IR 05000445/1987004
| ML20237L794 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/31/1987 |
| From: | Wagner P NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20237L788 | List: |
| References | |
| 50-445-87-04, 50-445-87-4, 50-446-87-04, 50-446-87-4, NUDOCS 8709090078 | |
| Download: ML20237L794 (48) | |
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L U. S. NUCLEAR REGULATORY COMMISSION Office of Special Projects NRC Inspection Report: 50-445/87-04 Permits: CPPR-126 50-446/87-04 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Dates: Unit 1: August 1, 1988 Unit 2: Extension request submitted.
Applicant: TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: January 1, 1987, through February 28, 1987 Inspector: - - MO N P. C. Wagner, Reac(pr Inspector Date i Consultants EG&G -;W. Richins (paragraphs 2, 4.s, u, w, x, and z) V. Wenczel (paragraph 6) j Parameter - D. Jew (paragraphs 4.t, aa, ab, af, ag l and ah) i R. Masterson (paragraphs 4.ac, ad, ae ; and ah) B. Saffell (paragraphs 2, 4.1, k, m-p and ac) g90gM$hs p G . __ - ____ ____-_ _
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- 2 Teledyne - D. Landers (paragraphs 3 and 5)
R. Hookway (paragraphs 4.1, q, r and 5) R. Wray (paragraphs 4.h, j and 5) L. Stanley (paragraphs 4.a, d, and e) J. Flaherty (paragraphs 4.v, y and 5) Reviewed By: W &/J//87 I. Barnes, Senior Project Inspector Date Apptoved: R F (1) J R. F._Warnick, Assistant Director W27/87
#Date for Inspection Programs Comanche Peak Project Division Office of Special Projects Inspection Summary Inspection Conducted: January 1 through February 28, 1987 (Report 50-445/87-04; 50-446/87-04)
Areas Inspected: Nonroutine, unannounced inspection of the Comanche Peak Response Team (CPRT) evaluation of construction deviations for safety. significance.
Results: Certain weaknesses including some of potential generic concern were identified with respect to the safety significance evaluation (SSE)-process and results. Areas of potential generic concern are summarized in paragraph 3 and included:
(a) determinations that deviations based on lack of required documentation were not safety significant, (b) improper or inadequate checking of calculations, (c) failure to consider manufacturer's criteria and recommendations in performing SSEs, and (d) apparent lack of consideration of need to update or rectify certified stress / design reports. Additional subjects of concern, which will be tracked as open items, are discussed in paragraphs 4 and 5.
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C '. 3 DETAILS. 1 1. 1 Persons Contacted-
*J.(M. Ayres; Quality' Engineering (QE) Supervisor, TU Electric
'*R. P. Baker, Regulatory _ Compliance Manager, TU Electric
*J. L. Barker, Engineering Assurance (EA) Manager, TU Electric
*J.' Beck,.Vice President, TU Electric
*E. J. Brabazon, Engineering Manager, CPRT
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R. Carle, Supports Lead Engineer of Safety. Significance
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Evaluation Group (SSEG), CPRT
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*W. G..Counsil, Executive Vice President,.TU Electric *R.._D. Delano, Nuclear. Licensing Engineer, TU Electric *J. Guibert, Senior Review Team (SRT),HCPRT *P. E. Halstead,. Site Quality Control (QC) Manager, TU Electric J. L. Hansel, Review Team Leader (RTL), CPRT *T. L. Heatherly, Regulatory Compliance Engineer, TU Electric *J. E. Krechting, Director of Engineering, TU Electric C. Lee, Structural Lead Engineer of SSEG, CPRT A. Lew, Electrical Lead Engineer of SSEG, CPRT R. Miller, Supervisor of SSEG, CPRT J. Mundo, Mechanical Lead Engineer of SSEG, CPRT I R. Munshi, Support Lead Engineer of SSEG, CPRT *L. D. Nace, Vice President, TU Electric A. A. Patterson, Issue Coordinator,_ERC *D. M. Reynerson, Unit 2 Project Manager, TU Electric *C. E. Scott, Start-up Manager, TU Electric- *M. R. Steelman, CPRT, TU Electric *J. F. Streeter, Quality Assurance (QA) Director, TU Electric T. G. Tyler, CPRT Program Director, TU Electric *J. E. Wren,- QC Services. Supervisor, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the March 3, 1987, exit interview.
2. Inspection Process (94941B) The NRC inspectors reviewed the'SSE process implemented by the
. CPRT. The CPRT process used to evaluate construction
. ' discrepancies for safety significance is described in Appendix E to the CPRT Program Plan. Appendix E states that all construction discrepancies are classified as either: L I (a) Construction Deviation: Any identified error related to construction or installation of safety-related hardware that has been determined to constitute a verified failure to construct or install a safety-related structure, t
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system or component in accordance with safety-significant attributes and criteria contained in design drawings and specifications or installation procedure / requirements, or (b) Construction Deficiency: Any identified construction deviation that has been determined to be safety-significant.
The initial NRC inspection of the SSE process was conducted from April 28 through May 1, 1986. The resdits of that inspection'were documented in a trip report provided in the Teledyne Engineering Services (TES) letter dated July 1, 1986; a copy is included as Attachment 1. j l During this report period,'the NRC inspectors re-reviewed t previously identified SSE questions and selected additional f SSEs. The sample selections were randomly chosen from a CPRT ' listing of all deviation reports (DRs). The listing showed the DR number, whether valid or invalid, the type of problem identified, the completion date of the SSE, and whether the deviation was safety significant. The NRC inspectors selected a sample of SSEs for review from each of the Issue-Specific Action Plan (ISAP) VII.c. populations. These samples comprised approximately 10 percent of the total SSEs in each * population and included most of the types of problems identified in the DRs. The samples were, however, weighted toward the areas of more significant problems; e.g., in the electrical equipment population, more samples were selected from the listing which indicated an improper modification than were . selected for identification numbering discrepancies. The NRC inspectors selected additional SSEs, as appropriate, to ensure adequate evaluation of the types of problems identified.
3. Inspection Findings of Potential Generic Concern (94941B)
(a) One general condition that the NRC inspectors observed in most of the populations involved the determination that a deviation based on the lack of required documentation was not safety significant. This type of dispositioning of a DR occurred frequently in the documentation review identified deviations. The evaluation of a DR written for missing or incomplete documentation usually stated that "Since no documentation is available for review, no conclusion can be drawn about the condition. The fact that there is missing documentation is not, in itself, evidence of unacceptable hardware." The conclusion is then drawn that " Based on the above evaluation, it is concluded that the missing documentation alone does not result in the inability of the (component) to perform its intended function". On this basis alone, the SSEs were determined to not be safety significant deviations.
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g An example of this; type of disposition is discussed in paragraph 4.a (R-E-CABL013-DR03).
In the NRC's view, the lack of required documentation is ' an indeterminate situation. Additional evidence such as other relevant documentation, inspections, tests, interviews, etc., is necessary before there is justification for making a conclusion of no safety significance for these DRs.. The NRC inspectors reviewed many SSEs where needed addi?ional evidence was identified and obtained to support the conclusions which avoided the indeterminate situations described above.
