l Establish detailed procedures and I instructions to provide a clear line of work responsibility between startup and
[s construction groups for pipe support
\- component adjustment. j Ensure that an adequate QC verification of j startup work activity exists.
l l
Revision: 1 Page 111 of 186
,_ RESULTS REPORT U) ISAP VII.c (Cont'd) 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Inappropriate Locking Devices
- The deviations for inappropriate or missing locking devices for threaded fasteners were combined into one common DR. The inappropriate locking devices were determined to be a CD. Inappropriate or missing locking devices create the potential for loosening or disengagement of the threaded fastener, with resulting redistribution of loads and possible overstress conditions.
Primary root cause: less-than-adequate information in engineering specifications and on design drawings to indicate types of bolting materials that required locking devices and failure of design drawings to specify the materials for construction
[/
k--
\ consistently.
A contributing cause was determined to be the analytical conclusion, later withdrawn, that paint was a suitable locking device for Unit 1 and areas common to both units. As long as paint was considered effective as a locking device, a complete corrective action was prevented.
Recommended corrective action: Install suitable locking devices on all vendor-supplied components (ASME Code) that do not have high-strength bolting.
Install locking devices on high-strength bolting that is not torqued to an acceptable preload.
Review procedures and specifications to ensure that appropriate code requirements for
- component supports are incorporated and that the requirements have been met and are verified by documented QC inspections.
Supporting documentation should also be updated to ensure that accurate identification of material type can be made for high-strength bolting that will not rT require locking devices.
b
Revision: 1 Page 112 of 186 RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
I Incorrect Angularity 1
- Two deviations for excessive angular offset of snubber eye rods were determined to be CDs. It was determined that pipe thermal movements in the vertical direction would cause binding of the eye rod and could result in loss of the snubbers' ability to stroke under operating conditions.
Primary root cause: less-than-adequate operations traveler preparation procedure.
The operations group replaced damaged snubbers following a water hammer event; however, the procedure followed by operations did nor include all engineering requirements that are normally part of the checklist in the traveler and that are relative to lh replacement or modification of component supports. Operations selected those items they thought were necessary for the work to be performed. The operations program is such that QC is involved in all inspection aspects.
Recommended corrective action: Walk down all vendor-supplied components to ensure that proper angularity exists.
The scope of the walkdown program should be extended to address generic implications within the three populations by. verification that safety-related design requirements with the potential to be affected are met.
Review operational procedures for maintenance of component supports to ensure that all installation specification requirements are included as specific items on maintenance checklists.
Broken Cotter Keys
- One deviation identifying a broken cotter key in a vendor-supplied component that prevents disengagement of snubber pipe clamp G load pin was determined to be a CD. The current condition of the cotter key may allow
l l
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.f ' RESULTS REPORT 1 $})
l ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i, it to fall out, with the potential for the snubber assembly to become disengaged. .This.
-could result in the inability of the support to perform its intended function.
Primary root cause: less-than-adequate construction workmanship related to construction and startup procedures that allowed additional work involving removal and/or replacement of cotter keys to be performed on QC accepted component supports without further reinspection. The procedures also lacked control over the work activity by allowing anyone to remove or replace these items on the component supports.
Recommended corrective action: Walk down supports (ASME Code) containing-
.,O -
vendor-supplied components; replace missing or broken cotter keys, and correct potentially loose bolting.
Revise construction and startup procedures to control the work properly and to include QC verification of work or rework performed after initial QC acceptance.
Documentation Review Of the approximately 11,000 review points,.
approximately 1,600 involved concrete expansion anchors. The documentation review results and !
deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions. For the approximately 9,400 remaining documentation review points, 99.4 percent were found to be as required. For the remaining 0.6 percent of these review points the deviations were insignificant. The l four documentation review attributes evaluated had no f findings. I l
4
_ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ D
Revision: 1 Page 114 of 186
/~ ~'- RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Small-Bore Pipe Supports 1
1 Reinspection '
Of the approximately 14,100 inspection points, approximately 2,600 involved concrete expansion anchors. The reinspection results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions.
For the approximately 11,500 remaining hardware inspection points, 99 percent were found to be in accordance with design requirements. For an additional 0.6 percent of these inspection points the deviations were insignificant. For the remaining 0.4 percent of these inspection points, the deviations were notable.
There were two construction deficiencies and one adverse trend. Additionally an unclassified trend was
(~' identified for the attribute of concrete inserts in i Appendix 33, " Concrete Insert Thread Engagement".
For the seven reinspection attributes evaluated, three had no findings. The attribute of configuration had an adverse trend for zero gaps. The attribute of bolting had a CD for inappropriate locking devices. The attribute of vendor-supplisd components had a CD for unsecured fasteners. These discrepancies with their root causes and recommended corrective actions are as follows:
i Zero Gaps
- The deviations relative to zero gap between pipe and the supporting members are considered to constitute an adverse trend.
The deviations were determined to be insignificant. However, for other piping systems, loads and stresses on the piping could exceed allowables if zero gap exists and the system is subject to temperature and pressure increases which cause radial expansion and system displacement.
i rg i
_____._O
Revision: 1 Page 115 of 186 RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- Primary root cause: less-than-adequate training and supervision of construction personnel to comply with installation requirements for maintenance of gap betwean pipe and pipe support as clearly specified in the engineering specification and construction procedure.
Secondary root cause: less-than-adequate training of QC personnel for the inspection requirements of QI-QAP-11.1-28.
- Recommended corrective action: Inspect all pipe supports (ASME Code) for proper gap taking into account special cases of deadweight supports and piping welds close to a support. Develop criteria for determining adequate clearance between a piping weld and ,
a support. Additionally, develop criteria to O address supports that provide deadweight support. i
- To address activities that are implicated but not covered by specific recommendations, extend the inspections of ASME Code Class 1, 2, and 3 piping to include safety-significant attributes with the exception of welding.
Inappropriate Locking Devices
- The deviations for inappropriate or missing locking devices for threaded fasteners on vendor-supplied components were combined into one common DR. The inappropriate locking devices create the potential for loosening or disengagement of the threaded fastener, resulting in a deviation from ASME Code requirements; this was determined to be a CD.
Primary root cause: less-than-adequate engineering specifications and design drawings that failed to indicate types of bolting materials that required locking devices and failed to specify consistently on design drawings the materials for
-O construction.
A contributing cause was determined to be the ,
l
Revision: 1 Pags 116 of 186 7 -w ,
RESULTS REPORT N] ISAP VII.c (Cont'd) 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) analytical conclusion, later withdrawn, that paint was a suitable locking device for Unit 1 and areas common to both units. While paint was considered effective as a locking device, complete corrective action was prevented.
Recommended corrective action: Install suitable locking devices on all vendor-supplied components (ASME Code) that do not have high-strength bolting.
Install locking devices on high-strength bolting that is not torqued to an acceptable preload.
Review procedures and specifications to ensure that appropriate code requirements for component supports are incorporated.
Supporting documentation should also be
[-s)
N#
updated to ensure that accurate identification of material type can be made for any high-strength bolting that will not require a locking device.
Unsecured Tasteners A deviation for a fastener on a turnbuckle assembly that was not se. cure we.s determined to be a CD. The carnouckle asssmbly was in a spring hanger that supported deadweight loads. The unsecured turnbuckle fastener could result in the spring hanger's loss of ability to support deadweight load.
- Primary root cause: less-than-adequate procedural interface between the startup and construction groups as to which procedure and acceptance criteria (no acceptance criteria stated in startup procedures) were in effect at the time of pipe support adjustment.
O(s
Revision: 1 Pags 117 of 186
^ RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
More specifically the primary root cause has been determined to include two elements:
(1) the lack of documentation (work authorizations) cf request for or instructions to construction personnel regarding the performance of work activitias on pipe supports and (2) .the performance of work by construction personnel without-invoking applicable procedures.
- Recommended corrective action: Verify that the fasteners have been secured for all _
vendor-supplied components (sway struts, snubbers and spring cans) during plant i startup and reoperation, using a complete and detailed procedure a9d check 11sc provided-and verified by QC.
Establish detailed procedures and in9tructions tc provide a clear line of work responsibility between startup and construction groups with appropriate training. Additionally, a walkdown of pipe supports having pipe clamps should be performed to establish that pipe supports are securely attached to pipes.
