ML20215B827

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Rev 0 to Quality Instruction QI-049, Reinsp of Large Bore Pipe - Welds/Matl. Related Info Encl
ML20215B827
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/14/1985
From: Boulton D
EVALUATION RESEARCH CORP.
To:
Shared Package
ML20197E251 List:
References
FOIA-86-272, FOIA-86-454 QI-049, QI-49, NUDOCS 8610090131
Download: ML20215B827 (200)


Text

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  1. b Page 1 of 7 o

EVALUATION RESEARCH CORPORATION COMANCHE PEAK RESPONSE TEAM QUALITY INSTRUCIION FOR ISSUE SPECIFIC ACTION PLAN ISAP-VII.c CO G OL.'ID _

FY CONTROL N08pC-d]. f-PROCEDURE NO.: QI-049 REVISION NO.: 0 ISSUE DATE: 10-14-85 -

(

REINSP$CTION OF LARGE BORE PIPE - WELDS / MATERIAL _

Prepared by: Date: /O-3-86

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Approved by: //[/4 d //- 844 --- Date: N ~ Y-EI Issue Coordinator i Approved by: b Date: !O!8!O On-Site QA Representativ i

/0!/O 87

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!M Approved by: - - - - Date:

/ /

OA/4K: ReviewTeamLeader(

8610090131 861003 PDR FOIA l j

GARDE 86-272 PDR

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f QI-049 Rev. O O

( 1.0 PURPOSE This procedure provides detailed instructions and accept / reject criteria for the reinspections of Large_, Bore Pipe Welds / Material.

2.0 APPLICABILITY This procedure shall be implemented for all QC accepted large bore pipe, mechanical penetration, and electrical penetration welds / material reinspections. 'This reinspection shall be limited to that weld / material which is designated as ASME III, Code class 1, 2, 3 or MC (NB, NC, ND, or NE respectively). The population is described in the Population Description for Large Bore Pipe Welds / Material, Reference 3.3.

3.0 REFERENCES

3.1 QA/QC-RT-501, Description Memorandum for Reinspection of Large Bore Pipe Welds / Material, dated October 7, 1985. J. Schauf to A. Patterson.

3.2 CPP-009, Performance of Reinspections and Documentation Review 3.3 " Population Description for Large Bore Pipe Welds / Material",

( Rev. 1, dated September 25, 1985.

4.0 GENERAL Reinspections are performed and documented in accordance with established CPRT procedures and instructions. This instruction establishes the attributes and accept / reject criteria for reinspections of Large Bore Pipe Welds / Material. Reference 3.2, provides the instructions for performing, documenting and processing the results of the reinspections.

4.1 Responsibilities QA/QC Inspectors perform reinspections in accordance with established project procedures and instructions. Reference 3.2 addresses the method used to perform reinspections and to document and process the results.

4.2 Policy Activities performed under this procedure shall conform to the policies contained in the latest Comanche Peak Response Team .g Program Plan and Issue-Specific Action Plan (s).

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QI-049 Rev. 0

, o 5.0 REINSPECTION PROCEDURE

{

Ceneral Requirements

~

Prior to the start of reinspection, assure that the welds are clean of any paint or any foreign material which would impede an adequate visual inspection.

Verification of reinspection attributes shall be recorded on the Comanche Peak Response Team Checklist, Attachment 6.1. Record deviation locations and dimensions, and any additional reinspection remarks, on the Supplemental Remarks Form, Attachment 6.3. All required data for the documentation review shall be recorded on the Data Recording Form, Attachment 6.4.

When it is necessary to measure weld dimensions or surface defects during the course of an inspection, unless specified tolerances are provided, such dimensions should be determined as accurately as is practically achievable using standard inspection tools. l Record the corresponding code of the reinspection tools used for each applicable attribute on the Reinspection Tools Used Form, Attachment 6.2. Attachment 6.2 provides a list of standard reinspection tools and their corresponding codes.

1. Welds

^f 1.A Configuration Verify the type of weld configuration. For nominal pipe sizes of 2 inches and larger, the joint

, connection shall be a butt weld (unless otherwise specified on the isometric drawing).

4 1.B Size and Profile (Bevel Welds) i Verify the weld size by assuring that the joint is welded flush.

For weldolet and sockolet connection welds to large bore pipe, verify that the weld tapers smoothly into the base material.

1.C Butt Weld Reinforcement Verify that the thickness of the reinforcement complies with Attachment 6.5, Table A for piping and penetrations, and Attachment 6.5, Table B for pumps and valves. ..

NOTE: The surface of the reinforcement of all butt welded joints may be flush with the base material or may have uniform crowns.

l 3

QI-049 Rev. 0

. 9

-k 5.0 REINSPECTION PROCEDURE (Cont'd) 1.D Radial Weld Shrinkage (Butt Welds only)

Verify that the amount of weld shrinkage does not exceed the following:

-ASME Class I welds For pipe wall thickness of 3/4-inches and greater, the radial weld shrinkage shall not exceed 3/16-inches.

For pipe wall thickness below 3/4-inches, the radial veld shrinkage shall not exceed one-quarter of the nominal wall thickness, see Attachment 6.6.

--ASME Class 2 and 3 For pipe wall thickness of 3/8-inches and greater, the radial weld shrinkage shall not exceed 3/16-inches.

For pipe wall thicknesses below 3/8-inches, the radial weld shrinkage shall not exceed one-half of the nominal wall thickness, see Attachment 6.6.

NOTE: The amount of shrinkage shall be measured by the distance from the lowest point of shrinkage (at the toe of the weld) and the ,

. top of the base metal.

1.E. Undercut Verify that the weld has no undercuts which exceed a depth greater than that tabulated on Attachment 6.7. l l

1.F. Surface of Welds l l

Verify that the surface of welds are sufficiently free i of overlap, abrupt ridges and ripples, so that proper interpretation of radiographic and other required  !

nondestructive examinations could have been performed. ,

1 1.G. Cracks, Lack of Fusion, Crater Cracks i

Verify that tre welds have no visible cracks, lack of 1 fusion or crater cracks. l l

4 4

ee e w-- -- - - , - , - - , - , w e , se -w- - s-- ,,.,wn,v,-e ,wov-- - - , -r,,---n- -. , _ . . . . , - - -, nm-,w-- .,-.- - n-

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QI-049 Rev. 0 t 5.0 REINSPECTION PROCEDURE (Cont'd) 1.H. Weld Rust (Stainless Steel only)

Verify that the weld has no rust colored corrosion product build-up which may be linear or localized.

Thin films of surface rust are acceptable.

NOTE: The materials engineer will be available in the evaluation of weld rust acceptability.

1.I. Welders ID Symbol Record welders ID symbol on Attachment 6.4.

NOTE: Record "Not Available" if the welders ID symbol is not marked.

2. Base Materials NOTE: The reinspection shall be limited to within two (2) feet on both sides of the veld being reinspected or to the nearest weld, whichever distance is less, unless stated otherwise.

2.A. Base Material Traceability Record, on Attachment 6.4, the material's heat number (pipe, valve, penetration, fitting, etc.), code or lot number, and/or any additional markings (i.e., there may be a marking symbol or code which identifies the material).

NOTE 1: For non-insulated pipe, inspect the area on l both sides of the reinspection weld and up to the nearest weld.

, NOTE 2: Record "Not Available" if the material 1

identification markings cannot be located or identified.

2.B. Base Material Defects Verify that the base material has no surface defects which exceed a depth greater than that tabulated on Attachment 6.8. -

Surface defects consist of the following possible types: Arc Strikes, Grinding Marks, Pit Marks, Gouges and Scratches Indentations. Identification Markings, i etc.

5 4

l QI-049 Rev. O O

( 5.0 REINSPECTION PROCEDURE (Cont'd)

2. Base Materials (Cont'd)

- 2.C. Material Rust (Stainless Steel only)

Verify that the base material has no rust colored corrosion product build-up which may be linear or localized. Thin films of surface rust are acceptable.

NOTE: The materials engineer will be available in the evaluation of base material rust acceptability.

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^

QI-049 Rev. 0

/ *

( 6.0 ATTACHMENTS 6.1 Comanche Peak Response Team Checklist 6.2 Reinspection Tools Used Form 6.3 Supplemental Remarks Form 6.4 Data Recording Form 6.5 Weld Reinforcement Tables 6.6 Nominal Pipe Wall Thickness Table 6.7 Undercut Allowable Defect Depth Table 6.8 Base Material Allowable Defect Depth Table

(

=

l 7

i Attachment 6.1  ;

COMANCHE PEAK RESPONSE TEAM QI-049 CHECKLIST Rev. 0-POPULATION DESC VERIFICATION PKG NO.

LARGE BORE PIPE pAgg i or 2 WELDS / MATERIALS I-M-LBWM- -

QUALITY INSTRUCTION QI-049 hREINSPECTION O c"* t ..

EQUIPMENT MARK / TAG NO. DOCUMENTATION REVIEW UNIT I l

C0te'ON l l

VERIFICATION ACCEPT REJECT DATE

1. WELDS A. Configuration B. Size & Profile C. Butt Weld Reinforcement

(

D. Radial Weld Shrinkage E. Undercut l F. Surface of Welds C. Cracks, Lack of Fusion, Crater Cracks H. Weld Rust (Stainless steel only)

PREPARED BY: APPROVED BT:

DISCIPLINE ENCR. DATE LEAD DISCIPLINE ENGR. DATE LasrEct w BI: APPROVED BY:

LN5FELluR DATE LEAD INSPECTOR DATE CPP-007.LA. Ravision 0 i

Attachment 6.1 o COMANCHE PEAK RESPONSE TEAM CHECKLIST QI-049 Rev. D

(

POPULATION DESC VERIFICATION PKG NO.

N h/k b$Eb I-M-LBWM- PAGE _2 op 2 VERIFICATION RN ACCEPT REJECT DATE I. Welders ID Symbol N/A N/A See Data Recording (not accept / reject Form. Attachment 6.4 attribute)

2. BASE MATERIALS A. Material N/A N/A See Data Recording Traceability Form, Attachment 6.4 (not accept /

reject attribute)

B. Material Defects C. Material Rust (Stainless steel only) i CPP-007.1B, Revision 0

. 1 Attachment 6.2 QI-049 Rev. 0 ,

Page 1-of 2 )

t REINSPECTION TOOLS USED FORM '

VERIFICATION PACKAGE NO. I-M-LBWM- 1 l

ATTRIBUTE TOOL CODE SERIAL N0/ CALIBRATION DUE DATE

1. WELDS A. Configuration B. Size and Profile C. Butt Weld Reinforce-ment
D. Radial Weld Shrinkage E. Undercut F. Surface of Welds

-- ~

G. Cracks, Lack of Fu-sion, Crater Cracks H. Weld Rust I i

i

. I. Welders ID Symbol INSPECTOR DATE REINSPECTION TOOL CODES CODE TOOL CODE TOOL AF ANGLE FINDER MI MICROMETERS BL BUBBLE LEVEL MM MIRROR BS BOROSCOPE MN MAGNET BW 1/32", 1/16", 3/32", 1/8" WIRE PB PLUM BOB '

CG CONTOUR CAGE PR PROTRACTOR DF DRY FILM THICKNESS GAGE SC SLIDE CALIPER FG FEELER CAGES SR 6" RULE FL FLASRLIGHT ST STEEL TAPE MEASURE FM FIBRE METAL FILLET GAGES TG TAPER CAGE GG GAL FILLET CAGES UD UNDERCUT GAGE (DIAL)

HL HI-LOW GAGE UP UNDERCUT GAGE (PIT) l MG MAGNIFYING GLASS VC VERNIER CALIPER VT VISUAL INSPECTION

l Attachment 6.2

  • QI-049 Rev. O REINSPECTION TOOLS USED FORM VERIFICATION PACKAGE NO. I-M-LBWM-ATTRIBUTE TOOL CODE SERIAL N0/ CALIBRATION DUE DATE
2. BASE MATERIAL A. Material Traceability B. Material Defects C. Material Rust INSPECTOR DATE REINSPECTION TOOL CODES CODE TOOL CODE TOOL AF ANGLE FINDER MI MICROMETERS BL BUBBLE LEVEL MM MIRROR BS BOROSCOPE MN MAGNET  ;

BW 1/32", 1/16", 3/32", 1/8" WIRE PB PLUM BOB CG CONTOUR CAGE PR PROTRACTOR DF DRY FILM THICKNESS GAGE SC SLIDE CALIPER FG FEELER GAGES SR 6" RULE FL FLASHLIGHT ST STEEL TAPE MEASURE FM FIBRE METAL FILLET CAGES TG TAPER GAGE GG GAL FILLET GAGES UD -

UNDERCUT GAGE (DIAL)

HL HI-LOW GAGE UP UNDERCUT GAGE (PIT)

< MG MAGNIFTING GLASS VC VERNIER CALIPER VT VISUAL INSPECTION 4

2

Attachment 6.3

. QI-049 Rev. O.

Page 1 of 1 SUPPLDENTAL REMARKS FORM LARGE BORE PIPE WELDS / MATERIAL VERIFICATION PACKAGE NO. I-M-LBWM-ATTRIBUTE (No./Deacription) REMARKS l

)

INSPECTOR DATE

Attach:s2nt 6.4

  • QI-C19 Rev. 0 Page I of 1

( DATA RECORDING FORM LARGE BORE PIPE WELDS / MATERIAL VERIFICATION PACKAGE NO. I-M-LBWM-ATTRIBUTE , DATA

1. Welds I. Welders ID symbol f 2. Base Material A. Material Traceability -

(heat number, code or lot number, and/or additional markings)

INSPECTOR DATE 4

Attachment 6.5

. QI-049

. Rev. Q Page 1 of 1 WELD REINFORCEMENT TABLES TABLE A (PIPING AND PENETRATIONS)

For butt joints the reinforcement shown shall apply to the outside surface. The reinforcement shall be measured from the higher of the abutting surfaces involved.

Nominal Thickness Maximus Reinforcement Inches Inches Up to 1/8. incl.

3/32 Over 1/8 to 3/16, incl. 1/8 Over 3/16 to 1/2 incl. 5/32 Over 1/2 to 1. incl. 3/16 Over 1 to 2. incl. 1/4

( TABLE B (PUMPS AND VALVES)

The height of reinforcement on each face of the weld shall not exceed the thickness in the following table:

Nominal Thickness Maximum Reinforcement '

Inches Inches Up to 1, incl.

3/32 Over 1 to 2 incl. 1/8 Over 2 to 3, incl. .

5/32 I

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NOMINAL PIPE WALL THICKNESS TABLE Attachment 6.6

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UNDERCUT ALLOWABLE DEFECT DEPTH TABLE Attachment 6.7 QI-049 Rev. 0

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  • EVAL 2JATICN O 2-C2CEACCM CCWPCWATION QA/QC-RT-753 DESCRIPTION MEMORANDUM FOR REINSPECTION OF POPULATICN: LARGE BORE PIPE SUPPORTS - RIGID CCDE: LBSR INSTRUCTION: QI-027, REV. 1, CHANGE NOTICE 002 October 16, 1985 TO: A. A. Patterson FROM: R. H. Brown Attached is Change Notice 002 to QI-027, Rev. 1 for your approval.

ITEM NO. DESCRIPTION OF CHANGE ,

1 Add Table 5.3-1, for Bolt Hole edge distance requirements as referenced in Paragraph 5.3.4.A.1 and 5.3.4.A.2.

NOTE: The above listed change will not have any impact on previous completed packages as the information was required to complete inspections.

Supplemental Instructions were given as required.

Prepared by: ... I VA/QC Disdipline Engineer l Approved by: , /<re , ,,nfuvt_.

QA/QC Lead Discipline Engineer Attachment I cc: ERC File VII.c Large Bore Pipe Supports-Rigid RHB/feo G - /O

& i 9

/

  • 10 'N 1.

Title:

NRC Audits of Comanche Peak Response Team Construction Reinspection / Documentation Review Program (ISAP VII.C)

2. NRC Staff and Consultants:

J. A. Calvo, NRC (Chairman) E. Tomlinson, NRC J. A. Nevshemal, Westec J. Flaherty, Teledyne B. F. Saffell, Battelle R. Philleo, Consulting Engineer R. Masterson, EAS J. Rivard, Teledyne

3. Persons Contacted:

J. L. Hansel, ERC J. M. Schauf, ERC T. Bori, ERC G. Hefter, ERC E. Baum, ERC J. T. Christensen, ERC A. Burke, ERC N. Bancrjce, ERC D. Boulton, ERC H. Bossung, ERC R. Brown, ERC J. Brand, ERC J. Brown, ERC J. Tablerion, ERC A. Patterson, ERC R. Tate, ERC J. Greer, ERC J. DiMare, ERC F. Korensky, ERC J. Warrington, ERC M. Iannuci, ERC

4. CPRT Construction Reinspection /Docismentation Review Program Audits of the Comanche Peak Response Team (CPRT) Construction Reinspection /Do'cumentation Review Program, subsequently referred to as theConstructionAdequacyReviewProgram,wereconductedonhber16 All and 17,1985,)and at the Comanche Peak Steam Electric Station site.

disciplines--mechanical, civil, and electrical--were audited by teams composed of NRC staff and consultants. Through these audits, the NRC reviewed the basis for establishment of the groupings within each discipline and the work process populations associated with each discipline and utilized by the CPRT for assessment of construction adequacy. The primary purpose of this audit was to determine the degree of homogeneity within each work process from an engineering perspective.

Detail audit of work process attributes will be accomplished in subsequent audits.

The construction adequacy review program is being performed within the purview of the Comanche Peak Response Team with ERC, Inc. responsible h- /'

l

2 for performing the review. The presentation made by Mr. John Hansel of ERC, Inc., at a public meeting held on October 3 and 4, 1985, in Grandbury, Texas, provided the basis for the staff's initial audit of the '

CPRT Construction Adequacy Program.

Work processes are being identified for construction of safety related systems, components, and supports. Each work process will be evaluated by a random sample drawn from the associated population of

systems, components, or supports related to that work process. Further, sample items reviewed are drawn from Unit 1. Unit 2, and comon areas, and must be construction complete and quality approved. Each work process sample is expanded to include an engineering sample. The engineering sample assures that a number of safe shutdown system items equivalent to the number of items addressed by the random sample are also reviewed for adequacy of construction.

Subsequent sections describe two NRC audits of this process.

5. Mechanical Discipline The mechanical discipline is divided into nine populations which are:

(a) HVAC ducts and plenums (b) HVAC equipment installation (c) Field fabricated tanks (d) Mechanical equipment installation (e) Large bore piping configuration (f) Small bore piping configuration (g) Pipe-welds / material (h) Piping system bolted joints / material.

Each of these populations was discussed with ERC personnel by NRC staff and consultants participating in the audit. The construction adequacy review for the mechanical discipline is approximately 15 percent complete l

' at the time of the initial audit. Completion is scheduled for the end of February, 1986. Only field construction work processes are addressed by c

the scope of this activity; vendor fabrication is not within the scope of I the Construction Adequacy Program. For each of the mechanical areas, ERC

3 had prepared a " Population Description" addressing the contents of each I category, its boundary, and any specific interfaces germane to the In addition to the Population Descriptions, a flow chart population.

describing the work processes and associated attributes for each sample population was provided and discussed with ERC's Population Engineers .

ERC indicated that these attributes provide the basis for the checklists which are being developed for re-inspection of mechanical systems and  !

components.

ERC reported that the construction adequacy review is being performed in accordance with their own quality assurance program wh ERC's compatible with the CPRT's quality assurance program.

implementation of the construction reinspection / documentation review program is being audited by both CPRT and ERC quality assurance personnel.

Specific coments on each population within the mechanical discipline are provided in the subsequent paragraphs.

This audit was initiated during the

a. HVAC Ducts and Plenums.

The HVAC Duct and Plenum population October 17 and 18,1985, site visit.

Fabrication, installation and welding are the encompasses 6800 items.

three work processes associated with construction of,HVAC ducts and plenums.

Bahnson Service Company was the only subcontractor to Brown &

Root for all HVAC duct and plenum fabrication and installation.

Reasonable homogeneity is demonstrated because fabrication and installation of this equipment are each characterized by a single craft-sheet metal workers for f abrication, welders for installation, and a Installation and fabrication procedures are based single subcontractor.

on Gibbs & Hill Specification MS-85. The attributes associated with each This audit was work process were reviewed and appeared to be complete.

continued during October 29-31, 1985, by a further review of the following ERC procedures:

a. Work Process Definitions
b. Population Items List
c. QI-023, " Reinspection of HVAC Equipment".

l

4 This population has been modified based on a concern raised during the October 16 audit. The work process for Equipment Setting by -

Brown & Root has been deleted and will be contined with the mechanical equipment installation population since the same B&F orocedures and installation specifications were used.

HVAC Equipment. As with the HVAC Ducts and tlenums, this audit b.

was initiated on the October 17 and 18 visit and continued during the October 29-31, 1985, visit. This population contains 604 items of passive equipment in the safety-related HVAC system whereas the HVAC This equipment was equipment population contains only active items.

either installed by Brown & Root or Bahnson and this was the basis for-subdividing this category. The work processes associated with HVAC equipment installation are the setting of the equipment and then connecting it to the plenum and ductwork. Further, the attributes of The each work process are the same, regardless of the installer.

attributes associated with the work processes were reviewed and appeared appropriate for the process.

The following ERC procedures were reviewed during the continuation of this audit:

a. Work Process Definitions-
b. Population Description
c. Population Items List
d. QI-039, " Reinspection of HVAC Ducts and Plenums".

QI-039 has been issued and is very detailed.

It contains much of the original documents and sketches required during the construction phase. The document review procedure has not been completed yet.

c. Field Fabricated Tanks. This particular activity was discussed ERC informed the audit team that eight field in a qualitative manner.

This was not f abricated tanks exist and that all would be reinspected.

pursued further as population homogeneity was not an issue because of the 100 percent reinspection.

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5 l

d. Mechanical Equipment Installation. Mechanical equipment audit )

The of October 17 and 18,1985, population encompasses 336 items. ~

governing construction document is the Gibbs & Hill Mechanical Erection Specification 2323-MS-101. The implementation of this is accomplished by Brown & Root Specification titled " General Installation of Mechanical Equipment", CP-1. The governing quality assurance procedure is Brown &

Root QI/QAP11.1-39 titled " Mechanical Equipment Installation Inspection".

Qualitative results of the sampling conducted so far indicates that 20 to 25 percent of the sample drawn is from Unit 2. The remainder of the The work processes associated

! sample is from Unit 1 and connon areas.

with mechanical equipment installation are setting, anchoring, welding and, for rotating equipment only, alignment. The attributes of each work ERC personnel indicated that if a process were discussed in depth.

particular attribute of the work processes was not addressed when the sampling activity was completed, assessment would be made as to whether If a or not the sample needed to be expanded to include that attribute.

decision was made not to specifically address that attribute, the basis for this decision would be provided in the report addressing the construction adequacy evaluation of, in this instance, mechanical equipment. Work process homogeneity is evaluated by checking to make sure that the same organizations are involved, procedures have remained nominally constant, and that the welder inspector qualification standards Sampling is performed at the work process level.

have remained the same.

Since evaluation of equipment is made at the work process level, each sample will be expanded such that sixty evaluations will be made for each This means that more than the minimum number of equipment work process.

items (60) are addressed during completion of the sampling process.

This particular category was pursued further in that an installation procedure for a heat exchanger and a pump (rotating equipment) was

~

reviewed to evaluate the compatibility of the attributes associated with work processes with the installation requirements contained in the procedure. Compatibility did appear to exist between the work process l In one case, the attributes and installation procedures for both cases.

' installation procedure for heat exchanger cpl-CCAHHX-01 was reviewed to see if this specific installation procedure was compatible with the i

- - . . _ _ _ _ - . . - - . _ . , . . _ . _ , . , _ _ _ . ~ . - - - . _ _ . - . _ . , , - _ - . _ _ _ . . - . _ _ _ . . . . _ . . _ _ _ _ . _ . _ . -. -

o 6

attributes of the work processes for mechanical equipment installation.

The procedure for installing an auxilliary feed water pump, cpl-AFAP- '

MD-01 was reviewed to evaluate its compatibility with the alignment work process attributes.

Audit of October 29-31, 1985 The following documents were reviewed as part of the continuing audit of the Mechanical Equipment Installation (MEIN) population:

(1) Work Process Definition for MEIN.

(2) Population Description.

(3) Population Item List.

(4) QI-059, Revision 0, Draft Procedure Quality Instruction for Issue Specific Action Plan (ISAP) VII.C., " Reinspection of Mechanical Equipment Installation").

(5) Original Mechanical Erection Specification 2323-MS-101, Revision 4,6/28/84, Gibbs & Hill, Inc., Specification.

Brown & Root Specification MCP-1, 8/1/84, Revision 4, " General (6)

Installation of Mechanical Equipment".

Brown & Root QI-QAP-11-1-39, Revision 4, 6/11/84, " Mechanical (7)

Equipment Installation Inspection Procedure;".

(8) Brown & Root, CCP-24, Revision 4, 6/26/80, " Rigging".

Brown & Root, " Grouting Base Plates, Bearing Plates and (9)

Equipment Bases", CCP-16, Revision 4, 2/8/84.

Brown & Root, " Installation of Hilti Drilled-In Bolts", CEI-20, (10)

Revision 9,12/16/83.

The There are currently three work processes being reviewed.

l l welding work process has been deleted from the MEIN population and, as of October 28, 1985, has been put in the appropriate pipe weld work process.

ERC is also reviewing the deletion of grout from the attribute list and This is establishing a new population that specifically addresses grout.

change is due primarily to the way documentation was established.

The ERC reinspection procedures and original construction specifications and procedures were reviewed and compared for homogeneit The writer feels of work processes and choice of generic attributes.

i

.7 that all attributes listed are appropriate and cover the original construction sequence.

Five documentation packages from the sagled population were I

reviewed for completion of documentation and comparison to general specifications and attribute list.

The six documentation packages reviewed were:

(1) Service Water Pump. P.O. CP-010-001 Rotating equipment installed per Hayward Tyler manual. Manual gave specific tolerances on parallel alignment between motor half coupling and collar.

(2) Pressurizer. P.O. -0001-18 All dimensions for installation are per Westinghouse drawings.

(3) Safety In.iection Pump. TBX-SIAPSI-01 and 02 Specified tolerances on rim-to-rim and face-to-face coupling alignment. A requirement was also given on vibration tolerance. In a discussion with ERC, ERC stated that this attribute may be added to attribute list as a documentation check.

(4) Centrifugal Charging Pump, TBX-CSAPCH-01 and CP-0001-024 for Unit 1 Installation is per manufacturer's manual. This pug is part of the Chemical and Volume Control System and was fabricated by Pacific Pumps.

(5) Motor-Driven Auxiliary Feedwater Pumps. P.O. CP-007-001 Alignment is per manufacturer's specifications. Criteria given for checking anchor bolts, level and alignment and grouting.

(6) Excess Letdown Heat Exchanges Criteria given for backing off of foundation bolts to allow for thermal growth. Requirement given by Westinghouse.

The work processes and their attributes are considered to be appropriate to the installation of mechanical equipment. The above six mechanical component document packages were well documented and the appropriate attributes listed on the ERC checklist. The review of the A

MEIN population will be completed upon resolution of two open items.

concern regarding the attribute of both torquing as it applies to equipment anchor bolts. The " tightness" attribute may address the need

8 to distinguish " hand tightening" from those instances requiring a specified torque limit. This issue will be further investigated in future audits. Second, ERC is reviewing the need for a vibration attribute. This will be addressed in the next audit.

1 e./f. Large Bore Piping Configuration /Small Bore Piping Configuration. The large and small bore piping configuration construction adequacy reviews are addressed using 3000 Brown & Root isometric drawings. The scope of this activity is intended to assess the work process of piping installation through evaluation of attributes such as location, size, and orientation of piping and pipe components. The Brown & Root isometric drawings provide the basis for sampling both large and small bore piping. Large bore piping includes that piping which is 2-1/2 inches and larger in diameter; small bore piping is that piping less than 2-1/2 inches in diameter. If an isometric drawing containing both large and small bore piping were to be drawn as part of a sample, it would be used in both the large and the small bore work process review.

The installation work process and its attributes are the same for both large and small bore piping. The piping considered in this review includes all ASME code piping. ERC reported that all piping of large and small bore is installed to one procedure and by one craft--pipe fitters.