The NRC inspectors discussed this condition with CPRT personnel and subsequently Corrective Action Request (CAR) CP-049 was issued on February 6, 1987. CAR CP-049 states, in part, "All indeterminate SSEs will be identified and revised where necessary to make it clear that no: conclusions can be reached concerning the ability 1 of the hardware to perform its intended function." A notation of an indeterminate conclusion is to be entered on the SSE title page and Procedure CPP016 will be revised to reflect this change. (A copy of Revision 5 to CPP-016, dated March 4, 1987, was reviewed subsequent to the end of this report period and was found to contain this change.) The NRC inspectors were also informed that the above type dispositions would be reevaluated in the population reports and trending analyses. This subject is an open item (445/8704-0-01).
Examples of this NRC concern are addressed in paragraphs 4.a(2), e, s(2), t, x(2), z, aa, ab, and ac(2), below.
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(b) Another general condition the NRC inspectors observed in a number of SSEs was the perceived lack of checking of -
the analysis or calculations performed to evaluate the safety significance of a discrepancy. Paragraph 5.2.3 of Revision 4 to CPP-016 states, in part, "For small calculations . . . the SSE reviewer may sign as both the checker and reviewer." The NRC inspector expected the
" CHECKER" block to be signed by either the reviewer when only "small calculations" were involved, or by another person (not the reviewer) for those cases requiring ;
extensive calculations. Instead, the checker block was often left blank or marked "NA." This was discussed with L ERC personnel who stated that for cases involving small 4 calculations the reviewer was also performing the l checking function. Further, ERC indicated that the I reviewer's signature indicated that the checking function had been performed. ERC did, however, agree to revise l CPP-016 to clarify the checker function and signature l block requirements. (Review of Revision 5 to CPP-016 )
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verified that the checker block is required to be either signed or marked NA.) Specific examples were identified, as discussed in detail in paragraph 4, where improper or inadequate checking of SSE calculations had occurred.
Adequacy of checking of calculations is an open item (445/8704-0-02).
' Examples of this item are included in paragraphs-4.p, t, aa, ac(2), ad(4) and ae(2) j (c) In a number of SSEs, the noted deviation was determined to be not safety significant through the use of engineering calculations or judgement without i consideration of manufacturer's recommendations. In many cases, the manufacturer of the item had established tolerances or allowabic values that could have been ,
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utilized to determine acceptability. Examples of this type of deviation are:
(1) Snubber functionality versus angularity of extension tube.
(2) Load capacity reduction for Hilti anchor bolts installed at an angle.
(3) Required torquing on flange joints.
These examples are addressed in more detail in paragraphs 4.ad, 4.ae, and 4.ah. Consideration of manufacturer's recommendations when evaluating deviations for safety significance is considered to be an open item j (445/8704-0-03). j (d) In performing some SSEs, it was necessary for CPRT to
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recalculate stresses or loads associated with an item that has a certified stress / design report (or load capacity data sheet) associated with it. The NRC inspectors are concerned that these certified reports (which are plant records) will not be updated and decertified to reflect the as installed condition.
Examples identified were: i: (1) pressurizer manway flange.
(2) Numerous pipe supports.
i These examples addressed in more detail in paragraph 4.m I (Item 1 above) and paragraphs 4.ad, 4.ae, and 4.ah i (Item 2). ! l l _
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Reconciliation of manufacturer's certified stress / design
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reports with the as installed condition is considered an open item (445/8704-0-04).
(e) The NRC inspectors also noted that the SSEs were performed for specific leviations with little or-no consideration given .o possible generic implications, (e.g., would the iandition be safety significant if it occurred in another area or if the condition were wide spread?). The NRC inspectors were informed by SSEG personnel that these types of. questions would be addressed by the collective evaluation' process. The collective evaluation process will be the subject of a future NRC inspection.
Examples of this item are included in paragraphs 4.h and j(2).
4. SSE Inspection Findings (92719) The SSEs reviewed by the NRC inspectors are listed below under the applicable ISAp VII.c population heading. Each SSE is identified by CPRT using an alphanumeric identification. The prefix indicates whether the deviation was discovered during documentation review (R) or physical inspection (I). The suffix indicates the deviation number except for SSEs associated with cumulative impact (CI). The NRC review consisted of checking the SSE and supporting information contained in the SSE file and, in some instances, supporting documentation and/or discussions with applicable SSEG personnel, a. Electrical Cable (CABL) I-E-CABL-GEN-CI I-E-CABL-071-DR02 I-E-CABL-003-DR02 I-E-CABL-076-DR02 I-E-CABL-003-DR05 I-E-CABL-078-DR01 I-E-CABL-003-DR09 I-E-CABL-084-DR01 R-E-CABL-013-DR03 I-E-CABL-084-DR02 I-E-CABL-015-DR01 I-E-CABL-091-DR01 I-E-CABL-022-DR01 I-E-CABL-092-DR01 I-E-CABL-022-DP02 I-E-CABL-092-DR02 I-E~CABL-026-DR02 I-E-CADL-092-DR03 I-E-CABL-038-DR02 I-E-CABL-093-DR01 I-E-CABL-043-DR04 I-E-CABL-099-DR01 R-E-CABL-043-DR04 I-E-CABL-099-DR02 I-E-CABL-044-DR01 I-E-CABL-108-DR01 , I-E-CABL-044-DR02 I-E-CABL-117-DR03 ' I-E-CABL-044-DR03 I-E-CABL-121-DR01 I-E-CABL-044-DR04 R-E-CABL-164-DR01 I-E-CABL-045-DR02 I-E-CABL-192-DR01 l I-E-CABL-048-DR01 I-E-CABL-244-DR01
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I-E-CABL-053-DR01 I-E-CABL-258-DR02 I-E-CABL-060-DR03 I-E-CABL-356-DR01 I-E-CABL-063-DR02 I-E-CABL-383-DR01 R-E-CABL-063-DR01 I-E-CABL-383-DR02 I-E-CABL-065-DR01 The NRC inspectors also reviewed the CI evaluations, where applicable. .The NRC inspectors noted the following
. findings during these reviews:
R-E-CABL-013-DR03 The DR was written because inspection report (IR) ET-3453 y indicated that the insulation and jacket removal from a 6.9KV cable (EG100040)' had not been observed by a QC inspector. -The evaluation states that "the fact that Item 4 of ET-3453 had a status'of 'not observed' is not, in itself, evidence of unacceptable hardware." The conclusion then states, " Based on the evaluation given above, the 'not observed' status alone for Item 4 of ET-3453 does not result in the inability of the cable to perform its function."
While the NRC inspector agreed that the failure to observe a particular procedural requirement did not, in itself, justify a conclusion that the installation was unacceptable; he could not agree that a conclusion that the installation was acceptable could be drawn, based on the information in the SSE.
The above was one of many such evaluations of documentation review DRs which concluded "no safety significance deviation" (NSSD) because missing or incomplete documentation does not, by itself, constitute unacceptability. This type of conclusion will be indicated as "the lack of required documentation for review resulted in no conclusion being drawn but the condition was determined to be NSSD" in the following paragraphs. This subject has been identified as an open item in paragraph 3.a above.
R-E-CABL-164-DR01 The failure to observe the jacket and insulation removal from a 6.9KV cable. This was another example of a lack of required documentation for review resulted in no conclusion being drawn but the condition was determined to be NSSD. See paragraph 3.a above.