Documentation Revleu .
Of the approximately 4,600 review points, approximately 860 involved concrete expansion anchors. The documentation review results and deviations related to concrete expansion anchors were referred to the ISAP VII b.4 report fer evaluation and conclusions. For the approximately 3,740 remaining documentation review points, 99.8 percent were found to be as required. For the remaining 0.2 percent of these review points the deviations were insignificant. The four documentation review attributes evaluated had no findings.
.t
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, RESULTS REPORT (Vn! ISAT VII.c (Cont'd) l-I 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Instrument Tube Supports Reinspection Of the approximately 45,000 inspection points, approximately 20,500 involved concrete expansion anchors. The reinspection results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions.
For the approximately 24,500 remaining hardware inspection points 96.4 percent were found to be in accordance with design requirements. For an additional l' 1.0 percent of these inspection points the deviations were insignificant. For the remaining 2.6 percent of these inspection points, the deviations were notable.
There were two construction deficiencies and two unclassified trends. There were no adverse trends.
p For the eight reinspection attributes evaluated, six
(} '
had no findings. The attribute of tube restraint had an unclassified trend for incorrect tube clamps. The Tetribute of bolting had CDs for an inadequately torqued and cdsaligned spring nut and for a loose bolt, as well as an unclassified trend for insufficient thretd engagement. These discrepancies with their root cav.ses and recommended corrective actions are as fo11cus:
Substitution of Clamp Type
- For the attribute of tube restreint the .
deviations for clamp types not in accordance with the. design drawings were determined to constitute an unclassified trend. Seven deviations were determined to be notable.
However, the effects of clamp substitutions q in the uninspected portions of the population are indeterminate.
Primary root cause: indeterminate, as sufficient information was not available.
1
- Recommended corrective action: Reinspect all I instrument lines to ensure that spacing and f restraint type are per procedure. ]
i
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ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Inadequately Torqued and Misaligned Unistrut Spring Nut 1
- The. deviation for a misa11gned and I incompletely engaged Unistrut spring nut coupled with insufficient torquing for the connection was determined to be a CD.
Misalignment and incomplete engagement of the j spring nut serrated grooves reduced the 1 overall capacity of the connection against sliding and, coupled with insufficient torquing, rendered the support assembly inadequate against the imposed load.
- Primary root cause: a combination of inadequate engineering instructions and less-than-adequste training and supervision of construction personnel because construction was not provided torque
( installation values or trained in the importance of correctly seating spring nuts.
Secondary root cause: incomplete review of engineering documents by Quality Control and less-than-adequate training and supervision of QC inspectors.
- Recommended corrective action: Implement a program to assure' proper alignment and torquing of all installed Unistrut spring nuts and bolts.
Evaluate the adequacy of the current procedures for the field implementation of fastening and inspection of Unistrut bolting.
Establish a training program for both construction and QC personnel in the installation and inspection of bolting, particularly with regard to spring nuts.
Loose Bolt
- The deviation for a loose bolt, not involving a Unistrue spring nut, was determined to be a CD. The bolted connection was loose enough to allow unintended sliding of the tube.
Rsvision: 1 Page 120 of 186
(/-~), RESULTS REPORT s_-
1 SAP VII.c j (Cont'd)'
5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- Primary root cause: less-than-adequate supervision of construction personnel.
Secondary root r:ause: less-than-adequate supervision of QC inspectors, as the QC inspection procedures were clear regarding inspection requirements.
Contributing cause: While the procedure was determined not to be the primary rout cause, it was determined to be a contributing cause in that the specification description
" securely fastened" is too ambiguous to ensure that design requirements are fully satisfied.
Recommended corrective action: Reinspect all instrument tube supports to ensure that connections utilizing non-Unistrut bolting
(}
\s/
are fastened to specified requirements.
Evaluate the adequacy of current procedures for the field installation, fastening, and inspection of non-Unistrut bolting.
Estab11eh a training program for both construction and inspection personnel in the fastening and inspection of non-Unistrut bolting.
Insufficient Thread ?ngagement Yor the attribute of bolting th,e deviations for insufficient thread engagenent for spring nut type bolting were determined to constitute an unclassified trend.
Primary root cause: less-than-adequate construction supervision.
Secondary root cause: less-than-adequate QC supe rvision.
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i 1
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[~'hl RESULTS REPORT ISAP VII.c (Cont'd) 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Recommended corrective action: Reinspect all instrument tube supports for correct thread engagement in Unistrut spring nut type bolting.
Documentation Review Of the approximately 500 review points, approximately 170 involved concrete expansion anchors. The documentation review results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions. For the approximately 330 remaining documentation review points, 38.8 percent were found to be as required. For an additional 44.2 percent of these review points the deviations were insignificant. For the remaining 17.0 percent of these review points, the deviations were
/"' notable. The three documentation review attributes
's_,T ) evaluated had no findings.
P,1pe Whip Restraints Retrospection Of the approximately 75,000 inspection points, approximately 1,300 involved concrete expansion anchors. The reinspection results and deviatione related to concrete expansion anchors were referred to the ISAP VII.b.4 report f or evaluation and conclusions.
For the approximately 73,700 remaining hardware inspectica points, 97.8 pert.ent were found to be in accordance with design requirements. For an additional 1.1 percent of these inspection points the deviations were insignificant. For the remaining 1.1 percent of these inspection points, the deviations were notable.
There were two construction deficiencies, four adverse trends, and one unclassified trend. Additionally an unclassified trend was identified for the attribute of I
concrete inserts in Appendix 33, " Concrete Insert Thread Engagement."
For the nine reinspection attributes, four had no findings. The attribute of configuration had an
!f-s) ~'
adverse trend f'>r missing components and CDs for an out-of-level beam and for missing shim welds. The attribute of cold gap between pipe and restraint had an i
_ _ _ _ . _ _ _ _ __________________9
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() RESULTS REPORT ISAP VII.c
~(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) unclassified trend for incorrect gaps. The attribute of structural bolting had adverse trends for missing-and incorrectly-installed locking devices and for lack of joint tightness. The attribute of welds made with AWS procedures had an adverse trend for missing AWS welds. These discrepancies with their root causes and recommended corrective actions are as follows:
Incorrect Configuration For missing components the deviations for missing stiffeners, missing cover plates, and missing enclosure plates on four sample items were determined to constitute an adverse trend. All the missing components were required to be field welded. The deviations themselves were classified as notable.
('"'
\
However, similar missing components on other pipe whip restraints or support structures could adversely affect their ability to perforn their intended function,
- For levelness and plumbness the deviaticn for an out-of-level beam that was part of a support structure was determined to be a CD.
T1.is beam was not aligned with the attached gusset plate as required by the drawing. The i deviation resulted in an over stress condition for the attached gust.at plate.
l
- Formissingahimveldsadeviationfor'a missing shim weld on shims used in a bearing type joint was determined to be a CD. The missing shim weld would cause substantial bolt bending and subsequent bolt overstressing under design loads.
Primary root cause: lack of specific instructions for the erection of pipe whip restraints. The construction practice of using travelers for the erection of pipe whip restraints was not adequate as implemented because there was no clear requirement on the
( traveler to ensure that all the components
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ISAP VII.c (Cont'd) 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) had been installed and. arranged as required by the design drawings.
Secondary root cause: lack;of corresponding inspection instructions for pipe whip restraints. The construction practice of using travelers for inspection of pipe whip restraints was not adequate.
Contributing causes (for missing components and missing shim welds only): lack of a comprehensive set of drawings, as design drawings had to be reviewed together with vendor shop drawings to determine the scope l
of field welding, and lack of a construction
! procedure defining the responsibilities for field welding betwecn two contractors.
While B&R directed which welds were CB&I's responsibility, no record of this direction
() -
was kept with the traveler package.
Recommended corrective action: Issue i instructions to detail the relationship between different sets of drawings and design l changen as it applies to the erection and I inspection of all itens in the CWC.
Review applicable drawings for all items in l this CWC to ensure that there is adequate cross referencing betw3cn design drawings, vendor drawings sud associated dec15 n change documents such that required scope of field welding for each detail ccn be yeadily e s tablished..