Some attributes such as piping valves would obviously be included in any sample for drawn for either large or small bore piping. There are other attributes such as expansion joints, screw joints, and strainers which l because they are very few in the system, might not be included in any selected sample. ERC reported that following the sampling process, a review to assess the adequacy of the sample for adequate representation of attributes would be made. However, a specific component, because it was not included in a sample, would not necessarily be examined only for that reason.

The number of attributes corresponding to the installation of large bore piping appeared accurate and complete. However, the number of them seems to preclude evaluation of them all through the random and engineered sampling process. If ERC suggests that it is not imperative that all such as screwed joints, strainers, and expansion joints be

9 evaluated from a configuration viewpoint, their report should justify this type of conclusion. It appears that the sample should include some '

number of components which are not extensively used in piping to provide confidence that these components are installed correctly. Their sampling process appears to address the key items such as piping orientation, valve location and orientation, and bends.

g. Pipe-Welds and Material Audit of Octnber 17 and 18, 1985 t

As with large and small bore pipe configuration, the welding of large and small bore pipe are considered as one grouping. Separate samples, however, are utilized to address each. More than 66,000 welds are required to connect safety-related large and small bore piping. The work processes associated with welding of either large or small bore are prewelding, welding, post-welding. As with the other categories within the mechanical discipline, the population description was reviewed and appeared complete. The process of construction adequacy review is about 40 percent complete. The initial review has been completed; samples have been drawn and preparation of reinspection procedures is in process.

Approximately 65 percent of the sample drawn is either Unit 1 or comon.

The remainder is Unit 2. ERC personnel were not sure if any Class 1 welds were included in the sampling. It was indicated that Brown & Root performed all field welding. ERC further reported that the weld The inspection processes are the same regardless of the ASME code class.

categories of large and small bore pipe welds were not separated to distinguish between the welding of stainless steel pipe opposed to carbon steel pipe. ERC indicated that the welders were qualified to weld both stainless steel and carbon steel piping and hence there was no need to separate this. At the exit, the audit team expressed concern regarding the lumping of stainless steel welds with carbon steel welds. ERC agreed to review the sample to determine the number of stainless an'd carbon steel welds. Welds addressed by this study include only field welds.

10 Welds of the penetration sleeve to flange were included within this category. There are 282 such welds in this category. None were included '

in the random or engineering sampling, however, the large and small bore samples were supplemented to include one mechanical and one electrical penetration weld.

Welds work processes and attributes appeared complete but conclusions regarding population homogeneity cannot be reached until review of implementation procedures and welder qualifications is completed. Further, as previously noted, concern exists for the consideration of stainless and carbon steel welds as part of the same population.

Audit of October 28-30, 1985 The piping welding area was addressed in the staff's second audit of the CPRT's Construction Reinspection / Document Review Program to verify (1) the basis for establishment of each population; (2) population boundaries;(3)populationexclusions;(4)populationinterfaces; (5) population list source and basis; (6) work process and basis; (7) attributes associated with work process; and (8) source of attributes.

Based upon the fact that both large bore and small bore pipe welds were fabricated to the same procedure and by the same craft, ERC decided to lump the populations together. Thestaffreviewedthe(LBWMandS8WM) population basis, description memorandum, population description, populations item list and work process definition. ERC indicated that only one work process was chosen, Welding. Apparently, regardless of the possible differences in the welds (configuration, material type, or process) each work process involves: (1) comon erection specification requirements; (2) comon installation procedure requirements; (3) comon craft labor performing the same basic types of operations; (4) comon inspection procedure; and (5) a comon inspection organization.

Since basically one two welding methods were used at CPSES, Gas Tungsten ARC Welding (GTAW) and Shielded Metal ARC Welding ('SMAW), ERC has comitted to two random samples of 60 welds for each welding method.

The staff expressed a concern for the lack of separation of carbon steel

O 11 and stainless steel welding. ERC pointed out that welder qualification is in compliance with B&R Specification WES-031 which qualifies a welder to both carbon and stainless steel welding. The staff reviewed WES-031 and B&R procedure CP-CPM-6.9D, " Welding and Related Processes", and found very few areas where the procedures or specifications differed with regard to carbon and stainless steel welding. Differences were associated with the two welding methods GTAW and SMAW. ERC said that of the 120 samples already established, approximately 50 percent were stainless steel welds.

In addition, an engineered sample of 60 welds for each method was picked to account for safe shutdown systems. In both cases, GTAW and SMAW, the original sample of 60 and the engineered sample overlapped. This necessitated increasing the original sample to achieve the engineered sample of 60 welds. In all, a total number of approximately 180 samples will be inspected.

Under the work process identified as " Welding", 24 attributes were identified, 18 of which are common to both welding methods and to all welds. The remaining 6 attributes will be inspected as the sample dictates. Additional samples for these 6 attributes will be chosen as deemed necessary, or a justification for not increasing the sample will be given at that time.

h. Piping System Bolted Joints Audit of October 17 and 18, 1985 i

I Two work processes comprise the piping system bolted joint category.

They are installation preparation and final bolt fitup. There are 7000 bolted joints at the Comanche Peak Power Station. The work processes and their attributes appear to adequately represent the bolting of piping The procedure which governs this is CP-CPM-6.9E Rev. 8. A flow joints.

chart and population description had been prepared to provide the basis for the sampling of bolted joints. The staff's audit did not yet pursue this to the depth required to draw a firm conclusion regarding the i

homogeneous nature of the work process populations.

12 Audit of October 29-31, 1985 t

i The following ERC procedures were reviewed during the continuation of this audit:

(a) Work Process Definitions (b) Population Description (c) Population Items List (d) QI-021 Revision 1, " Reinspection of Piping System Bolted Joint Material.

During the October 18 audit, the NRC audit team raised a concern on torque being an attribute and not a work process. The concern was relative to equipment specifications requiring a specific torque value on certain types of flanges and the reinspection attribute not containing sufficient samples. In the discussion with ERC, it was noted that there I

are approximately 7000 items in the piping system bolted joint population.

f Of the approximately 7000 items, 6700 are in line-piping connections.

, which were installed in accordance with Brown & Root Procedure CP-CPM 6.9E.

Section 3.12 of the B&R procedure did not require a specific torque value to be used. The governing requirement was that the joint "shall be tightened sufficiently to prevent leakage during pressure Since ISAP VII.C is addressing QC-accepted items, only i testing".

reinspection per the original specification is required.- The only flanges l

which may have required specific torque values would therefore be in the Mechanical Equipment Population. ERC has reviewed the MEIN population and has only found approximately six flanges which required specific f

values. Therefore, the issue raised during the October 16 audit is not an l

issue for Piping System Bolted Joints.

l It was also noted that the Population Description and Population l Item Lists will be revised to delete instrument flanges. These will now l be included in the electrical area.

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13

6. Electrical Discipline W

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7. Civil / Structural Discipline ,

The civil structural discipline is divided into 15 populations which are:

(a) Concrete Placement (b) Structural Steel (c) Liners (d) Fuel Pool Liner (e) Fill and Backfill Placement (f) Grout-Cement (g) Grout-Epoxy (h) Large Bore Pipe Supports - Rigid (i) Large Bore Pipe Supports - Non-rigid (j) Small Bore Pipe Supports (k) Large Bore Pipe Whip Restraints (1) Instrument Pipe / Tube Supports (m) Category 1 Conduit Supports (n) HVAC Duct Supports (o) Equipment Supports.

Most of these areas were discussed with ERC personnel by the NRC staff and consultants participating in the first two audits. Some areas have been reviewed in depth while others have been treated in a cursory mariner and will be examined further in future audits. Populations (k) through (1) have not been reviewed as of this time because they had recently been formulated and the work processes and work process attributes were still being developed.

a. Concrete Placement. The concrete placement population was reviewed in a cursory manner during the initial audit and in depth during the second. During this time the following documents were reviewed to determine if homogeneity of the work processes and attributes had been achieved.

(a) ERC's Work Process Definitions for Concrete Placement Population.

(b) ERC's Population Description for Concrete Placement, 8/5/85.

(c) ERC's Population Description for Concrete Placement, 8/5/85.

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l o l 15 (d) ERC's Population Items List for Concrete Placement, 9/5/85.

(e) Procedure QI-043, Revision 0, 9/16/85, Procedure, Quality Instructions for Issue-Specific Action Plan No. VII.C.,

" Reinspection of Concrete Placement".

(f) Gibbs and Hill Specification 2323-SS-9, 1/16/79, " Concrete". l (g) Gibbs and Hill Specification 2323-SS-30, 2/10/84, " Structural Embeddments".

(h) Brown & Root Construction Procedure 35-1195-CCP-11. " Concrete Placement", Rev. O.

The concrete placement population is presently subdivided into three work processes, each work process having various numbers of attributes.

Some of the attributes are to be reviewed by means of a field reinspection; others can only be reviewed by means of a document review; and some will be reviewed utilizing both field reinspection and documentation review. The field reinspection was in progress at the time of this audit and the documentation review had not yet begun. No reinspection packages were reviewed.

A few concerns evolved from this audit; however, the reinspection of concrete placement's work processes and attributes does achieve an appropriate level of homogeneity. These concerns were discussed with ERC and were left as open items. The following is a list of open-items which ERC should address:

i (a) It may be more appropriate to establish cadwelds as a work process rather than as an attribute. ERC is to review the cadweld inspection procedure and the concrete pour card sign-i off requirements to determine whether cadwelds should be a separate work process.

(b) ERC to consider establishing Richmond Inserts as a separate attribute instead of including it with the embeddment

! attribute.

(c) ERC to determine if the condition exists where embedded pipe sleeves are used to anchor the piping system. If this situation does exist, the embedded sleeves should be a separate attribute.

i

16

b. Structural Steel. Cursory review of this area was done during the second audit to determine if the concept of choosing work processes and attributes would achieve acceptable homogeneity. A limited review of -

the following documents was performed.

(a) Procedure QI-045, Rev. 1, 10/23/85, and Change Notice 001, 10/23/85, Quality Instructions for Specific Action Plan VII.C, Reinspection Procedures for Structural Steel.

(b) ERC's Description Memorandum for Reinspection of Structural Steel:

l

1. Rev. O, 9/15/85
11. Rev. 1, 10/8/85 iii. Change Notice to Rev. 1,10/23/85.

(c) Gibbs and Hill Specification 2323-55 168, " Structural Steel",

5/12/75.

(d) TUGC0 Instruction QI-QP-11.0-15, " Verification of Baseplates for Grouting", Rev. 8, 3/13/85.

After performing this general overview of the structural-steel reinspection activity, it is felt that the work processes and attributes

identified generally will achieve acceptable homogeneity. However, a more detailed audit of the reinspection procedures will be required to make more detailed coments.
c. Liners. The containment liner population includes horizontal, vertical, and penetration welds. The work processes were reviewed and ERC was informed that consideration should be given to including a plumbness requirement as a work process. Also, it was suggested that ER.

consider revising the tolerance when a 6-inch template is substituted for a 10-inch template.

This area will be reviewed in subsequent audits.

d. Fuel Pool Liners. The first audit addressed only the formation of the populations. All welds covered by travelers will form this ~

population. This area will be reviewed in subsequent audits.

17

e. Fill and Backfill Placement. The initial audit addressed the population formation and the work processes within the population.

Testing is a work process within this population and not within concrete. '

Consideration should be given to the need for consistency. If testing is retained as a work process, the population description should be modified to reflect this as a separate work process.

f./g. Grout-Cement / Grout-Epoxy. These are new populations which have not yet been reviewed.

h./i./j. Large Bore Pipe Supports--Rigid (LBSR)/ Nonrigid (LBSN)/Small Bore Pipe Supports (SBPS). All of the noted pipe support populations were addressed in the audit of October 29-31, 1985. These populations were formulated in order to assure a proper sampling of rigid and non-rigid pipe supports. This is important, since the majority of

" standard catalog supports" are in the non-rigid category. The small bore sampling was r.ot divided, because the number of non-rigid small bore supports is very small and also because the type of support is not readily obvious from the support number (as in the case for LB supports).

ERC intends to sample 60 supports from each of the three groups (LBSR, LBSN, and SBPS). The SBPS population was made up of four work processes;

! fabrication, installation, welding, and inspection. The ERC management seemed to be confused as to whether inspection should be a work process or an attribute. The two LB populations did not show inspection as a work process. After much discussion, the individual in charge of the SBPS group indicated that rework to a support very often occurred during

' the inspection phase as a result of an UNSAT Inspection Report (IR).

I Since this work was performed under the umbrella of inspection in order to close out the IR, this was a separate work process. The individuals

in charge of the LB group appeared hesitant to accept this but eventually they did. However, at the exit interview, ERC upper management balked at this agreement and said that they would like to investigate this area further. They indicated that if they made any changes they would contact l the staff (the staff agrees with inspection being a separate work process).

l

  • r 18 The staff reviewed the various documents (description memorandum, population description and basis, population items list, work process

~

justification, attribute description and basis, and QI-019-020, 027 through 030). An auditable trail existed such that all work processes and' accompanying attributes could be verified. The staff noted that under pipe supports welding two attributes were omitted (cleanliness and base metal defects). ERC pointed out that cleanliness was unattainable both from an inspection standpoint (prewelding attribute), and from the point of view of document review (cleanliness was not a hold point on the Multiple Weld Data Card (MWDC)). ERC also said that they did not include base metal defects for supports as an attribute, since it was difficult to see defects through the paint. The staff pointed out that requirements for identifying base metal defects existed in ASME Subsection NF-4000 and B&R Procedure QI-QAP-11.1-28. ERC stated that during the reinspection of the sample supports, base metal defects were looked for in each case and noted as an "out of scope" observation for inclusion in the normal deviation system. The staff would not accept this, and asked ERC to reconsider this approach. After some discussion, ERC committed to put base metal defects into the attribute list and to treat all instances as part of the construction adequacy.

k. Large Bore Pipe Whip Re'straints. An overview of the pipe whip restraint population was provided by ERC. This population consists of moment restraints, pipe whip restraints and restraint support structures listed in Section 3.6 of FSAR. Due to the original construction, two populations may be established, one for the restraint and one for the support structure. Nine systems have postulated line breaks. Some restraints are listed by Gibbs and Hill and other restraints are listed by Site Damage Group. At this time ERC is still reviewing the work process and is establishing which groups were responsible for installation.

These populations were formed after the initial audit and have not yet been reviewed.

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19 1

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1. Instrument Pipe / Tube Supports.
m. Category / Conduit Supports. t
n. HVAC Duct Supports. .

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. . 1WWb-10-EE 14:b4 MHilhLLE COLUMBUW 14WW111 WE E. Y t

1.

Title:

Comanche Peak Response Team Construction Adequacy Program Audit

2. NRC Staff and Consultants:

JE .. A l , NRC "6."E S e t. ..;..; } E. Tomlinson, NRC

c. .. Chv otteure.Al J. A. Nevshemal, %stes Vf576C J. Flaherty, Toledyas T O p Y g [

F. Saffell, Battelle R. Philleo Consult +ng h#

i 3. Persons Contacted: -

J. L. Hansel ERC J. M. Schauf. ERC J. T. Christensen, ERC G. Hefter, ERC l D. Boulton, ERC A. Burke, ERC J. Brand ERC H. Bossung, ERC A. Patterson, ERC J. Brown, ERC p d J. DiMare, ERC R. Tate, ERC p M. Iannuci, ERC

  • g
4. CPRT Construction Adequacy Program fW#

An audit of the Comanche Peak Response Team (CPRT) Construction Adequacy Program was conducted on October 16 and 17, 1985, at the Comanche Peak Steam Electric Station site. All disciplines--

mechanical, civil, and electrical--were audited by a team composed j of NRC staff and consultants. Through this audit,.the NRC reviewed the basis for establishment of the groupings within each discipline and the work process populations associated with each discipline  :

and utilized by the CPRT for assessment of construction adequacy.

The primary purpose of this audit was to evaluate the homogenuous ,

nature of the work pr'ocess populations from an engineering perspective.

Detail review of work process populations will be accomplished

~

in subsequent audits. l The Construction Adequacy Program is being perfonned within l I

the purview of the Comanche Peak Response Team with ERC. Inc.

responsible for performing the construction adequacy review. l The presentation made by Mr. John Hansel of ERC, Inc., at a public meeting held on October 3 and 4, 1985, in Grandbury Texas, provided j the basis for the staff's initial audit of the CPRT Construction Adequacy Program.

6- /D

, ,IUWb-lW-MM 143bb MHIthLLE COLUf1MUW 14WW111 U'd

.. 2 Work process populations are being developed for the construction activities for safety related systems, components, and supports.

Each work process is evaluated by a random sample drawn from

'a~ category of systems, components, or supports related to that

~

work process. Further, items reviewed as part of a sample must be construction complete and quality approved. Each work process sample is expanded to include an engineering sample. The engineering sample assumes that a number of safe shutdown system items equivalont to the number of items addressed by the random sample are also reviewed for adequacy of construction.

5. Mechanical Discipline The mechanical discipline is divided into nine groupings or categories which are:

(a) HVAC ducts and plenums (b) HVAC equipment installation -

(c) Field fabricated tanks (d) Mechanical equipment installation (e) Large bore piping configuration (f) Small bore piping configuration (g) Large bore pipe welds / material (h) Small bore pipe welds / material (1) Piping system bolted joints / material.

Each of these areas was discussed with ERC personnel by NRC staff and consultants participating in the audit of the Construction Adequacy program. The construction adequacy review for the mechan-ical discipline is approximately 15% complete as of this inspection, g Completion is scheduled for the end of February, 1986. In terms of scope, the Construction Adequacy Program Review for the mechan-i ical discipline is addressing only construction complete and -

l quality approved items. Only field construction activities are addressed by the scope of this activitys vendor fabrication is not within the scope of the Construction Adequacy Program. For each of the mechanical areas. ERC had prepared a " Population

. Description" addressing the contents of each category, its boundary, i

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and any specific interfaces germane to the population. In addition to the Population Descriptions, a chart describing the work processes associated with the mechanical items within each grouping was provided and discussed with ERC's Population Engineers. This flow chart contained attributes associated with each work process.

ERC indicated these attributes are providing the basis for the checklists which are being developed for re-inspection of mechanical systems and components.

ERC reported that the construction adequacy review is being performed in accordance with their own quality assurance program which is compatible with the CPRT's quality assurance program.

ERC's implementation of the Construction Adequacy Review Program is being audited by both CPRT and ERC quality assurance personnel.

Specific connents on each of the areas within the mechanical discipline are provided in the subsequent paragraphs.

s. HVAC Ducts and Plenums. The HVAC duct and plenum category l encompasses 6800 items. Fabrication, installation and welding are the three work processes associated with construction of HVAC ducts and plenums. Bahnson Service Company was a subcontractor to Brown & Root for all HVAC duct and plenum construction. The installation of this equipment was characterized by a single craft

-- sheet metal workers and welders and a single subcontractor.

Installation and fabrication procedures are based"on Gibbs & Hill ,

Specification MS-85. The attributes associated with each work l process were reviewed and appeared to be complete.

b. HVAC Ecutoment. There are 604 items in the HVAC equipment category. This equipment was either installed by Brown & Root _

or Bahnson and this was the basis for subdividing this category.

The work processes associated with HVAC equipment installation ,

are, basically the setting of the equipment and then connecting it. These two work processes are being evaluated for each installer of this equipment. Further, the attributes of each work process DRAFT

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.4 are the same, regardless of the installer. The attributes associated with the work processes were reviewed and appeared appropriate for.the process. '

c. Field Fabricated Tanks. This particular activity was discussed in a qualitative manner. We were informed that eight field fabricated tanks exist and that all would be reinspected.

This was not pursued further as population homogeniety was not an issue because of the 100% reinspection.

d. Mechanical Equipment Installation. Mechanical equipment installation encompasses 336 items to be installed in.both Unit 1 and Unit 2. The governing design document is Gibbs &. Hill Mechanical Erection Specification 2323-MS-101. The implementation of this is accomplished by Brown & Root Specification titled " General Installation of Mechanical Equipment", CP-1. The governing quality assurance procedure is Brown & Root QI/QAP11.1-39 titled " Mechanical Equipment Installation Inspection". Qualitative results of the sampling conducted so far indicates that 20-25% of the sample drawn is from Unit 2. The remainder of the sample is from Unit I and conmon areas. The work processes associated with mechanical equipment installation are setting, anchoring, welding and, for rotating equipment only, alignment. The attributes of each work process were discussed in depth. ERC personnel indicated r that if a particular i attribute of the work process was not addressed when the sampling activity was completed, assessment would be made as to whether or not the sample needed to be expanded to include that attribute.

! If a decision was made not to specifically address that attribute,

the basis for this decision would be provided in the report addressing the construction adequacy evaluation of, in this instance, mechanical -

equipment. Work process homogeniaty is evaluated by checking to l make sure that the same organizations are involved, procedures have remained nominally constant, and that the welder inspector l

qualification' standards have remained the same. Sampling is performed WET

. .Iwwn-tu-zz 14:d/ tmiiktLE coLunsus 14ew111 ew at the work process level. Since evaluation of eauipment is made at the work process level, each sample will be expanded such that sixty evaluations will be made for each work process. This means that more than the minimum number of equipment items (60) are addressed during completion of the sampling process.

This particular category was pursued further in that an installation procedure for a heat exchanger and a pump (rotating equipment) was reviewed to evaluate the compatibility of the attributes associated with work processes with the installation requirements contained in the procedure. Compatibility did appear to exist between the work process attributes and installation procedures for both cases.

In one case, the installation procedure for heat exchanger CPI-CCAHHX-01

~

was reviewed to see if this specific installation procedure was compatible with the attributes of the work processes for mechanical equipment installation. The procedure for installing an auxilliary feed water pump, CP1-AFAP-MD-01 was reviewed to evaluate its compatibility with the alignment work process attributes.

The work processes and their attributes are considered to be appropriate to the installation of mechanical equipment. Further, work process population homogeniety appeared to exist based on the two installation procedures reviewed.

e./f. Large Bore Pipino Configuration /Small Bore Pioing Configuration.

The large and small bore piping configuration construction adequacy

! reviews were addressed together using 3000 Brown & Root isometric drawings. The scope of this activity is intended to assess the work process of piping installation through evaluation of attributes l such as location, size and orientation of piping and pipe components.

I The Brown & Root isometric drawings provide the basis for sampling both large and small bore piping. Large bore piping includes that -

piping which is 2h inches and larger in diameter; small bore piping is that piping less than 2 inches in diameter. If an isometric drawing containing both large and small bore piping were to be b

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g drawn as part of a sample, it conceivably could be used in both the .large and the small bore work process populations. The installation work process and its attributes are the same for both large and s' mall bore piping. The piping considered in this review includes all ASME code piping. As with the other mechanical categories, a sample of sixty will be drawn for large bore piping and another sample of 60 will be drawn for small bore piping at random. Each sample would then be examined and expanded to ensure that sixty cases of piping within safe shutdown systems were considered for each large and small bore piping. ERC reported that all piping of large and small bore is installed to one procedure and by one craft -- pipe fitters. Some attributes such as piping valves would obviously be included in any sample for drawn for either large or small bore piping. There are other attributes such as expansion joints, screw joints, and strainers which because they are very few in the system, might not be included in a sample. ERC reported that following the sampling process a review to assess the adequacy of this sample for construction adequacy review would bo made.

However, a specific component, because it was not included in a sample, would not necessarily be examined only for that reason.

The number of attributes corresponding to the installation I of large bore piping appeared accurate and complete. However, the number of them seems to pro:1ude evaluation af th = =11 thenunh N"#

the random and enainteated_sa pl S; process. If ERC suggests that it is not imperative that all such as screwed joints, strainers, and expans. ion joints be evaluated from a configuration viewpoint, their report should justify this type of conclusion. It appears that the sample should include some number of components which are not extensively used in piping to provide confidence that these j components are installed correctly. Their sampling process appears -

to address the key items such as piping orientation, valve location l and orientation, and bands. l l

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g./h. Laroe Bore Pipe Welds & Material /Small Bore pipe Welds

& Materials. As with large and small bore pipe configuration, the welding of large and small bore pipe are considered as one grouping. Separate samples, however, are utilized to address each.

More than 66,000 welds are required to connect safety-related large and small bore piping. The work processes associated with welding of either large or small bore are prewelding, welding, post-welding.

As with the other categories within the mechanical discipline, the population description was reviewed and appeared complete.

The process of construction adequacy review is about 40% complete.

The initial review has been completed; samples have been drawn and preparation of reinspection procedures is in process. Approximately 65% of the sample drawn is either Unit 1 or coninon. The remainder is Unit 2. ERC personnel were not sure if any Class 1 welds were included in the sampling. It was indicated that Brown & Root performed all field welding. ERC'further reported that the wold inspection processes are the same regardless of the ASME code class. The categories of large and small bore pipe welds were not separated to distinguish between the welding of stainless steel pipe opposed to carbon steel pipe. ERC indicated that the welders were qualified to weld both stainless steel and carbon steel piping and hence

, there was no need to separate this. At the exit, the staff expressed concern regarding the lumping of stainless steel welding with carbon steel welds. ERC agreed to review the sample to determine the number of stainless and carbon steel welds. Wolds addressed by this study include only field welds.

Welds of the penetration sleeve to flange were included within this category. There are 282 such welds in this category. None were included in the random or engineering sampling, however, the large and small bore samples were supplemented to include one mechanical and one electrical penetration weld.

. Welds work processes and attributes appeared complete but conclusions regarding population homogeneity cannot be reached until review of implementation procedures and welder qualifications is completed. Further, as previously noted, concern exists for the consideration of stainless and' arbon steel welds as part of the same population.

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i. Pipina System Bolted Joints. Two work processes comprise the piping system bolted joint category. They are installation preparation and final bolt fitup. There are 7000 bolted joints -

it the Comanche Peak Power Station . The work processes and their attributes appeared to be compatible with the bolting of piping joints. The procedure which governs this is CP-CPM-6.9E Rev. 8.

A flow chart and population deceription had been prepared to provide the basis for the sampling of bolted joints. The staff's review did not yet pursue this to the depth required to draw a firm conclusion regarding the homogeneous nature of the work process populations.

6. Electrical Discipline
7. Civil / Structural Discipline ,
8. Conclusion 9

0 e 8 DWI 4

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... / 'o,, UNITED $TATES -

! g NUCLEAR REGULATORY COMMISSION O E WASHINGTON, D. C. 20555 I

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OCT !. :. ad NOTE T0: Harold Denton Jim Taylor Bob Martin Darrell Eisenhut Dick Vollmer Hugh Thompson Brian Grimes Jane Axelrad Dick Denise Ed Christenbury Ed Jordan FROM: Vincent Noonan

SUBJECT:

COMANCHE PEAK RESPONSE TEAM (CPRT) STATUS P. Keshishian recently visited the Comanche Peak site to discuss status and progress with various CPRT managers. I have enclosed a copy of his trip report. Any NRC management action needed will be identified separately.

This report will be the final one of this type relative to CPRT activities.

More comprehensive reports of site construction activities are now being issued by Region IV in the fom of a monthly status repor IE is also issuing a weekly design adequacy review report.

gy -

. o an , Director

'manche P ak Pro $ect

Enclosure:

P. Keshishian to V. Noonan memo dated 10/22/85 cc: H. Livemore T. Westerman, RIV C. Hale, RIV L. Shao, CPP J. Calvo, CPP C. Tramell, CPP S. Treby, ELD L. Chandler, ELD D. Norkin, IE D. Landers, TELEDYNE C. Haughney, CPP R. Heishman, IE R. Rohrbacher, IE J. Milhoan, IE t ?,9 b G- l3

- OCT221985 MEMORANDlH FOR: Vincent S. Noonan, Director Comanche Peak Pioject FROM: Paul Keshishian Comanche Peak Project

SUBJECT:

COMANCHE PEAK RESPONSE TEAM VERIFICATION AND CORRECTIVE ACTION ACTIVITIES A review was conducted of the ongoing Comanche Peak Response Team (CPRT) activities during the period of October 1h-18, 1985. The principal CPRT activities in progress at the present time are those associated with the:

1.- Stone & Webster (SWEC) Design Verification Effort <

2.- Ebasco Design Verification Effort '

3.- TERA Design Verification Effort k.- QA/QC Construction Verification Effort 5.- TRT Issue Specific Action Plans Implementation.

1. Stone & Webster Design Yerification Effort This effort will involve a reanalysis of Unit #1 large bore Class 2 and 3 piping and supports and an evaluation of non-Westinghouse designed supports on Class 1 piping. In addition, for Unit #1, a sample reanalysis of small bore Class 2 and 3 piping will be perforr.ed. For Unit #2, similar work will be performed for large bore piping and supports, however, the reanalysis will include 100% of Class 2 and 3 small bore piping. The re-analysis effort will be perfomed utilizing established SWEC methodologies.