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' - , 9 I-E-CABL-258-DR02 A size 18 AWG vendor supplied conductor had been connected within.a battery room exhaust fan circuit junction box to a Weidmuller SAKEN terminal block specified by Gibbs and Hill (G&M). This terminal block was designed to accommodate 8 AWG to 16 AWG wire sizes.
Weidmuller data stated that the use of smaller wire sizes was permissible if done in a factory setting;.however, this particular conductor was connected at the CPSES site. ERC confirmed that the conductor was attached by exerting a gentle pull on the conductor, and stated that the quality control applied at the site was comparable to that achieved in a factory environment, q I-E-CABL-383-DR01 The minimum bend radius violation for a cable (EW128190) installed between the Nuclear Instrumentation System cabinet and the Solid State Protective System cabinet was I evaluated in the SSE. The evaluation concluded, based on the proper operation of the cable to date,.and an onsite test, that the cable installation was not safety j significant and would not result in the inability of the l cable to perform its safety-related function. The NRC + inspector noted, however, that a letter from the vendor, Westinghouse Electric Corporation, dated October 14, ! 1986, stated that approval of the installed bend radius ! could not be granted. ! The NRC inspector discussed this SSE with ERC and CPRT I personnel and was informed that additional information was being requested from the vendor; however, as of the y end of this report period, additional information had not j been provided. The NRC inspector could not agree with ! the NSSD determination on the basis of the available j information.
The NSSD determination for this condition is an open item I I
(445/8704-0-05).
Other than the open items discussed above, the NRC 1 inspector identified no further open items in the SSEs reviewed.
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I-E-CATY-GEN-CI I-E-CATY-004-DR01 I-E-CATY-004-DR02 .R-E-CATY-011-DR01 I-E-CATY-039-DR01 I-E-CATY-050-DR01 R-E-CATY-050-DR01 I-E-CATY-050-DR03 I-E-CATY-077-DR01 R-E-CATY-077-DR01 I-E-CATY-125-DR01 I-E-CATY-174-DR01 I-E-CATY-195-DR03 I-E-CATY-287-DR01 The CI evaluations for Package Nos. 077 and 174 were evaluated by the NRC inspector as part of the review of SSEs for the cable tray population. The'NRC inspector -4 found all of the above evaluations to be acceptable and l identified no open items. 8 c. Electrical Conduit (CDUT) I-E-CDUT-008-DR02 I-E-CDUT-042-DR02
'I-E-CDUT-016-DR02 I-E-CDUT-046-DR01 I-E-CDUT-017-CI 1-E-CDUT-056-DR01 I-E-CDUT-017-DR01 I-E-CDUT-066-DR01 I-E-CDUT-040-DR01 I-E-CDUT-114-DR01 I-E-CDUT-041-DR01 During the review of the above SSEs, the NRC inspector l noted the following findings: j I-E-CDUT-017-DR01 The DR documented that an insulation bushing for conduit C15B06008 inside electrical cabinet IVPC3 was not hand tight. The purpose of the bushing was to provide !
protection for installed electrical cables from l mechanical, rubbing damage. The SSE concluded that the j bushing was not required to prevent damage to the i electrical cable because the conduit was filled with a ( sealant that precluded cable movement. This deviation 1 and three other valid deviations were then cumulatively evaluated. The other deviations involved the use of flexible instead of rigid conduit, miscing identification on a conduit and missing color code on a conduit. The CI evaluation considered the combined effects of these deviations and concluded NSSD existed. The NRC inspector agreed with the conclusions.
l I-E-CDUT-046-DR01 A DR was written because conduit C13004498 did not have sealing material installed as specified on the drawing.
The evaluation concluded this condition to be NSSD based -_-
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.on the provisions of Design Change Authorization (DCA) ,
f 18133, Revision 1, and the fact thatithis conduit was a I horizontal run. DCA 18133' revised the requirement for {' sealing _ stub-up conduits as shown on Gibbs and Hill (G&H) Drawing 2323-El-1702. The requirement for fire stop seals was changed to environment seals for' preventing the entry of dust, water,cor other debris. In addition) the i environmental qualification of the motor control center (MCC) at the'other'end of this conduit did not I assume.the existenceof any conduit seals. Therefore, l the SSE concluded that the condition was a NSSD. Al The NRC inspector identifibd no open ite:ns from the # j review of these SSEs. j d. Electrical' Equipment Installation [EEIN)- I-E-EEIN-011-DR01 I-E-EEIN-071-DR01 I-E-EEIN-012-DR03 I-E-EEIN-075-DR02 ' I-E-EEIN-Oi3-DR03 I-E-EEIN-075-DR03 I-E-EEIN-018-DR01 I-E-ENIN-077-DR02 I-E-EEIN-021-DR01 I-E-EEIN-022-DRU4 I-E-EEIN-079-DR08 I-E-EEIN-080-DR01 ' I-E-EEIN-023-DR01 I-E-EEIN-061 0R017 I-E-EEIN-023-DR02 I-E-EEIN-091 DR01 I-E-EEIN-030-DR02 I-E-EEIN-093-DR01 I-E-EEIN-030-DR03 I-E-EEIN-093-DR02 I-E-EEIN-035-DR02 XI-E-EEIN-093-DR03 I-E-EEIN-035-DR03 j 'I-E-EEIN-093-DR04 I-E-EEIN-035-DR05 ' I-E-EEIN-097-DR01 I-E-EEIN-037-DR01 I-E dIEIN-097-DR02 I-E-EEIN-037-DR03 I-E-EEIN-097-DR03 I-E-EEIN-040-DR01 I-E-EEIN-097-DRO4 I-E-EEIN-040-DR02 I2E-EEIN-097-DR05 I-E-EEIN-045-DR02 I-E-EEIN-097-DR06 I-E-EEIN-048-DR02 I-E-EEIN-097-DR07 I-E-EEIN-048-DR04 I-E-EEIN-097-DR08 I-E-EEIN-049-DR02 I-E-EEIN-097-DR09 I-E-EEIN-055-DR01 I-E"EEIN-097-DR10 I-E-EEIN-063-DR02 I-E-EEIN-097-DR11 I-E-EEIN-067-DR04 I-E-DEIN-101-DR02 I-E-EEIN-068-DR13
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The NRC inspector noted the following findings during the review of the above SSE packages: I-E-EEIN-023-DR02 The DR identified a loose locknnt for<a conduit connection to a junnti'on box associated with instrument rack CP1-EIPRLI-33. An analysis in the SSE confirmed
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J if the. junction. box was located.in a mild or harsh environment. This information was not available during
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I-E-EEIN-030-DR03 A defective ground fault relay (PET-869) used for Unit 1 j battery room Train A loads was replaced with the _ 1 corresponding relay from' Unit 2. An incorrect tag number
* (PET-670) was applied to this' relay during its .
Installation. The SSE justified that the relay was
.technicillp acceptable for this appliention,-but did not indita'e t that an incorrect tag number could lead to inadequate periodic test, surveillance, and maintenance 4 activities. . The NRC inspector was provided documentation J, e indicating that actions to correct this relay name tag '
we're being implemented.