Reinspect all iteds of this CWC for this attribute to ensure that all required components are installed and arranged as specified on the design documents and that shims in bearing type joints meet ' the design .
requirements. Determine the inspection -
requirements to ensure that the configuration of the installed hardware is functionally J
adequate. This need not include a verification of dimensions by measurement.
Include the above requirements for erection
/ and inspection on all future construction k%/ work travelers.
Establish a process for documenting assigned responsibilities between contractors performing' work.
1
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/"'% RESULTS REPORT d -
l ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Incorrect Gaps The deviations for installations resulting in incorrect gaps between the pipe and the pipe whip restraint were determined to constitute an unclassified trend. Although all but one of the deviations were classified insignificant, and that one deviation was classified as notable, it could not be determined if similar installations on other pipe whip restraints could potentially be adversely affected in their ability to perform their intended function- . Subsequent to pipe whip restraint installation the piping system has been tested twice for thermal expansion. Engineering was responsible for review of gap measurements
/~N taken during the tests and for specifying
(,,) needed adjustments. The notable deviation resulted from engineering changes that were not implemented.
Primary roct cause: lack of a procedure that delineates responsibilities for determining, tracking, and implementing final adjustments of pipe whip restraints to ensure proper gaps betweco oipe and restraints.
Contributing cause: lack of an t.cceptance ;
criterion tnat could have been evaluatad by the testing orgat.iza tion. ,
Recommended corrective action: Establish a procedure delineating evaluation, tracking, and implementation rrspensibilities to ensure that required final adjustments are made and that the gaps meet the design requirements.
This procedure should also include a section that indicates a method for documenting engineering acceptance of the final gap settings for all pipe whip restraints. This procedure should be applied if hot functional testing is again performed.
- Review and analyze the reinspection results for the attribute to evaluate if the
['-) existence of similar deviations in the remainder of the population would constitute j
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ )
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(}
LJ RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) a Construction Deficiency.
If a Construction Deficiency develops, corrective action such as reinspection of all restraints, reevaluation of prior HFT data, or reverification during a future HFT should be adopted, as appropriate, to verify that the gaps between the pipe and restraint meet the design requirements.
Missing and Incorrectly-installed Locking Devices Deviations identifying missing and incorrectly-installed locking devices were not evaluated for safety significance. These deviations were considered to constitute an adverse trend based on similar conditions resulting in construction deficiencies found
/' in other populations and on a CPRT
(_)h recommendation to TU Electric for 100 percent reinspection of locking devices.
Primary root ca.use: inadequate instructions or criteria from engineering addressing the acceptance and proper installation of locking devices and cotter pins.
Recommended corrective action: Reinspect
{
bolted joints and U-bar restraints for proper i installation of required lockir.g devices,
]
Construction prccedures should be revised to j prov$da installatico instructions and acceptsnce criteria f or loching devices.
1 Lack of Joint Tightness I
- Deviations for lack of joint tightness in structural bolted joints were considered to q constitute an adverse trend. These bolted l joints include hand-tight, bearing, friction type, and other joints required to be tightened to a specified torque value.
Deviations were noted for loose and missing g bolts, gaps in bolted joints, and bolts that j had less than the required torque. The
(_ deviations themselves were either classified i as insignificant or notable. However, l
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RESULTS REPORT (m}
ISAP VII.c j R
(Cont'd) 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) similar deviations on other pipe whip restraints may significantly reduce the ;
capability of the- joint to perform its !
intended function.
- Primary root cause: less-than-adequate construction procedure, as it does not explicitly require proper seating of mating surfaces or identify the need for torque sequencing or touch-up.
Recommended corrective action: Bolted joints should be reinspected to verify that the bolts have been installed to proper installation torque.
Construction procedures should be revised to provide sufficient instructions for I tightening bolted connections to ensure that similar deviations do not occur in the future.
Missing AWS Welds
- The devictions for missing velds made with i
! AWS procedures were considered to ccustitute an adverse rrend. The missing welds were for field-installed fillet welds.- The devia tions themselves were classified as notable.
l- However, similar deviations on other pipe whip restraints could adveracly, affect the i
restraints' ability to perforn their intended I
function.
Primary root cause: lack of specific instructions for the erection of pipe whip restraints. The construction practice of using travelers for the erection of pipe whip restraints was not adequate as implemented because there was no clear requirement on the traveler to ensure that all the components had been installed and arranged as required by the design drawings; this root cause has
/"'s also been identified for missing components.
(,,) Secondary root cause: lack of corresponding detail inspection instructions for pipe whip I' I
Revision: 1 Page 127 of 186 RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) restraints. The construction practice of using travelers for inspection of pipe whip restraints was not adequate.
Contributing causes: lack of a comprehensive set of drawings, as design drawings had to be l reviewed together with vendor shop drawings to determine the scope of field welding.
Lack of a construction procedure defining the responsibilities for field welding, between two contractors. While B&R directed which welds were CB&I's responsibility, no record of this direction was kept with the traveler package.
Recommended corrective action: Reinspect all l items in the CWC to verify that the required AWS field welds have been installed.
9 A corresponding standard step or set of steps should be added to future travelers for verification of required welds by contatruction and QC.
No other action is reco= mended in this section, as it it included under
" Con. figuration."
Documentation Review Of rhe approximately 28,000 review points, approximately 30 involved concrete expansion anchors.
The documentation review results and deviations related to concrete expansion anchors were referred to the ISAP V11.b.4 report for evaluation and conclusions. For the approximately 27,970 remaining documentation review points, 99.6 percent were found to be as required. For an additional 0.3 percent of these review points the deviations were insignificant. For the remaining 0.1 percent of these review points, the deviations were notable. There were no unclassified trends. Thus, the eight documentation review attributes evaluated had no findings.
O
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[d S RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION 0F ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Equipment Supports Reinspection Of the approximately 22,000' inspection points, approximately 5,000 involved concrete expansion anchors. The reinspection results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions.
For the approximately 17,000 remaining hardware inspection points, 98.4 percent were found to be in accordance with design requirements. For the remaining 1.6 percent of these inspection points the deviations were insignificant. For the attribute of bolting, proportional sampling found that the previously identified findings for jam nuts, locking devices, joint tightness and gaps between connected plies extend to the equipment support CWC. The remaining three
[]/
\_ reinspection attributes evaluated had no findings.
Documentation Review Of the approximately 7,000 review points, approniuately 1,700 involved concreta exp.ansion anchora. The documentation review results and deviations related tc concrete expansion anchors were referred to the ISAI VII.b.4 report. for evaluation and conclusions. For the approximately 5,300 remaining documentation review points, 99,4 percent were f ound to be as required. For an additional 0.2 percent of these review, pointo the deviations were insignificant. For the remaining 0.4 percent of these review points, the deviations were notable. The four documentation review attributes evaluated had no findings.
HVAC Duct Supports ,
i Reinspection For 93.8 percent of the approximately 35,500 inspection points the hardware condition was found to be in accordance with design requirements. Reinspection results and deviations relative to concrete expansion
,j anchors were referred to the ISAP VII.b.4 report for s
evaluation and conclusions. There were one unclassified trend and two CDs. l l
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,a i 2 RESULTS REPORT L)
ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The unclassified trend applies to all six reinspection attributes of the CWC. The attribute of support frame configuration and orientation had CDs for non-attachment of duct to supports. These discrepancies with their root causes and recommended corrective actions are as follows:
All Attributes The deviations that resulted in notable reductions of capacity for a number of deviation types were determined to constitute an unclassified trend for all attributes of the HVAC duct supports. It is not known if these deviations, when encountered in the uninspected portion of the population, would result in the tailure of the duct supports to
,_s\ perform their intended functions. Due to the
'(
\I high number and potential of the deviations, no bounding analysis cr. classification of deviations was perforced. However, an unclassified trend was determined to exist for all attributes in this population includirig all deviations described in this report.
- Primary and secondary root causes:
less-thr.n-adequate development and implementation of a p:Jogram to ensure that the HVAC supports were installe,d in accordance with design requirements.
Contributing causes: less-than-adequate response by TU Electric's QA audit program to ,
the 1983 NRC CAT deviations. j l
Recommended corrective action: Initiate a j program to correct all duct support detail J drawings and reevaluate the design of the duct supports. In addition, revise the duct support location drawings to show correct locations of all supports on these drawings.
Verify that the program for installation and
('}
(_,/ QC verification of HVAC duct supports is adequate. This review should include revision of procedures, improvement of training, and acquisition of qualified personnel where deemed necessary.