TERA is conducting the third-party overview of this activity.

a. _ Current Activities: '

(1) SWEC is continuing to mobilize manpower for this task at the site and off-site offices and present indications are that the work will be perfomed at a number of locations. The New York office of SWEC will manage and participate in the effort and design verification work will also be performed at their Houston, Boston, Cherry Hill and Toronto offices.

(2) SWEC is in the process of completing two key procedures necessary for their portion of the piping and support verification work. Comanche Peak Project Frocedure (CPPP) #7 " Design Criteria for Pipe Stress and Pipe Supports" is expected to be issued by October 25th. CPPP #6 " Pipe Stress Analysis for As-Built MD

ASME Class 2 and 3 Piping ~ Systems" is expected to be issued -

- by October 25th.

(3) Of the approximate 300 large bore pipe and support stress analysis packages required by WEC for reanalysis of Unit

  1. 1, 178 have been transmitted from the site to SWEC.

(b) Prior to the initiation of the WEC effort TUGC0 had decided to modify some 200 large bore supports on each unit. This work was temporarily stopped the week of August 26th. This modification work is now proceeding as previously scheduled.

The redesign of these supports by TUGC0 are being verified by the site SWEC engineers prior to being released to construction.

(5) SWEC is in the process of developing a methodology to permit representative sampling of the Unit #1 anall bore piping and supports to permit stress snalysis. It is anticipated that this effort will be completed by mid-November and then will be submitted for review by the NRC staff.

(6) Piping and support analysis for Unit #2 has been initiated.

To date a few large bore stress problems have been completed and 13 small bore stress problems are in the reconciliation phase.

Large bore stress problems will be perfomed off-site and #2 unit small bore stress problems will be perfomed by the on-site SWEC engineers.

(7) The present estimate for SWEC completion of Unit #1 work of the reanalysis effort is May 1986, and Unit #2 reanalysis by the Fall of 1986. The completion date for modifications and redesign re-sulting from the reanalysis effort will be dependent upon the extent of Modifications and redesign required.

(8) The WEC reanalysis of and possible modification and redesign of supports for Comanche Peak will be considered to be the design of record. Third party overview of WEC's effort will be performeo by TERA as described in the Program Plan.

(9) In early October, the NRC staff met with SWEC and TUGC0 at a public meeting and discussed the issues of large bore piping and support walkdowns. The attributes being reviewed by SWEC will be expanded during their walkdowns.  ;

(10) TUGC0 has tentatively scheduled audits of the SWEC site and New l' York Office activities for the latter part of October.

SWEC Engineering Assurance has performed an audit of the SWEC l' New York Office activities and has scheduled audits of the Boston and Cherry Hill activities for November 1985 ,

(11) The current estimate for the SWEC reanalysis, modification 2

and redesign effort is estimated to be 675,000 manhours. This estimate does not include the manhours associated with the l physical hardware changes.
2. EBASCO Design Verification Effort This effort involves a complete verification of original design and as-built construction associated with the design and construction of j the Unit #1 and #2 electrical cable tray and conduit suopn-ta. l
a. Current Activities:

(1) For Unit #1 and those cable tray supports in the. common area serving Unit F1, of h527 supports approximately 1270 have been as-built. l Of these 1270, some 933 have been transmitted to EBASCO for design verification.

l (2) At the time of the inspection there were 17 walkdown teams document-ing Unit #1 as-built conditions for cable tray supports. These teams consist each of an engineer, QC inspector and construction personnel. The present intent, is to increase the number of teams to 25 in order to complete the walkdown effort by the end of Decenber.

(3) On Unit #1, TUGC0 has determined the total population of conduit .

supports. This conduit population has been further subdivided into discrete populations for power / control and lighting groups.

Sanples of 60 runs will be selected for each of the two groups to establish a statistically based sample and their.walkdown teams will document their as-built condition. Subsequent to the as-built determination TUGC0 will analyze the supports and perform design modifications ad required. The as-built walkdowns are presently underway and should be completed by mid-December. The TUGC0 engi-neering analysis should be completed by the end of December and will be reviewed by Gibbs and Hill. i (h) The Unit #2 cable. tray supports and those supports in the comon area serving Unit #2, a total of 3859, have been as-built verified.

Of the total supports, 2876 have been design verified. EBASCO ex-perience to date indicates that approximately 25% of these vill require actual field minor and major modifications. These modifications are now in progress and of the estimated 950 supports requiring decign modifications 680 have been design modified. To date very few of the supports have been fiela modified. The present schedule calls for completion of the design verification and modification effort by April 1986.

(5) of approximately 15,000 conduit supports required for Unit #2 some 13,000 supports have been installed. These supports are being designed to more conservative criteria than that utilized for Unit #1 and incorporate those modifications that were considered necessary for 3

a I Unit #1. Many of the Unit #1 conduit-supports had utilized Unistrut  !

but on Unit #2 Unistrut has not been utilized for conduit support  !

design.

(6) Corporate consulting and Development has been conducting a series of tests for conduit suppcrts. The purpose of this test program is to demonstrate that the Unistrut supports used in the Seismic Category I conduit and junction box supports are structurally adequate to withstand the maximum loads postulated to be applied to the supports during the design basis earthquake condition. These tests are asso-ciated with the use of Unistrut, conduit clamps and junction boxes for the conduit and support installations. Some of the above testing is complete and the balance of the testing is expected to be completed by January 1986. As a result of these tests, modifications will be required to some Unistrut, conduit clamps and junction box installa-tions.

(7) Drider TUGC0 direction, ANCO Engineers is phnning to conduct a series of tests in support of the Unit #1 cable tray support program. These 4 -

tests involve shake table testing, Hilti bolt base plate connections, cable tray clamps, and specific support configurations. The objective of this test program is to verify modelling assumptions perfomed by Gibbs and Hill and to support modelling planned .by TERA. This testing is scheduled to start in the first week of November at ANCO facili-ties in Culver City, California and the total test program is scheduled to be corr.pleted by March 1986.

(B) TUGC0 recently employed Impe11 Corporation as a consultant to review the portion of the cable tray support design being performed by EBASCO. The objective of the Impell overview is to determine if some of the cable tray support modifications being recomir. ended by EBASCO can be safely reduced.

(9) Within the past month TUGC0 corporate quality assurance and Gibbs and Hill quality assurance organizations have conducted audits of the EBASCO site and home office activities.

i (10) A revised estimate has been made of the effort required by EBASCO to complete their work associated with the cable tray and conduit supports.

The most recent estimate for the total EBASCO plant effort is 1,500,000 manhours.

3. TERA Design Verification Effort TERA is responsible for the Design Adequacy Plan, acts as third party i

reviewer for design review, resolution of TRT issue specific action plans for the mechanical, civil and structural areas, tracking all external issues and will prepare and issue a final design adequacy report at the conclusion of their effort.

h l

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a. Current Activities (1) TERA has essentially completed the Design Adequacy Procedures (DAP) for implementation of their design review process. Of the total of 19'CPRT - DAP procedures required, 17 have been issued for use and the remaining two have been released for interim use.

(2) TERA's site force of a manager and six issue coordinators are per-forming their respective activities relative to the TRT Issue Specific Action Plans that they are participating in.

(3) TERA has developed and placed in service a computer based tracking system for all external source issues. This system, on demand, will identify the issue, the source of the issue, and status. The issues are being added to the tracking system and some lh0 specific piping and support issues have been identified and transmitted to Stone and Webster.

(h) TERA has received the NRC's staff programmatic and detailed comments to the CPRT Program Plan and is in the process of presenting their suggested revisions for their portion of the work to the CPRT Senior Review Team.

(5) TERA is now completing the Phase 3 effort of their Design Adequacy Plan. The Phase 3 effort involves the performance of validation checks to confirm that the design review areas selected can be uti-lized as representative of the total plant design. The NRC staff plans to review this Phase 3 effort in the latter part of October.

(6) TERA is continuing to review detailed equipment lists to identify those vendors that supplied hardware unique to the Comanche Peak site. This effort is being performed to assure that hardware de-livered to the site is in accordance with FSAR requirements and procurement specifications.

(7) TERA has essentially completed the review of the Gibbs and Hill drawings for the redesign of. the cor.tnol room ceiling. Their comments have been transmitted to Gibbs and Hill.

(8) TERA is continuing to prepare procedures and. inspection check lists to implement their design verification activities for the Auxiliary Feedwater System and the Electric Power System.

(9) The IE Division of Quality Assurance, Vendor and Technical Training Center Programs continues to evaluate the TERA Design Adequacy Program.

They are issuing weekly reports to document the progress of their evaluation of the DAP.

5

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(10) The current estimate for the TERA scope of work involved in the CPRT effort is now 110,000 manhours.

h. QA/QC Construction Verification Effort This effort encompasses a statistically based sample reinspection of QC accepted construction work supplemented by a review of related quality documentation.
a. Current Activities:

(1) The administrative control procedures for this effort are complete and issued. Overall control of this effort is also contained in a Management Plan that describes which of the 10CFR 50 Appendix B criteria are applicable to this effort.

(2) The 26 hardware population descriptions for the construction veri-t ~,

fication effort have been completed. For the present scope of reinspection about 22h0 inspection packages will be required to conduct all reinspections. As of October 11, 1985 9h6 of these i' packages had been utilized for field inspections. By this measure, approximately h0% of the field inspections have been  ;

completed.  !

(3) As a result of the hardware inspections 923 Deviation Reports ,

(DRs) have been issued as of October 11, 1985. Of these 923 DRs some h3h have been determined to be valid of which 187 have been i evaluated for safety significance. A separate Safety Significance j Evaluation Group of 30 engineers conduct independent evaluations I of valid DRs to determine safety significance. I (h) Valid DRs are transmitted to TUGC0 where a TUGC0 Inspection Report

- and Nonconformance Report are generated for tracking, dispositioning l and implementing corrective action where necessary. This process j maintains the facility inspection of record under TUGC0 control and l places documentation and corrective action under the TUUC0 Quality -)

Assurance Program.

(5) Region IV is maintaining its goal of witnessing 10% of the rein-spections and independently inspecting 5%. Monthly meetings are being held with TUGC0 to comment on the reinspection effort and R-IV is currently issuing a monthly inspection report that documents their efforts in the hardware and documentation verification effort.

(6) The internal Quality Assurance Program relative to the construction verif.4 cation effort is currently being implemented. To date one audit

and 15 surveillances of their reinspection activities have been
conducted.

i

. (7) The review of hardware documentation packages is now in progress.

This effort is utilized to assess items that are inaccessible or non-recreatable. Of the approximate 2360 documentation packages to be reviewed, 580 packages have been issued and 360 have been reviewed as of October 11, 1985. Of the packages reviewed, some 367 DRs have been generated. The detemination of the validity and safety significance of these DRs has not yet fully cossnenced.

(8) Staffing for the Q&/QC construction verification effort was at 171 persons on site during the week of October lh, 1985. It is anticipated:that this effort will peak out at about 180 persons.

(9) At the time of the inspection it is estimated that about 30% of the total hardware and documentation reinspection effort has been completed. This effort is now approximately one month behind schedule and is anticipated to be corrpleted in February 1986.

(10) The cura nt estimate for the construction verification and documenta-tion review effort is approximately 190,000 manhours.

5. TRT Issue Specific Action Plans-Implementation Each of SSER's prepared as a result of the TRT inspections resulted in specific actions required by TUEC to resolve outs +=nM ng deficiencies.

For each of the issue specific items TUEC has developed action plans and is in the process of implementing them. As each of the action plans is completed a results report will be prepared for each item. The specific details for each of the following TRT issue specific items can be found in the respective SSERs or in the Program Plan under Appendix C..

a. Current Activities:

The following is a listing of the TRT items and their status at the time of the site review:

ITEM STATUS

. Heat Shrinkable . Actions completed.

Insulation Sleeves (I.a.1) Preparing results report

. Inspection Reports on Butt Splices (I.a.2) . Actions completed. As result of QC Inspector reviews action plan being expanded.

. Butt Splice Qualification . Actions completed.

(I.a.3) Results report in review cycle.

. Agreement Between DWGS . Actions completed.

i and Field Term's (I.a.h) Revising-results report.

. NCRs on Vendor Installed . Work completed.

Amp. Terminal Plugs (I.a.5) Results report in

' review cycle.

7

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ITEM STATUS

. Flexible Conduit To . Additional analysis in Flex. Conduit Separation (I.b.1) progress.

. Flex. Conduit to Cable . Additional analysis in Separation (I.b.2) progress.

. Conduit to Cable Tray . Actions completed.

Separation (I.b.3) Results report in review cycle.

. Barrier Removal (I.b.h) . l.;tions completed.

Preparing results report.

. Electrical Conduit . Analysis and walkdowns in Supports (I.C) progress.

. QC Inspector Qur.l's . Electrical Inspector (I.d.1) Qualifications Review in progress.

. Guidelines for Admin. . Procedure completed.

Of QC Inspection Test (I.d.2) Reviewing implementation.

Preparing results report.

. Reinforcing Steel In . Work completed.

The Reactor Cavity (II.a) Results report in preparation.

. Concrete Compression . Field work completed.

Strength (II.b) Preparing results report.

. Maint. of Air Gap . Mapping of air gaps is Between Concrete complete. Removal of Buildings (II.c) concrete and debris to start shortly.

. Seismic Design of . Gibbs & Hill design of Control Room Ceiling new ceiling complete. TERA Elements (II.d) reviewed design and submitted comments.

. Rebar in the Fuel . Evaluation in progress.

Handling Building (II.e)

. Hot Functional (HFT) . Review completed.

Data Packages (III.a.1) Preparing results report.

. JTG Approval ofcTest . Work complete.Results Data (III.a.2) report in review cycle.

8

l i

l ITEM STATUS 1

. Technical Specification . Work complete. Action For Deferred Tests (III.a.3) Plan implemented.

. Traceability of Test . Work complete. Results Equipment (III.a.14) report in review cycle.

Conduct of CILRT (III.b) . Work complete. Preparing results, report.

. Prerequisite Testing (III.c) . Evaluation complete.

Results report in review cycle.

. Preoperational Testing (III.d) . Review completed.

Results report in review cycle.

. Skewed Welds in NF . Sample inspected.

Supports (V.a) Engineers evaluating results.

. Steam Generator . Work on " Hold". Awaiting Anchor Bolts (V.b) completion of evaluation of upper lateral support by Gibbs and Hill.

. Design Consideration . Reanalysis to be performed For Piping Systems Bet. by SWEC with overview Seis CAT I & Non-Seismic by TERA.

l Cat I Bldgs. (V.c)

. Plug Welds (V.d) . Inspection in Progress.

. Installation of Main . Completed field work.

Steam Pipes (V.e) Results report in review cycle.

. Gap Between Reactor . Design change and critical Vessel Insulation & space review in progress.

Biological Shield Wall (VI.a) Preparing sample population list and. conducting 1 reviews.

. Polar Crane Shimming (VI.b) . Crane Rail motion test complete.

To make final inspections.

. Valve Disassembly (VII.b.2) . Results report in review cycle.

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ITEM STATUS

. Material Traceability . Review pending input (VII.a.1) from other reinspection activities.

. Non-conformance and . Review of various corrective Corrective Action Systems action systems continues.

(VII.a.2)

. Document Control (VII.a.3) . Review pending results from VII.c document review

. Audit Program and Auditor . Results report in review Qualification (VII.a.h) cycle.

. Manegement Assessment . Review in progress.

(VII.a.5) Examining INPO and other utility programs.

. Exit Interviews (VII.a.6) . Review in progress.

Examining other utility programs.

. Housekeeping and system . Preparing results report.

Cleanliness (VII.a.7)

. Fuel Pool Liner Documentation . Review of travellers (VII.a.8) in progress.

. Onsite Fabrication . Sample selection completed.

VII.b.1) Review of packages to start shortly

. Valve Disassembly . Results report in (VII.b.2) review cycle.

. Pipe Supports (VII.b.3) . Issuing reinspection packages.

. Hilti Bolts (VII.b.h) . Developing torque test program.

. Electrical Raceway Supports . Selected sample, (VII.b.5) preparing inspection packages.

emerl

' t_.

Paul Keshishian Comanche Peak Project l

l l

-- 5 i, c u:

'o UNITED STATES

/

! g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

  • ,t a

\...../ acr , ,

MEMORANDUM FOR:

J.A. Calvo, Manager Systems / Operational Group Comanche Peak Project FROM:

E.B. Tomlinson, Leader Review Support Group Systems / Operational Group Comanche Peak Project

SUBJECT:

TRIP REPORT - Comanche Peak Site Visit Attached is a report of the Comanche Peak Site visit by E. Tomlinson, J. Knox and P. Chan during the period of September 10-12, 1985.

b G772 W E.B. Tomlinson, Leader v

Review Support Group 3 Systems / Operational Group Comanche Peak Project D

/ (J I-Attachment g yg f cc: V. Noonan C. Poslusny C. Tramell

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,s A. Vietti-Cook T. Westerman - RIV -

(. #' j

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e_ A. Johnson - RIV

),f- v['

) "'i' J. Knox .

C, P. Chan - LLNL F t 4

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E. Marinos '

Docket 445/446 files g ' y,./

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S' I.D e

', Trip Report Travel to Comanche Peak Sept. 10-12, 1985 1

During the period of Sept. 10-12, 1985, the following Comanche Peak Project (CPP) personnel / consultants visited the Comanche Peak Site:

E. B. Tomlinson - Comanche Peak Project J. Knox - Comanche Peak Project P.M. Chan - Comanche Peak Project (Consultant)

The site visit was for multiple purposes as listed below:

Discuss and exchange technical information relating to ISAP I.B.I.

Discuss the impact of SSER #11 on electrical and instrumentation action items identified in SSER # 7.

Obtain and review data associated with specific allegations currently under review by the Systems / Operational (S/0) Group of the Comanche Peak Project.

Follow up on potential problems with cable bend radius identified in CAT Report of April, 1983.

The following Region IV personnel were contacted during the site visit:

H. Phillips T. Westerman I. Barnes A. Johnson

~

The following 'Jtility/ Contractor personnel were contacted during the site A- visit:

I

{ R. Camp I. Vogelsang T. Tyler M. Jones W. Stroop S. Martinovich l

F. Powers L. Bates During the visit we had discussions with the applicant regarding ISAP 1.B.I.

These discussions covered TRT's position regarding cable separation in the effected panels and the justification for this position. The disc.ussion also covered the various options open to the applicant to demonstrate the acceptability of their design. No specific conclusions were reached as a

result of these discussions. It was agreed, however, that the option (s) selected by the applicant would be detailed in a Results Report which would be submitted fomally to the NRC CPP staff for review.

This inspection A thorough inspection of Bisco seals was conducted in Unit 1.

covered penetration seals which had been partially removed for pulling new cables, seals through which new cables were in the process Theofseals beinginspected pulled, completed seals, and completed seals with ploymer caps.

included those for air drop and sleeve penetrations in both vertical and horizontal positions. The seals were inspected from both top and bottom (for The vertical penetrations) and from both sides (for horizontal penetrations).

inspection included lengthy discussions with craft and QA/QC personnel regarding procedures for seal removal, seal restoration and inspection of work.

We also inspected the tools used for seal removal. No conclusions were reached or discussed during or after this inspection. The results of this inspection will be documented in the Systems / Operational Group inputs to a SSER covering specific allegations.

Considerable time and effort was spent locating, obtaining, and reviewing data relative to the Systems / Operational Group's on-going review of specific allegations. The results of this effort will be reported in a supplement to the SER.

The final significant item discussed was follow up on the problem ofThe cable bend radius which was identified in the CAT report of April,1983.

Applicant provided documentation on the follow up for the specific cables identified in the CAT Report. In addition to the specific follow up, l inspection of cables for proper bend radius is included in the CPRT Program Plan. The CAT Report follow up will be covered in more detail in a separate report.

On Thursday afternoon Sept. 12, we conducted an exit interview with the

-applicant. An outline of the major discussion point covered in this interview is included as an attachment to this report.

I l

It is the consensus of the S/0 personnel that this was a productivc trip both '

'- in terms of infomation exchange and establishing working relationships with Region IV CPRT personnel.

It should be noted that the Region IV CPRT office was outstanding in their cooperation and efforts on our behalf to make this a worthwhile visit. Without this cooperation, we could not have accomplished I recomend the Region IV efforts be anywhere near as much as we did.

acknowledged separately.

Exit Interview CPP Site Visit ,

9/10-12/85 P,urpose

1. To review dato and conduct physical inspections relative to ongoing evaluatior.s of specific allegations for inclusion in a supplement of the CP SER (currently scheduled for #12).

AE-55, AE-56, AQE-34, 8 AQE-37

2. Informal discussions and exchange of technical information regarding ISAP I.B.I.
3. Informal discussions of Appendix P of SSER # 11 as it relates to SSER #7 items.
4. Obtain information regarding the disposition of item II.B.1.b in CAT Report dated 4/11/83.

Activities

1. Conducted physical inspection of penetration seals in Unit No. I which had been partially removed for the purpose of pulling additional cables.

Inspection covered the control room, cable spreading room, and mechanical equipment room. Obtained samples of seal material and seal dam material. Obtained and reviewed data relative to the above mentioned allegations.

2. Discussed the various options for possible resolution of ISAP I.B.I.
3. Appendix P of SSER fil as it relates to electrical, instrumentation and

'- control items will be discussed in the next revision to the CPRT Program Plan.

4. Obtained copies of NCR's covering item II.B.1.b of the CAT Report and a copy of Instruction No. QI-014 covering cable reinspection.

Conclusions No conclusions were drawn or discussed during this visit.

l Deviations, Violatio,ns, etc.

None _

Utility Cooperation Excellent

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PAGE 1 0F 5 8D ,7vol COMANCHE PtaK .MEAM ELECTRIC STATION

- DESIGN CHANGE AUTHORIZATION

.TUGC0(2)

} (WILL) (MB88XR81) BE INCORPORATED IN DESIGN DOCUMENT DCA N0 19948 REV 2 v' l . SAFETY RELATED DOCUMENT: XX YES N0

2. ORIGINATOR: THE XX CPPE b

ORIGINAL DESIGNER

3. DESCRIPTION: 2323-El-0710-01 20 2323-E2-1700 205 A. APPLICABLE $M/DWG/dOMMf( 2323-El-1700 REV. 326
8. DETAILS "THIS R.EVISION VOIDS AND SUPERSEDES DCA#19,948 REV. l'"

PROBLEM: Due to EWI-300, deletion and sparing of numerous cables is required.

SOLUTION: Delete and spare affected cables as shown on attached pages.

REY. 1 : Revises page 2 as shown.

REV. 2: Removes cable E0146313A from page 3 as noted.

NO FIELD WORK REQUIRED -

0I303 a IIII.i., IMC.

Oc t- urn 4\ L b/ 6 4 V L 3./ Wil0M 3 "

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bd JAN 181985 JAN 2 91985 lbl % dT[IG a DOCUMENT CONTROL ~

4. SUPPORTING DOCUMENTATION:

DCA#19862 REV.1; DCA#1S542 REV.12; DCA#14884 REV. 3; DCA#19921 REV. O AND Weh :n.p n:: r _: A N1 FNC'\F:7 \n C O M Y',

- 5. APPROVAL SIGNATURES; MDA:ylb JANUAP.Y 11, 1985 A. ORIGINATOR: DATE /-/5 /f

B. DESIGN REPRESENTATIVE
a.-- /M DATE /-/.s'-sh' C. DESIGN REVIEW PRIOR TO ISSUE:

[ _ <M _

DATE//2#/86

/ / /

]6. STANDARD DISTRIBUTION:MIKE ANDERSON Westinghouse (1)

TNE U/1 TF (1)

ARMS (ORIGINAL) (1) M ELL 1 ns gag]{,,ENG{}EERING , , _ Q} DARR0N SLOVER EsE U/2 TF (1) -

_.m .vu v ra u . m . m. '

t

/

MARK WELCH QA (1) g '

    • : i '. ' .?

DCA #19,948 R.2.

)~- -

Page 2 of 5 Spare cables as indicated below:

Old Cable Number New Cable Nuecer Oricin Destination E0015921 SP015921 T130CCP97 T130CCP44 E0015922 5P015922 T130CC045 T130CCP44 EG015953 SP015953 JB1A-795G XTC04 E0015956 SP015956 XCV03 JB1A-17200

.- A0016528 SP016528 1CR07 1CR13 EG016591 SP016591 J81A-777G XCV03 E0016592 SP016592 JS1A-7830 XTC03 EG016594 SP016'594 JBIA-792G XCV03 EG016597 SP016597 JBIA-795G XCV03 l 3016599 SP0165995 JBIA-17200 XCV03 E0016601 5P016601 JE1A-7960 XTC03 EG016616 SP016616 1CR04 XCV03 E0016618 5P016618 1CR03 XTC_03 SPC18S11 7C203 .;B1A-7sca E0018811 E0021850 5P021850 1CR03 XCV03

' EG021851 57021851 1CR04 XCV03 EG021852 SP021852 ICR14 XCV03 E0021854 SP021854 1CR03 XTC03 .

SP021855 CR13 XTC03 E2021855

[SP02[18565) 1CR15 XCV01 EG021856 SP021860 XTC03 XCV03 l E0021850 EG021909M SP021909M XC'403 .1/A f 2CR04 EG021909N SPC21909N tt/A E0206145 SP206145 2TC41 2CR03 l L ..

.~.--.___._ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ , , _ _ _ , _ , , _

.- - ~ .-.. .-- --...-- -.

..!- N . DCA #19.948 R.12.

Page .3 of 5 1

Old Cable Number New Cable Number Oricin Destination EG021925M SP021925M 1CR04 N/A EG021925N SP021925N N/A 2CR04 E0021936M SP021936M XCV03 N/A E0021936N SP021936N N/A 2CV02A EG140016 SP140016 1CR15 XTC04 E0140017 SP140017 1CR03 XCV03 E0140018 SP140018 1CR03 2CV02A Delete and remove the follcwing cables:

E0016065 EG016076 E0015921A E0015921B

~~ ~ ~ ' ' ~ ~ ~

E0015921C~

! Delete and remove conduits listed below:

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?- PAGE b 0F 5 .

M .

CABLE CARD REVISION CODE

./ NOTE: FOR GIBBS & HILL USE ONLY L ,

REV. REV. REV.

CABLE CODE CABLE

~

CODE CABLE CODi '

< E6015921 216G E6021760 2 526 L Ed015921 A 0300 E$O21909M 2r596 E$ois92 i s 2s.W5F5 oils'o9 W ' 2 > n!\

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Ed 01659I IGGA <[ i _h 3 A__  !

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E0 / G594 25 %

E 416 59 7 32 %

Ed/G599 33C6 E HoGol 2g L E6d (oG l(o noA -

E6cl661 T 2996 . . . . . . . . . . . . .

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Edo21756 2666 4

, C. ACHE PEAK SitiAM ELECTRIC S* .N #' '*/ ' '

  • u NTIES NONCONmRMANCE D.E"%i NCR; dE"8 RATINC. co

. J-S5- /00486S Page 1 of 2[ g UNIT $?RUCTURE/ SYSTEM ITEM / COMPONENT TAG /IO NUMBER LOCATION OR ELEVATION AIR NO.

I 6401 CPI-ECPRCR-01&O: Unit 1 Control TBX-ESELSP-01 Room El. 830' N/A 50NCONFORMING CONDITION CP-SAP-6 paragraphs 4.1.4 and 4.1.4.1 state "_A SWA vill be processed in accordance with this procedure for the following: . Work to be perfc,rmed by contractor personnel in I accordance with normal . construction and inspection procedures as required to make the f installation conform to drawings or specifications which affects system or component s

j operability..."

Contrary to this requirement, the portions of ECN-203 (TUGC0 Deci ,n 7 Modification 3

DM-84-183) affecting Solid State Protection System (SSPS) Output Cabinet No. I b

,j Train "A" and Train "B" (TBX-ESELSP-01) and Solid State Safeguards Sequencer (SSSS)

Cabinet Train "A" (CPI-ECPRCR-01) were implemented without an SWA. Only a portion of f

the snodifications within Train "B" Solid State Safeguards Sequencer (SSSS) cabinet CP-SAP-5 9 4,1, m ,1,4, REFERENCE CUCUMENT. pp ,,gA REPORTED BY:

Lon pffndlerg(TUGC0 Startup) ext. 490 LA a.u cMy x s

[ 5 DATE:

f 10 f 85 OE REVIEW /APPAOVAL: CATE:

y fj Y / l0/FS U ACTION ADDRESSEE -

DEPARTMENT ,

e . rspu.s- -- t'M7 " / \

DISPOSITION:

REWORK XX REPAIR USE AS IS SCRAP See pages 3 through 5 for disposition.