I-E-EEIN-075-DR03
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D NC The DR associated with this SSE stated that the convi!rsion of diesel generator initiation relay contacts T had atot been implemented in accordance with field s j Traveler Z-2918. This change was needed to
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' ' convert normally closed RX-2/2B relay contacts to be- j normally open to permit starting of the diesel j generators. Based on a reinspection by one individual, i ~
the SSE stated that the. contacts had been changed, but i 4id not indicate that the original DR had actually been l
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'an observation error. The NRC inspector was concerned {
that the SSE and supporting documentation did not I conclusively prove that the correct contact configuration j h'ad been implemented. During this inspection, two ERC 1 individuals reexamined the affected relay and confirmed e that the change had been correctly implemented.
J-E-EEIN-097-DR08 In June 1986, an incorrect Westinghouse AC relay (Model j AR 440 SR) was found installed in a panel where a DC ; relay (Nodel ARD 440 SR) was required. The SSE and its supporting data suggested that the correct relay type had been present in the panel prior to November 1984. ERC > was unable to locate any maintenance or test records to i support a relay substitution at the plant site. An i extensive analysis was provided in the SSE to confirm ': l l
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that an AC relay would operate for a brief period of time in the DC circuit. The NRC inspector was advised that a 100 percent reinspection was recommended for all auxiliary relay panels provided by YEP Industries, Inc.
This recommended action was based on the premise that an error had been made by the vendor prior to panel shipment in 1982 and had not been detected by QA/QC inspections, initial operation of the panel relays, or periodic surveillance tests. This is an open item pending receipt of justification for limiting this reinspection activity to the single vendor (445/8704-0-07).
I-E-EEIN-093-DR03 Loose mounting bolts were found in a rear support bracket for the 1-PR-403 recorder in a main control room panel.
The SSE indicated that the Reliance panel vendor seismic analysis did not consider a rear support for the recorder, and stated that the seismic test results provided by Wyle Laboratories had been satisfactory without clarifying whether the tests had been performed with or without the rear support. Existing G&H documentation identified this recorder as a Train C (i.e., nonsafety-related) device; however, a design change indicated that the recorder provided an accident monitoring function. In this instance, the recorder would have to operate during and after a seismic event.
The SSE did not consider whether the rear support was necessary for the recorder to accomplish this postaccident monitoring requirement. This is an open item pending clarification of this situation (445/8704-o-08).
I-E-EEIN-080-DR01 and I-E-EEIN-091-DR01 These two DRs identified incorrectly sized fuses used for load-shedding circuits. In one instance, installed 3 ampere fuses were inappropriate since the drawings called for 6 ampere fuses; in the second instance, 15 ampere fuses should have been used in place of existing 6 ampere fuses. Each of these fuses must remain intact for the normally deenergized load-shedding circuits to operate properly. Opening of the circuit fuse is not annunciated to the control room operator.
Moreover, the calculated current values are 5.4 and 10.8 amperes respectively. This subject is an open item pending additional justification of the installed and l specified fuses (445/8704-0-09).
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a v, .nstalled flexible conduit connection had been j
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druermined to be a NSSD'by the'SSEG.- The NRC inspector ]
df.d not agree with that ccnclusion because postulated
; moisture entry into tria damag0d f:.exibic conduit for an ~
V electric conductor seal asserrbly (ECSA) could invalidate 4 4 e ' 3 %L N the environmental qualification of iba solenoid valve
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Q T A thtt controls steam generatori sample ' valve 1-l'V-2404A.
,' A 6 j hThe NdC' inspector's re-review of th5.s SSE determined that
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.q 3 t flexible conduit.".7;CSA had been repidced, and the cause of 3 . % the dffect hai %dn attributnJ to a workman atepping or i s"
b f pulling on the ECSA(because t h oE its location directly :
- e below a stairway gr:1 ting. j q( , 1 '
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, inspector identified nc further opda items in this .
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, I-E-lbiTN-002-DR0 2 I-FININ-076-R-DR01 I-E-IN?.N 005-DR01, Irf-ININ-080-DR02 -
I-E-IN'CN 006-DR02 * I-E-ININ-082-DR01 I-EsININ-007-DR01 I-E-ININ-082-DR02 I-E-ININ-007-DR02 I-E-ININ-094-R-DR04 I-E-ININ-027-DR01 1-FININ-100-DR02 I-E-ININ-020-DR01
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The NRC inspector noted the following findings during the review of the above pack. ages:
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I"B-ININ-GEN-DR01 l 4 The us.e; of Rectorseal Es an instrument tubing sealant was ij prohibited in all areas and the use of teflon tape was
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similarly prohibi wd except for the turbine building after January 1981. This SSE noted that the scalant used
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on some NPT threadrsd joints was not visible and could not ! be determined. Nevertheless, the SSE report reached a I conclusion that,the absence of positive identification documentation for the sealant used would not result in a 4 nardware defect. The basis for this conclusion was not provided. This 3s an additianal exampla of insufficient
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documentation leading to a determination of NSSD. See paragraph 3.'a above.
I-E-ININ-005-DR01 This DR documented the misalignment of the torque indicators on the flexible tubing which connected the sensing line rigid tubing to the instrument. The torque indicators are lines etched onto the end fittings of the flexible tubing. Since the flexible tubing was not intended to be installed in an excessively twisted condition, the torque indicators are observed to determine the degree of misalignment agd hence the amount of twisting within the tubing. The 45 angle of twisting documented in the DR was evaluated to be acceptable in the SSE based on the manufacturer's recommendations which specified allowable installation configurations. The NRC inspector found these recommendations to be acceptable.
I-E-ININ-007-DR02 This SSE evaluated a condition of inadequate tubing slope l ' and was similar to many of the conditions evaluated in this. population. The SSE notes that, subsequent to the anstrument equipment inspections, the applicable erection specification (2323-MS-625A) was amended by revising the required slope from 1" per foot to 1/4" per foot. All of the SSEs reviewed by the NRC inspectors for incorrect slope were determined to be NSSDs because the as-found slope was greater than 1/4" per foot.
I-E-ININ-082-DR01, I-E-ININ-082-DR02 and I-E-ININ-100-DR02 During the April 1986 initial inspection, the NRC inspector noted that Section 5.2.2(b) of ERC Procedure CPP-016 only required the consideration of a single safety function during a component safety significance evaluation. A number of components in the CPSES plant may actually have two or more safety functions which may impose conflicting requirements, such as valve opening for ECCS purposes and valve closing for containment isolation. Several examples of incompletely stated safety functions within the foregoing SSEs were identified. During this inspection, it was determined that neither the procedure nor the SSE reports had been revised. This subject is an open item (445/8704-0-10).
Other than the open items addressed above, the NRC l inspector identified no additional open items for the SSEs reviewed in this population.
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f. Safety-Related plant Lighting (LITG) J f ?* 'The NRC inspecto-' reviewed the LITG SSE files and noted l that ERC memoranda QA/QC-RT5127 and 5128, both dated December 15,J1986, tabulated 135 reinspection.DRs and-l D 10 documentation review DRs. The inspector noted that of L' the~135 reinspection DRs, 65 had been' written for bad- j wire joint installations and 35 were for equipment- ' damage. ERC memorandum QA/QC-RT3621, Revision 1,. dated September ~ 25,-1986, recommended that reinspection be 1 discontinued and that no safety-significant evaluations
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be1 performed due'to the high number (135) of deviations. 3 encountered in the first 24 samples that were j reinspected. ' i
.. 'The NRC' inspector also reviewed QA/QC-RT2042 dated May 15, 1986,. and observed that ERC had recommended that the project inspect 100% of Class 1E'AC Lighting System 1 Wiring in accordance with QIO71, and in particular for:
w' -(1);1oose wire nuts,.(2) damage to conductorsLand wire ,
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nuts at junction boxes and fixture boxes, (3) correct colorecoding; and (4) excessive number of conductors in junction boxes.