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( ) RESULTS REPORT v
ISAP VII.c (Cont'd) 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Implement a test program to establish the allowable loadings for bolting in concrete inserts with less than full thread engagement. Demonstrate the acceptability of field installations through a margin analysis on those supports most heavily loaded.
Repair those installations that do not meet margin analysis criteria. These corrective actions should include, in the testing programs and analyses, a determination of the effect of pretensioning bolts during installation.
Verify that the material provided to the HVAC duct contractor by the primary contractor is acceptable for use in safety-related seismic Category I applications.
Reinspect all HVAC duct supports for all
[h safety-related attributes.. P.eview existing
\ -)
~ documentation for these supports, and conbine these two sets of dor.uments to ensure that records of QC gacceptance are completa and accurate.
Perform en evaluation tar the possibility of inadequate weld fit-up on welding parformed before 1981. This program should includa an evaluation of the effect of potentially less-than-adequate fit-up on ef fective throats of velds. Upon completion of this evaluation, a per gram to repair any less-than-adequate welds should,be initiated.
Non-attachment of Duct to Support The two deviations identifying non-attachment of the duct to the support were determined to be CDs. The lack of attachment of the ducts to specific supports effectively prevents the supports from performing their intended function.
("'\ i
\_,)
l
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( j RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Primary root cause: same as unclassified trend, above.
Secondary root cause: same as unclassified trend, above.
Recommended corrective action. included in recommendations for unclassified trend, above.
Documentation Review For 88 percent of the approximately 2,200 review points the documentation was found to be as required. The documentation results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions. There
-s s
was one unclassified trend identified which applied to
() all five documentation review attributes of the CWC.
Inroequate Documentation
- The magnitude of the inspection and material traceability documentation deviations related to documentation that cannot be located or does not exist was determined to constitute an unclassified trend.
Primary root cause: same as the unclassified trend for reinspection deviations.
Recommended corrective action: ' ncluded i in recommendation for the unclassified trend applicable to all reinspection attributes, above.
Conduit Supports Reinspection Of the approximately 19,000 inspection points, approximately 6,100 involved concrete expansion anchors. The inspection results and deviations related
(}
'N.-
to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions. For the approximately 12,900 remaining hardware inspection points 99.2 percent were found to be in accordance with
l t
Revision: 1
- page 132 of 186
-l
-RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) design requirements. For an additional 0.7 percent of these inspection points the deviations were-insignificant. For the~ remaining 0.1 percent of these inspection' points, the deviations were notable. There were no adverse or unclassified trends and no CDs.
Thus, the 10 reinspection attributes evaluated had no findings.
l . Documentation Review Of the approximately 1,000 review points, approximately 340 involved concrete expansion anchors. The documentation review results and deviations related to concrete expansion anchors were referred to the ISAP VII.b.4 report for evaluation and conclusions. For the approximately 660 remaining documentation review points 67.4 percent:were found to be as required. For an additional 23.5 percent of these review points the
[h' deviations were insignificant. For the remaining 9.1 percent of these review points, the deviations were notable.- There were no unclassified trends. Thus, the five documentation review attributes evaluated had no findings.
5.2.7 Othe-r - Details .i Resulta tre presented in this section for the three j actributes reinspected on a proportional sampling l basis, investigation of documentation review deviations !
regarding inspector certification, and thp investigation of harassment and intimidation of QC inspectors.
The three attributes reinspected on a proportional sampling basis were the quality of installation of (1) concrete inserts, (2) bolting, and (3) welds made by Brown & Root in accordance with the American Welding Society (AWS) standard D1.1.
Concrete Inserts Approximately 87 percent of the 323 inspection points p showed the hardware to oe in accordance with design Q requirements. There were one unclassified trend and no CDs.
)
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- i RESULTS REPORT v
ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The deviations regarding less-than-required thread engagement into concrete inserts used in pipe whip restraints, pipe supports, and structural steel was determined to be an unclassified trend. Several of the deviations were considered notable. However, without more precise description of the loadings on supports utilizing concrete inserts and strength versus engagement data, it could not be determined if the hardware was adequately installed.
Primary root cause: less-than-adequate (1) training of construction personnel on installation requirements and proper installation methods for bolting material
,s into concrete inserts and (2) supervision of construction personnel during the (N ') installation of boltin6 material-Secondary root causs; less-than-adequate QC procedures that did not specifically address the steps necessary to establish that an acceptable engagement had teen ret.
Contributing cause: less-chan-adequate assessment during a room-by-room review of thread engagencut iuto Richmond inscrts and a lass-than-adequate QC final support walkdown.
Recommended corrective action: Initiate a program that will: ,
- 1. Perform a test program to establish the allowable loadings for bolting in concrete inserts with less than full thread engagement.
- 2. Demonstrate acceptability of field installations through a margin analysis on those construction work categories most heavily loaded.
- 3. Repair those installations, if any,
/N that do not meet margin analysis
(_,) criteria. Verify that personnel have been retrained for future installations.
f
Revision: 1 Page 134 of 186 k RESULTS REPORT ISAP VII.c (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Bolting l
Approximately 95.5 percent of the 32,751 inspection :
points showed the hardware condition to be in I accordance with design requirements. There were no l adverse trends or CDs that were not previously i identified in the individual CWC results reviews.
However, those CDs and ATs previously identified required corrective action to be taken in those l l
I populations with similar work processes and procedures.
Those populations affected are structural steel, pipe whip restraints, and equipment supports. For i documentation review, more than 98% of the 796 review l points showed the documentation to be as required. All documentation deviations were classified as insignificant or notable.
h Brown & Roct AWS DI .1 Welding Approximately 99.2 percent of the approximately 100,248 inspection points showed tie hardware condition to be j in accordance with design requirements. There were no !
adverse trends or CDs that were not previously identified in the individual CWC results review. For documentation review, approximately 98.3 percent of the j 11,600 review points showed the documentation to be as required.
Inspector Certification s l A total of 27 CWCs addressed the adequacy of inspector certification. An evaluation of the qualification of the 465 inspectors identified during implementation of ISAP VII.c was performed under ISAP I.d.l.
Approximately 97 percent of the inspectors evaluated were determined to be capable of performing satisfactory inspections, based upon a review of their qualifications and a substantial amount of positive information including, where appropriate, reinspection of their work. The capabilities of five inspectors who conducted cable pulling inspections were indeterminate because those inspections were not recreatable. Based G upon a lack of reinspection information, the quantity of indeterminate inspectors, and the substantial lack of experience of these indeterminate inspectors, these inspectors were therefore determined to constitute an
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[}
v RESULTS REPORT ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) unclassified trend. An analysis of the root cause and generic implications of this unclassified trend and recommendations for corrective action are discussed in the ISAP I.d.1 Results Report. For those inspectors found to be not capable of performing satisfactory inspections, it was determined, on the basis of further evaluations of the nature and severity of the inspection discrepancies attributable to each inspector, that inspection errors thac may affect the documentation relied upon by this ISAP would have no significant effect on the conclusions presented in this report.
Harassment and Intimidation Data were evaluated to resolve concerns regarding the potential for adverse impacts on the quality of
/"' installed hardware that could be attributable to
(_j potential harassmen; or intimidation of QC inspectors.
A comprehensive search of external source issues was performed to identify all concerns. This search of external sources, including NRC reports, which also covered allegations and independent auditor's reports, was developed into a ns.trix of external souree issues, which was used to assure that valid concerns were ccn'aidered in the CPRT evaluation process. The NRC reports identified some instances of potential intimidation; reported NRC investigation results (not complete as of the date of the reports) r,evealed appropriate action taken by TU Electric to prevent inspector intimidation.
As part of the ASLB Contention 2 proceedings, two external panels reviewed and reported on allegations of intimidation. They concluded that there were some incidents but no " climate of intimidation." Neither study suggests that poor-quality work resulted from the incidents that did occur.