E tu C'

C O

Z 9

G n }

ENG. REVIEW / APPROVAL / DATE:

/ /

OE REVIEW APPROVAt: [ DATE. ,

wg Y f /2 f / fY l LOSU E: DATE:

O ' OLSP ITipN VERtFICATION &

b/28 Zar [29 4 /N/

i CCMMENTS:

I j L N'- + o 1

y hk .

?V-NCR- B - % 5- lOO4 l>3 Page 2 )I

&N y-21-9 f were done with an SWA (SWA 14948). The remaining Train "B" Sequencer modifications were accomplished without an SWA.

The following items were implemented without an SWA:

Train "A" SSPS Output Cabinet No. 1 (TBX-ESELSP-01)

Cable E0lll216(B) spared Cable E0lll216(W) spared Cable E0106994(B) spared Cable E0106994(W) spared Train "B" SSPS Output Cabinet No. 1 (TBX-ESELSP-01)

Cable EG111217(B) spared Cable EG111217(W) spared Cable EG107118(B) spared Cable EG107118(W) spared Train "A" SSSS Cabinet (cpl-ECPRCR-01)

'- Cable E0lll216(B) spared

- Cnbie E0lll216(W) spared Cable E0ll8517(WB) terminated 4 ,[-

-- - TB6-5 to TB24-9 jumper installed *

-TB6-6 to TB24-10 jumper installed

-TB24-9 to TB34-9 jumper lastolled Train "B" SSSS Cabinet (CP1-ECFRCR-02)

Cable EG111217(B) spared Cable EG111217(W) spared Cable EG016547 (WB) terminated

  • ~ TB6-5 to TB24-9 jumper installed

---TB6-6 to TB24-10 jumper installed CP-SAP-6 paragraphs 4.1.4 and 4.1.4.2 state "A SWA will be processed in accordance with this procedure for the following: Work to be performed in accordance with travelers issued by engineering or construction departments if the work affects system operability."

Contrary to this requirement, travelers EE85-ll460-8904 (MAR 85-2126) and EE85-11462-8904 (MAR 85-2122) were worked without an SWA.

Work performed by the travelers is as follows:

Traveler EE85-11460-8904 Replace butt splice of cable EG145739(BL) conductor.

, Traveler EE85-11462-8904 Determ cable E0111169 (0),(B),(BL),(R),(W) and (G) conductors and spread splices apart.

. ~.

~

s a'M* *,;CH81 TE.'.:. SLw ELECimC STATION _

o m mGCO. NONCONFORMANCE REPORT (NCR)

~

CONTINUATION SHEET Page _3 of 5 DISPOSITION:

1. The nonconformance as outlined on this NCR is the result of the confussion generated when working an item under two separate and independent programs.

Consider the following conflicts:

a. Train "A" SSPS Output Cabinet # 1 (TBX-ESELSP-01)

This cabinet is still under the custody of Start-Up and the requirements of CP-SAP-6 apply for any work affecting system operability. The cables waich were spared in this equipment, E0111216(B)&(W) and E0106994(B)&(W), are under the custody of TUGCo Operations and the requirements of STA-606 apply for any work affecting system operability.

b. Train "B" SSPS Output Cabinet # 1 (TBX-ESELSP-01)

This cabinet is still under the custody of Start-Up and the requirements of CP-SAP-6 apply for any work affecting system operability. The cables which were spared in this equipment, EG111217(B)&(W) and EG107118(B)&(W), are under the custody of TUGCo Operations and the requirements of STA-606 apply for any work affecting system operability,

c. Train "A" SSSS Cabinet (CPI-ECPRCR-01)

This cabinet is still under the custody of Start-Up and the requirements of CP-SAP-6 apply for any work affecting system operability. The cable which was terminated, E0118517(WB), and the jumpers which were installed (TC6-5 to TB24-9, TB6-6 to TB24-10 and TD24-9 to TB34-9) fall into this category. The cables which were spared in this equipment, E0111216 (D)&(W), are under the custody of TUGCo Operations and the requirweni.3 of 51 A-out apply for any worr attecting system operability.

d. Train "B" SSSS Cabinet (CP1-ECPRCR-02)

This cabinet is still under the custody of Start-Up and the requirements of CP-SAP-6 apply for any work affecting system operability. The cable which was terminated, EG016547(WB), and the jumpers which were installed (TB6-5 to TB24-9 and TB6-6 to TB24-10) fall into this category. The cables which were spared in this equipment, EG111217(B)&(W), are under the custody of TUGCo Operations and the requirements of STA-606 apply for any work affect-ing system operability.

e. Traveler EE85-11460-8904 Cable EG145739 (BL) is under the custody of Start-Up and the requirements of CP-SAP-6 apply for any work affecting system operability. The work was performed in Auxiliary Relay Rack CPI-ECPRCR-14 which is under the custody of TUGCo ,0perations and the requirements of STA-606 apply for any work affect-ing system operability. ,

M Ws-n-er

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5

,3. y ,g COH ANCHE PF8". T.TLe.1 ELECTTsv =TallON GENERATWG CO. NONCONFORMANCE REPORT (NCR)

-1004865 CONTINUATION SHEET

- Page 4 of -5 DISPOSITION CONTINUED:

f. Traveler EE85-11462-8904 Cable E0111169 (0), (B), (BL), (R), (W) and (G) is under the custody of Start-Up and the requirements of CP-SAP-6 apply for any work affecting system operability. The work was performed in Auxiliary Relay Rack CPI-ECPRCR-13 which is under the custody of TUGCo Operations and the requirements of STA-606 apply for any work affecting system operability.
2. The Unit 1 Paper Flow Group has been instructed to review all packages to establish custody control for every item contained therein to ensure that the proper paperwork is generated prior to issuance to field. See attached three part memo.

>- 3. Three SWA's shall be issued as follows:

a. One SUA shall be issued for Train ' A' SSPS Output Cabinet # 1 (TBX-ESELSP-01),

Train 'B' SSPS Output Cabinet # 1 (TBX-ESELSP-01), Train'A' 5555 Cabinet (CP1-ECPRCR-01) and Train 'B' SSSS Cabinet (CPI-ECPRCR-02).

b. One SUA shall be issued for traveler EE85-11460-8904.
c. One SWA shall be issued for traveler EE85-11462-8904.

NOTE: The applicable MAR's will be referenced on the SWA's.

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To  ; - - - . . _ - _ _

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, ,..m 6-23-86 -

~ 31;E LANITTPFUerKONkEL HAVE

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    stion Page 17 of 17 System Title,: ,

N)f67214- TE"/74/\/

Unit No.: / Startup Systen No.: _ 68# / Authori:ation No.: j f,2 7 f Work Description (Include identifi:ation of cor.ponents affected):

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Vork Location (Eldg., elevation, roce, area, etc.): _89//9' fr30 35-~

Reascn for Work: (i.e., DCA, CF.C , )etc.) [N-/dCf86[

Esticated time required to co=plete work: / /) N kork keqvcsted py: WS7t/ , .p'//7.s k - 6.3 6 SJ ff Name/Pnone Extension /Date Safety Tags Required: YES !NO If Yes, CP-SAP-5 Authorization No. : ,

g STA-605 Clearance No: d//A Work Authorized Ey- b'M $ Placed on Hold by: /A STE/Date STE/Date Work Ce p ted h[ .2, M S THIS FORM TO TUCCO STARTUP Cg6ftruction Department /Date Work Verified Coc:plete:

Startup Engineer /Date Retesting Required:

l Retest Co=plete:

Startup Engineer /Date Required Retests and Retest Data Approved By: _ Date:

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Title:

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Work Description (Include identification of components affected):

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Reference Dravings:

Work Location (Eldg., clevation, rooc, crea, etc.): 8PSV (*30 /3 T Reason f or Work: (i.e.. DCA, CMC, etc.) /-M- /dd#ff' Esti=ated tice required to co=plete work: / hgu r kerk .Es pested by: 'heName1Pnone 547 h// 47/5 Er. tension /Date 8 _2 W Safety Tags Required: YES-  ! NO If Yes, CP-SAP-5 Authot1 ration No.:

l STA-605 Clearance No: A/A/ .M/A Work Authorized Ey: a STE/Date

~28 [ Placed on Hold by: M//

STL/Date I

rk C 9dJ [') RETURN THIS FOP.M TO TUCCO STARTUP l Con'7fructionDepartment/Date l Work Verified Co=plete:

Startup Engineer /Date Retesting Required:

l Retest Co:plete: '

Startup Engineer /Date l Kequired Retests and Retest Data Approvr:d By: Date:

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Rovision c Starrue Work Authe '.: .. t. n Page 17 of j; Syatec

Title:

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Authori:ation 5o.: J2 M 7J_

Work Description (Include identifi:ation of components affected):

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  1. 4,9st b6 f Reference Drawings:

Work Location (Eldg., elevation, room, area, etc.): 89dY IP3c) f Reason for Work: (i.e., DCA, CMC, etc.) fff--//h / /((,

Esticated tice required to complete work: / OM/

Vork Renuested hy: O S $^y i r$14,r15 k' A 6/ fff[

Nace//Pnone Extension /Date Safety Tags Required: YES NO If Yes, CP-SAP-5 Authorization No.: [A STA-605 Clearance No: A//A Work Authorized By: htta f-2846Placed on Hold by: M/A STE/Date 4TE/Date All Construction Wotk Completed: _

[' 4L /[Wo ,2f/09pRETURN THIS FORM TO TUCCO STARTUP Co'yftruction Departmedt/Date Work Verified Complete:

Startup Engineer /Date Retesting Required:

Retest Complete: -

Startup Engineer /Date Required Retests a d Retest Data Approved By: Date:

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                                          } !' F1 'fS                                                    1 l/ N!s 'l /                                               l DISPOSITION REWORK                 REPAIR    XX               USE AS IS                          SCRAP Repair the damaged insulation of white Conductor of Cable EG113759 using tape m

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!)I .                                                                                                                        i 05/01/86                                                ATTACHMENT I                                PAGE      1 PART B                              SHEET ___ 0F ___

FIELD DESIGN CHANGE & REVIEW STATUS LOG AFFECTED DOCUMENT UPDATE REPORT DWG 2323-El-0172 SHEET 017 REV CP4 NUMBER REV STATUS NUMBER REV STATUS NUMBER REV STATUS D 005739 010 NI " DCA 006717 000 14 DCA 007279 000 14 / DCA 007,450 000 14 410 OPL /J TD CR >- DCA. 007946 000 14

 >* DCA        007958     000             NI DCA    007958     002             14 DCA    011436     000             15 DCA     012165     000             NI DCA    012165     001           UNI DCA     014376     000             NI DCA     014376     001           CP1 DCA     014926    000              NI DCA     0149?6    001             NI DCA     014926     00?             16 DCA     014Y26    003              16 DCA     015771     003            NA
      -DCA    016452     000              16 "OA    016',52    001             r41 DCA     016452    002          CP1 DCA    016695     000             NI DCA    016695     001             NI DCA    016695     002             NI DCA    016695     003             NI DCA    016695     004          CP1                                                                                  l-DCA    017306     000             NI DCA    017396     001         CP1                                                                                  ((

i EcR. II SB cP-) l lbb PREPARED Y

                                                                                                  /  /

I I APPROVED BYs ____.-. ._____.____________ __/. / l l l l 1 l i l l. I' l A/- /3r I L

7 _

      ".                                                                    bb7 l  Pega 1 9    1/15/85 DRAFT SER INPUT from D. Lur i o , X-24989 4

The follouing eaterial is nritten by Dan Lurie NRC/Rit/Blfi, (302) 492-4989 To be included in Bernie Saffell's section 5.1.1 (SELF-INITIATED VALUATION - SCOPE ) THE STATISTICAL EVALUATION GIVEN BELOW IS BASED IN PART ON MY EXPECTATION OF THE SAMPLING SCHEME TO BE DESCRIBED IN THE FORTHCOMING REVISION OF APPENDIX D. Section 5.1.1 - A quick reference to the sampling approach is already given in Saffell's Introduction , para.1, page 1: "The CPRT Plan consists of a sampled reinspection of DC accepted safety related construction work ...". This, I believe, is all that is needed here 5.1.2.1 Statistical Assumptions <<< this is a new subheading The reinspection procedure followed by the CPRT is targeted to provide a 95/5 ccsurance about the quality of safety-related construction activit2es. The procedure requires a careful partition of the activities into homogeneous work processes and a random selection of a sample of safety related items from each These item are then inspected for quality. For the most part, work process. these inspection classify an item as acceptable or as a deviant. This dichotomy suggests using the statistical binomial distribution function as an inferential tool for the purpose of quantifying the assurance for the tested work process. The sampling procedure is based on assumptions that characteriz o binomial peoulation. These assumptions include, among others: (1) homogeneity of items within a work process; (2) random selection of sample items from a work procsss; (3) ability to classify an item as acceptable or as deviant with certainty (4) essentially infinite number of items in a work process. l {k &'S Q

e 1/15/85 DRAFT SER INPUT from D. Lurie, X-24989 Page 2 The homogeneity of the various work processes, required by assumption (1), is dstermined and justified by engineering considerations. If the work process o interest is foand to be non-homogeneous, the work process boundaries are rcdrawn. Random sample (s) is (are) then selected at random from the redefined work process (s). A discussion of the work process definition is given in 5.1.2.2. The random selection of the items into the sample, required by assumption (2) is accomplished by the use of an unbiased randomization procedure. The procedure used by the CPRT is described in Appendix D, Attachment 3,

     " Guideline for Generating Random Samples".       Basically, the procedure determine the number of items in the work process (say, N) and assigns each item a uniqu cequential number 1 through N.        The selection of the items into the sample is is made by the use of a random number generator or a table of random digits.

Assumption (3) is essential to a correct probabilistic statement. Departure from this assumption renders the assurance overstated or understated. For thi reason the CPRT utilizes qualified inspectors capable of correct classificatio of the inspected items. If assumption (4) is inccrrect, the sample size ,1f anything, is larger than need to be. The level of assurance, in such cases is understated. Sec ti on 5.1. 2. 2 Homonenecus Constructi on Acti vi ti es The need for careful definition the boundary for each work processes is recognized by the CPRT . . . . .

7 . Paga 3

  • 1/15/83 DRAFT SER INPUT from D. Lurio, X-24989
  • Section 5.1.2.3 Sampl e Size Determination Appendix D ("CPRT Sampling Approach, Application, and Guidelines") gives sampi cize used in the statistical sampling to achieve the targeted 95/5 assurance.

If no safety For each work process of interest, a sample of size 60 is taken. cignificant deviations are found in the sample, the work process is accepted. If a deviant is found, the sample is expanded. For a single sample expansion, the sample is increased to 95 and the work process is accepted only if the total number of deviants does not exceed one. For a double sample expansion, total of 126 items are inspected and the work process is accepted if no more than two items in the entire sample are found unacceptable. Apart from the potential expansion of the sample due to the identification of one or two deviants, a sample is often augmented for a different reason. Again, a sample size of 60 is needed to ensure a sufficient initial sample size to evaluate the adequacy of the saf ety-significant attributes associated with the homogeneous work processes. In addition to this, the utility elected to 1,cok at a random sample of size 60 to provide a focused assurance about the portion of the total work process which is required to safely shut down the plant. To achieved the focused assurance, additional safety shutdown related items are randomly selected until 60 such items are collected. The augmented cample size for each work process, hence, varies between 60 and 120. The 95/5 assurance level was selected as a criterion to allow a quantification of the quality of the work process without having to reinspect each and every individual item in a work process. This assurance level is a targeted, rather than an exact, assurance. For most applications, the actual assurance can be easily higher than the targeted assurance.

r. Pag 2 4 1/15/05 DRAFT SER INPUT from D. Luria, X-24989 From a strict probabilictic vicw, th2 scmpling plon stated in Appandix D which ic based on the initial sample of size 60 offers less than 95% assurance, primarily because of the plan's associated expansions. A plan which allows no Gxpansion (accepts the work process only if zero deviants are found in a samol of size 60) actually offers 95.4% assurance (that no less than 95% of the item in the work process are acceptable.) If one expansion is allowed, the assuranc Icvel is only 93%. If two sample expansions are allowed, the assurance level

      .cpproaches 91%. This expansion, however must not be confused with the cugmentation required to meet a minimum of 60 shutdown saf ety related items.

The latter augmentation only enhances the overall level of assurance of the plant, even though no attempt is made to quantify this enhancement. Some of these other factors that enhance the stated assurance.

      .There are still fcctors are given below:
1. The sampling scheme often assumes (assumption 4) that the size of the work process is infinite. For small work processes, the sample size is considerably larger than need be and hence the associated assurance is understated.

The sampling assurance is increased when a deviant is identified anc 2. repaired. For small work processes this increase may be very significant.

3. When a deviant is identified, it serves to identify a potential error path, which leads to further sampling. This activity increases the sample size, generally giving a still greater assurance.

Pcgm 5

,  ' 1/15/85 DRAFT SER INPUT from D. Lurie, X-24989 5.1.2.4     Rel ationshi o to Test of Hvoothesis
      -The sampling scheme follows the statistical procedure known as a test of hvoothesis. The test of hypothesis requires statements of the null and the citernative hypotheses. a statement of the level of significance chosen, a ctatement of the assumptions relative to the statistical distribution of the m asured response, an identification of the test statistic and the critical rcgion, a presentation of any computations, and the derived conclusions.

In the CPRT context, the n,ull hypothesis is that the percentage of deviants in the tested' work process is 5% or larger, the alternative hypothesis is that that percentage is smaller than 5%. The assumptions that underlay this test os hypothesis are the four assumptions for the binomial population stated above. This The level of significance for the 95/5 assurance is given as alpha =.05. in the probability that the test would-fail to reject the work process when the population proportion is 5% or larger. The test statistic is the actual count of deviants f ound in the sample, and the critical region for a single expansia. is the count of deviants that lead to the rejection of the null hypothesis; in this case this count is zero. The computation of the statistic, is extremely simple; it is the count, or tally, of the deviants in a sample. If this count is zero it may be concluded that the percentage of deviant in the work process is less than 5% If the count is 1 or larger, it is concluded that the percentage of deviants was not proven to be less than than 5%.

1/15/85 DRAFT SER INPUT from D. Lurim, X-24989 Paga 6 5.1.2.4 Tol er ance limits. e NOTE - The following paragraph is discussed briefly in Appendix D as nell as in the November 22 utility response. It does not seen to have been an issue, but it is presented here for the sake of completion. Furthermore, it is not clear Nhat the utility did with the results or against which criterion these tolerance limits were compared. In some cases the sampling plan requires the use of tolerance limits. The ccceptable quality of a populations of items or quantity of materia 1 is often cpecified by setting either an upper or a lower bound value based on a cpecified percentage of the population exceeding or falling short of this value. When such a bound is specified in statistical terms it is called a tolerance limit. A tolerance limit is expressed as either M+KS or as M-KS, where M is the sample average and S is the sample standard deviation. The tolerance factor, K, is a function of sample size, the specified work process propor ti on , and the desired level of assurance (95% in this application.) The corresponding sample size is given in Table 2 of Appendix D. Table 2 of Appendix D is based on the assumption that the investigated population of iten follows the normal distribution.

Pace 7 1715/85 DRAFT SER INPUT from D. Lurio, X-24989 5.1.3 Staff Evaluation e The staff believes that the reinspection was carried according to sound otatistical principles. The staff believes that the classificaticn of the work process has been carried caref ully to allow meaningful and systematic ctatement of assurance. The targeted 95/5 is e reasonable targeted assurance. The minimum assurance for any work process can be shown to be 91/5. However, due to the shutdown focused sampling and the additional factors given in p.rs&_ ga//t below the targeted 95/5 5.1.2.3 it is likrE; that the assurance never 1Gvel of assurance. D

.',                          a EVALUATION CJCEAUCH k,                              CCWPCWATION t

QA/QC-RT-632 - DESCRIPTION MEMORANDUM FOR DOCUMENTATION REVIEW OF POPULATION: LARGE BORE PIPE SUPPORTS - NON RIGID CODE: LBSN PROCEDURE: QI-030 REV. O, CHANGE NOTICE 001 October 2, 1985 TO: A.A. Patterson FROM: R.H. Brown

SUBJECT:

Change Notice 001 is herewith transmitted to you for your approval. The following is an itemized list of changes made in this revision: Paragraph / Item Change / Reason /Effect 5.4/1 Added paragraph D. to clarify Hilti Inspectors' Certification requirement /Hilti inspectors need only be certified in accordance with TUGC0 Instruction QI-QAP-11.2-1/No effect on population because previously issued Verification Packages included this instruction as a supplemental instruction. 5.5/2 Relaxed accept / reject criteria for material identification numbers obtained during reinspection / numbers obtained during reinspection have proved unreliable /no effect on population

                                                               ~

because criteria is less stringent. 5.5/3 Added sentence to allow initials and date for QC signoff.in lieu of signature and date/ initials in lieu of signatures is not deemed safety significant, enly identification of Inspector /no effect on population because accept / reject criteria is relaxed. 5.6.B.2/4 Delete "the same" from sentence / grammatically tin sentence was confusing, deletion does not change intent /no effect, clarification only. G-

e ,

.i ' , '
(

QA/QC-RT-632 Page 2 Paragraph / Item Change / Reason /Effect Attachment 6.2, P.2/5 Added P-numbers of materials / inspectors requested this information/no effect on populatien because document reviews could not proceed if this information was required. Prepared by: [MW - b v o Approved by: NA~ < 'u r Atk~r J'. 8 Mus. - QA/QC Engineering Supervisor

                   ~

RHB/ls cc: ERC File

f/O E a EVALUATGN WEBEATCH CCWPCWATION l QA/QC-RT-657 DESCRIPTION MEMORANDUM FOR REINSPECTION OF POPULATION: LARGE BORE PIPE SUPPORTS - NON-RIGID CODE: LBSN PROCEDURE: QI-029. REV. 1, CHANGE NOTICE 002 October 2, 1985 - TO: A. A. Patterson FROM: R. H. Brown

SUBJECT:

Change Notice 002 is herewith transmitted to you for approval. The following is a description of the changes made in this revision: ITEM CHANGE 1 Revised Heading. 2 Added definition of a U-Guide. 3 Added Paragraph E which revises Accept / Reject criteria for "U-Bolt Type Supports". 4 Added Note defining U-Bolt Type Supports. 5 Added requirement when no torque is specified. REASON 1 thru 5 These changes are a result of a clarification made by TUGC0 concerning U-Guides vs. U-Bolts in response to TIR-054. , EFFECT ON REINSPECTION 1 thru 5 Supports which have been reinspected must be reevaluated (not necessarily inspected again). Prepared by: h A/QC Discipline Egif,ineer Approved by: 4 &*L-- QA/Qf tead Structural Engineer (W l- *:f M s-----

 'QA'/QC Engineering Supervisor RHB/ls

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                                                                                             -//~ / //

,

  • EVAL.UATICN 1 COCEAGCM

, CCTPOWATION C QA/QC-RT-635 DESCRIPTION MEMORANDUM FOR DOCUMENTATION REVIEW OF POPULATION: LARGE BORE PIPE SUPPORTS - RIGID CODE: LBSR INSTRUCTION: QI-028, REV. O, CHANGE NOTICE 001 October 2, 1985 TO: A. A. Patterson FROM: R. H. Brown - Attached is Change Notice 001 to QI-028 for your approval. The reasons for the changes and their effect on previously completed documentation reviews are as follows: ITEM NO. CHANGE / REASON

1. Added clarification that Hilti Inspectors need only be certified to TUGC0 Instruction QI-QAP-11.2-1 at the time of inspection.
2. Relaxed Accept / Reject criteria for material identification numbers obtained during reinspection.

The change is required because identification numbers obtained during reinspection have been found to be illegible in whole or part.

3. Added sentence to allow initials and date for QC sign-off in lieu of signature and date. Signatures were deemed not safety significant, only identification of the inspector.
4. Deleted "The Same" from sentence because the sentence was grammatically confusing.
5. Corrected Attribute Number (SG) to (6G).
6. Added SA515 Gr 55, 60, 65 P1-Group 1 and SA515 Gr 70 P1-Group 2.

NOTE: The addition of Item No. I will have no effect on Verificatica Packages previously issued because a Supplemental Instructis.c delineating this change was included in all packages. The changes described in Items 3, 4 and 5 do not require reevaluation because they are relaxations of Accept / Reject criteria or are clarifications only. Item No. 2 has no effect on population because the criteria is less stringent. No DRs have been processed to date.

g QA/QC-RT-635 Page 2 of 2 0 Item No. 6 has no effect on packages previously issued because documentation reviews could not have been completed without a supplemental instruction from Engineering. (I Prepared by: /.1 QA/QC Discipilne Engineer Approved by: F_24~ - W QA/QC, Lead Engineer

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APPROVED BY: & /. na4w DATE: /0/7/B( _ _ QA/QC LEAD DISCIPLINE ENGINEER CPP-006.1, Revision 0 V ks

O A t Eke.s '2 et 3 COMANCHE PEAK REVIEW TEAM Flst.<,T RANDOM SAMPLE IDENTIFICATION POPULATION: SMALL BORE PIPE SUPPORTS PREPARED BY' 0__ kT 4u.~% d l A DI9CIPLIME ENGINEER j RAN/ l SAMPLE SEQ POP PKG NO. NO. DESCRIPTION ITEM ACCESS NO. COMMENTS 154G 64.t. AO olo .o20 3 Y6*a Yt.9 02(e _ 76 _

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e en O Pu.s, Scr3 COMANCHE PEAK REVIEW TEAM FilLsT RANDOM SAMPLE IDENTIFICATION POPULATION: S!! Alt. BORE PIPE SUPPORTS PREPARED BY: ,L., ( \ d$v > QA/ DI$CIPLI!E ENGINEER RAN/ SAMPLE SEQ POP PKG NO. NO. DESCRIPTION ITEM ACCESS NO. COMMENTS El 5574 M.v . As.est.co4 5 W %s osi 51 8i484 ns. t, Se. *G' *al. 5  %  % es 2. __ 63 5504* C4 L' d!C' *01 8 55 * ~3 TM Ys=, 05'b _ _% _ t(,64 cW. I . A6 040.ot'A . 3 Yes 'l66 054 . M (,,3w2, p.c.t.56.co5 00 2 5 Ye NGs 06G sip '289 M.E. A6 056. cot. S Yss Yes 05G _ 67 47 t'1 seat. N D .soG e et9 9 Tes  % e5'l Wer final oc. Ass _grso .. 56 f524 (11 2 . A 8 8 8 85'* 6o5 < 3 YM ps 056 50 1931- es.l a.s.cor. coast Tr6 p .._ 8859 6o 3935 c5 I. It 2 .*T 3 2

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APPROVED BY: _ w[. DATE: /F[7[6'[ QA/QC 1EAD DISCIPLINE ENGINEER CPP-006.1, Revision 0

5 EVALUATICN ff/J T]CEACCM CCEPCWATION QA/QC-RT-702 DESCRIPTION MEMORANDUM FOR REINSPECTION OF POPULATION: LARGE BORE PIPE SUPPORIS - RIGID CODE: LBSR INSTRUCTION: QI-027, REV. 1, CHANGZ NOTICE 001

c. October 7, 1985 TO: A. A. Patterson FROM: R. H. Brown Attached is Change Notice 001 to QI-027, Rev. 1 for your approval. The reasons for the changes and their effect on previously completed reinspections are described below:

ITEM NO. CHANGE / REASON /EFFECT 1, 2 Added clarification of welded and bolted U-Guides per response to TIR-054. Previously completed reinspections shall be reviewed accordingly. 3,4,5 Added clarification of U-Bolt type support per response to TIR-054. Previously completed reinspections shall be reviewed accordingly.

                         \\

Prepared by: _ b _Q /L .m

                   'QA/QC Discipline Engineer Approved by:         @         .< sum

_QA/qC Lead Discipline Engineer cc: ERC File VII.c Large Bore Pipe Supports - Rigid JG/rr

                                                                                   ~

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                                                                                           ~43 'M is. concurrences, eksposers, D0 l  10T wee this term as a RECORD of a steerences, and similar actsons l

Room No.-Sidg. FROM: (Name, org. symbo!, Agency / Post) l

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AGENDA NRC INSPECTION AUDIT CPRT CIVIL / STRUCTURAL REVIEW (Preliminary) 6 OCTOBER 10-11,1985 Comanche Peak Site Thursday, October 10,1985, 2:00 p.m.-S:00 p.m. (NRC Troiler) I, Wolkdown of Units I and 2 ( f6 d ho/) h MT M) NRC wovId like to view relevant areas of the plant related to the C/S TRT issues and cable trays / conduit supports.