Since no SSEs were performed en'this population, no NRC R inspection was, therefore, conducted; nor were'any.open items identified.
g. Nuclear Instrumentation System (NIS)_ Terminations (NIST) I-E-NIST-003-DR03 R-E-NIST-029-DR02
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R-E-NIST-014-DR01 R-E-NIST-053 "DR01-R-E-NIST-016-DR01 R-E-NIST-055-DR02 R-E-NIST-027-DR01 R-E-NIST-071-DR01 The above list-includes all of the ERC SSEs for the NIST population. This population consisted of documentation reviews only; no physical reinspection were conducted.
The NRC inspector, in addition-to review of the above-SSEs, also reviewed three SSEs (030-DR02, 052-DR02 and 053-DR01) which had been cancelled as a result of l determining.that the DRs were not valid. The invalidation of these DRs was based on the finding that the involved cables'were spare conductors and, therefore, the' procedural check found to be in deviation was not applicable.
The NRC inspector identified no open items for the SSEs performed for the above DRs.
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s y h. HVAC" Ducts and Pl'nums-(DUPL) e >l
. 'I-M-DUPL-001-DR01 I-M-DUPL-034-DR01:
R-M-DUPL-001-DR01 I-M-DUPL-047-DR09' p I-M-DUPL-001-DR05 R-M-DUPL-049-DR01: I-M-DUPL-002-DR01- I-M-DUPL-054-DR03 R-M-DUPL-002-DR01 ?I-M-DUPL-063-DR01 I-M-DUPL-003-CI I-M-DUPL-066-DR02-IkM-DUPL-010-DR01 I-M-DUPL-066-DR03
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R-M-DUPL-012-DR01 I-M-DUPL-07L-DR04 I-M-DUPL-019-DR03 I-M-DUPL-099-DR02 I-M-DUPL-024-DR05 a The NRC inspector noted the following during the review of the above SSEs: R-M-DUPL-001-DR01 ' This documentation DR vas one of several of its type that
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deals with the lack of pressure leakage test: documentation 11n the duct / plenum' population.' This DR-involved a section (rectangular elbow-joint 24) of the main exhaust line in the fuel handling building. The rationale employed by the SSE was any-leakage would be.
", inleakage and start-up testing would. include final air balancing and pressure testing of the buildings. .The SSE concluded there was no potential adverse: affect on the safe operation of the primary plant vent: exhaust system due to thisl lack of documentation. While the.NRC inspector did not disagree with the.SSE conclusion, it was noted that the SSE (and.others sampled from this population) did'not address overall system leakage and performance aspects. The NRC inspector was informed by CPRT staff that such subjects are addressed by the collective evaluation process. This process will be inspected by NRC staff in the final review actions for ISAP VII.c. See paragraph 3.e above.
I-M-DUPL-066-DR03 The DR. dealt with a missing segment of flange gasket in a p 22" x 12" Level 2 supply duct (BSC Subsystem SBD-Y) in ' the control building. The gasket was missing over the entire, lower 22" length of the flange connection. The SSE concluded the DR was not safety significar.t for the following reasons: .(1) a leakage calculation showed that system performance would not be significantly affected by-the missing gasket and (2) this component is only 2'6" away from the supply register that serves the ceiling space. The NRC inspector agreed with the SSE conclusion, but had the same question, as discussed above, regarding
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l the SSE not addressing overall system leakage and l- performance aspects.
1 The NRC inspector identified no open items for the above evaluations.
i. Field Fabricated Tanks (FFTA) R-M-FFTA-001-DR02 I-M-FFTA-003-DR02 R-M-FFTA-001-DR03 I-M-FFTA-003-DR05 R-M-FFTA-001-DR05 I-M-FFTA-003-DR07 R-M-FFTA-002-DR09 R-M-FFTA-007-DR01 I-M-FFTA-003-DR01 R-M-FFTA-007-DR03 The NRC inspector made the following finding during his review of the above SSEs: I-M-FFTA-DRO1_ The NRC inspector noted that a number of DRs had been written against this item, Boric Acid Tank 1-CPX-CSATBA-01, but a CI evaluation had not been performed. Discussion with ERC personnel revealed that CIs were in various stages of preparation. Many had been : completed but were not reviewed.
The NRC inspector identified no open items for the above evaluations. {
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j. HVAC Equipment Installation (HVIN) I
I-M-HVIN-001-DR01 I-M-HVIN-055-DR02 I-M-HVIN-009-DR01 I-M-HVIN-073-DR01 1 I-M-HVIN-012-DR04 I-M-HVIN-081-DR01 ) I-M-HVIN-013-DR03 I-M-HVIN-113-DR03 ) I-M-HVIN-013-DR04 I-M-HVIN-134-DR01 ) I-M-HVIN-026-DR01 I-M-HVIN-135-DR01 j I-M-HVIN-031-DR01 I-M-HVIN-155-DR01 ) I-M-HVIN-032-DR03 I-M-HVIN-160-DR01 I-M-HVIN-032-DR05 I-M-HVIN-193-DR02 The inspector also reviewed CI evaluations l I-M-HVIN-012-CI and I-M-HVIN-013-CI as part of the review l of the SSEs for this population. . I The NRC inspector noted the following during this review: I I-M-HVIN-001-DR01 The DR (and others on similar installations) was written because lock washers were not installed at the bolted
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angle duct joint to damper CPX-VADPBC-07. 'The evaluation consisted of a visual examination which indicated that the joint was tight, the gasket compressed, and the duct and damper rigidly supported. The evaluation included a generic evaluation and discussion which concluded that lock washers'were not essential on bolted duct joints.
The NRC inspector agreed with the SSE assessment that this DR was not safety significant. During the review of SSEs in this population, the NRC inspector had similar questions, however, to those discussed in paragraph 4.h above. For example, the SSEs did not always check for leakage or vibration while the system was operating or, if not operating, check leak testing documentation. This practice was recommended in the generic evaluation as a method for verifying joint tightness. In addition, it was not always apparent frc. the SSEs that a comprehensive visual check for joint tightness had been made. Review of overall system leakage and performance aspects will be included in NRC inspection of the collective evaluation process; see paragraph 3.e, above.
I-M-HVIN-155-DR01 The DR was written because the lock nut for the counterweight arm attachment to the shaft on gravity damper CPI-VADPGC-15 was loose. In addition, the counterweight arm did not move freely to the closed position. Based on an inspection of the subject damper, the SSE concluded that it was NSSD for the following reasons: (1) the counterweight arm was fully threaded into the bushing on the damper arm, (2) it took significant force to initiate unthreading of the arm from the bushing, and (3) the local vibration field was very low. While the NRC inspector agreed with the SSE conclusion for this specific case, it was observed that , there were a number of similar DRs written against other i gravity dampers. This subject will be further reviewed ! during NRC inspection of the collective evaluation process; see paragraph 3.e, above.