The review of SAFETEAM records revealed a few employee {
concerns related to harassment and intimidation. In each case effective and complete action was taken by TU (f' ~) Electric or subcontractor management to resolve the concern. The CPRT in ISAP VII.a.6 determined that the SAFETEAM program does " effectively encourage employees to voice concerns and provide adequate means to do so."
i
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\
RESULTS REPORT v
ISAP VII.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The assessments of identified deficiencies, adverse trends, and unclassified trends performed in Action Plan VII.c includes an investigation of root causes for each such finding. In cases where the root cause was determined to be inspector error, the potential for QC inspector intimidation may have existed. In some of these cases, other likely causes for inspector error were determined, and no positive indicatiot of harassment or intimidation was identified. In other cases, involving a low frequency of errors, harassment or intimidation, while not likely as a widespread factor, could not be ruled out as a possibility in individual instances. These few situations, as an extra caution, are being referred to TU Electric SAFETEAM for further investigation and resolution.
Had there been a climate of harassment and intimidation
('
s affecting hardware quality, the extensive investigations by CFRT and other organizations reported above would have revealed some evidence of it.
Therefore, it is concluded that, subject to confirmaticu by the SAFETEAM investigation, inspector harassment and tutimidation did not have a significant effect on the adequacy of hardwr.re or inspections a; CPSES.
6.0 CONCLUSION
S 6.1 General ,
The results of the ISAP VII.c reinspection and documentation )
review program were provided in Section 5.2.3 through 5.2.6 for each of the four major disciplines that encompass the 32 CWCs. Three attributes (concrete inserts, bolting and Brown
& Root AWS welding) were sampled on a proportional basis and are covered in Section 5.2.7. Concrete expansion anchors, which were also sampled on a proportional basis, are covered in the ISAP VII.b.4 Results Report.
The findings, which include construction deficiencies, adverse trends, and unclassified trends, have each resulted in fg recommendations for corrective actions. Implementation of j
(_,) these corrective actions will guide ongoing activities, bring the safety-related plant hardware into conformance with che j design, and strengthen or improve the software (e.g.,
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. RESULTS REPORT ISAP VII.c (Cont'd)
6.0 CONCLUSION
S (Cont'd)
. procedures and training) and should prevent future recurrence of significant problems that have been found. The results of the VII.c effort and the implementation of corrective actions 1n conjunction with consideration of the information and results of other ISAP investigations would support an overall conclusion that the hardware has been installed in adequate conformance with the design.
'The VII.c methodology for evaluation of deviations and determination of findings was conservative. The evaluation techniques included -conservatism such as:
- ' Code allowables were used as the basis for safety-significance evaluations, even though code allowables are significantly lower than material ult 1 mate strength.
() - Acceptance criteria typically were based on hardware item functional capability, rather than system functional capability. In.particular, the effect of any item redundancy uas not evaluated.
- Conservative hand-calculation techniques were generally used to evaluate deviations, rather than using computer analyses that'have the capability of more precisely evaluating the effects of deviations.
- Future scheduled plant walkdowns, turnover procedures, preoperational tests, and startup tests that will provide opportunities for detection and additlanal {
corrective action were typically not considered.
The safety f actors and conservatism incorporated in the various national codes that govern the design and construction i of nuclear power plants result in acceptance criteria that often reduce the allowable capacity of an item to a much lower value than the actual capacity of the item. While construction deficiencies are defined based on code allowables, exceeding a code allowable does not necessarily result in hardware failure or loss of functional capability.
In addition, code design rules are generally conservative, and )
their use results in additional margins.beyond the code l allowables themselves. Actual material properties such as
(#' -
ultimate strength generally must be reached prior to failure.
Revision: 1 Page 138 of 186 RESULTS REPORT v
ISAP VII.c (Cont'd)
6.0 CONCLUSION
S (Cont'd)
The " safety-significant" acceptance criterion, as defined in Appendix E, of functional capability at the hardware item level is more restrictive than that usually implied by the term " safety-significant" for regulatory purposes or in common parlance. As defined and used by the CPRT, the term ignores overall system performance and functional redundancies that do exist in the actual plant. Therefore, classification of a deviation as a construction deficiency for the purposes of ISAP VII.c is not equivalent to a statement that the deviation, if uncorrected, would have resulted in unsafe system or plant operation. The ultimate criterion would be whether the required overall safety-related function of the affected system would be accomplished.
The verification of functional capability of an item is not dependent solely on the construction QC inspection. The
,_ inspections, walkdowns, and tests performed during
( construction completion, turnover from construction to K operations, reoperation, and startup are integral parts of the normal evolution of the plant and all confirm or add assurance that the plant will function as designed.
Due to these conservatism the deviations addressed by these findings would not necessarily have presented a significant risk to safe plant operation even if uncorrected. The >
corrective action recommendations, however, do address concerns and problem areas that, when corrected, will provide reasonable assurance that all design and construction defects that would have prevented the facility from being capable of operation in conformance with NRC Regulations haye been detected and appropriate corrective actions for such defects have been defined.
The overall conclusions regarding the hardware will be reached through the QOC collective evaluation review that follows the ISAP VII.c program and the approval of the Project's corrective actions. These steps are described in Section 6.2.
The bases of the conclusions reached in this program are built on the use of three distinct techniques (the 95/5 statistical screen, analyses for the presence of trends, and root cause and generic implications analyses) that progressively identify
('
(,
either actual or possible but undetected construction deficiencies and provide the basis for recommended corrective actions. These techniques are summarized in Section 6.3.
Rsvision: 1 Page 139 of 186 p)
(_, RESULTS REPORT ISAP VII.c (Cont'd)
6.0 CONCLUSION
S (Cont'd)
Conclusions based on reported results are summarized in Section 6.4.
6.2 Role of VII.c and QOC Review 6.2.1 ISAP VII.c The purpose of the construction reinspection /
documentation review (ISAP VII.c) was to evaluate the quality of construction either directly, by reinspection, or indirectly, by documentation review.
These reinspection and reviews resulted in a number of findings, identified in the report as construction deficiencies, adverse trends, or unclassified trends.
In addition, a number of other issues were identified and classified as special cases, with a recommendation for corrective action.
fs
\,
The root cause(s) were identified for each finding and also for each special case. Generic implications within each population of the identified root causes were determined. The determination of root causes and generic implications permitted focused recommendations for corrective action to be developed. The CPRT Program Plan did not require that recommendations be made, but only that the findings be issued to the Project for determination of corrective action acceptable to CPRT. The recommendations are therefore offered as possible corrective actions. The Project has the option of accepting the recommendations or proposing an alternative solution. In either case, detailed corrective action plans are required to be subm1tted to the third party for review and approval for all findings (construction deficiencies, adverse trends, and unclassified trends) and for all special cases.
The root cause(s) also permitted a review to be made for broader generic implications. The results of this review, where performed, have been discussed within this report. However, a more comprehensive review for generic implications will be made as part of the
[,_ broader collective evaluation process and, where i recommended, as part of the Project's corrective action program, both of which are discussed further below.
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() RESULTS REPORT ISAP VII.c (Cont'd)
6.0 CONCLUSION
S (Cont'd) 6.2.2 Collective Evaluation The results of the ISAP VII.c I
reinspection / documentation review will be further evaluated in the collective evaluation phase, as follows:
Combine the results of the ISAP VII.c review with the results from other ISAPs.
- Explore broader generic implications more extensively, based on the combined analysis of ISAP VII.c and other ISAPs.
- Develop overall conclusions relative to hardware and supporting documentation.
() 6.2.3 Previous Work / Future Work The construction reinspection / documentation review has been conducted based on a sampling plan of QC-accepted work for Unit 1 and Unit 2. In general, the construction work categories, work processes, and attributes were developed in the second half of 1985.
Packages were then issued for reinspection and documentation review, with the bulk of the reinspection and document reviews conducted in the first half of 1986. The analysis of the results of the reinspection and documentation reviews was conducted in the second half of 1986, with reports finalized in 1987.
The corrective actions become effective at the time that each approved corrective action (both retrospective and prospective) is implemented. Thus, the retrospective action will cover all work done up to that point in time, and the prospective action will cover all work done beyond that time.
6.2.4 Corrective Action Program The findings, root causes, and recommendations O developed from the ISAP VII.c review will be reviewed by the Project, and detailed corrective action plans and procedures will be submitted to the third party for concurrence in accordance with Appendix H of the CPRT Program Plan.
1 Revision: 1 Page 141 of 186 f'%
( ,) RESULTS REPORT ISAP VII.c (Cont'd)
6.0 CONCLUSION
S (Cont'd)
The Project has responded to all VII.c recommendations, either agreeing with the CPRT recommendation or proposing an alternative. All alternative proposals have been determined to be acceptable to CPRT.