           -  Areas of interest include:

Control Room Ceiling Building Gops/ Debris Steam Generator Upper / Lower Lateral Supports Missing / Cut Rebor Concrete Testing Cable Troys / Conduit Supports including As-Builting and Retrofitting Responsibi_ lities/Porticiponts Project R. Hooton, Coordinotor, et al. EBASCO Representative Gibbs and Hill Representative Third Porty J. Honekomp y v C. Mortgot H. Levin

                                                                                       \

l

a _NRC (Approximotely 10 people) D. Jeng, NRR, et of. D. Norkin, R. Shewmoker, l&E, et of.

  • Brookhaven National Laborofory Friday, October I 1,1985,8:30 a.m. - 3:00 p.m. (CPRT Conference Room)
l. TRT Issues Review (J.Honekomp, Leod - 2h Hours)
            -        1.C Electrical Conduit Supports II.A Reinforcing Steel in the Reactor Cavity II.B Concrete Compression Strength II.C Maintenance of Air Gap Between Concrete Structures II.D Seismic Design of Control Room Ceiling Elements
              -        II.E Rebor in the Fuel Handling Bu'Iding -

V.B Improper Shortening of Anchor Bolts in Steam Generator Upper Loterol Supports Succested Outline for Above items: A. Summary of Initiatives; Planned and any Changes identified During implementation B. Summary of implementation including identification / Discussion of I Data Generated C. Ongoing Activities D. Steps Required for Closure t, Leod - 3 Hours) Design Adeavocy Proorom Review (C. Mort 11. (;.: o-o Ptn - fi r* PM )b 5 Co/io/ r A. Coble Troys / Conduit Supports Programs

1. Overview of Project and Third Party Activities (Mortgot) and 2 As-Builting Programs
2. Overview / Status of Units I (Hooton/EBASCO) 2
  • 3. Overview / Status of Units I ond 2 Project Design Verification Programs (Hooton/EBASCO)
4. Identification of Potential Modifications (Hooton/EBASCO)

S. Cable Troys / Supports Testing (G. Howard, ANCO)

                   - Description of All Phases / Status s
6. Conduit / Supports Testing (R. Yow, CCL)
                   - Description of All Phases / Status for Trains A and B, Train C B. Seismic Loads Verification (5 Hour)
1. Status of Project Activities (R. Hooton)
2. Overview of Third Party Verification of Seismic Models (C. M.ortgot)

Porticipants Project R. Hooton, et al. R. lotti, EBASCO, et al. E. Bezkor, Gibbs and Hill, et al. Third Party C. Mortgot C. Kircher R. White H. Levin Testina Oroonizations G. Howord, ANCO, et al. l l R. Yow, CCL, et al. NRC D. Jeng, NRR, et al. D. Norkin, R. Shewmaker, l&E, et al. Brookhaven National Laboratory 3

r UNITED STATES

      .[ 3
                   'o,,

o NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 O ej oer e as MEMORANDUM FOR: Vincent S. Noonan, Director Comanche Peak Project FROM: Charles J. Haughney Comanche Peak Project

SUBJECT:

COMANCHE PEAK RESPONSE TEAM VERIFICATION AND CORRECTIVE ACTION o ACTIVITIES A review was conducted of the ongoing Comanche Peak Response Team (CPRT) activities during the period of Septembar 23-26, 1985. The principal CPRT , activities in progress at the present time are those associated with the:

1. - Stone Webster (SWEC) Design Verification Effort
2. - Ebasco Design Verification Effort
3. - TERA Design Verification Effort
4. - 0A/QC Construction Verification Effort
5. - TRT Issue Specific Action Plans Implementation
1. Stone Webster Design Verification Effort This effort will involve a reanalysis of Unit #1 large bore Class 2 and 3 piping and supports and an evaluation of non-Westinghouse designed
                -   supports on Class 1 piping. In addition, for Unit #1, a sample reanalysis of small bore Class 2 and 3 piping will be performed. For Unit #2, similar work will be perfomed for large bore piping and supports; however, the reanalysis will include 100% of Class 2 and 3 small bore piping. The reanalysis effort will be perforn d utilizing established l

SWEC techniques. TERA is conducting the third ,m.of overview of this activity. 1

a. Current Activities l (1) Staffing for the project is proceeding well with personnel being I assigned from SWEC's New York, Houston, Boston, Cherry Hill, and Toronto offices.

(2) SWEC is in the process of completing two key procedures necessary for their portion of the piping and support verification work _ Comanche Peak Project Procedure (CPPP) #7 " Design Criteria for Pipe Stress and Pipe Supports is expected to be issed by October 11. CPPP #6 -

                          " Pipe Stress Analysis for As-built ASME Class 2 and 3 Piping Systems" is expected to be issued by October 7. Some delay has been I                          experienced in issuing final versions of these procedures because of their length (about 300 pages in the case of CPPP-7) and complexity, s $ [h               y , 4 QLp M ? &
                         -a

l-[ which has resulted from making them stand- alone documents rather than referencing a large number of in-house SWEC procedures. (3) SWEC has completed a sample walkdown of Unit #1 79-14 program to assess the accuracy of existing as-built documentation previously verified by the project. The sample, which was selected from the entire population of Unit 1 ASME large bore supports, examined supports for four attributes as follows: 80 packages for valve location, 200 packages for support location; 200 packages for support functions; 200 packages for valve and support orientation. The last attribute, valve and support orientation, had enough rejects during the walkdown to require a 100% re-survey of all as-built packages prior to re-analysis. NRC staff assisted by contractor engineers from TELEDYNE were on site the week of September 23 to determine the acceptability of this walkdown. (4) Of the approximately 300 as-built packages needed by SWEC for reanalysis, 158 had been transmitted from the site to SWEC. All the original Gibbs and Hill analysis packages had been sent. . (5) Prior to SWEC's involvement in this re-analysis project, TUGC0 in consultation with R. L. Cloud had selected over 100 supports that

   -              required modification, SWEC is now reassessing which of these supports should be modified before completion of re-analysis.

Preparation of some of these modification packages has begun, with the packages developed under ASME Section XI requirements. TUGC0 is using this process as the first major test of its operational modification control program. (6) SWEC is in the process of selecting a Unit il small bore piping and support random sample to permit stress analysis. They are now in the process of determining the correct representative population to pennit adequate sample size selection. This effort is not trivial, since different analysis groups were involved in the original design (TUGCO's Pipe Support Engineering (PSE) and Gibbs and Hill); and some supports were computer analyzed, while some were analyzed by nomograph. TUGC0 expects to have a sampling program description ready to present to the staff by the end of October. 6 (7) Unit 2 piping and support analysis is just beginning, with the first large bore stress problem scheduled to be run the week of September 23 and two small bore problems to be run the week of September 30. (8) Current schedule calls for SWEC to complete Unit I work by May 1986 and Unit 2 work by Fall 1986. (9) TUGC0 considers these SWEC efforts to be producing designs.of record for piping and pipe supports. Third party overview of SWEC's efforts are being perfonned for the CPRT by TERA.

2. EBASCO Design Verification Effort 2
 '     This effort involves a complete verification of original design and as-built construction associated with the design and construction of the Unit #1 and #2 electrical cable tray and conduit supports.                                       I
a. Current Activities l

Unit 1 Cable Tray Supports - The as- built walkdowns of 531 of the (1) 4527 cable tray hangers have been completed: Ten walkdown teams l i consisting of an engineer, QC inspector and craft support were , working the week of September 23, with a build up to about 25 teams anticipated. This walkdown program should end about mid-December. Ebasco is staffing - up to about 200 engineers to perform the design verification analyses to determine the acceptability of the as-built I design. EBASCO design procedures and calculational techniques will l be used. EBASCO will design any necessary cable tray support modifications. As an aid during the walkdowns, the walkdown teams are performing a prelimini constructability review to identify and

                                                           ~

resolve interference problems that will accompany likely support modifications. The engineering effort should end in mid-February. . (2) ANCO Engineers is performing four categories of category The first testing in support is a of the Unit I cable tray support program.The test specifications and system test on ANCO's shake table. The procedures were in final development the week of September 23.1) a Hilti other three categories of tests involve three components:

              . bolt baseplate connection; 2) cable tray clamps; and 3) a particular support configuration. The purpose of the testing is to verify modelling assumptions performed by Gibbs and Hill and to support modelling planned by the third-party, TERA. The testing schedule presently runs from October 10 to mid-January.

(3) Unit 1 Conduit Supports - These supports were field installed by craft using generic specs. The conduit routing was not specifiedThe by iso, as the the case with most of the Unit 2 conduit supports. population of safety related and seismically - supported conduit has been determined and has been divided into two groups: 1) power & control; and 2) lighting. Each group will have A a run sample of 60 runs is a uniquely selected for as-built walkdown and analysis. numbereci conduit for power and control and a particular circuit for lighting. The walkdowns are scheduled to start the week of 30 September and to complete in about four weeks. TheThe engineering need for analysis should then complete about mid-December. possible sample expansions or modifications is unknown at this time, as in any resulting slippage in schedule. (4) Unit 2 Cable Tray Supports - the as-built walkdowns of 100% of these support is complete. Of the 3833 supports, 2738 have been design verified; and about 25% of these (about 700) require modifications. Drawings for these mods have been transmitted to the Paper QC hasFlow Group accepted (PFG) 203 for issue supports to properly as being the craft to allow modified. installation.Present schedule. ca this entire job to complete on April 1,1986. r l l l 3 l

4 (5) Unit 2 Conduit Supports - Some of this conduit and its supports has not been installed. For example, 3594 conduit supports for runs in the Safeguards and Reactor Buildings have not had isos issued, and 351 supports in the same buildings have been installed and QC accepted. l (6) About 2800 conduit supports in the Auxiliary Building (common area) were engineered and installed per the same generic spec (S-910) as Unit 1. These supports are being re-evaluated using Unit 2 criteria. The schedule for Unit 2 conduit completion is complex and is actually keyed to system turnover events. (7) Corporate. Consulting and Development (CCL) has been conducting three categories of tests for conduit supports: (a) Unistrut - Testing of Unistrut members is complete and a test results report is in preparation. About 600 of the 8000 supports using Unistrut will require modifications, based on these test results. , (b) Conduit Clamps - Certain Superstrut conduit clamps were field modified to a configuration not supplied or qualified by the i vendor. This testing is about to start. (c) Junction Boxes - Some junction boxes have ears welded to the ' sides. At times, these ears were drilled in the field to allow fastening to a support, a configuration that was not qualified. A test procedure to examine this practice is in preparation. (8) Similar to the case with SWEC for piping and pipe supports, EBASCO is producing design drawings of record for electrical raceway supports. Gibbs and Hill still remains tne AE of record for the entire CPSES project.

3. TERA Design Verification Effort TERA is responsible for the Design Adequacy Plan, acts as third party reviewer for design review, resolution of TRT issue specific action plans for the mechanical, civil and structural areas, tracking all external issues and will prepare an issue a final design adequacy repart at the conclusion of their effort.

(1) TERA personnel responsible for the Design Adequacy Plan were not on ' site during the week of September 23. Their activities are now being examined by the NRC staff's design adequacy team, which will separately communicate the results of their review. (2) TERA'sonsitepersonnelassignedresponsibilitiesformecEanical, civil, and structural ISAPs provided status of their progress, which is included with the status of all ISAPs in paragraph 5 of, this memorandum. 4

4. QA/QC Construction Verification Effort 1

^ 4

T This effort emcompasses a statistically based sample reinspection or QC accepted construction work supplemented by a review of related quality documentation. The lead contractor is Evaluation Research Corporation (ERC),

a. Current Activities:

(1) The administrative control procedures for this effort are complete and issued. Overall control of this effort is also contained in a Management Plan, which describes how the 10 CFR 50 Appendix B 18 criteria are or are not applicable to this effort. (2) The 26 hardware population descriptions for ISAP VII c have bee: 1 completed. It is estimated that, in the absence of any future sample expansions that may arise, about 2200 inspection packages will be required to conduct all the reinspections. As of September 23, 948 of these packages had been issued and 693 packages had been used in the field for reinspection. By this coarse measure, about one third of the field activities associated with reinspections have been completed. , (3) The 26 hardware populations, involve about 160,000 items from which the statistical and engineered samples will be drawn. (4) 614 Deviation Reports (DRs) had been issued with 199 of these determined to be valid. Some of the remainder had not been through a complete validity check. Valid DRs are sent to TUGC0 where a TUGC0 Inspection Report and NCR are generated for corrective action and dispositioning. This latter process maintains the facility inspection of record in TUGC0 control. (5) Evaluations of valid DRs for safety significance was underway. This evaluation process was complex and typically involved engineering analysis and calculations to assess the effects of a particular deviation. 71 valid DRs had been determined to be not safety significant, and others were being evaluated. (6) The review of documentation packages had just begun. This effort is used to assess items that are inaccessible or processes that are non-recreateable. Of the approximately 2100 documentation review packages to be issued for all 26 populations, 304 packages had been issued; and of these 304, 101 had been reviewed. This review had resulted in 108 DRs, but none of these DRs had been through the validity checks. (7) Staffing for the QA/QC effort was near its peak with 160 persons on site the week of September 16 and an expected peak of about 180 in October. _ (8) The schedule for this effort is now expected to complete in February . 1986, baring and significant increases in the scope of reinspection or document review that could result from sample expansions. 5

                                        .=.-.-     .--- ---    .. _ _         .-        . _ . - - -

O (9) RIV has been able to maintain its goals of witnessing 10% of the  ; reinspections and independenily inspecting 5%.  : I

5. TRT Issue Specific Action Plans-Implementation Each of the SSER's prepared as a result of the TRT inspections resulted in f

J specific actions required by TUEC to resolve outstanding deficiencies. For each of the issue specific items TUEC has developed action plans and is in the process of implementing them. As of each of the action plans is completed a results report will be prepared for each item. The specific , details for each of the following TRT issue specific items can be found in the respective SSERs or in the Program Plan under Appendix C.

a. Current Activities:

The following is a listing of the TRT items and their status at the time of the site review: STATUS ITEM (ISAP No.) . Action completed.

              .       Heat Shrinkable                          .

Preparing results Insulation Sleeves (I.a.1) report. Action complete.

               .      Inspection Reports on                    .

Results report in ButtSplices(I.a.2) review cycle. Butt Splice Qualification . Pull testing of butt splices removed (I.a.3) from service complete. Report in preparation. Results report in

                .      Agreemen't Between DWGS                           review cycle and Field Term's (I.a.4)

Work completed.

                 . NCRs on Vendor Installed                  .

Revising result report. Amp. Tenninal Plugs (I.a.5) Additional analysis in

        *        . Flexible Conduit To                        .

progress. Flex. Conduit Separation (I.b.1) Additional analysis in

                  . Flex. Conduit to Cable                    .

progress. Separation (I.b.2) Conduit to Cable Tray . Actions completed. Results report in review Separation (I.b.3) cycle. Actions completed.

                   . Barrier Removal (1.b.4).                    .

Revising results report. 6

r-ITEM (ISAPNo.) STATUS

              . Electrical Conduit               . Analysis in progress and                  l Supports (I.c)                        walkdown to start September 30.                              ,

l Electrical Inspector

              . QC Inspector Qual's              .

(I.d.1) Qualifications Review Completed. Reinspection  : of one inspecter's work in progress. Review of ASME inspector qualifications in progress

         *    . Guidelines for Admin.            . Review completed.

of QC Inspector Test Preparing results (I.d.2)

              . Reinforcing Steel in             . Work Completed.                 .

the Reactor Cavity Results report in (II.a) review cycle. .

              . Concrete Compression              . Field work completed.

Strength (II,b) Preparing results report.

               . Maint. of Air Gap                 . Mapping of air gaps Between Concrete                       is complete. Trial Buildings (II.c)                      effort for removal of concrete and debris to start in October.
               . Seismic Design of                  . Gibbs & Hill design of Control Room Ceiling                   new ceiling complete.

Elements (II.d) TERA reviewing design. Final design should be on site in mid October.

                . Rebar in the Fuel                  . Review scope expanded.

Handling Building (II.e) Evaluation continuing.

                . Hot Functional (HFT)               . Review completed.

Data Packages (III.a.I) Results report in review cycle.

                . JTG Approval of Test               . Work complete.

Data (III.a.2) Results report in review cycle. 7

i STATUS

  • ITEM (ISAP No.)

Work complete. Results Technical Specification . report in review cycle, y ForDeferredTests(III.a.3) Work complete. Results Traceability of Test . report in review cycle. Equipment (III.a.4) Work complete.

              .          Conduct of CILRT (III b)                       Preparing results
  • report.

Evaluation complete. 1 Prerequisite Testing . Preparing results (III.c) report. Review completed. Preoperational Testing Preparing results (III.d) report. .

                                                              .          Sample inspected.
                 .        Skewed Welds in NF                             Engineers evaluating Supports (V.a)                                 results.
                                                               .         Work on " Hold".
                 .        Steam Generator                                Awaiting completion of Anchor Bolts (V.b) evaluation of upper lateral support by Gibbs and Hill.

Reanalysis completed. Design Consideration Preparing results For Piping Systems Bet. report. Data to be Seis CAT I & Non-Seismic transferred to SWEC Cat I Bldgs. (V.c) for piping reanalysis.

                                                                  .        Inspection complete.
                    .       PlugWelds(V.d)                                 Report in preparation.

All field work complete.

                     .      Installation of Main                            Preparing results Steam Pipes (V.e)                               report.

Design change and Gap Between Reactor critical space review Vessel Insulation & in progress. Preparing Ciological Shield Wall sample population list. (VI.a) Crane test complete, Polar Crane Shiming (VI.b) . reviewed. results being'nspection Girder seat i scheduled for mid-October. 8

STATUS ITEM (ISAP No.) Material Traceability . Review pending input from other reinspection (VII.a.1) activities. Non-conformance and . Review of various cor-Corrective Action Systems reactive action systems (VII.a.2) continues. Document Control (VII.a.3) . Review pending results from VII.c document review. Audit Program and Auditor . Results report in review cycle. Qualification (VII.a.4) Management Assessment . Review in progress. Examining INPO and other (VII.a.5) utility programs. - ExitInterviews(VII.a.6) . Review in progress. Examining other utility programs.

                                                                  . Review and inspection Housekeeping Cleanliness VII.a.7)  (andSystem                             in progress.

Fuel Pool Liner Documentation . Review of travellers in progress. (VII.a.8)

        . Onsite Fabrication                                     . Sample selection in progress.

(VII.b.I) Valve Disassembly (VII.b.2) . Valve inspections complete, drafting results report PipeSupports(VII.b.3) . Preparing inspection checklists. Hilti Bolts (VII.b.4) . Developing torque test program. Electrical Raceway Supports . Selected sample, preparing inspection (VII.b.5) packages. _ I

                                                                                 /

Charles J. Haughney l Comanche Peak Project i 9

o' pt 7 ) mtg-sampling: MISC 8 Draft 1 - 10/23/85 Meeting on Sampling Populations, Comanche Peak October 16-17, 1985 Robert E. Philleo On the morning of October 16, NRC representatives and consultants held a meeting to prepare for a meeting with CPSES personnel in the af ternoon. In the afternoon, we had a brief meeting with John Hansel and then subdivided into Structural, Mechanical, and Electrical groups. I was the only representative of NRC in the structural group. In addition to myself, the group consisted'of: A. A. Patterson, Supervisor of the Action Plan R. H. Brown, Lead Structural Engineer F. Kovensky, Concrete Placement Support Engineer T. F. Boni, Fill and Backfill Placement Support Engineer E. L. Baum, Structural Steel Support Engineer N.Baneee,substitutingforS.H.Poppe[,SupportEngineerfor Containment and Fuel Pool Liners. We examined, in detail, the defined populations for concrete, fill and backfill, structural steel, containment liner, and fuel pool liner; the sampling scheme for drawing a sample from the population; and the attributes to be measured. The general approach appeared satisfactory although I had several comments which should be addressed before the plans are fully implemented. The most serious was the disposition of field-cured concrete cylinders. While adequacy of curing is one of the attributes to be examined, there was no plan to look at the several hundred, field-cured, cylinder results. Most of the work will consist of examination of documentation. h' 1

1

i. My recommendations were as follows:

General Reconsider definition of " Documentation Review." Many of the reinspection items are " documented."

1. Concrete Examine records of field-cured cylinders and decide whether they should be included. They should not be ignored. If they are not included, use explanation such as " specifications do not include a rejection criterion."
2. Fill and Backfill
a. Examine " testing" work process vis a vis concrete and decide whether different treatment is justified,
b. If testing is kept as a work process, there needs to be a testing item in writeup.
c. The testing role of Mason, Johnson needs to be shown.
3. Structural Steel Consider rewording the work process " Connect Item to Structure." The p' resent wording is not entirely accurate.
4. Containment Liner
a. Consider revising tolerance when 6' template is substituted for 10' template.
b. Construct population so that plumbness requirement can be checked.

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ISAP Vit. C: CONSTRUCTION RE-INSPECTION /DOClfENTATION REVIEW PLAN [ SCOPE: RE-INSPECTION / DOCUMENTATION REVIEW 0F QC ACCEPTED SAFETY RELATED CONSTRUCTION WORK ACTIVITIES  : M PURPOSE: PROVIDE A MECHANISM FOR SURFACING AND RESOLVING ANY CURRENTLY UNIDENTIFIED CONCERNS RELATED TO CONSTRUCTION QUALITY PROVIDES AN ADDITIONAL EVALUATION OF THE QUALITY OF INSTALLED g i HARDWARE ! 5 e " QC INSPECTOR QUALIFICATION l 8 e ALLEGED INTIMIDATION E E i En ll OBaHeHe e ( <e,-s...,,,e,,,,j

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G ETHODOLOGY 1

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S e RE-INSPECTION OF A SAMPLE n 5 e BASED UPON/ STATISTIC TECHNIQUES i e QC ACCEPTED SAFETY RELATED CONSTRUCTION WORK

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ESTABLISH POPULATIONS  : 8 SELECT SAWLES DEVELOP CHECKLISTS AND INSPECTION PROCEDURES PREPARE VERIFICATION PACKAGES

                                                                                   's PERFORM RE-INSPECTIONS AND DOCUMENTATION REVIEWS                              y 9

DOCUENT DEVIATIONS n S l EVALUATION OF DEVIATIONS FOR SAFETY SIGNIFICANCE $ s EVALUATION OF DEVIATIONS FOR ADVERSE TRENDS EVALUATION OF SAMPLE RESULTS PRESENTATION OF RESULTS 8 OBalfelle g g i ( .

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5 RESPONSIBILITIES $ G CPRT QA/0C REVIEW TEAM: IPFLEMENTATION  : 5 CPRT OTHER REVIEW TEAM LEADERS: DEVIATION REVIEW E TUGCO: ASSIST IN IMPLEMENTATION d l" l m 8 SAFETY SIGNIFICANCE EVALUATION GROUP: EVALUATE DR'S k 5 i O e OBattelle q c., . . _.,

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i ACTION PLAN RESULTS REPORT: DOCl# TENT OVERALL RESULTS FOR ALL - POPULATIONS g i r { INDIVIDUAL REPORTS: DOCUMENT INSPECTION RESULTS FOR EACil , INDIVIDUAL POPULATION m

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1985-10-31 11:34 BATTEL _E COLUMBUS 1409111 11

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i G S! STAFF REVIEW PUUI '

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                                                                                                .S j                                 e   GENERIC j                                                                                                  !!

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e d ACCOMPLISHED THROUGH AUDIT OF PROCESS DURING IMPLEMENTATION AND

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5 OBJECTIVES OF STAFF REVIEW AND AUDITS $ 5 UNDERSTANDING 0F THE PROCESS _ 8 IMPLEMENTATION OF THE PROCESS i l 5 EVALUATION OF RESULTS d i l" l l;, 1 a r ASSESSMENT OF CONCLUSIONS E c I U1 i DOCUMENTATION i c

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                                                                                        ~

GEERIC REVIEW 0F CONSTtHCTION ADEQUACY PR0[FM , i POPULATION FORMULATION b WORK PROCESS APPROACH - ca e ATTRIBUTES e BASIS FOR HOM0GENIETY SAMPLING "n

e EXPANSION d i

l EVALUATION OF SAMPLE "' l n 4 e RE-INSPECTION y= fn e DOCUENTATION REVIEW -l DISCREPANCY IDENTIFICATION, EVALUATION AND DISPOSITION DOCUMENTATION 1

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SPECIFIC REVIEW 0F CONSTRUCTION ADEQUACY PROCESS Y ! 3 ACCOMPLISilED BY ADDRESSING GENERIC REVIEW ITEMS - FOR SELECTED ITEMS BEING EVALUATED L m i e SELECTED AREAS WILL BE COMPLETELY REVIEWED

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e ELEMENTS OF OTHER AREAS WILL BE d
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i e i  : OBattelle Columbus Laboratories , d i

 . 1995-10-3! 11:36        BATTEL E COLUMBLS
                                     -                                                   1409111               15
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G STATUS OF STAFF REVIEW Y 4 a , i i S NRC CONSTRUCTION ADEQUACY PROGRAM AUDITS - S e OCTOBER 16 & 17, 1985 e OCTOBER 28 - 31, 1985 i to i E i 51 F SCOPE OF AUDITS

  • l 8

E j 2 e CIVIL / STRUCTURAL ! e MECHANICAL

e ELECTRICAL _

i e 1 2 OBanelle q ~ - - - ...  ;

D- a POPULATION FORRLATION T a e MAJOR CATE6ORIES OF HARDWARE CONTAINING SIMILAR b" l SAFETY-RELATED WORK ACTIVITIES FORM REASONABLY HOMOGENE0US POPULATIONS l n 8 s

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                                                                                                         !o CIVIL / STRUCTURAL POPtLATIONS I

S CIVIL STRUCTURAL  : e CONCRETE PLACEENT FlLL AND STRllCTURAL STEEL i BACKFILL PLACEENT LINERS LARGE BORE PIPE SUPPORTS (RIGID) i FUEL P00L LINER LARGE BORE PIPE SUPPORTS (NON-RIGID) l

;                                                          SMALL BORE PIPE SUPPORTS PIPE WHIP RESTRAINTS INSTRUMENT PIPE /IUBE SUPPORTS               3' j                                                           CATEGORY CONDUIT SUPPORTS HVAC DUCT SUPPORTS                            f i                                                                                                          En i                                                                                                       5
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ro l ELECTRICAL POPULATIOllS  ! Y S i CONDUIT - a CABLE

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O i ELECTRICAL EQUIPMENT P fi l 2 r INSTRUMENTATION EQUIPMENT 5 i n m } i i i 1 e I I \' 1 OBaneHe Columbus Laboratories m G l

rn a ECHANICAL ' l 5 s HVAC DUCTS a PLENUMS e FIELD FABRICATED TANKS  :

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HVAC EQUIPMENT INSTALLATION e ECHANICAL EQUIPMENT INSTALLATION j e LARGE BORE PIPING CONFIGURATION e LARGE BORE PIPE WELDS / MATERIALS

e SMALL BORE PIPING CONFIGURATION e SMALL BORE PIPE AND INSTRUNENT PIPE / TUBE WELDS / MATERIAL E i

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g 8 PRELIMINARY COPENTS/ FINDINGS

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i o CONSTRUCTION ADEQUACY PROGRAM TO ADDRESS FIELD CONSTRUCTION ACTIVITIES 5 l e POPULATIONS ENC 0FFASS APPROPRIATE HARDWARE INSTALLATION OR CONSTRUCTION l e HOM06ENEITY EVALUATION IN PROCESS: SOE ADDITIONAL POPULATIONS APPEAR , LIKELY E. r j e POPULATION DEF9IPTIONS DEFINE THE CONTENTS OF EACH, THE BOUNDARIES, AND [ ANY SPECIFIC INTERFACES [ Yn G OBaHelle 4 ( <.,_ _ _, 4 a

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i PRELIMINARY COMENTS/ FINDINGS e SAMPLE EVALUATION OCCURS AT WORK PROCESS LEVEL; WORK PROCESS IS BEING " EVALUATED , e WORK PROCESS ATTRIBUTES FORM BASIS FOR DEVELOPENT OF REINSPECTION AND DOCUENT REVIEW CHECKLISTS w E e FIRST LEVEL REVIEW COMPLETED; ADDITIONAL REVIEWS REQUIRED IN AREAS l INVOLVING VENDOR PROCEDURES {o