The SSE also concluded thrP the slight rubbing of the damper blade against the .:t did not prevent the damper from closing. This was based on manual testing of the damper, which is not recommended by the TU Electric instructions to ERC (refer to TU Electric office memorandum dated May 1, 1986, which is Attachment "D" to I-M-HVIN-193-DR02). T'e proper test for gravity damper operations is to have the Control Room start and stop the associated fan and observe the damper operation. This subject is an open item pending receipt of additional information (445/8704-0-11). , j ____
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f I-M-HVIN-160-DR01 A DR was written on gravity damper CP1-VADPGC-19 because
.the counterweight was not installed and the counterweight arm had been secured in the open position with duct tape to an adjacent unistrut. The assessment of the SSE was that the intended function of the damper to provide a positive means of stopping backflow was redundant because the hydraulic parameters of the system always provide for forward flow through the damper. Consequently,.the SSE concluded that this damper did not perform a safety-related function. However, the CPRT procedure.for safety significance evaluations of DRs, procedure CPP-016, specifies that, in assessing safety significance, no credit can be allowed for redundancy.
Secondly, the damper provided the solo positive means to prevent backflow. The backflow in the case of this damper could involve contaminated air from the post accident sampling modules and possible exposure to personnel in the area who would be conducting the air sample testing.
Therefore, the NRC inspector disagreed with this SSE; this is an open item (445/8704-0-12).
Other than'the above open items, the NRC inspector identified no additional open items from the review of the above SSEs.
k. Large Bore Piping Configuration (LBCO) I-M-LBCO-002-DR01 I-M-LBCO-063-DR02 I-M-LBCO-002-DR02 I-M-LBCO-070-DR01 I-M-LBCO-014-DR01 I-M-LBCO-070-DR02 I-M-LBCO-014-DR02 I-M-LBCO-070-DR03 I-M-LBCO-014-DR03 I-M-LBCO-070-DR04 I-M-LBCO-018-DR01 I-M-LBCO-070-DR05 I-M-LBCO-019-DR01 I-M-LBCO-102-DR01 I-M-LBCO-019-DR02 I-M-LBCO-102-DR03 I-M-LBCO-039-DR01 I-M-LBCO-102-CI The above list contains two DRs (014-DR01 and 014-DR02) which were superseded by a subsequent DR, and two DRs (019-DR01 and 019-DR02) which were declared invalid.
The NRC inspector found the above SSEs to be acceptable. ; No open items were identified. ) i i
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1. Laroe Bore welds / Materials (LBWM) 1 I-M-LBWM-041-DR01 I-M-LBWM-097-DR01 ; I-M-LBWM-137-DR01 ] i There were only six SSEs issued for this population and 1 the NRC inspector identified no open items for the above { sample. { j m. Mechanical Equipment Installation (MEIN) R-M-MEIN-GEN-DR01 R-M-MEIN-065-DR01 I-M-MEIN-004-DR03 I-M-MEIN-065-DR04 l R-M-MEIN-007-DR01 I-M-MEIN-078-DR03 I-M-MEIN-009-DR01 I-M-MEIN-099-DR01 R-M-MEIN-031-DR01 I-M-MEIN-138-DR02 ! I-M-MEIN-037-DR03 I-M-MEIN-138-DR03 I-M-MEIN-038-DR01 I-M-MEIN-138-DR05
"-M-MEIN-038-DR01 I-M-MEIN-173-DR03 i M-MEIN-050-DR01 R-M-MEIN-256-DR01 I-M-MEIN-058-DR01 I-M-MEIN-256-DR01 I-M-MEIN-059-DR01 The above list contains three DRs (007-DR01, 031-DR01 and 038-DR01) which were superseded by subsequent DRs.
R-M-MEIN-GEN-DR01 This generic DR noted that elevation would not be considered as an attribute for 15 pieces of equipment.
This DR was discussed with ERC personnel who reported that a memorandum had been prepared to justify this revision to population attributes. Review of CPP-007,
" Preparation of Checklists and Data Base Reports,"
indicated that attributes of a population can be revised by memorandum.
I-M-MEIN-004-003 This DR was issued as a result of an inspection on the cap screws on the seal housing of the safety injection pump for Unit 1.
This DR was found to be nonsafety-significant by the CPRT. Their conclusion is that by using Section XI, Preservice and Inservice Inspection and Testing of Pumps, , degrading (if it happens) of the pump will be detected.
The NRC inspector agrees with this conclusion only if all pumps in the population are required to be inspected and tested under Section XI of the ASME Code. This question is considered an open item (445/8704-0-13).
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, '22 I-M-MEIN-050-DR01 This DR was issued as a result of an inspection of the torque on the closure stude for the Unit 1 pressurizer.
Nine of the116 studs did not meet the minimum torque value specified in the inspection (70% of installation ! torque value specified by the manufacturer).
The SSE indicated that the deviation was acceptable for the following reasons:
(1) Hot functional test was performed approximately 10 months after bolt installation, and no leaks were reported.
(2) Stud relaxation, other than creep, occurs in a short time after initial tightening. It was considered by the evaluation that the' relaxation had occurred between initial tightening and hot functional. No further relaxation was expected.
(3) Pressurizer temperatures are not in the creep range a for the stud material; therefore, no relaxation due i to creep was expected.
(4) The manway was located in the upper head in the vapor environment, remote frcm any severe temperature transients caused by liquid surges.
Therefore, any bolt-load variation caused by temperature transient loads would be minimal. { l (5) The original torquing effort used a very controlled procedure. The fact that 7 of the 16 studs met the 70% torque criteria would indicate that the remaining 9 studs would have a torque close to the 70% criteria.
The NRC inspector observed that: (1) the reference used in the evaluation to address loss of bolt load due to relaxation indicated an average loss of 5% to 6% which would result in a loss of 90 to 100 ft-lbs of torque; (2) the manway geometry could result in temperature differences that could significantly affect bolt load because of the differences in thickness of the mating parts (see EDSK 379440B) and the effect of the stainless steel insert; and (3) the calculation used to demonstrate adequacy was only related to pressure load. Therefore, the NRC inspector disagreed with this SSE; this is an open item (445/8704-0-14).
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'. '. 23 I-M-MEIN-078-DR03
'This DR was written because the hold-down bolts on the air intake filter to the d_esel generator (CP1-MEFTIF-03)
did not meet the' inspection requirements.
The CPRT conclusion for this DR is-that it is not safety significant based on a review of the manufacturer's calculations which assumed that all loading went through the plenum bolts. No credit was taken for the anchor
' bolts.- However, the ERC inspection showed that the plenum bolts had been replaced by welds. The NRC inspector agreed with the evaluation and conclusion provided an analysis was performed to show that the plenum weld was sufficient to take all of the load. This is an open item (445/8704-O-15).
Other than the above open items, the NRC inspector'had no
'further.open items from the above SSE reviews.
n. Pipe Bends - Fabricated (PBFA) I-M-PBFA-045-DR01 There were only two DRs in this population. The NRC inspector identified no open items for the above evaluation selected for review.
o. Piping System Bolted Joints (PBGM) , R-M-PBOM-007-DR01 I-M-PBOM-043-DR01 I-M-PBOM-007-DR01 I-M-PBOM-086-DR01 I-M-PBOM-007-DR01 I-M-PBOM-015-DR01 R-M-PBOM-043-DR01 I-M-PBOM-062-DR01 The NRC inspector made the following findings during these reviews: I-M-PBOM-015-DR01 This SSE did not fully comply with the requirements of ; CPP-016 for documenting evaluations of deviations. ! Attachment 6.3 to CPP-016 indicates that each evaluation i should include: ,
(1) Description of the inspection item and the deviation.
l (2) Function of the item.
l (3) Evaluation.