An appropriate level of confirmatory overview will be performed for the corrective actions developed as a result of ISAP VII.c findings.
6.3 Basis for Conclusions 6.3.1 General The main objective of the ISAP VII.c investigation is to evaluate the quality of the construc;ed hardware.
There are three principal techniques that were 7-s utilized:
() -
95/5 statistical screen Analysis for the presence of trends
- Root cause and generic implication analysis 6.3.2 95/5 Statistical Screen The 95/5 statistical screen was used to determine whether the deficiency rate is greater or less than 5 percent. This was accomplished by using the defined threshold for a construction deficiency. ,If no samples were found to be deficient, there is a 95 percent confidence that less than 5 percent of the accessible population is deficient. A second sample of representative safe shutdown items enhanced the screen for most populations. In general, whenever a construction deficiency was identified by the 95/5 screen, a recommendation for 100 percent corrective action was made to cover like items in the population.
The design of the 95/5 statistical screening process provided for sample expansion whenever a construction 7,,
deficiency was determined. However, as the program was implemented, the intermediate step of sample expansion
- was omitted, and as noted above, corrective action was recommended that would identify and correct any similar deficiencies.
Revision: 1.
Page 142 of 186
() RESULTS REPORT ISAP VII.c (Cont'd)
6.0 CONCLUSION
S (Cont'd)
The 95/5 statistical screen identified 23 construction deficiency types, each addressed by corrective' action.
Specific construction deficiencies are described in.
Section 5.0 of this report and in Table 5.2-2.
6.3.3 Analysis for the Presence of Trends Trend analysis provided a more stringent filter for deficiencies than the'95/5 statistical screen. The search for a deficiency using the statistical screen determined, with a 95 percent confidence, whether the deficiency rate is greater or less than 5 percent.
-Trend analysis, as constituted by the CPRT Program Plan, was used'to determine whether the non-safety-significant deviations provided evidence.of the existence of even a single undetected construction deficiency in the uninspected portion of the
() population.
The trend analysis methodology considered the following-factors:
- 1. The acceptance criteria applied to determine deviations for the attribute.
- 2. The frequency of each deviation type or similar deviation types.
- 3. The magnitude of the deviation (s) and the impact on the capacity of the 1; ems.
- 4. The design margin inherent in the items in-the construction work category.
- 5. The severity of the. deviations.
i Severity is determined by comparing the ;
reduction in capacity due to the magnitude of the deviation to the design margin inherent in the construction work category; i.e. the CWC's susceptibility to the deviation.
- 6. The apparent (root) cause of the deviation A types, which may limit the magnitude of remaining deviations in the subset of the population to which the deviation type applies.
- - -_--_--_-____-_____O
l ,
i-Revision: 1 Page 143 of 186
() RESULTS REPORT ISAP VII.c (Cont'd)
6.0 CONCLUSION
S (Cont'd)
- 7. The size of the unsampled portion of the CWC.
Deviations and deficiencies differ with respect to l
safety significance. Since deviations have a lower threshold than deficiencies, they exist at a higher frequency in a population than deficiencies. The 95/5 statistical screen applied to the sample is a very good tool for detecting systematic deficiencies within a population. A finer screen, establishing additional assurance of the detection of deficiencies and of the quality of construction throughout the population, is afforded by trend analysis. The 95/5 sample screen information obtained with the sample was thus used, in conjunction with trend analysis,-to infer a rate of
' deficiencies that in most cases is much smaller than 5 percent.
Eleven types of adverse trends and 19 types of unclassified trends were identified through trend analysis. It is important to note'that more findings were determined as adverse trends and unclassified trends than were determined as construction deficiencies. This is an indication of the extent to which this filter is, in fact, more stringent than the 95/5 screen and of the effect that it had on the results (findingo) of the construction-reinspection / documentation review. It should be further noted that there are more unclassified trends than adverse trends. Since an unclassified trend is ;
identified when it is uncertain whether ap adverse trend exists, this is another indication of the conservatism of the program.
6.3.4 Root Cause ar.d Generic Implications Analysis l
For each finding from either the statistical screen or the trend analyses, a root cause analysis was i performed. In these analyses, such factors as the I specification requirements, the procedures for l construction, the scope of training, the supervision of i craft, and the qualification of personnel were considered, based on available evidence. With few exceptions, the analyses were able to determine root
-( cause(s).
1 o
i I
l Revision: 1~ ,
I Page 144 of 186 )
(f RESULTS REPORT
{
ISAP VII.c j- (Cont'd) l 6.0- CONCLUSIONS (Cont'd)
! Each identified root cause was evaluated to determine its generic implications within the affected .l population. To determine generic implications, each j root cause was reviewed to identify those work process elements applicable to other items or attributes within ,
the population that were potentially affected by the i same root cause. Where effects were substantiated, generic implications were identified, and corrective action recommendations were expanded to address them.
In some cases, generic implications outside the affected population were also identified.
The root cause and generic implications analysis did not lead to additional findings directly but did result in additional corrective actions. Like the trend analyses, the root cause and generic implications analysis supplemented the 95/5 statistical screen, by 4 extracting additional information from the sample that could have substantive impact on the scope of.the corrective action applicable to the uninspected portion of the population. The search for undetected construction deficiencies is thus broadened by pursuing found process weaknesses (i.e. root causes with generic implications).. Additional assurance that construction deficiencies throughout the plant will be detected and corrected was thus provided.
6.4 Summary Statement Based on the reinspection / documentation review, ;here were 53 types of findings in the 32 CWCs with recommendations for corrective action, both retrospective and prospective. In addition, there are seven recommendations for corrective action associated with special cases.
The findings include 23 types of construction deficiencies, 11 (
types of adverse trends, and 19 types of unclassified trends. {
These numbers indicate the importance of trend analysis in that well over half of the findings were as a result of trend analysis . Further, the unclassified trends, while of uncertain safety significance, are conservatively treated the same as the more definite findings and have had corrective actions recommended similar to those for construction
\ deficiencies and adverse trends.
Revision: 1 Page 145 of 186 1
RESULTS REPORT ISAP VII.c (Cont'd) t
6.0 CONCLUSION
S (Cont'd)
It is thus concluded that:
very high casurance has been provided that there are no programmatic deficiencies not detected by the statistical screen, trend analysis, or root cause and generic implication analysis and reasonable assurance is obtainable (by consideration of the totality of evaluations and results and the Laplementation of recommended corrective actions) that construction defects that would have prevented.the facility from being capable of operation in_confonnance with NRC regulations have been detected, and )
appropriate recommendations for corrective actions have been defined.
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Rsvision 1 Page 153 of 186 f^s RESULTS REPORT i,
s_
) 1 ISAP VII.c l (Cont'd) l Table 5.2-2 Reinspection Attribute Results Construction Work Category Attribute Classification Description Electrical Conduit Size and Material None Identification & Color Code None Origin and Destination None Installation of Fittings AT Missing bushings on lighting conduit AT Loose unions f.-
(S)
Installation of Expansion AT Slack across shake space less Fittings and Flexible than specified one inch Conduit CD Incidental damage to flexible conduit Conduit-Cable Tray None Interface Clearance for Power Conduit None and Pipe Electrical Separation AT Install'ations with less than specified separation Rating of Junction Boxes None Cable Tray Tray Identification and None Color Code Damage None Tray Size. None
(N Tray Routing and None
\_._- Arrangement Attachments SC Incorrect installation of tray splice plates j
Revision 1 Page 154:of 186 1
'RESULTS' REPORT ISAP VII.c (Cont'd)
Tabic 5.2-2 Reinspection Attribute Results Construction Work Category Attribute- Classification Descriptions Cable Tray Welding. AT Missing. welds (Cont'd)
Rung Spacing SC Rung spacing greater than specified nine inches Bolting None Mechanical Clearance None
. Electrical Separation. AT Installations with less
-than'specified separation.