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e EVALUATION OF WORK PROCESS DEFINITIONS AND POPULATION CONTENT IS E ONG0ING i i

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1995-10-31 11:41 BATTELLE COLUI1 BUS 1409111 25 Y i Ei 2 E o

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g u O b l l l l _ . . _ _ - _ . - _ . _ - . _ - - . - _ . _ - . . - _ _ . _ _ _ _ _ _ - - _ , _ - _ _ _ _

s ECHANICAL AREA SPECIFIC C0ffENTS E e REVIEWED POPULATION DESCRIPTIONS FOR ALL ELEMENTS OF MECHANICAL CATEGORY E ! S e REVIEWED INSTALLATION PROCEDURES FOR MECHANICAL EQUIPENT. DETERMINED l THAT VENDOR PROCEDURES WOULD HAVE TO BE REVIEWED FOR HOMOGENEITY l ASSESSMENT e POPULATION SIZES RANGE FROM 8-FOR FIELD FABRICATED TANKS TO GREATER THAN 65,000 FOR LARGE BORE /SMALL BORE WELDS E 3 e TWO SETS OF VENDOR INSTALLATION PROCEDURES REVIEWED F HEAT < EXCHANGER n

              -- PUMP                                                         -

COMPATIBILITY OF WORK PROCESS ATTRIBUTES WITH VENDOR INSTALLATION g PROCESS EXISTS fa e TWO CATEGORIES -- L.B./S.B. PIPE CONFIGilRATION AND L.B./S.B. WELDS -- ARE LUTED INTO SINGLE POPULATIONS, SEPARATE SAMLES FOR L.B. AND S.B. ARE DRAWN AND EVALUATED  ; 8 e LARGE BORE /SMALL BORE PIPE WELDS: NO SEPARATION OF STAINLESS FROM E CARBON STEEL WELD POPULATIONS OBallelle ,. Q ~ - - , , . ,

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G E CIVIL /STRUCTIRAL SPECIFIC COPERTS E e FIELD-CURE CONCRETE CYLINDERS NOT TO BE EXAMINED. SHOULD RECONSIDER e EXAMINE FILL AND BACKFILL "TESflNG" WORK PROCESS VIS-A.Vis CONCRETE AND DECIDE IF TESTING SHOULD BE KEPT AS WORK PROCESS. DOCUMENTATION REQUIRED IF INCLUDED 5 m o POPULATION SHOULD BE CONSTRUCTED TO PERMIT CONTAINMENT LINER PLUMBNESS REQUIREMENT [ l n o E

                                                                                                                             =

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G 8 SUMARY A CONCEPT OR PROCESS IS ACCEPTABLE TO STAFF AUDITS WILL CONTINUE WHILE PROCESS IS BEING IPPLEMENTED E STAFF IS NOT PREPARED TO DEFINITIVELY ACCEPT ANY POPULATIONS WITHOUT d FIIRTHER REVIEW. MANY APPEAR APPROPRIATE FOR THEIR APPLICATION  ? m E 9 , m E 5 i i r OBattelle m ( m_- <. 1.m p-

H 4) r e e REGION IV CPSES INSPECTION PROGRAM INSPECTIONS BEING PERFORMED INCLUDE: ROUTINE IE MANUAL CHAPTERS IE MC-2512 CONSTRUCTION IE MC-2513 PREOPERATIONAL TESTING IE MC-2514 STARTUP TESTING IE BULLETINS, CIRCULARS. INFORMATION NOTICES NRR GENERIC LETTERS OPEN PREVIOUS INSPECTION ISSUES IMPLEMENTATION OF THE CPRT PROGRAM ACTION PLAN ALLEGATIONS CDMANCHE PEAK REGION IV MANPOWER ASSIGNED 10 REGION IV INSPECTOR PERSONNEL 13 CONTRACTOR PERSONNEL

                                                              @,        p/   11/85

! REGION IV CDMANCHE PEAK GROUP i 1 REGIONAL ADMINISTRATOR REGION IV i

0FFICE OF INSPECTION . -------_ DIRECTOR, DIVISION OF - - - - - - - DIRECTOR. COMANCHE PEAK
           & ENFORCEMENT                                            REACTOR SAFETY & PROJECTS                                                 PROJECT CHIEF, COMANCHE PEAK REGION IV GROUP ALLEGATIONS /SAFETEAM                                                                                                      ' PROJECT STATUS i

i i GROUP LEADER . . s i I

                                                         ~

l [ l OPERATIONS - CONSTRUCTION QA/QC' ISSUES CIVIL / MECHANICAL ELECTRICAL SENIOR RESIDENT SENIOR RESIDENT TEAM LEADER TEAM LEADER TEAM LEADER INSPECTOR INSPECTOR l , 1 k 't CONTRACTOR PERSONNEL ASSIGNED AS REQUIRED 1 i

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s INSPECTION OF CPRT PROGRAM IMPLEMENTATION OA/QC PROGRAM REVIEW & AUDIT CPRT PROGRAM ISAP's INSPECT IMPLEMENTATION OF ISAP WITNESS INSPECTIONS OF HARDWARE VERIFY RESOLUTIONS & CORRECTIVE ACTIONS REGARDING DEVIATIONS VERIFY RESULTS REPORTS ISAP VII.C QA/QC AND CONSTRUCTION ADEQUACY WITNESS OF HARDWARE INSPECTIONS INDEPENDENTLY INSPECT HARDWARE INSPECT DOCUMENTATION REVIEWS VERIFY RESOLUTION & CORRECTIVE ACTIONS REGARDING DEVIATIONS VERIFY RESULTS REPORTS SITE MODIFICATIONS INSPECT MODIFICATIONS TO

           -   CABLE TRAY SUPPORTS CONDUIT SUPPORTS PIPE SUPPORTS DSAP's ASSIST IN ONSITE ENGINEERING WALKDOWNS AS REQUESTED O

11/85

r 9 INSPECTION REPORTS MONTHLY REPORTS ARE TO BE ISSUED WHICH COMBINE ALL INSPECTION EFFORTS BY THE REGION IV GROUP INSPECTIONS NOT PERFORMED UNDER THE DIRECTION OF THE CPSES REGION IV GROUP WILL BE ISSUED SEPARATELY ENFORCEMENT ACTIONS WILL BE TAKEN ON AN INSPECTION-BY-INSPECTION BASIS THE INSPECTION REPORT FOR AUGUST HAS BEEN ISSUED FINDINGS INCLUDE THE FOLLOWING: , 1 VIOLATION 2 DEVIATIONS 2 UNRESOLVED ITEMS 36 OPEN ITEMS THE INSPECTION REPORT FOR SEPTEMBER IS BEING TYPED AND THE OCTOBER INSPECTION IS IN PREPARATION 11/85

                                                                         ' ona         lt > -

R .. __ _ TUGC0 Meeting with NRC CPRT Monthly Status November 5 and 6, 1985 Plantation Inn /Granbury, Texas November 5, 1985 - 1:30 P.M. I. NRC Remarks II. Public Comments III. CPRT Status 1 E. A Introduction New CPRT Members B. Electrical ISAPs C. Testing ISAPs D. Civil, Structural, Mechanical, Miscellaneous ISAPs November 6, 1985 - 8:30 A.M. III. CPRT Status (Continued) E. Design Adequacy Program Ph se 3 Scope DAP Implementation Piping / Pipe Supports Cable Tray / Conduit Supports F. Quality of Construction ISAP Status ISAP VII.c Status W Coss < w /Os 6 64c co r4 x IV. Closing Remarks l CPRT-104

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                                                                                +7 TRT ISSUE: 1.C - CONDUIT SUPPORTS COMPLETED MILESTONES AS-3UILT AND SEISMIC ANALYSIS OF BOTH SAMPLES PROGRAM CHANGES ADDED TEST PROGRAM ON-GOING ACTivtTTES INTERACTION EVALUATION DAMAGE ASSESSMENT
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s . TRT ISSUE: II.A - REINFORCING STEEL IN THE REACTOR CAVITY COMPLETED MILESTONES ANALYSIS OF AS-BUILT CONDITION NCR REVIEWS FOR MISSING REBAR AND EMBEDMENTS POUR CARD REVIEWS PROCEDURE REVIEW PROGRAM CHANGES _ --

                                                                                                      .,.c NONE ON-GOING ACTIVITIES FINAL EVALUATION l

l l 0481/ MISC 2

s TRT ISSUE: 11,8 - CONCRETE COMPRESSION STRENGTH COMPLETED MILESTONES SCHMIDT HAMMER TESTS FOR

                       - CONCPETE AT ISSUE
                       - CONTROL CONCRETE ANALYSES OF RESULTS PROGRAM CHANGES                                                        --
                                                                    ,,.c      .

NONE ON-GOING ACTIVITIES FINAL EVALUATION 4 0481/ MISC 2

TRT ISSUE: II.C - MAINTENANCE OF AIR GAP BETWEEN CONCR STRUCTURES _ COMPLETED MILESTONES AS-BUILT INSPECTION OF BLDG.-TO-BLDG. GAPS PROCEDURE REVIEW DEBRIS REMOVAL FROM SINGLE WALL GAPS PROGRAM CHANGES ADDED GAP BETWEEN CONTAINMENT AND INTERNAL ST ON-GOING ACTIVITIES DEBRIS REMOVAL FROM DOUBLE WALL GAPS WIDENING GAP WHERE LESS THAN REQUIRED FINAL INSPECTION I f I 0481/ MISC 2

TRT ISSUE: II.D - SEISMIC DESIGN OF CONTROL ROOM CEILING E COMPLETED MILESTONES REMOVAL OF EXISTING CEILING DESIGN OF NEW CEILING PROGRAM CHANGES NONE ON-GOING ACTIVITIES --

                                                                                   - ,a-3RD PARTY REVIEW OF NEW CEILING DESIGN DAMAGE STUDY VERIFICATION 0481/ MISC 2

8 TRT ISSUE: II.E - REBAR IN THE FUEL HANDLING BUILDING COMPLETED MILESTONES PROCEDURE REVIEW REVIEW OF ALL REBAR CUT REQUESTS FOR HILTI BOLT INSTALLATION INSPECTION OF CASES WHERE POTENTIAL EXISTED TO CUT 2ND REBAR ANALYSES OF CASES WHERE 2ND BAR MAY HAVE BEEN CUT PROGRAM CHANGES SHEAR LUG REVIEW REVIEW OF CMCS/DCAS PRIOR TO 1/81 F0P REBAR CUTTING. ON-GOING ACTIVITIES SHEAR LUG REVIEW CMC /DCA REVIEW l 0481/ MISC 2 l

TRT ISSUE: V.A - INSPECTION OF CERTAIN TYPES OF SKEWED WELDS SUPPORTS COMPLETED MILESTONES _ WELD REINSPECTION OF SAMPLE PROCEDURE REVIEW PROGRAM CHANGES NONE

                                                                                                          ,a ON-GOING ACTIVITIES EVALUATION OF RESULTS                                  .

4 I 0481/ MISC 2

TRT ISSUE: V.s - IMPROPER SHORTENING OF ANCHOR BOLTS IN GENERATOR UPPER LATERAL SUPPORTS COMPLETED MILESTONES INSPECTION OF 120 BOLTS PROGRAM CHANGES NONE ON-GOING ACTIVITIES REANALYSES OF UPPER AND LOWER LATERAL SUPPORTS (DA INSPECTION OF OTHER BOLTED CONNECTION SAMPLES RECORDS REVIEW PROCEDURE REVIEW 0481/ MISC 2

TRT ISSUE: V.C - DESIGN CONSIDERATIONS FOR PIPING SYSTEMS BE SEISMIC CATEGORY I AND NON-SEISMIC CATEGORY I BUIL COMPLETED MILESTONES IDENTIFICATION OF ALL LINES WHICH HAVE A SEISMIC ANALYSIS TRANSITION ON-GOING ACTIVITIES THIS ISSUE WILL BE COVERED BY THE PROJECT PIPING AND SUPPORTS REANALYSES PROGRAM THIRD PAPTY OVERVIEW UNDER DAP (DSAP IX) l 1 0481/ MISC 2

TRT ISSUE: V.D - PLUG WELDS COMPLETED MILESTONES INSPECTION OF CABLE TRAY SUPPORTS INSPECTION OF ASME PIPE SUPPORTS EVALUATION OF PLUG WELD DCA PROGRAM CHANGES NONE --

                                                                     .,.c ON-GOING Ac11vfTIE_SS EVALUATION OF RESULTS 0481/ MISC 2

TRT ISSUE: V.E - INSTALLATION OF MAIN STEAM PIPES COMPLETED MILESTONES

  • ANALYSES OF UNIT 1, LOOP 1 AND LOOP 4, MAIN STEAM PIPES REVIEW CONSTRUCTION PRACTICES RELATED TO THE USE OF TEMPORARY PIPE SUPPORTS PROGRAM CHANGES NONE ON-GOING ACTIVITIES EVALUATION OF RESULTS 0481/ MISC 2

s TRT ISSUE: VI.A - GAP BETWEEN REACTOR PRESSURE VESSEL INSULATION AND THE BIOLOGICAL SHIELD WALL COMPLETED MILESTONES REVIEW OF COOLING FLOW FOR BOTH UNITS PROCEDURE REVIEW PROGRAM CHANGES NONE ON-GOING ACTIVITIES REVIEW 0F A SAMPLE OF NON-SAFETY DESIGN CHANGES CRITICAL SPACES REVIEW AND REINSPECTION 0481/ MISC 2

TPT ISSUE: VI.B - POLAR CRANE SHIMMING COMPLETED MILESTONES RECORDS REVIEW RAIL MOTION TESTS PROGRAM CHANGES NONE ON-GOING ACTIVITIES . GIRDER SEAT INSPECTION GENERAL INSPECTION REVIEW 0F DESIGN MODIFICATION TO ELIMINATE RAIL MOTION l l l l 0481/ MISC 2 L_ _

3

                                                      #     TELEDYNE ENGINEERING SERVICES 3                                                            130 StCOND Avf NUE
                                                            *ALIMAM MA$$ACMUS(TT5 07254
                                                            '61718943350 Twx17106 324 7508 November 21, 1985 6410-21 C,            -

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Mr. Vince Noonan, Project Director j Comanche Peak Project F U. S. Nuclear Regulatory Commission h Office of Nuclear Reactor Regulation Division of Licensing

                                                               /          D Mail Stop P-234                                   o          Z                                      ,

Washington, D. C. 20555 , 6' 4 y

Dear Mr. Noonan:

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                                                                            -   I e     nduc<;

Attached please find our preliminary Trip Report or act vi A at CPSES related to the Construction Adequacy Program. j If you have any cuestions please do not hesitate to cont ct m /( Very truly yours, d TELEDYNE ENGINEERING SERVICES MFWu

                                                                                                    ~

Donald F. Landers Executive Vice President DFL/lh Attachment cc: L. Shao (USNRC) J. Calvo (USNRC) C. Trammell (USNRC) C. Poslusny (USRNC) 6410 File (TES)

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s WTri Fr#NE ENGINEERING SERVCES TRIP REPORT NO. 2178 PROJECT 6410T VISIT OF JAMES A. FLAHERTY AND JAMES J. RIVARD TO COMANCHE PEAK FOR AUDIT OF CPRT ACTION PLAN ITEM NUMBER: VII.C CONSTRUCTION REINSPECTION / DOCUMENTATION REVIEW PLAN October 29-31, 1985 The scope of this audit was the in-depth review to establish if homogeneity of the work process and attributes had been achieved for selacted populations in the mechanical and structural area being performed by ERC as part of Item VII.C of the program plan. This was an extension of the previous trip of October 16 through 18, 1985, which was also held at the Comanche peak site. of the NRC audit team, Tuesday, TES met with other members Evangelos Marinos of the NRC was the October 29, 1985 at the ERC trailer. James audit leader. James J. Rivard was assigned to the structural area. A. Flaherty was assigned to the mechanical / structural area and Robert Masterson of EAS was also assigned to the mechanical / structural area to specifically review piping and pipe-support populations. Tuesday afternoon, I sat with R. Masterson and discussed the areas he had reviewed. Bob had reviewed rigid and non-rigid large-bore pipe-support populations. In addition, I sat in on a discussion on large-bore /small-bore piping welds. I. PIPE WELDS / MATERIAL POPULATION ERC has revised the welding population and work processes since the audit of October 16. The revised population combines large-bore and small-bore piping weld, since the same weld-procedure specificationsGas were used. Tungsten Within the welding process, two welding methods were used: Arc Welding (GTAW) and Shielded Metal Arc Welding (SMAW). Both methods were utilized for carbon- and stainless-steel welding and were performed by i the same work force. Therefore each This welding method will have a mir.imum of revision of the Pipe Welds / Material 60 randomly selected samples. Population Group (PIWM) removes my concern, which was raised during the October 16, 1985 audit. This is a more homogneous approach to the PIWM i reinspection. It Bob Masterson reviewed the originJ1 Brown and Root specification. l ' was noted that the original specification required noting of cleanliness and listing of any base-metal defects. The attributes list 5d on the PIWM ERC was asked to review and l checklist did not include these two elements. I cormtent.

s 1eTri m(NE Trip Report SNCE No. 2178 II. MECHANICAL EQUIPMENT INSTALLATION The afternoon and evening of Tuesday, October 29, 1985, James A. Flaherty reviewed the Mechanical Equipment Installation (MEIN) population. The following documents were reviewed.

a. Work Process Definition for MEIN.
b. Population Description.
c. Population Item List.
d. QI-059, Revision 0 Draft Procedure Quality Instruction for
                                                                 " Reinspection of Issue Specific Action Plan (ISAP)        VII.C.,

Mechanical Equipment Installation").

e. Original Mechanical Erection Specification 2323-MS-101, Revi-sion 4, 6/28/84, Gibbs & Hill, Inc. Specification, f.

Brown & Root Specification MCP-1, 8/1/84, Revision 4, " General Installation of Mechanical Equipment".

g. Brown & Root QI-QAP-11-1-39, Revision 4, 6/11/84, " Mechanical Equipment Installation Inspection Procedure".
h. Brown & Root, CCP-24, Revision 4, 6/26/80, " Rigging".

i. Brown & Root, " Grouting Base Plates, Bearing Plates and Equip-ment Bases, CCP-16, Revision 4, 2/8/84. J. Brown & Root, " Installation of Hilti Drilled-In Bolts, CEI-20, Rvision 9, 12/16/83. There are currently three work processes being reviewed. The welding work process has been deleted from the MEIN population and, as of October 28, 1985, has been put in the appropriate pipe weld work process. ERC is also reviewing the deletion of grout from the attribute list and is This establishing a new population that specifically addresses grout. change is due primarily to the way documentation was established. The ERC reinspection procedures and orginal construction specifica-tions and procedures were reviewed and compared for homogeneity of work processes and choice of generic attributes. The writer feels that all attributes listed are appropriate and cover the original construction sequence. Five documentation packages from the sampled population were reviewed for completion of documentation and comparison to general specifications and attribute list. The five documentation packages reviewed were:

ifE NN ENGNEERNG SERVICES S Trip Report No. 2178 .

1. Service Water Pump, P.O. CP-010-001 Manual Rotating equipment installed per Hayward Tyler manual.

gave specific tolerances on parallel alignment between motor half coupling and collar.

2. Pressurizer, P.O. -0001-18 All dimensions for installation are per Westinghouse drawings.
3. Safety Injection Pump, TBX-SIAPSI-01 and 02 Specified tolerances on rim-to-rim and face-to-face coupling alignment. A requirement was also given on vibration tolerance.

In a discussion with ERC, ERC stated that this attribute may be added to attribute list as a documentation check.

4. Centrifugal Charging Pumo, TBX-CSAPCH-01 and CP-0001-024 for Unit 1 Installation is per manuf acturer manual. This pump is part of the Chemical and Volume Control System and was fabricated by Pacific Pumps.
5. Motor-Driven Auxiliary Feedwater Pumps, P.O. CP-007-001 Criteria given Alignment is per manuf acturer's specifications.

for checking anchor bolts, level and alignment and grouting.

6. Excess Letdown Heat Exchanges Criteria given fcr backing off of foundation bolts to allow for thermal growth. Requirement given by Westinghouse.

l l The above six mechanical component document packages were well doc- The ! umented and the appropriate attributes listed on the ERC checklist. only open item was the vibration attribution documentation check, which ERC is reviewing. l III. PIPING SYSTEM BOLTED JOINTS / MATERIAL On Wednesday, October 30, James A. Flaherty reviewed the Piping The following ERC procedures f System Bolted Joints / Material Population. l were reviewed: (a) Work Process Definitions. (b) Population Description. (c) Population Items List.

l SeTELEDYNE

 '. Trip Report                                             NING SONICES No. 2178 (d) 01-021, Revision 1, " Reinspection of Piping System Bolted Joint Material.                                                                 :

I During the October 18 audit, the NRC audit teams raised a concern on torque being an attribute and not a work process. The concern was relative to equipment specifications requiring a specific torque value on certain types of flanges and the reinspection attribute not containing sufficient samples. In the discussion with ERC, it was noted that there are approx-imately 7000 items in the piping system bolted joint population. Of the approximately 7000 items, 6700 are in line-piping connections which were Sec-installed in accordance with Brown & Root Procedure CP-CPM 6.9E. tion 3.12 of the B&R procedure did not require a specific torque value to be used. The governing requirement was that the joint "shall be tightened Since I3AP VII.C sufficiently to prevent leakage during pressure testing". is addressing QC-accepted items, only reinspection per the original spec-ification is required. The only flanges which may have required specific torque values would therefore be in the Mechanical Equipment Population. ERC has reviewed the MEIN population and has only found approximately six Therefore the issue raised during flanges which required specific values. the October 16 audit is no longer an issue to this auditor. It was also noted that the Population Description and Population Item Lists will be revised to delete instrument flanges. These will now be included in the electrical area. IV. HVAC EQUIPMENT INSTALLATION This population was reviewed Wednesday afternoon. This was a con-The tinuation of the audit of October 16 on homogeneity of the population. following ERC procedures were reviewed.

a. Work Process Definitions.

i

b. Population Items List.
c. QI-023, " Reinspection of HVAC Equipment".

This population has been modified based on a concern raised during the October 16 audit. The work process for Equipment Setting by Brown & Root has been deleted and will be combined with the MEIN population since the same B&R procedures and installation specifications were used. V. HVAC DUCTS AND PLENUMS This population contains all passive equipment in the safety-related HVAC systen whereas the HVAC equipment population contains, only active items. The following ERC procedures were reviewed.

a. Work Process Definitions.
b. Population Description.

(

SeTm m(NE ENGNEERING SERVICES l' Trip Report No. 2178

c. Population Items List.
d. QI-039, " Reinspection of HVAC Ducts and Plenums".

It contains much of the QI-039 has been issued and is very detailed. the construction phase. original documents and sketches required during The document review procedure has not been completed yet'. VI. PIPE WHIP RESTRAINTS James A. Flaherty was given an overview of the Pipe Whip Restraint Population. This population consists of moment restraints, pipe whip restraints and restraint support structures listed in Section 3.6 of FSAR. Due to the original construction, two populations may be Nine established, one systems have the support structure. for the restraint and one for postulated line breaks. Some restraints are listed byAt Gibbs and Hill and this time ERC is other restraints are listed by Site Damage Group. still reviewing the work process and is establishing which groups were responsible for installation. VII. CONCRETE PLACEMENT POPULATION James J. Rivard reviewed the Concrete Placement Population Tuesday During this time afternoon and Wednesday morning, October 29 and 30, 1985.to determine if homo the following documents were reviewed work processes and attributes had been achieved.

a. ERC's Work Process Definitions for Concrete Placement Popula-tion.
b. ERC's Population Description for Concrete Placement, 8/5/85.
c. ERC's Population Description for Concrete Placement, 8/5/85.
d. ERC's Population Items List for Concrete Placement, 9/5/85.

QI-043, Revision 0, 9/16/85, Procedure, Quality

e. Procedure Action Plan No. VII.C.

Instructions for Issue-Specific

                        " Reinspection of Concrete Placement".

f. Gibbs and Hill Specification 2323-55-9, 1/16/79, " Concrete".

g. Gibbs and Hill Specification 2323-55-30, 2/10/84, " Structural Embedments".

1

h. Brown & Root Construction Procedure 35-1195-CCP-l', " Concrete Placement", Rev. O.

The concrete placement population is presently subdivided into three work processes, each work process having various numbers of attributes. Some of the attributes are to be reviewed by means of a field reinspection;

                                                         "AP WNE Trip Report ENGNEERNGSERVICES
  /                                                  No. 2178 others can only be reviewed by means of a document review; and some will The         be reviewed utilizing both field reinspection and documentation review.

field reinspection was in progress at the time No of this audit and the doc-reinspection packages were umentation review had not yet begun. reviewed. The reviewer has a few concerns; however, he feels that in general the reinspection of concrete placement's work processes and attributes does achieve an approoriate level of homogeneity. These concerns were discussed with ERC and were lef t as open items. The following is a list of open-items wnich ERC snould address:

1. It may be more appropriate to establish cadwelds as a work process rather than as an attribute. ERC is to review the cad-weld inspection procedure and the concrete pour card sign-off requirements to determine whether cadwelds should be a separate worx process.
2. ERC to consider establishing Richmond !nserts as a separate attribute instead of incluaing it with tne emoedment attribute.
3. ERC to determine if tne condition exists where embeaded pipe sleeves are used to anchor the piping system. If this situation does exist, the emoeoded sleeves should be a separate attribute.

VIII. STRUCTURAL-STEEL POPULATION On Wednesday afternoon. October 30, 1985, James J. Rivard performed a At this time only a cursory review of the structural steel population. review was done to determine if the conceDt of choosing work processes and attributes would achieve acceptable homogeneity. A limited review of - the following documents was performeo. Procecure 01-045, Rev. 1, 10/23/85, and Change 'iotice 001, a. 10/23/85, Quality Instructions for Specific Action Plan VII.C. Reinspection Procedures for Structural Steel,

b. ERC's Description Memorandum for Reinspection of Structural Steel:
i. Rev. O, 9/15/85 ii. Rev. 1, 10/S/S5 iii. Change Notice to Rev. 1, 10/23/S5
c. Gibbs and Hill Specification 2323-5S 168, " Structural Steel",

5/12/75.

d. TUGC0 Instruction QI-QP-11.0-15, " Verification of Baseplates for Grouting", Rev. 8, 3/13/85.

this general overview of the str y,ttral-steel After performing reinspection activity, it is felt that the work processes and attributes

s TF WE I l Trip Report NO No. 2178 identified generally will achieve acceptable homogeneity. However, a more detailed audit of the reinspection procedures will be required to make more detailed coments. One item of concern identified is grouting. This should be a separate population since it is now not appropriately being reinspected. An exit interview was held the af ternoon of Wednesday to cover those areas rev,iewed by all members of the audit group. Comments and open-items are given above in the specific population. James A. Flaherty and James J. Rivard left Dallas for Boston, Thursday, October 31, 1985.

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                                            /JamesJ.5ivard JAF/JJR:jej 1 - Trip Report File 1 - Comanche Peak Project File 1 - B. Saffell (Battelle) i 1 - D. F. Landers I

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                                                                             &&-   ffYC! '.Q Y W(w i    (               N MEMORANDUM FOR:    V. S. Noonan, Director, Comanche Peak Project      '

E. H. Johnson, Acting Director, DRSP $[ THROUGH: FROM:

SUBJECT:

T. F. Westennan, Chief, Comanche Peak Region IV Grol p\ VISUAL INSPECTION PAINTED ASME SECTION III PIPE WELDS Y[ C .O - During our onsite inspections, it has been identified that there are ASME Section III nina wald_s_which have been painted. This situation is similar to S f T Fsisection of the painted NF support welds, except that NDE o en ASME Code requirement for most of these welds. In addition, shc rntmoval of paint to perfonn inspections in Unit I can invalidate the N st$4 (Section III) and ISI Preservice Inspection (Section XI, surface noteu n rsctive examinations). Paint was removed from several ASME Section. (II pipe welds during initial ERC Issue Specific Action Plan V II.c reinspections, but this has been stopped. Region IV reconsnends that the staff review the applicant's action on this issue.' -

                                                             ?