(4) Conclusion.
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'. ' . 24 The DR was not contained in this SSE file and the SSE did not identify the item inspected, the function of that item, or the evaluation objective. This was discussed with ERC personnel who indicated that this evaluation was performed early in the program; had been re-reviewed; :and, although marginal in content, was considered acceptable. As discussed below, the NRC inspector l considered the documentation omissions to be an isolated !
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I-M-PBOM-062-DR01 The comments noted for DR I-M-PBOM-015-DR01, above, also apply.to'this DR with the exception that the DR was ' included in this SSE file and the inspected item was identified. ; The NRC inspector did not identify other examples of this. , lack of deviation description and considered these to be isolated occurrences which did not affect the SSE conclusions.
The NRC inspector identified no remaining open items from review of the above SSEs.
p. Small Bore Piping Configuration (SBCOL l I-M-SBCO-004-DR01 1-M-SBCO-010-DR01 I-M-SBCO-004-DR02 I-M-SBCo-010-DR02 I-M-SBCO-004-DR03 I-M-SBCO-039-DR01 I-M-SBCO-004-DR04 I-M-SBCo-105-DR01 I-M-SBCO-010-CI- I-M-SBCO-114-DR01 The above list contains two DRs (004-DR02 and 03) which ,
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were superseded by subsequent DRs. The NRC inspector noted the following during his review: I-M-SBCO-039-DR01 The DR stated that the clearance between a safety l injection system line and a pipe support was less than i the inspection procedure requirement of 1". Evaluation of this deviation, which was judged to be not safety significant, required the use of a-previously performed analysis. No new calculations were performed. The 4
" CHECKER" block was not signed to indicate that the work had been checked. The NRC inspector considered this to j be an example of a case which should be checked to verify that the proper analysis was used and interpreted correctly. The " REVIEWED BY" block was signed and ERC indicated that this meant the calculation had been checked by the reviewer. (The SSE for I-M-SBCO-105-DR01
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' was similar.) Checking of calculations has been ! identified as en open item in paragraph 3.b. l The NRC inspector identified no additional open items from review of'these SSEs.
q. Small Bore Welds and Material (SBWM) I-M-SBWM-004-DR02 I-M-SBWM-123-DR02 only three SSEs had been issued for this population; the NRC inspector found the above two to be acceptable. No open items were identified.
r. Tubing Welds and Materials (TUWM) I-M-TUWM-086-DR01 of the 19 SSEs issued for this. population, the NRC inspector selected the above for review. The NRC inspector found this evaluation to be acceptable; no open items were identified.
s. Concrete Placement (CONC) , R-S-CONC-GEN-DR03 R-S-CONC-002-DR01-I-S-CONC-016-DR01- I-S-CONC-018-DR01 R-S-CONC-019-DR02 I-S-CONC-023-DR01 R-S-CONC-023-DR06 I-S-CONC-024-DR02 I-S-CONC-025-DR01 R-S-CONC-027-DR02 I-S-CONC-039-DR01 I-S-CONC-057-DR01 R-S-CONC-057-DR02 I-S-CONC-064-DR01 I-S-CONC-080-DR01 R-S-CONC-082-DR05
.I-S-CONC-084-DR01 I-S-CONC-084-DR02 I-S-CONC-088-DR01 I-S-CONC-096-DR01 I-S-CONC-118-DR02 I-S;-CONC-12 3 -DR0 3 The NRC inspector noted the following findings during these reviews:
R-S-CONC-GEN-DR03
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This generic DR addressed a missing notation in the i concrete pour package that trucks were discharged before l 45 minutes (90 minutes if approved by the engineer) if ) the ambient temperature was above 85 degrees. The DR applied to 60 concrete pour packages. The lack of required documentation for review resulted in no conclusion; however, the condition was determined to be a NSSD. See paragraph 3.a above.
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_ _ _ _ _ . _ _ _ _ - '. . 26 R-S-CONC-002-DR01, R-S-CONC-023-DR06, R-S-CONC-027-DR02, and R-S-CONC-082-DR05 These DRs addressed missing documentation in the concrete placement packages. The missing documentation consisted of: (1) documentation verifying that the mix design card corresponded to the mix specifl.e1 by the field engineer for R-S-CONC-002-DR01, (2) concrete compressive strength-test results for R-S-CONC-023-Dx06, (3) curing documentation for'R-S-CONC-027-DR02, and (4) documentation verifying that the construction joint was properly wetted for R-S-CONC-082-DR05.
These SSEs are four more examples where the lack of required documentation for review resulted in no conclusion; however, the conditions were determined to be NSSDs. See paragraph 3.a above.
Other than the above open items, the NRC inspector j identified no additional open items for the above SSEs.
t. Conduit Supports (COSP) R-S-COSP-005-DR01 I-S-COSP-091-DR01
'I-S-COSP-006-CI I-S-COSP-093-DR02 R-S-COSP-014-DR09 I-S-COSP-093-DR03 R-S-COSP-036-DR01 I-S-COSP-094-DR03 I-S-COSP-044-DR01 I-S-COSP-100-DR01 R-S-COSP-044-DR02 I-S-COSP-100-DR01 R-S-COSP-044-DR03 I-S-COSP-102-DR03 R-S-COPS-048-DR01 R-S-COSP-102-DR03 R-S-COSP-054-DR06 I-S-COSP-102-DR05 R-S-COSP-054-DR07 R-S-COSP-103-DR03 I-S-COSP-054-CI I-S-COSP-104-DR02 I-S-COSP-055-DR01 I-S-COSP-117-DR02 R-S-COSP-059-DR03 I-S-COSP-125-DR01 I-S-COSP-060-DR01 I-S-COSP-127-DR03 I-S-COSP-063-DR01 I-S-COSP-200-DR03 R-S-COSP-063-DR01 I-S-COSP-204-DR01 R-S-COSP-066-DR03 I-S-COSP-228-DR03 I-S-COSP-081-DR01 I-S-COSP-229-DR01 The NRC inspector noted the following findings during these reviews:
I-S-COSP-102-DR03 The DR was written to identify that one of four bolts attaching a junction box to conduit support C13004315-01 did not meet the minimum torquing requirements. The SSE included a calculation which showed that by neglecting the bolt that did not attain the minimum torque, the
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a safety significant function of the support would not be altered. , r During NRC review of this calculation, however, it was determined that an error had been made. One of the first steps of the calculation process was to determine the location of the centroid of the remaining three effective bolts. The error had been made when determining this centroid and involved utilizing the wrong number of holts when determining the total cross sectional area of the bolt pattern. Instead of using the area of three bolts, the area of four bolts was used. Subsequently, all calculations that followed were incorrect because the . initial centroid location was incorrect. It should be noted that this calculation was checked per Section 5.3.1 of Procedure CPP-016, " Safety Significant Evaluations of Deviation Reports." See paragraph 3.b above.
When this error was brought to the attention of the SSEG 1ead discipline engineer, the process of correcting, revising, and reissuing the package was initiated; the NRC inspector reviewed the reissued SSE package and agreed with the calculation process and the NSSD determination.