Cables . Size, Type'and Color None-Damage None Power Cable Spacing UT Installations with less than specified cable spacing within a cable tray Slack AT Slack in free air cable less than specified two inches ,
Routing None Bend Radius UT Cables with bend radii less than minimum specified Support None Cable Support Grip None Installation Separation None Separation Barrier AT Installation of Material Installation separation barrier material not as specified
Revision 1 Page 155 of 186 RESULTS REPORT ISAP VII.c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction Work Category Attribute Classification Description Cables Splices and Repairs None (Cont'd) ,
Tie-down Installation UT Cable tie-down spacings greater than specified Terminations CD Loose connections on Weidmuller terminal blocks CD Cables not terminated in accorcance with the drawings CD Loose connections on O- terminal blocks NIS Cable Documentation Review Only N/A Termination Lighting All Attributes UT Multiple deviations Cable that were widespread and involved several attributes Electrical Identification None Equipment ,
Install- Location and Orientation None ation Damage CD Bus insulator in a load center transformer with small crack and loose bolt CD Damaged solenoid-operated valve AT Ruptured flexible conduit between a solenoid-operated valve and its O ECSA
Revision 1 Page 156 of 186 1( f RESULTS REPORT ISAP VII.c (Cont'd)
Table.5.2-2 Reinspection Attribute Results Construction Work Category Attribute Classification' Description Electrical Damage . UT Incorrectly reassembled Equipment .(Cont'd) and damaged doors, Installation hardware, and gaskets (Cont'd)
Assembly or Modificatic. CD Wrong type of relay installed in an auxiliary-related rack CD Fuse sizes not changed as specified by a modification (This
,s. .
envelopes 2 CDs.)
Instrumen- Material Identification None tation Equipment Tubing Size None-Installation Tubing Marking None Tubing Routing None Tubing Slope None Tubing Air Gap None ,
Tubing Separation None l Tubing Minimum Bend None ,
Radius i Tubing Crimps, Kinks, or None Flattening on Bends Flexible Hose CD Flexible hose installed l Installation with excessive twist Instrument Identification None Instrument Location None 1
Page 157 of 186 RESULTS REPORT
(
ISAP VII.c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction Work Categor3 Attribute Classification Description Instrumen- Instrument Vents, Drains, None tation and Connections Equipment Installation Instrument Separation None (Cont'd)
Other Observation PDR Presence of unauthorized sealant Mechanical Large-bore Piping and Component None Piping Identification Configuration l
Piping and Component None Sequences and Location Orientation of Piping and SC Flow element installed Components in flow direction opposite to that specified on piping isometric drawing Piping Clearances UT Less than specified pipe-to,-pipe and pipe-to-component clearances Expansion Joint CD Loose tie rods and missing Installation lock nuts Small-bore Piping and Component None Piping Identification Configuration Piping and Component None Sequence and Location Orientation of SC Metal diaphragm type of j
O Piping and Components globe valve installed with flow arrow opposite to I system flow
Revision 1 Page 158 of 186 (m)
'v' RESULTS REPORT ISAP VII.c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction Work Category Attribute Classification Description Small-bore Piping Clearances UT- Less than specified Piping pipe-to-pipe and Configuration pipe-to-component (Cont'd) clearances Piping Bend Radius None Fabrication Ovality None Buckling and Flattening None Piping Bolt, Stud, or Cap Screw None
! > Systems Diameter
\- Y Bolted Joints Nut Height None Thread Engagement None Bolt, Stud, Cap Screw, None and Nut Material and Gasket Type Flange Pressure Rating None and Flange Type ,
Bolted Joint Completeness None Bolt Tightness None Gasket Coverage Over None Flange Sealing Surface Pipe Welds Weld Identification None and and Location Material Weld Configuration None
(~'}
V' Weld Size None
. i
Revision 1 Page 159 of 186 r~
f l RESULTS REPORT U
ISAP VII.c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction Work Category Attribute Classification Description Pipe Welds Radial Weld Shrinkage SC Excessive radial weld and shrinkage Material (Cont'd) Weld Undercut None Surface of Weld None Weld Cracks and Lack of None Fusion Weld Rust (SS) None I 1 Base Material Defects UT Base material reduction due to overgrinding adj acent to a weld Base Material Rust (SS) None Tubing Weld Identification None Welds and and Location Material Weld Configuration None Weld Size None Weld Undercut None Surface of Weld None ,
1 Weld Cracks and Lack of None Fusion Weld Rust (SS) None Base Material Defects None Base Material Rust (SS) None p)
'w Field- Nameplates None fabricated Tanks Shell Top Angles None i
Revision 1-Page 160 of 186
)- RESULTS REPORT ISAP VII.c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction i Work l Category Attribute Classification Description
' Field- Anchor Bolt Rings, Anchor None fabricated Bolt Chairs, and Anchor Bolt-Tanks Nut Tightness (Cont'd)
Wald Seam Offsets None l 1 l Nozzle Type, Size, and None
[ . Location l
Nozzle Insert Reinforcement None Plates t( ) . Nozzle and Manhole None Reinforcing Pads Seismic Restraints None Welding None Base Material Defects None Weld and Base Material None Rust Grout None ,
HVAC Ducts Location None and Plenums l Configuration UT
- Hardware installed l without approved design details Longitudinal Seam Type None Gasket Installation None
- A total of seven deviations against the configuration, bolt location, and g .
- ? welding attributes were determined to collectively represent a single unclassified trend.
- - - - _ - - _ _ _ _ _ - - _ _ _- _ i
Revision 1 Page 161 of 186
(,) RESULTS REPORT ISAP VII.c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction Work Category Attribute Classification Description HVAC Ducts Bolt Location UT
- Hardware installed and Plenums without approved design (Cont'd) details Bolt Installation None Welding UT
- Hardware installed without approved design details HVAC Identification None g., Equipinent C) Installation Location None Orientation None Configuration None Flange Bolt Holes None Duct Connections - None Bolt Tension Duct Connections - None Gasket installation ,
Duct Connections - Bolt None -
Thread Engagement Accessory Connections None Mechanical Equipment Identification None l Equipment Installation Orientation None l Levelness None l
l j
f%
\ \
\--
- A total of seven deviations against the configuration, bolt location, and welding attributes were determined to collectively represent a single l unclassified trend. ,
Revision. ..
1 Page 162 of 186
- RESULTS REPORT ISAP VII.c.
'(Cont'd)
Table 5.2-2 i
Reinspection Attribute Results Construction-Work ,
Category Attribute Classification Des crip tic'n- l Mechanical Configuration CD- Broken' hold-down bolts on Equipment a control room air :
Installation conditioning unit > .j (Cont'd) compressor SC Approximately 1/2 of manway cover bolts on pressurizer
& safety. injection system accumulator failed to meet-minimum tightness criteria. q Grout None O.. Anchor Bolt Location None Anchor Bolt Hardware, None Engagement, and Tightness Rotating Equipment None Alignment Temporary Coatings and None Preservatives Rust (SS) None Concrete Expansion See Results Report for Anchor ISAP VII.b.4.
Structural Concrete Location None Placement i
Size None i
Surface Conditions UT Unsound mortar at construction joints l O that extends beyond reinforcing steel Anchor Bolts and Embeddeo None Plates
. - - _ ________ ______________________ - _____ a
Revision 1 I I
4 Pags 163 of 186
-RESULTS REPORT ISAP.VII.c (Cont'd)
Table 5.2-2 l i
Reinspection Attribute Results 1 Construction j Work-Category Attribute Classification Description Structural ' Member Configuration UT Smaller-size member Steel substituted for
' Alterations- None I
Connecting Component None Configuration, Including Field-installed Details Configuration Welding AT Missing welds on a
- reactor cavity platform installation UT Weld configuration having welds undersized or with unacceptable profiles for a portion of their length Structural Bolting SC Use of bolts with diameters 1/8 inch less than that specified on design , drawings CD Lack of jam nuts or other acceptable locking devices for Unit I rotating and pressurizer platform threaded connections CD Excessive gap between bolt nuts and steel angles in a connection that transmits seismic loads via i tension O
Rsvision 1 Page 164 of 186 RESULTS REPORT
[%))
ISAP VII,c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction Work Category Attribute C3 ossification Description l- Structural Structural Bolting CD Excessive gap between Steel (Cont'd) connected plies and between l (Cont'd) baseplates and embedded plates in connections l that transmit loads via bearing (This envelopes 2 CDs.)
Coacrete Inserts UT Thread engagement less than specified (UT the result of combined evaluation of deviations
('
from several CWCs.)