T. F. Westennan, Chief Comanche Peak RIV Group cc: R. D. Martin, RA, RIV R. Heishman, IE HQ C. Trannell, NRR J. Cook, NRR G cRS~

OBattelle Columbus Division i.. {'h g., BERNARD F. SAFFELL, JR. 424 5294 ,, p 2 5' / f h5 [ k f,nu

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1.

Title:

NRC Audits of Comanche Peak Response Team Construction Reinspection / Documentation Review Program (ISAP VII.C)

2. NRC Staff and Consultants: {

J. A. Calvo, NRC (Chairman) E. Tomlinson, NRC J. A. Nevshemal, Westec J. Flaherty, Teledyne B. F. Saffell, Battelle R. Philleo, Consulting Engineer R. Masterson, EAS J. Rivard, Teledyne

3. Persons Contacted:

J. L. Hansel, ERC J. M. Schauf, ERC T. Bori, ERC J. T. Christensen, ERC G. Hefter, ERC E. Baum, ERC D. Boulton, ERC A. Burke, ERC N. Bancrjce, ERC J. Brand, ERC H. Bossung, ERC R. Brown, ERC A. Patterson, ERC J. Brown, ERC J. Tablerion, ERC J. DiMare, ERC R. Tate ERC J. Greer, ERC M. Iannuci, ERC F. Korensky, ERC J. Warrington, ERC

4. CPRT Construction Reinspection / Documentation Review Program Audits of the Comanche Peak Response Team (CPRT) Construction Reinspection / Documentation Review Program, subsequently referred to as the Construction Adequacy Review Program, were conducted on October 16 and 17, 1985, and at tt Comanche Peak Steam Electric Station site. All disciplines--mechanical, civil, and electrical--were' audited by teams composed of NRC staff and consultants. Through these audits, the NRC reviewed the basis for establishment of the groupings within each discipline and the work process populations associated with each discipline and utilized.by t:1e CPRT for assessment of construction adequacy. The primary purpose of this audit was to determine the degree of homogeneity within each work process from an engineering perspective.

Detail audit of work process attributes will be accomplished in subsequent audits. The construction adequacy review program is being performed within the purview of the Comanche Peak Response Team with ERC, Inc. responsible

2 for performing the review. The presentation made by Mr. John Hansel of ERC, Inc., at a public meeting held on October 3 and 4, 1985, in Grandbury, Texas, provided the basis for the staff's initial audit of the ' CPRT Construction Adequacy Program. Work processes are being identified for construction of safety celated systems, components, and supports. Each work process will be evaluated by a random sample drawn from the associated population of syste:ms, components, or supports related to that work process. Further, sample items reviewed are drawn from Unit 1. Unit 2, and common areas, and must be construction complete and quality approved. Each work process sample is expanded to include an engineering sample. The engineering sample assures that a number of safe shutdown system items equivalent to the number of items addressed by the random sample are also reviewed for adequacy of construction. Subsequent sections describe two NRC audits of this process.

5. Mechanical Discipline The mechanical discipline is divided into nine populations which are:

(a) HVAC ducts and plenums (b) HVAC equipment installation (c) Field fabricated tanks-(d) Mechanical equipment installation (e) Large bore piping configuration (f) Small bore piping configuration (g) Pipe-walds/ material (h) Piping system bolted joints / material. Each of these populations was discussed with ERC personnel by NRC staff and consultants participating in the audit. The construction adequacy review for the mechanical discipline is approximately 15 percent complete at the time of the initial audit. Completion is scheduled for the end of February, 1986. Only field construction work processes are addressed by the scope of this activity; vendor fabrication is not within the scope of the Construction Adequacy Program. For each of the mechanical areas, ERC

3 had prepared a " Population Description" addressing the contents of each category, its boundary, and any specific interfaces germane to the population. In addition to the Population Descriptions, a flow chart ' describing the work processes and associated attributes for each sample population was provided and discussed with ERC's Population Engineers. ERC indicated that these attributes provide the basis for the checklists which are being developed for re-inspection of mechanical systems and components. ERC reported that the construction adequacy review is being performed in accordance with their own quality assurance program which is compatible with the CPRT's quality assuranc' program. ERC's implementation of the construction reinspection / documentation review program is being audited by both CPRT and ERC quality assurance personnel. Specific comments on each population within the mechanical discipline are provided in the subsequent paragraphs.

a. HhC Ducts and Plenums. This audit was initiated during the October 17 and 18, 1985, site visit. The HVAC Duct and Plenum population encompasses 6800 items. Fabrication, installation and welding are the three work processes associated with construction of HVAC ducts and plenums. Bahnson Service Company was the only subcontractor to 3rown &

Root for all HVAC duct and plenum fabrication and installation. Reasonable homogeneity is demonstrated because fabr eation and installation of this equipment are each characterized by a singh craft- . sheet metal workers for fabrication, welders for installatioi:, and a single subcontractor. Installation and fabrication procedures are based on Gibbs & Hill Specification MS-85. The attributes associated with each work process were reviewed and appeared to be complete. This audit was continued during October 29-31, 1985, by a further review of the following ERC procedures:

a. Work Process Definitions
b. Population Items List
c. QI-023, " Reinspection of HVAC Equipment".

4 ' This population has been modified based on a concern raised during  ! the October 16 audit. The work process for Equipment Setting by Brown & Root has been deleted and will be combined with the mechanical - ' equipment installation population since the same B&R procedures and installation specifications were used,

b. HVAC Equipment. As with the HVAC Ducts and Plenums, this audit was initiated' on the October 17 and 18 visit and continued during the October 29-31, 1985, visit. This population contains 604 items of passive equipment in the safety-related HVAC system whereas the HVAC equipment population contains only active items. This equipment was either installed by Brown & Root or Bahnson and this was the basis for subdividing this category. The work processes associated with HVAC equipment installation are the setting of the equipment and then connecting it to the plenum and ductwork. Further, the attributes of each work process are the same, regardless of the installer. .The attributes associated with the work processes were reviewed and appeared appropriate for the process.

The following ERC procedures were reviewed during the continuation of this audit:

a. W.ork Process Definitions
                                                 ~
b. Population Description
c. Population Items List
d. QI-039, " Reinspection of HVAC Ducts and Plenums".

QI-039 has been issued and is very detailed. It contains much of the original documents and sketches required during the construction phase. The document rev.iew procedure has not been completed yet.

c. Field Fabricated Tanks. This particular activity was discussed in a qualitative manner.. ERC informed the audit team that eight field fabricated tanks exist and that all would be reinspected. This was not pursued further as population homogeneity was not an issue because of the 100 percent reinspection.
                                                                                       - .- - - - - -- -, o
                                     --  ,   m        ---e.r-- , - - , . - - - . , - e

5 l

d. Mechanical Equipment Installation. Mechanical equipment audit l of October 17 and 18, 1985, population encompasses 336 items. The governing construction document is the Gibbs & Hill Mechanical Erection '

Spscification 2323-MS-101. The implementation of this is accomplished by Brown & Root Specification titled " General Installation of Mechanical Equipment", CP-1. The governing quality assurance procedure is Brown & Root QI/QAPil.1-39 titled " Mechanical Equipment Installation Inspection". Qualitative results of the sampling conducted so far indicates that 20 to 25 percent of the sample drawn is from Unit 2. The remainder of the sample is from Unit 1 and comon areas. The work processes associated with mechanical equipment installation are setting, anchoring, welding and, for rotating equipment only, alignment. The attributes of each work process were discussed in depth. ERC personnel indicated that if a particular attribute of the work processes was not addressed when the sampling activity was completed, assessment would be made as to whether or not the sample needed to be expanded to include that attribute. If a decision was made not to specifically address that attribute, the basis for this decision would be provided in the report addressing the construction adequacy evaluation of, in this instance, mechanical equipment. Work process homogeneity is evaluated by checking to make sure that the same organizations are involved, procedures have remained nominally constant, and that the welder inspector qualification standards have remained the same. Sampling is performed at the work process level. Since evaluation of equipment is made at the work process level, each sample will be expanded such that sixty evaluations will be made for each work process. This means that more than the minimum number of equipment items (60) are addressed during completion of the sampling process. This particular category was pursued further in that an installation procedure for a heat exchanger and a pump (rotating equipment) was reviewed to evaluate the compatibility of the attributes associated with work processes with the installation requirements contained in the procedure. Compatibility did appear to exist between the work process attributes and installation procedures for both cases. In one case, the installation procedure for heat exchanger cpl-CCAHHX-01 was reviewed to see if this specific installation procedure was compatible with the

6 attributes of the work processes for mechanical equipment installation. The procedure for installing an auxilliary feed water pump, CP1-AFAP - MD-01 was reviewed to evaluate its compatibility with the alignment work pr6 cess attributes. Audit of October 29-31, 1985 The following documents were reviewed as part of the continuing audit of the Mechanical Equipment Installation (MEIN) population: (1) Work Process Definition for MEIN. (2) Population Description. . (3) Population Item List. (4) QI-059, Revision 0, Draft Procedure Quality Instruction for Issue Specific Action Plan (ISAP) VII.C., " Reinspection of Mechanical Equipment Installation"). (5) Original Mechanical Erection Specification 2323-MS-101, Revision 4, 6/28/84, Gibbs & Hill, Inc., Specification. (6) Brown & Root Specification MCP-1, 8/1/84, Revision 4, " General Installation of Mechanical Equipment". (7) Brown & Root QI-QAP-11-1-39, Revision 4, 6/11/84, " Mechanical Equipment Installation Inspection Procedure".

                       '(8) Brown & Root, CCP-24, Revision 4, 6/26/80, " Rigging".

(9) Brown & Root, " Grouting Base Plates, Bearing Plates and Equipment Bases", CCP-16, Revision 4, 2/8/84. (10) Brown & Root, " Installation of Hilti Drilled-In Bolts", CEI-20, Revision 9, 12/16/83. There are currently three work processes being reviewed. The welding work process has been deleted from the MEIN population and, as of Octc.ber 28, 1985, has been put in the appropriate pipe weld work process. ERC is also reviewing the deletion of grout from the attribute list and is establishing a new population that specifically addresses grout. This change is due primarily to the way documentation was established. The ERC reinspection procedures and original construction 1 specifications and procedures were reviewed and compared for homogeneity l of work processes and choice of generic attributes. The writer feels I

7 that all attributes listed are appropriate and cover the original ! construction sequence. Five documentation packages from the sampled population were ' refiewed for completion of documentation and comparison to general 4 specifications and attribute list. De six documentation packages reviewed were: (1) ~ Service Water Pump, P.O. CP-010-001 Rotating equipment installed per Hayward Tyler manual. Manual gave specific tolerances on parallel alignment between motor half coupling and collar. (2) Pressurizer, P.O. -0001-18

All dimensions for installation are per Westinghouse drawings.

(3) Safety Injection Pump, TBX-SIAPSI-01 and 02 Specified tolerances on rim-to-rim and face-to-face coupling alignment. A requirement was also given on vibration tolerance. In a discussion with ERC, ERC stated that this attribute may be added to attribute list as a documentation check. (4) Centrifugal Charging Pump, TBX-CSAPCH-01 and CP-0001-024 for Unit 1 ! Installation is per manufacturer's manual. This pump is part of the Chemical and Volume Control System 'and was' fabricated by Pacific Pumps. (5) Motor-Driven Auxiliary Feedwater Pumps, P.O. CP-007-001 4 Alignment is per manufacturer's specifications. Criteria given for checking a. ichor bolts, level and alignment and grouting. (6) Excess Letdown Heat Exchanges Criteria given for backing off of foundation bolts to allow for thermal growth. Requirement given by Westinghouse. The work processes and their attributes are considered to be j appropriate to the installation of me.:hanical equipment. The above six mechanical component document packages were well documented and the appropriate attributes listed on the ERC checklist. The review of the MEIN population will be completed upon resolution of two open items. A I concern regarding the attribute of both torquing as it applies to equipment anchor bolts. The " tightness" attribute may address the need

8 to distinguish " hand tightening" from those instances requiring a specified torque limit. This issue will be further investigated in future audits. Second, ERC is reviewing the need for a vibration ' attribute. This will be addressed in the next audit. e./f. Lyrge Bore Piping Configuration /Small Bore Piping Configuration. The large and small bore piping configuration construction adequacy reviews are addressed using 3000 Brown & Root isometric drawings. The scope of this activity is intended to assess the work process of piping installation through evaluation of attributes such as location, size, and orientation of piping and pipe components. The l Brown & Root isometric drawings provide the basis for sampling both large

and small bore piping. Large bore piping includes that piping which is 2-1/2 inches and larger in diameter; small bore piping is that piping less than 2-1/2 inches in diameter. If an isometric drawing containing both large and small bore piping were to be drawn as part of a sample, it would be used in both the large and the small bore work process review.

The installation work process and its attributes are the same for both large and small bore piping. The piping considered in this review includes all ASME code piping. ERC reported that all piping of large and small bore is installed to one procedure and by one craft--pipe fitters. Some attributes such as piping valves would obviously be included in any i sample for drawn for either large or small bore piping. There are other attributes such as expansion joints, screw joints, and strainers which because they are very few in the system, might not be included in any selected sample. ERC reported that following the sampling process, a

review to assess the adequacy of the sample for adequate representation of attributes would be made. However, a specific component, because it was not included in a sample, would not necessarily be examined only for that reason.
                            -The number of attributes corresponding to the installation of large bore piping appearei accurate and complete. However, the number of them seems to preclude evaluation of them all through the random and engineered sampling process. If ERC suggests that it is not imperative that all such as screwed joints, strainers, and expansion joints be

9 evaluated from e configuration viewpoint, their report should justify this type of conclusion. It appears that the sample should include some number of components which are not extensively used in piping to provide

             ~

confidence that these components cre installed correctly. Their sampling process appears to address the key items such as piping orientation, valve location and orientation, and bends.

g. Pipe-Welds and Material Audit of October 17 and 18, 1985 As with large and small bore pipe configuration, the welding of large and small bore pipe are considered as one grouping. Separate samples, however, are utilized to address each. More than 66,000 welds are required to connect safety-related large and small bore piping. The work processes associated with welding of either large or small bore are prewelding, welding, post-welding. As with the other categories within the mechanical discipline, the population description was reviewed and appeared complete. The process of construction adequacy review is about 40 percent complete. The initial review has been completed; samples have been drawn and preparation of reinspection procedures is in process.

Approximately 65 percent of the sample drawn is either Unit 1 or common. The remainder is Unit 2. ERC personnel were not sure if any Class I welds were included in the sampling. It was indicated that Brown & Root performed all field welding. ERC further reported that the weld inspection processes are the same regardless of the ASME code class. The categories of large and small bore pipe welds were not separated to distinguish between the welding of stainless steel pipe opposed to carbon steel pipe. ERC indicated that the welders were qualified to weld both stainless steel and carbon steel piping and hence there was no need to separate this. At the exit, the audit team expressed concern regarding the lumping of stainless steel welds with carbon steel welds. ERC agreed to review the sample te determine the number of stainless and carbon steel welds. Welds addressed by this study include only field welds.

10 Welds of the penetration sleeve to flange were included within this category. There are 282 such welds in this category. None were included in the random or engineering sampling, however, the large and small bore samples were supplemented to include one mechanical and one electrical penetration weld. Welds work processes and attributes appeared complete but conclusions regarding population homogeneity cannot be reached until review of implementation procedures and welder qualifications is completed. Further, as previously noted, concern exists for the consideration of stainless and carbon steel welds as part of the same population. - Audit of October 28-30, 1985 The piping welding area was addressed in the staff's second audit of the CPRT's Cor.struction Reinspection / Document Review Program to verify (1) the basis for establishment of each population; (2) population boundaries; (3) population exclusions; (4) population interfaces; (5) population list source and basis; (6) work process and basis; (7) attributes associated with work process; and (8) source of attributes. Based upon the fact that both large bore and sniall bore pipe welds were fabricated to the same procedure and by the same craft, ERC decided to lump the populations together. The staff reviewed the (LBWM and SBWM) population basis, description memorandum, population description, populations item list and work process definhion. ERC indicated that only one work process was chosen, Welding. Apparently, regardless of the possible differences in the welds (configuration, material type, or process) each work process involves: (1) comon erection specification requirements; (2) common installation procedure requirements; (3) common craft labor performing the same basic types of operations; (4) comon inspection procedure; and (5) a comon inspection organization. Since basically one two welding methods were used at CPSES, Gas Tungsten ARC Welding (?iTAW) and Shielded Metal ARC Welding (SMAW), ERC has committed to two random samples of 60 welds for each welding method. The staff expressed a concern for the lack of separation of carbon steel

11 and stainless steel welding. ERC pointed out that welder qualification is in compliance with B&R Specification WES-031 which qualifies a welder to-both carbon and stainless steel welding. The staff reviewed WES-031 and '

 .                                                          B&R procedure CP-CPM-6.9D, " Welding and Related Processes", and found very l                                                      - few areas where the pr'ocedures or specifications differed with regard to
                                                        - carbon and stainless steel welding. Differences were associated with the two welding methods GTAW and SMAW.                           ERC said that of the 120 samples
 ~

already established, approximately 50 percent were stainless steel welds. In addition, an engineered sample of 60 welds for each method was picked to account for safe shutdown systems. In both cases, GTAW and SMAW, the original' sample of 60 and the engineered sample overlapped. This necessitated increasing the original sample to achieve the engineered 1 sample of 60 welds. In all, a total number of approximately 180 samples

;                                                          will be inspected.

Under the work process identified as " Welding", 24 attributes were identified, 18 of which are common to both welding methods and to all welds. The remaining 6 attributes will be inspected as the sample dictates. Additional samples for these 6 attributes will be chosen as deemed necessary, or a justification for not increasing the sample will be given at that time. i

h. Pipin'g System Bolted Joints-Audit of October 17 and 18, 1985 Two work processes comprise the piping system bolted joint category.

They are installation preparation and final bolt fitup. There are 7000 bolted joints at the Comanche Peak Power Station. The work processes and l their attributes appear to adequately represent the bolting of piping joints . The procedure which governs this is CP-CPM-6.9E Rev. 8. A flow chart and population description had been prepared to provide the basis

for the sampling of bolted joints. The staff's audit did not yet pursue this to the depth required to draw a firm conclusion regarding the homogeneous nature of the work process populations.

i

   -.      ,_ . ,_-___ _ _ __._ - ,.___--_,_____._,..._ _ -... _ __ . ._.__ ,_,_ _. _ ,_.-_                                         _....m,.      --_..._-,....,,.m. . _ _ . _ ,-__

12 Audit of October 29-31, 1985 l The following ERC procedures were reviewed during the continuation of'this audit: (a) Work Process Definitions (b) Population Description (c) Population Items List (d) QI-021, Revision 1, " Reinspection of Piping System Bolted Joint Material. During the October 18 audit, the NRC audit team raised a concern on torque being an attribute and not a, work process. The concern was relative to equipment specifications requiring a specific torque value on certain types of flanges and the reinspection attribute not containing sufficient samples. In the discussion with ERC, it was noted that there are approximately 7000 items in the piping system bolted joint population. Of the approximately 7000 items, 6700 are in line-piping connections which were installed in accordance with Brown & Root Procedure CP-CPM 6.9E. Section 3.12 of the B&R procedure did not require a. specific torque value to be used. The governing requirement was that the joint "shall be tightened sufficiently to prevent leakage during pressure testing". Since ISAP VII.C is addressing QC-accepted items, only reinsp5ction per the original specification is required. The only flanges which may have required specific torque values would the.refore be in the Mechanical Equipment Population. ERC has reviewed the MEIN population and has only found approximately six flanges which required specific values. Therefore, the issue raised during the October 16 audit is not an issue for Piping System Bolted Joints. It was also noted that the Population Description and Population Item Lists will be revised to delete instrument flanges. These will now be included in the electrical area. l

13

6. Electrical Discipline e

e

                                            ..n. ..-. . - _ .- ,   ,,- --

14 1 .

7. Civil / Structural Discipline The civil structural discipline is divided into 15 populations which are: -

(a) Concrete Placement (b) Structural Steel (c) Liners (d) Fuel Pool Liner (e) Fill and Backfill Placement (f) Grout-Cement (g) Grout-Epoxy (h) Large Bore Pipe Supports - Rigid (1) Large Bore Pipe Supports - Non-rigid (j) Small Bore Pipe Supports (k) Large Bore Pipe Whip Restraints (1) Instrument Pipe / Tube Supports (m) Category 1 Conduit Supports (n) HVAC Duct Supports (o) Equipment Supports. Most of these areas were discussed with ERC personnel by the NRC staff and consultants participating in the first two audits. Some areas have been reviewed in depth while others have been treated in a cursory manner and will be examined further in future audits. Populations (k) through (1) have not been reviewed as of this time because they had recently been formulated and the work processes and. work process attributes were still.being developed.

a. Concrete Placement. The concrete placement population was reviewed in a cursory manner during the initial audit and in depth during the second. During this time the following documents were reviewed to determine if homogeneity of the work processes and attributes had been achieved.

(a) ERC's Work Process Definitions for Concrete Placement Population. (b) ERC's Population Description for Concrete Placement, 8/5/85. (c) ERC's Population Description for Concrete Placement, 8/5/85.

                    \

15 (d) ERC's Population Items List for Concrete Placement, 9/5/85. (e) Procedure QI-043, Revision 0, 9/16/85, Procedure, Quality - Instructions for Issue-Specific Action Plan No. VII.C., '

                                        " Reinspection of Concrete Placement".

(f) Gibbs and Hill Specification 2323-SS-9,1/16/79, " Concrete". (g) Gibbs and Hill Specification 2323-5S-30, 2/10/84, " Structural Embeddments". (h) Brown & Root Construction Procedure 35-1195-CCP-ll, " Concrete Placement", Rev. O. The concrete placement population is presently subdivided into three work processes, each work process having various numbers of attributes. Some of the attributes are to be reviewed by means of a field reinspection; others can only be reviewed by means of a document review; and some will be reviewed utilizing both field reinspection and documentation review. The field reinspection was in progress at the time of this audit and the documentation review had not yet begun. No reinspection packages were reviewed. A few concerns evolved from this audit; however, the reinspection of concrete placement's work processes and attributes does achieve an i appropriate level of homogeneity. These concerns were discussed with ERC and were left as open items. The following is a list of open-items which ERC should address: (a) It may be more appropriate to establish cadwelds as a work . process rather than as an attribute. ERC is to review the cadweld inspection procedure and the concrete pour card sign-off requirements to determine whether cadwelds should be a separate work process. (b) ERC to consider establishing Richmond Inserts as a separate attribute instead of including it with the embeddment attribute. (c) ERC to determine if the condition exists where embedded pipe j sleeves are used to anchor the piping system. If this situation does exist, the embedded sleeves should be a separate attribute.

      --.,,-,.,--,.---,,-c         -               -

'. j 16

b. Structural Steel. Cursory review of this area was done during the second audit to determine if the concept of choosing work processes and attributes would achieve acceptable homogeneity. A limited review of '

the following documents was performed. (a) Procedure QI-045, Rev. 1, 10/23/85, and Change Notice 001, 10/23/85, Quality Instructions for Specific Action Plan VII.C, Reinspection Procedures for Structural Steel. (b) ERC's Description Memorandum for Reinspection of Structural Steel:

1. Rev. O, 9/15/85
11. Rev. 1, 10/8/85 .

iii. Change Notice to Rev. 1, 10/23/85. , (c) Gibbs and Hill Specification 2323-SS 16B, " Structural Steel", 5/12/75. (d) TUGC0 Instruction QI-QP-11.0-15 " Verification of Baseplates for Grouting", Rev. 8, 3/13/85. After performing this general overview of the structural-steel reinspection activity, it is felt that the work processes and attributes identified generally will achieve acceptable homogeneity. However, a more detailed audit of the reinspection procedures will be required to make more detailed coments.

c. Liners. The containment liner population includes horizontal, vertical, and penetration welds. The work processes were reviewed and ERC was informed that consideration should be given to including a plumbness requirement as a work process. Also, it was suggested that ERC consider revising the tolerance when a 6-inch template is substituted for a 10-inch template.

This area will be reviewed in subsequent audits.

d. Fuel Pool Liners. The first audit addressed only the formation of the populations. All welds covered by travelers will form this population. This area will be reviewed in subsequent audits.
                       ,-w-en~y-s,,-r-,-.g,~        ,e-.a,-.-----e-ws.--w-_va.my, , , , , , _   .-e. eer,,w, ,e,-m--=e--,y-,.ewec-w.a--,--m-n.-qp-

17

e. Fill and Backfill Placement. The initial audit addressed the population formation and the work processes within the population.

Testing-is a work process within this population and not within concrete. ' Consideration should be given to the need for consistency. If testing is I retained as a work process, the population description should be modified. to reflect this as a separate work process. f./g. Grout-Cement / Grout-Epoxy. These are new populations which have not yet been reviewed. h./1./j. Large Bore Pipe Supports--Rigid (LBSR)/ Nonrigid (LBSN)/Small Bore Pipe Supports (SBPS). All of the noted pipe support

                                                                                            ~

populations were addressed in the audit of October 29-31, 1985. These populations were formulated in order to assure a proper sampling of rigid and non-rigid pipe supports. This is important, since the majority of

                            " standard catalog supports" are in the non-rigid category. The small bore sampling was not divided, because the number of non-rigid small bore supports is very small and also because the type of support is not readily obvious from the support number (as in the case for LB supports).

ERC intends to sample 60 supports from each of the three groups (LBSR, LBSN, and SBPS). The SBPS population was made up of four work processes; fab'ication, r installation, welding, and inspection. The ERC management seemed to be confused as to whether inspection should be a work process or an attribute. The two LB populations did not show inspection as a j work process. After much discussion, the individual in charge of the l SBPS group indicated that rework to a support very often occurred during l the inspection phase as a result of an UNSAT Inspection Report (IR). l Since this work was performed under the umbrella of inspection in order to close out the IR, this was a separate work process. The individuals l in charge of the LB group appeared hesitant to accept this but eventually i they did. However, at the exit interview, ERC upper management balked at this agreement and said that they would like to investigate this area further. They indicated that if they made any changes they would contact the staff (the staff agrees with inspection being a separate work process). i

  ,-a  . - , , - - .  .- m .--...---,,,+n.--.n,-n,n-a,_,,,,-a.n,..,e-.                                  ,,,..,,_,-,,.,,n--,,,.,-,,,,,,-,-n.-~_v,n-~

7 ', 18 The staff reviewed the various documents (description memorandum,  ! population ~ description and basis, population items list, work process l I justification, attribute description and basis, and QI-019-020, 027 ' I

-thPough030). An auditable trail existed such that all work processes and accompanying attributes could be verified. The staff noted that
                                               ~

under pipe supports welding two attributes were omitted (cleanliness and base metal defects). ERC pointed out that cleanliness was unattainable both from an inspection standpoint (prewelding attribute), and from the point of view of document review (cleanliness was not a hold point on the Multiple Weld Data Card (MWDC)). ERC also said that they did not include [ n base metal defects for supports as an attribute, since it was difficult

to see defects through the paint. The staff pointed out that

! requirements for identifying base metal _ defects existed in ASME ] Subsection NF-4000 and B&R Procedure QI-QAP-11.1-28. -ERC stated that l a during the reinspection of the sample supports, base metal defects were j looked for in each case and noted as an "out of scope" observation for j inclusion in the normal deviation system. The staff would not accept i this, and asked ERC to reconsider this approach. After some discussion, ERC committed to put base metal defects into the attribute list and to treat all instances as part of the construction adequacy.

k. Large Bore Pipe Whip Restraints. An overview of the pipe whip

, restraint population was provided by ERC. This population consists of

moment restraints, pipe whip restraints and restraint support structures listed in Section 3.6 of FSAR. Due to the original construction, two populations may be established, one for the restraint and one for the l support structure. Nine systems have postulated line breaks. Some restraints are listed by Gibbs and Hill and other restraints at3 listed by Site Damage Group. At this time ERC is still reviewing the work

[ j process and is establishing which groups were responsible for installation. l These populations were formed after the initial audit and have not i yet been reviewed. s

19 e

1. Instrument Pipe / Tube Supports.
m. Category / Conduit Supports. '
n. HVAC Duct Supports.

{

          'O. Equipment Supports.

1 i

g/ }. .h .

  ;.                                                                  Page 1 of 11 WORK PROCESS DEFINITION FOR                              j LARGE BORE PIPE SUPPORT - NON-RIGID POPULATION GROUP (LBSN)

INTRODUCTION The Large Bore Pipe Support - Non-Rigid Population includes supports for piping systems (2 1/2 inch nominal pipe si e and larger) all of which are. safety related, Safety Class 1, 2, or 3 and Seismic Category 1. It includes only those supports which utilize constant or variable spring hangers or snubbers as components. It includes all the items shown on the pipe support detail drawings (BRHs). , The installation of all supports within this population requires the following work processes: Fabrication - includes all activities prior to installing the support in its final location in the plant, i.e., before connecting the support structure or components to the building structure and the vendor supplied component item to the pipe attachment point. The process also includes rodification of vendor supplied catalog

     -       items.