Installation of Concrete See Results Report for Expansion Anchors ISAP VII.b.4.
(Hilti Bolts)
Fill and Documentation Review N/A Backfill Only Placement Cement Documentation Review N/A Grout Only Epoxy Documentation Review N/A Grout Only Containment Liner Local Contour
- None Liners and Stainless Steel Tank Weld Seam Offset
- None Liners Weld Seam Surface
'(' Weld Seam Surface on stainless steel tank
( liner veld seam surfaces
- Denotes attributes for containment liner only.
. _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _a
'l5 Revision 1 Page 165 of 186 m
j ); RESULTS REPORT ISAP VII.c (Cont'd)
Table 5.2-2 i Reinspection Attribute Results Construction Work Category Attribute Classification Description Fuel Pool Irregularities on Weld None Liner Surface Rust or Corrosion on None Weld-affected Area Supports Large-bore Identification of Support Mone Pipe Assembly.
Supports -
Rigid Location and Orientation of None
,I Support Assembly s_
Configuration of Support CD Installation of incorrect Assembly size of vendor-supplied bolt on a pipe clamp-assembly AT Zero gaps between pipe and the supporting member Concrete Inserts UT Thread engagement less chan specified (UT the result of combined evaluation of deviations from several CWCs.) j ASME Bolting of Support CD Inappropriate or missing Structure locking devices for non- i high-strength threaded fasteners ASME Welding of Components hone Installation of Concrete See Results Report for ISAP Expansion Anchors VII.b.4.
Installation of CD Spacers for pipe clamps Vendor-supplied not as specified Components
__ ._-__________w
Revision 1 Page 166 of 186
() RESULTS REPORT ISAP VII.c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction Work C-at e gory Attribute Classification Description Large-bore CD Sway strut assemblies eye Pipe rod jam nuts not secured Supports - (This envelopes 2 CDs.)
Rigid (Cont'd) CD Loose pipe clamp assembly for a sway strut Large-bore Identification of Support None Pipe Assembly Supports -
Non-rigid Location and Orientation None of Support Assembly Configuration of Support CD Spring can assembly not Assembly correctly adjusted ASME Bolting of Support CD Inappropriate or missing Structure locking devices for non-high-strength threaded fasteners (This envelopes 2 CDs.)
Concrete Inserts UT Thread engagement less than specified (UT the result of combined evaluat' ion of deviations from several CWCs.)
ASME Welding of Components None Installation of Concrete See Results Report for ISAP Expansion Anchors VII.b.4.
(Hilti Bolts)
Installation of Vendor- CD Snubber eye rod angular supplied Components offset greater than maximum allowable (This envelopes 2 CDs.)
CD Broken cotter key
Ravision 1 Page 167 of 186 RESULTS REPORT L '( )
ISAP VII.c j
-(Cont'd)
Table 5.2-2.
' Reinspection Attribute Results Construction Work Category- Attribute Classification Description Small-bore Identification of Support None Pipe- Assembly Supports-Location and Orientation None of Support Assembly j Configuration of Support AT Zero gaps between pipe and Assembly the supporting members ASME Bolting for Support. CD Inappropriate or missing Structure locking devices for non-high-strength threaded fasteners Concrete Inserts UT Thread engagement-less thsn specified (UT the result of combined evaluation of deviations from several CWCs.)
ASMI Welding of Components None Installation of Concrete See Results Report for ISAP Expansion Anchors VII . b . 4,.
(Hilti Bolts)
Installation of Vendor- CD Unsecured turnbuckle supplied Components fastener for a spring hanger Instrument Tube Restraint UT Incorrect tube clamps on a Tube valve manifold Supports Tube Spau None Unique Baseplate None Identifier Compsaents None Configuration None
Ravision 1 Pags 168 of 186 RESULTS REPORT
( )
ISAP VII.c (Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction Work Category Attribute Classification Description Instrument Welding None Tube Supports Bolting CD Misaligned and (Cont'd) insufficiently-torqued Unistrut spring nut installation CD Loose bolt UT Thread engagement on Unistrut spring nut
(~ Concrete Expansion Anchors See Results Report for G ISAP VII.b.4.
Baseplate Bearing None Pipe Whip Identification None Restraints Location None Orientation None Configuration AT Missing components CD Levelness and plumbness CD Missing shim welds in bearing-type joints Cold Gap Between Pipe UT Incorrect gaps between pipe and Restraint and pipe whip restraint Structural Bolting AT Missing or incorrectly-installed locking devices AT Lack of joint tightness
- in hand-tight, bearing, and friction-type bolted i
joints l
Revision 1 Page 169 of 186 y ,f : -RESULTS REPORT ISAP VII.c (Cont'd) >
Table 5.2-2 Reinspection Attribute Results
~
Construction Work Category Attribute Classification- Description-Pipe Whip Concrete Inserts and UT Thread engagement less Restraints Nuts for Embedded Bolts than specified '(UT the (Cont'd) result of combined ~
evaluation from several CWCs.)
Concrete Expansion Anchors See Results Report for ISAP VII.b.4.
Welds Made With ASME None Procedures
{ Welds - Other AT Missing welds Equipment Location and Orientation None Supports Configuration of Support None Assembly Bolting of Support CD, AT* *Previously identified Structure findings for jam nuts, locking devices, joint tightne,ss and gaps between cornected plies,,
extended as a result of proportional sampling.
Welding of Components None Installation of Concrete See Results Report for j ISAP VII.b.4.
Expansion Anchors HVAC Duct All UT Numerous and widespread ', '.
Supports deviations that resulted in notable reductions of capacity Support Frame Configuration CD Ducts not attached to and Orientation support (This envelopes 2 CDs.)
,i' Revision. 1 Page-170 of 186 RESULTS REPORT ISAP VII.c
.(Cont'd)
Table 5.2-2 Reinspection Attribute Results Construction.
Work Category Attribute Classification Description Conduit Capacity None Supports Conduit Span None Orientation None
. Components None Configuration None Welding None Bolts None Concrete Expansion Anchors See Results Report for ISAP VII.b.4.
Conduit Bearing None Clamps None Base Plates Bearing None O
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Rzvision 1 Page 177 of 186
[NJ') RESULTS REPORT ISAP VII.c (Cont'd)
Table 5.2-4 Documentation Review Attribute Results Construction Work Category Attribute w/ Finding Trend Description Electrical Conduit Reinspection Only Cable Tray None Cable QC Acceptance of Cable Unclassified Trend for Jacket and Insulation unverified 6.9kV cable Removal jacket and insulation removal NIS Cable Termination None
{}
x-Lighting Cable All Unclassified Trend -
consistent with reinspection Electrical None Equipment.
Installation Instrumentation None Equipment Installation ,
Mechanical Large-bore Piping Reinspection Only Configuration Small-bore Piping Reinspection Only Configuration i
o('~x l
l l
Rsvision 1 Page 178 of 186
,m t RESULTS REPORT
\v'i ISAP VII.c (Cont'd)
Table 5.2-4 (Cont'd)
Construction Work Category Attribute w/?inding Trend Description Piping Bend Minimum Wall Thickness Unclassified Trend for lack Fabrication Verification of documentation recording minimum wall thickness prior to bending Piping Systems Bolted None Joints Piping Welds and None Material Tubing Welds and None Material
-- Field-fabricated None Tanks HVAC Ducts & None Plenums HVAC Equipment Reinspection Only Installation Mechanical Equipment Reinspection Only Installation Structural Concrete Placement None J Structural Steel All Unclassified Trend for lack ]
of inspection documentation for 31 sample items Fill & Backfill None Placement g
Cement Grout None G
Epoxy Grout None l
l j
Revision _
1 Page 179 of 186 RESULTS REPORT ISAP VII.c (Cont'd)
Table 5.2-4 (Cont'd)
Construction Work Category Attribute w/ Finding. Trend Description Structural.
(Cont'd)
Containment Liners None and Steel Tank Liners Fuel Pool Liners ~ None Supports La'rge-bore Pipe None Supports - Rigid c .I Large-bore Pipe None Supports - Non-rigid Small-bore Pipe None Supports Instrument Tube None Supports Pipe Whip. Restraints None Equipment Supports None HVAC Duct Supports All Unclassified Trend.for missing documentation-concerning inspections and material traceability Conduit Supports None O
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