Installation - includes all activities required to install the support at its final location in accordance with the pipe support detail drawing (BRH) and the construction hanger package. Welding - includes all welding processes during fabrication and installation. The following work process descriptions demonstrate that reasonable homogeneity does exist at the work process level. Regardless of the type of support, size of pipe being supported or material and components used, each work process involves: a common specification, a common construction procedure, a common construction canagement organization, common craft labor performing the same basic types of operations, a common inspection instruction, and a common inspection organization. r i 49 l 0505/WRKPRI . anaaaana I

1 WORK PROCESS: FABRICATION

1. INTRODUCTION Fabrication is the first of the work processes required for the installation of large bore pipe supports - non-rigid. It includes all activities performed prior to connecting support structures or components to the building structure and attaching the component support to the pipe. It includes modification of vendor-supplied component parts. The Fabrication Work Process applies to all items in the LBSN population.
2. HOMOGENEOUS WORK PROCESS JUSTIFICATION
a. Source of Attributes and Acceptance Criteria Reinspection and/or documentation review attributes for the Fabrication Work Process are derived from common specification, procedures and quality instructions:

Three Gibbs & Hill Design Specifications --

1. 2323-MS-46A, " Nuclear Safety Class Pipe Hangers and Supports"
2. 2323-MS-100, " Piping Erection"
3. 2323-SS-30, " Structural Embedments" One Brown & Root Construction Procedure
1. CP-CPM-7.3, " General Fabrication Procedure" One Brown & Root Quality Instruction
1. QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Corponent Supports" The activities performed during the Fabrication Work Process are governed by the construction procedure and documentation.

The type of support construction is given on the design drawing and related paperwork.

b. Installation Procedure Installation Procedures are not applicable here as they are treated as a separate work process altogether. The second work process describes the installation procedure.

2 0505/WRKPR1

e WORK PROCESS: FABRICATION (Cont'd)

2. HOMOGENEOUS WORK PROCESS JUSTIFICATION (Cont'd)
c. Applicable Codes and Standards The ASME B&PV Code, Section III, Subsection NF is applicable to all Safety Class 1, 2, and 3 pipe supports. The requirements of this code are incorporated in the specifications, procedures and instructions. Gibbs & Hill Specification 2323-MS-46A, Rev. 6. " Nuclear Safety Class Pipe Rangers and Supports" invokes the requirements of the ASME
  • Code along with specified addenda and Code Cases. The use of the ASME Code as a basis for all construction activities ensures attribute homogeneity.
d. Construction Work Force All fabrication activities were performed by Brown & Root employed Structural Ironworkers, who received training to the construction procedures governing fabrication. (CP-CPM-7.3,
                        " General Fabrication Procedure")                                 _.
e. Inspection and Acceptance Standards and Inspection Group Inspections were performed in accordance with the requirements of Brown & Root Instruction QI-QAP-11.1-28 for those activities which required witnessing by QC Inspectors. All inspecticns were performed by Brown & Root QC Inspectors, who were trained to the inspection instruction.
3. ATTRIBUTE APPLICABILITY
a. Description of Attributes Attribute Verified By Activity l

2

1. Verify identification Identification Documentation marking transfer during Review cutting operations
2. Ensure the configuration Configuration Reinspection
is in accordance with the design drawing Ensure mechanical Bolting Reinspection 3.

connections are Documentation made properly Review 3 0505/WRKPRI 12/02/85

                                                                                               \

WORK PROCESS: FABRICATION (Cont'd)

a. Description of Attributes (Cont'd)

Activity Attribute Verified By

4. Ensure all material is Material Documentation acceptable for its Traceability Review intended use and is identifiable until installation ,
b. Inaccessible Attributes There are no attributes in the Fabrication Work Process that cannot be either reinspected or evaluated by means of a document review.
c. Attribute Consistency and Sufficiency All attributes applicable to the Fabrication Work Process, with the exception of bolting, have the same accept / reject criteria and is applicable to all sanple items within the population.

Attribute consistency and sufficiercy of bolting will be attained by combining three populations (small bore, large bore rigid and non-rigid supports). Accept / Reject criteria for each type of bolted joint is the same for these three populations. Although there will not be 60 of each type of bolted joint in one population, 60 of each type of bolted joint will be attained among the three populations, thereby assuring sufficiency.

d. Apparently Dissimilar Work Processes There are no such activities within the fabrication work process.
                                                                                         )

i l 4.. __ . _ . _ . . ._ _... _0505 /WRKPRI _

o WORK PROCESS: INSTALLATION I. INTRODUCTION Installation, paralleled by welding, is the next work process required for the installation of large bore pipe supports - non-rigid. It includes all activities required to connect the piping to a building structure through an intermediate support structure. The installation work process should result in a configuration consistent with the design. The Installation Work Process applies to all items in the LBSN Population.

2. HOMOGENEOUS WORK PROCESS JUSTIFICATION
a. Source of Attributes and Acceptance Criteria Reinspection and/or documentation review attributes for the Installation Work Process are derived from common specification, procedures and quality instructions:
  • Three Gibbs & Hill Design Specifications
1. 2323-MS-46A, " Nuclear Safety Class Pipe Rangers and Supports"
2. 2323-MS-100, " Piping Erection"
3. 2323-SS-30, " Structural Embedments" Three Brown & Root Construction Procedures
1. CP-CPM-9.10. " Component Support Installation"
2. CP-CPM-9.10A, " Installation of Vendor Supplied Component Support Catalog Items"
3. CEI-20 " Installation of Hilti Drilled-In Bolts"
  • One TUGC0 Engineering Instruction
1. CP-El-4.5-1, " General Program for As-Built Piping

! Verification"

  • One Brown & Root Quality Instruction i
1. QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports" The activities performed during the Installation Work Process are governed by the construction procedure and documentation.

The type of support construction is given on the design drawing and related paperwork. 5 0505/WRKPRI 12/02/85

        -, . _ - _ _ _ - - . - . . - _ - . . - . -- . . - ~ - _ . . .                                         - - _ , -   . . . - - - _ - - -

a WORK PROCESS: INSTALLATION (Cent'd)

2. HOMOGENEOUS WORK PROCESS JUSTIFICATION (Cont'd)
b. Installation Procedure All supports are installed in accordance with Brown & Root Procedure CP-CPM-9.10 and CP-CPM-9.10A as stated in a. above.

Concrete Expansion Anchors are installed in accordance with Browr. & Root Procedure CEI-20, " Installation of "Hilti" Drilled-in Bolts". ,

c. Applicable Codes'and Standards The ASME B&PV Code, Section III, Subsection NF is applicable to all Safety Class 1, 2, and 3 pipe supports. The requirements of this code are incorporated in the specifications, procedures and instructions. Gibbs and Hill Specification 2323-MS-46A, Rev. 6 " Nuclear Safety Class Pipe Hangers and Supports" invokes the requirements of the ASME Code along with specified addenda and Code Cases. The use of ~ ~

the ASME Code as a basis for all construction activities ensures attribute homogeneity.

d. Construction Work Force-All installation activities were performed by Brown & Root Structural Ironworkers, who received training to the construction procedures governing installation. (CP-CPM-9.10
            " Component Support Installation" and CP-CPM-9.10A
            " Installation of Vendor Supplied Component Support Catalog Items")
e. Inspection and Acceptance Standards and Inspection Group All inspections of installation work processes were performed in accordance with the requirements of Brown & Root Instruction QI-QAP-11.1-18. All inspections were performed by Brown and Root QC Inspectors, who were trained to the appropriate inspection instruction (s).
3. ATTRIBUTE APPLICABILITY
a. Description of Attributes Activity Attribute Verified By
1. Ensure support is Identification Reinspection permanently marked with support number.
2. Ensure location and Location and Reinspection orientation are Orientation acceptable
                                          -                        au.vussm:m

WORK PROCESS: INSTALLATION (Cont'd)

a. Description of Attributes (Cont'd)

Activity Attribute Verified By

3. Ensure all items are Configuration Reinspection installed in accordance with the drawing
4. Ensure bolting meets Bolting Reinspection the requirements Documentation -

Review

5. Ensure Hilti Bolts Concrete Expansion Reinspection are installed Anchors Documentation properly Review
6. Verify Vendor Vendor Supplied Reinspection Supplied Component Components Documentation Support Catalog Review ,,

Items are installed properly

7. Ensure all material Material Documentation acceptable and . Traceability Review identification of material is documented
b. Inaccessible Attributes There are no attributes in the Installation Work Process that cannot be either reinspected or evaluated by means of a document review.
c. Attribute Consistency and Sufficiency All attributes applicable to the Installation Work Process, with the exception of bolting, have the same accept / reject criteria which is applicable to all sample items within the population.

Attribute consistency and sufficiency of bolting will be attained by combining three populations (small bore, large bore rigid and non-rigid supports). Accept / Reject criteria for each type of bolted joint is the same for these three populations. Although there will not be 60 of each type of bolted joint in one population, 60 of each type of bolted joint will be attained among the three populations, thereby assuring sufficiency. 7 0505/WRKPRI 12/02/85 . . . _ - -

WORK PROCESS: INSTALLATION (Cont'd) i

3. ATTRIBUTE APPLICABILITY (Cont'd)

I

d. Apparently Dissimilar Work Processes I

There are no such activities within the Installation Work Process.

                                                                           ~-e b

4 8 0505/WRKPRI 12/02/85

o 4 - WORK PROCESS: WELDING

1. INTRODUCTION Welding is a work process which can be performed during the fabrication and installation work processes. It includes all the activities required to join two members together by welding.
2. HOMOGENEOUS WORK PROCESS JUSTIFICATION

. a. Source of Attributes and Acceptance Criteria Welding has been divided into Piping Welds (integral)and Support Welds (non-integral) because they are governed by dif f erent Subsections of the ASME Code. Piping Weld attributes are derived from the ASME B&PV Code, Section III, Subsections NB, NC, or ND for Code Classes 1, 2, and 3, respectively. Support Weld Attributes are derived from the ASME B&PV Code, Section III, Subsection NF. The characteristics of the two welding groups are identical, only the accept / reject criteria differs.

b. Installation Procedure All welding for component supports i= performed in accordance with Brown and Root Procedure CP-CPM-7.3D, " Welding and Related Processes". All welding for piping attachments is performed in accordance with Brown and Root Procedure CP-CPM-6.9D, " Welding and Related Processes".
c. Applicable Codes and Standards Welding for component supports is governed by Subsection NF,
  • piping attachments by Subsections NB, NC, and ND, of the ASME Code as stated in a. above.
d. Construction Work Force All welding activities were performed by Structural Ironworkers, who received training to the construction procedures governing installation and certification to applicable welding procedures.
e. Inspection and Acceptance Standards and inspection Group All support welds were inspected to the criteria given in Brown and Root Instruction QI-QAP-11.1-28. Piping Welds were inspected to the criteria given in Brown and Root Instruction QI-QAP-ll.1-26. All welding inspections are performed by Brown and Root OC Inspectors.

9 0505/WRKPR1

      -                                                                                     12/02/85

l t-4 WORK PROCESS: WELDING (Cont'd)

3. ATTRIBUTE APPLICABILITY
a. . Description of Attributes Activity Attribute Verified By
1. Ensure location, size, Location, Size Reinspection
and profile of weld is and Profile acceptable
2. Ensure reinforcement Reinforcement, Reinspection .

and offset of butt welds Offsets are within specified limits 3.. Ensure surface condition Surface Condition, Reinspection acceptable and there are Cracks / Fusion Documentation cracks or lack of fusion Review I

4. Verify welds were Welder ID Reinspection

'j performed by qualified Documentation ~~ welders Review

5. Ensure no rust exists Rust Reinspection on stainless steel f piping welds
b. Inaccessible Attributes There are no attributes in the Welding Work Process that cannot be either reinspected or evaluated by means of a document review.
c. Attribute Consistency and Sufficiency Piping welds are only applicable to supports which have members integrally welded to the pipe. All accept / reject criteria for the attributes are the same for all sample items

' within the population, thereby ensuring consistency. Multiple

piping welds can be used for one sample item and the similarity of large bore pipe supports-rigid and small bore pipe supports populations will ensure that a sufficient number of items are inspected to draw valid conclusions about piping.

welds. Support welds are applicable to all sample items within the population. -Accept / reject criteria for all welds is the same, ensuring consistency. Multiple welds for each sample item will be sufficient to draw valid conclusions regarding the I adequacy of support welds. i l i 10 0505/WRKPR1 j 12/02/85

                                               .      ~.           ~            -                 -

9 L' WORK PROCESS: WELDING (Cont'd)

3. ATTRIBUTE APPLICABILITY (Cont'd)
d. Apparently Dissimilar Work Processes,.

There are no such activities within the' Welding Work Process. 4 e J t 'Y

                                                                                                                                     ~=

4 I t t t I i i i 11 0505/WRKPR1 4 12/02/85

a. . .. s SIRUCIURAL ,

POPULATIONS I I LARGE BORE LARGE BORE SMALL BORE PIPE SUPPORTS PIPE SUPPORTS PIPE SUPPORTS RIGID NON-RIGID .I ACTIVITIES /AT1RIBUTES 1 I I WORK PROCESS l FABRICATION l l lNSTALLAT10Nl l WELDING l ATTRIBUTES -IDEliTi rICAT I0ri -IDENTIFICATION -PIPE WELDS (INTEGRAL)

                   -C0rlF IGUR AT 10tl          -LOCATI0fl 1 ORIENTATIOff          -SUPPORT WELDS (NON-lNTEGRAL)
                   -BOL T it!G                  -CONFIGURATION
                   -MATL TRACEABILITY *         -BOLTING
                                                -CONCRETE EXPAtlS1014 ANCl10RS**
                                                -VENDOR SUPPLIED C0flPONENTS**
                                                -MATL. TRACEABillTY*
  • DOCUMENT REVIEW ONLY
    • REINSPECTION AND DOCURLlif REVIEW NO
  • MEANS PERFORMED ONLY DURING Tile REINSPECIlull PROCESS 0505/wsKrat 12/02/85
    .                                                                               D 7 Page 1 of 11 WORK PROCESS DEFINITION FOR SMALL BORE PIPE SUPPORT POPULATION GROUP (SBPS)

INTRODUCTION The Small Bore Pipe Support Population includes supports for piping systems (2 inch nominal pipe size and smaller) all of which are safety related, Safety Class 1, 2, or 3 and Seismic Category I. It includes all small bore supports including those which utilize constant or variable spring hangers or snubbers as components. It includes all the items shown on the pipe support detail drawings (GHH's and BRH's). The installation of all supports within this population requires the following work processes: Fabrication - includes all activities prior to installing the support in its final location in the plant, i.e., before connecting the support structure or components to the building structure and the vendor supplied component item to the pipe attachment point. The process also includes modification of vendor supplied catalog items. _, Installation - includes all activities required to install the support at its final location in accordance with the pipe support detail drawing (BRH) and the construction hanger package. Welding - includes all welding processes during fabrication and installation. The following work process descriptions demonstrate that reasonable homogeneity does exist at the work process level. Regardless of the type of support, si:e of pipe being supported cr material and components used, each work process involves: a common specification, a common construction procedure, a common construction management organization, common craf t labor performing the same basic types of operations, a common inspection instruction, and a common inspection crganization. V 30 0513/WRKPR1 useuna I

 's WORK PROCESS: FABRICATION
1. INTRODUCTION Fabrication is the first of the work processes required for the installation of small bore pipe supports. It includes all activities performed prior to connecting support structures or components to the building structure and attaching the component-support to the pipe. It includes modification of vendor-supplied component parts. The Fabrication Work Process applies to all items in the SBPS population.
2. HOMOGENEOUS WORK PROCESS JUSTIFICATION
a. Source of Attributes and Acceptance Criteria Reinspection and/or documentation review attributes for the Fabrication Work Process are derived from common specification, procedures and quality instructions:

Three Gibbs & Hill Design Specifications .,

1. 2323-MS-46A, " Nuclear Safety " lass Pipe Hangers and Supports"
2. 2323-MS-100, " Piping Erectior"
3. 2323-SS-30, " Structural Embedments" One Brown & Root Construction Procedure
1. CP-CPM-7.3, " General Fabrication Procedure" One Brown & Root Quality Instruction
1. QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Conponent Supports" The activities perforced during the Fabrication Work Process are governed by the construction procedure and documentation.

The type of support construction is given on the design drawing and related paperwork.

b. Installation Procedure Installation Procedures are not applicable here as they are treated as a separate work process citogether. The second work process describes the installation procedure.

2 0513/WRKPRI

WORK PROCESS: FABRICATION (Cont'd)

2. HOMOGENEOUS WORK PROCESS JUSTIFICATION (Cont'd)
c. Applicable Codes and Standards The ASME B&PV Code, Section III, Subsection NF is applicable to all Safety Class 1, 2, and 3 pipe supports. The requirements of this code are incorporated in the specifications, procedures and instructions. Gibbs & Hill Specification 2323-MS-46A, Rev. 6 " Nuclear Safety Class Pipe Hangers and Supports" invokes the requirements of the ASME -

Code along with specified addenda and Code Cases. The use of the ASME Code as a basis for all construction activities ensures attribute homogeneity.

d. Construction Work Force All Fabrication activities were performed by Brown & Root employed Structural Ironworkers, who received training to the construction procedures governing fabrication. (CP-CPM-7.3, _,
           " General Fabrication Procedure")
e. Inspection and Acceptance Etandards and Inspection Group Inspections were performed in accorcr.nce with the requirements of Brown & Root Instruction QI-QAP-11.1-28 for those activities which required witnessing by QC Inspectors. All inspections were performed by Brown & Root QC Inspectors, who were trained to the inspection instruction.
3. ATTRIBUTE APPLICABILITY
a. Description of Attributes Attribute Verified By Activity
1. Verify identification Identification Documentation marking transfer during Review cutting operations
2. Ensure the Configuration Reinspection configuration is in accordance with the design drawing
3. Ensure mechanical Bolting Reinspection connections are Documentation made properly Review 3 0513/WRKPR1
  .i WORK PROCESS:             FABRICATION (Cont'd)
a. . Description of Attributes (Cont'd)

Activity Attribute Verified By

4. Ensure all material Material Documentation is acceptable for .

Traceability Review its intended use and is identifiable until installation

b. Inaccessible Attributes There are no attributes in the Fabrication Work Process that cannot be either reinspected or evaluated by means of a document review.
c. ' Attribute Consistency and Sufficiency All attributes applicable to the Fabrication Work Process, ~

with the exception of bolting, have the same accept / reject criteria which is applicable to all sample items within the population. Attribute consistency and sufficienc < of bolting will be attained by combining three populatians (small bore, large i bore rigid and non-rigid supports). Accept / Reject criteria for each type of bolted joint is the same for these three populations. Although there will not be 60 of each type of bolted joint in one population, 60 of each type of bolted joint will be attained arong the three populations, thereby assuring sufficiency.

d. Apparently Dissimilar Work Processes There are no such activities within the Fabrication Work Process.

1 i 4 0513/WRKPR1

 ..      6 WORK PROCESS:                                   INSTALLATION
1. INTRODUCTION Installation, parallelled by welding, is the next work process required for the installation of small bore pipe supports. It includes all activities performed in connecting the piping to a building structure through an intermediate support structure. The Installation Work Process should result in a configuration consistent with the specified design. The Installation Work Process applies to all items in the SBPS Population.
2. HOMOGENEOUS WORK PROCESS JUSTIFICATION
a. Source of Attributes and Acceptance Criteria Reinspection and/or documentation review attributes for the Installation Work Process are derived from common specification, procedures and quality instructions:
  • Three Gibbs & Hill Design Specifications _,
1. 2323-MS-46A, " Nuclear Safety Class Pipe Hangers and Supports"
2. 2323-MS-100, " Piping Erection" f
3. 2323-SS-30. " Structural Embedments" Three Brown & Root Construction Procedures
1. CP-CPM-9.10. " Component Support Installation"
2. CP-CPM-9.10A, " Installation of Vendor Supplied Component Support Catalog Items" l 3. CEI-20 " Installation of Hilti Drilled-In Bolts"
                       '    One TUGC0 Engineering Instruction
1. CP-EI-4.5-1, " General Program for As-Built Piping Verification"
                        '   One Brown & Root Quality Instruction
1. QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports" The activities performed during the Installation Work Process l are governed by the construction procedure and documentation.

The type of support construction is given on the design , drawing and related paperwork. 5 0513/WRKPR1

4 WORK PROCESS: INSTALLATION

  • (Cont'd)
2. HOMOGENEOUS WORK PROCESS JUSTIFICATION (Cont'd)
b. Installation Procedure

< All supports are installed in accordance with Brown & Root Procedure CP-CPM-9.10 and CP-CPM-9.10A as stated in a. above. Concrete Expansion Anchors are installed in accordance with Brown & Root Procedure CEI-20, " Installation of "Hilti" Drilled-in Bolts". 1

c. Applicable Codes and Standards
  • The ASME B&PV Code, Section III, Subsection NF is applicable to all Safety Class 1, 2, and 3 pipe supports. The requirements of this code are incorporated in the  !

specifications, procedures and instructions. Cibbs and Hill i

'              Specification 2323-MS-46A, Rev. 6. " Nuclear Safety Class Pipe Hangers and Supports" invokes the requirements of the ASME

' Code along with specified addenda and Code Cases. The use of "~ r the ASME Code as a basis for all construction activities I 1 ensures attribute homogeneity. j

d. Construction Work Force All installation activities were performed by Brown & Root Structural Ironworkers, who received training to the construction procedures governing installation. (CP-CPM-9.10,

, " Component Support Installation" and CP-CPM-9.10A,

                " Installation of Vendor Supplied Component Support Catalog Items")
e. Inspection and Acceptance Standards and Inspection Group All inspections of Installation Work Processes were performed in accordance with the requirements of Brown & Root Instruction QI-QAP-11.1-28. All inspections were performed by i

Brown and Root QC Inspectors, who were trained to the appropriate inspection instruction (s). 1

3. ATTRIBUTE APPLICABILITY i

t

a. Description of Attributes Activity Attribute Verified By f

Reinspection

1. Ensure support is Identification l permanently marked i with support number.

6 0513/WRKPRI

.= WORK PROCESS: INSTALLATION (Cont'~d)

a. Description of Attributes (Cont'd)

Activity Attribute Verified By

2. Ensure location and Location and Reinspection orientation are Orientation acceptable
3. Ensure all items are Configuration Reinspection installed in accordance '

with the drawing

4. Ensure bolting meets Bolting Reinspection the requirements Documentation Review
5. Ensure Hilti Bolts Concrete Expansion Reinspection are installed Anchors Documentation properly Review
6. Verify Vendor Vendor Supplied Reinspection Supplied Component Componente Documentation Support Catalog Review Items are installed properly .
7. Ensure all material Material Documentation acceptable and Traceability Review identification of material is documented
b. Inaccessible Attributes There are no attributes in the Installation Work Process that cannot be either reinspected or evaluated by means of a document review.
c. Attribute Consistency and Sufficiency All attributes applicable to the Installation Work Process, with the exception of bolting, have the sane accept / reject criteria which is applicable to all sample items within the population.

Attribute consistency and suf ficiency of bolting will be attained by combining three populations (small bore, large bore rigid and non-rigid supperts). Accept / Reject criteria 7 0513/WRKPR1

WORK PROCESS: INSTALLATION (Cont'd)

c. Attribute Consistency and Sufficiency for each type of bolted joint is the same for these three populations. Although there will not be 60 of each type of bolted joint in one population, 60 of each type of bolted joint will be attained among the three populations, thereby assuring sufficiency.
d. Apparently Dissimilar Work Processes There are no such activities within the Installation Work Process.

't E 8 0513/WRKPRI

WORK PROCESS: WELDING

1. INTRODUCTION Welding is a Work Process which can be performed during the Fabrication and Installation Work Processes. It includes all the activities required to join two members together by welding.
2. HOMOGENEOUS WORK PROCESS JUSTIFICATION
a. Source of Attributes and Acceptance Criteria

) Welding has been divided into Piping Welds (integral) and . Support Welds (non-integral) because they are governed by different Subsections of the ASME Code. Piping Weld attributes are derived from the ASME B&PV Code, Section III, Subsections NB, NC, or ND for Code Classes 1, 2, and 3, respectively. Support Weld Attributes are derived from the ASME B&PV Code, Section III, Subsection NF. The characteristics of the two welding groups are identical, only the accept / reject criteria differs,

                                                                                                       ~
b. Installation Procedure All welding for component supports is performed in accordance with Brown and Root Procedure CP-CPP-7.3D, " Welding and i Reinted Processes". All welding for piping attachments is performed in accordance with Brown and Root Procedure CP-CPM-6.9D, " Welding and Related Processes".
c. Applicable Codes and Standards Welding for component supports is governed by Subsection NT, piping attachments by Subsections NB, NC, and ND, of the ASME Code as stated in a. above.
d. Construction Work Force All welding activities were performed by Structural Ironworkers, who received training te the construction procedures governing installation and certification to applicable welding procedures.
e. Inspection and Acceptance Standards and Inspection Group All support welds were inspected to the criteria given in Brown and Root Instruction QI-QAP-11.1-28. Piping Welds were inspected to the criteria given in Brown and Root Instruction QI-QAP-11.1-26. All welding inspections are performed by Brown and Root QC Inspectors.

9 0513/VRKPRI

WORK PROCESS: WELDING (Cont'd)

3. ATTRIBUTE APPLICABILITY
a. Description of Attributes Activity Attribute Verified By
1. Ensure location, Location, Size Reinspection size, and profile and Profile of weld is acceptable
2. Ensure reinforcement Reinforcement, Reinspection .

and offset of butt Offsets welds are within specified limits

3. Ensure surface Surface Condition, Reinspection condition acceptable Cracks / Fusion Documentation cracks or lack of Review
              ' fusion
                                                                            ~~
4. Verify welds were Welder ID Reinspection performed by qualified Documentation welders Review
5. Ensure no rust exists Rust Reinspection on stainless steel piping welds
b. Inaccessible Attributes There are no attributes in the Welding Work Process that cannot be either reinspected or evaluated by means of a document review.
c. Attribute Consistency and Sufficiency Piping welds are only applicable to supports which have members integrally welded to the pipe. All accept / reject criteria for the attributes are the same for all sample items within the population, thereby ensuring consistency. Multiple piping welds can be used for one sample item and the similarity of large bore pipe supports-rigid and large bore pipe supports - non-rigid populations will ensure that a sufficient number of items are inspected to draw valid conclusions about piping welds.

Support welds are applicable to all sample items within the population. Accept / reject criteria for all welds is the same, ensuring consistency. Multiple welds for each sample item will be sufficient to draw valid conclusions regarding the adequacy of support welds. 10 0513/WRKPRI

WORK PROCESS: WELDING (Cont'd)

3. ATTRIBUTE APPLICABILITY (Cont'd)
d. Apparently Dissimilar Work Processes There are no such activities within the Welding Work Process.

en, p 4 6 11 0513/WRKPRI

S'TP ' ~ "_'l PCFt'L AT!rg I LARGE SCRE LARGE Br6E

                                         '                                                                       SFALL BORE PIPE SUPPORTS                                         PIPE SUPPORTS                                 PIPE SUPPORTS RIGID                                               NON-RIGIF                                                   '

ACTIVITIES / ATTRIBUTES I WORK PROCESS IFAERICATION] [ INST ALL ATION] [WELDi t:Gl ATTRIEUTES -IDENTIFICATION -IDENTIFICATION -PIPE '4 ELDS (INTEGRAL)

                      -EONFIGURATION                 -LOCATION 1 ORIENTATION                 -SUPPORT WELDS (KOK-INTEGPAL)

BOLTING -CONFIGURATION

  • 4kTt. TRACEABILITY * -BOLTING
                                                    -CONCPETE EXPANSION ANCHORS **

VENDOR SUPPLIED COMPONENTS ** ,

                                                    -MATL. TRACEAPILITY*

00 CUP.ENT REVIEW ONLY

 ** REINSPECTION AND DOCUPENT REVIEW NO
  • FEANS PERFORRED ONLY DURING THE REINSPECTION PROCESS 0505/uttrRI 3 .}}