I-S-COSP-093-DR03 This DR identified one Hilti bolt on conduit support C14Y13168-02 in which the top of the bolt was one full thread lower than the top of the nut. The procedure required that they both be flush, as a minimum. The SSE showed that a reduced Hilti bolt capacity, based upon the lack of required thread engagement, was still sufficient for the support loads; therefore, it was a NSSD.
The NRC inspector concurred with the SSE determination of l NSSD but questioned the one aspect of the calculations that had to do with the bevel around the top of the Hilti bolt. This bevel, which was neglected by the SSEG, takes i the place of one thread. The SSEG revised and reissued the package and showed that the effects of neglecting the bevel were minimal. The NRC inspector agreed with the revised conclusion after a review of the reissued SSE package. j i R-S-COSP-103-DR03 l l The DR was issued because documentation review revealed that there was no IR in the support package confirming QC verification of the Hilti bolts. The SSE concluded that missing information alone is not evidence of )
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This item was another example where the lack of required documentation for review resulted in no conclusion; ;
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however, the condition was determined to be a NSSD.- See' paragraph 3.a above.
Other than the above open items, the NRC inspector identified no'further open items on the above SSEs.
c u. ~ Fill and Backfill (FILL) R-S-FILL-GEN-DR02 I-S-FILL-036-CI ; R-S-FILL-036-DR01 R-S-FILL-036-DR02 l R-S-FILL-058-DR01 R-S-FILL-061-DR01 R-S-FILL-092-DR02 R-S-FILL-095-DR01 R-S-FILL-107-DR01 R-S-FILL-108-DR02 R-S-FILL-109-DR05 F-S-FILL-111-DR07 R-S-FILL-117-DR05 R-S-FILL-164-DR02 In the fill and backfill population, approximately 270 of the 361 deviations which were written involved incomplete data on the IR checklist. The NRC inspector selected five of these DRs for review with the balance selected from the remaining deviation types. The NRC inspector identified no open items for any of the above 1 evaluations.
v. Fuel Pool Liners (FPLR) R-S-FPLR-006-DR01 R-S-FPLR-009-DR02 R-S-FPLR-013-DR01 R-S-FPLR-184-DR01 : The NRC inspector found the above SSEs to be acceptable.
W. Cement Grout (GRTC) R-S-GRTC-GEN-DR01 R-S-GRTC-003-DR01 I-S-GRTC-010-CI R-S-GRTC-010-DR01 R-S-GRTC-035-DR04 R-S-GRTC-039-DR01 R-S-GRTC-039-DR03 R-S-GRTC-039-DR05 R-S-GRTC-058-DR02 R-S-GRTC-059-DR02 l DRs were written because some attributes on cement grout irs were left blank; i.e., not checked " SAT" or "UNSAT." l The QC inspectors had, however, signed and dated the irs and had checked " Inspection completed, all applicable items satisfactory." The Safety Significance Evaluation Group (SSEG) concluded that the missing ~ check marks were inadvertent oversights. Since the irs were signed and l the inspection procedure identified, the SSEG judged that i
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* . '. 29 the grouting work was performed in accordance with l project requirements, and the missing check marks were not safety significant.
The NRC inspector discussed this situation with a past concrete grout QC inspector who stated that the signature present on the irs described above does not override the need for each attribute to be checked. The NRC inspector concluded that the above condition is indeterminate as the original QC inspector may have failed to inspect for the attributes that were not checked.
The following DRs address attributes on the irs that were I left blank:
. R-S-GRTC-035-DR04 ;
All attributes regarding curing were left blank.
. R-S-GRTC-039-DR01 The attribute verifying that the area to be grouted was vibration free was left blank.
. R-S-GRTC-039-DR05 The attribute verifying that the grout was placed continuously and properly consolidated was left blank.
This subject is an open item pending NRC inspector review of additional information (445/8704-0-16).
Other than the above open item, the NRC inspector identified no additional open items for the SSEs reviewed in this population.
x. Epoxy Grout (GRTE) R-S-GRTE-GEN-DR02 R-S-GRTE-012-DR01 R-S-GRTE-GEN-DR03 R-S-GRTE-038-DR01 R-S-GRTE-GEN-DR04 R-S-GRTE-070-DR01 The NRC inspector noted the following findings during these reviews: R-S-GRTE-GEN-DR02, R-S-GRTE-GEN-DR03, and R-S-GRTE-GEN-DR04 These generic DRs addressed missing documentation in the epoxy grout packages. The missing documentation consisted of: (1) compressive strength test results for ___u____ _ _ _ !
_ _ _ _ _ _ _ _ _ _ _ _ _- ___-__ __
._ _ - '. 30 R-S-GRTE-GEN-DR02, (2) documentation that placing was continuous with the pot life of the grout not exceeded for R-S-GRTE-GEN-DR03, and (3) documentation that the grouted areas were not placed in service prior to the-cure time for R-S-GRTE-GEN-DR04.
These.SSEs are three more examples where the lack of required documentation for review resulted in no conclusion; however, the conditions were determined to be NSSDs. See paragraph 3.a above.
I R-S-GRTE-038-DR01 and R-S-GRTE-070-DR01 These DRs concern documentation missing from the epoxy grout packages. The irs do not have notation'to verify that gaps between base plates or equipment bases and the concrete meet requirements. The lack of required-documentation for review resulted in no conclusion; however, the conditions were determined to be NSSDs. See paragraph 3.a above. I Other than the open items discussed above, the NRC ' inspector identified no additional open items for these SSEs.
y. Liners (LINR) I-S-LINR-006-DR01 I-S-LINR-064-DR01 I-S-LINR-007-DR01 I-S-LINR-071-DR02 I-S-LINR-008-DR02 I-S-LINR-089-DR01 I-S-LINR-010-DR01 I-S-LINR-022-DR01 I-S-LINR-012-DR02 R-S-LINR-010-DR01 ; I-S-LINR-020-DR01 R-S-LINR-011-DR01 I-S-LINR-057-DR01 R-S-LINR-019-DR01 The NRC inspector noted the following during his review of these SSEs: I-S-LINR-012-DR02 This DR was issued due to a weld seam undercut on the Unit 2 containment on the lith ring at AZ208. The SSE reviewer utilized actual physical test strength (from Certified Material Test Report) for the specific plate to show no safety significance by assuming that thickness was decreased 12.5%, while yield strength increased 30%. However, the actual ultimate tensile strength (UTS) only increased 10%. The significance of the lower change in UTS was not accounted for in the evaluation.
, The requirements contained in the ASME Boiler and Pressure Vessel Code, Section III, Division II, 1973, require that construction deviations be considered in the analysis _ - - _ _ _ _ --_
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l (see paragraph CC-3610). In addition, many of the L alsowable capacities in the Code are also based on ultimate capacity-(not-just yield).
The SSEs for DRs I-S-LINR-020-DR01, 022-DR01 and 057-DR01 I contained problems similar to the above. The NRC i inspector does not agree that the SSE sufficiently supports the conclusion of NSSD, due to the analysis being incomplete with respect to addressing all Code criteria. This subject is an open item (445/8704-0-17).
I_-S-LINR-064-DR01 . This DR was written for embedded iron rust found in the stainless steel reactor makeup water storage tank liner.
The SSEG determined that the corrosion mechanism would be 1
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slow and, by proper monitoring of the water chemistry (original requirement) and physical examinations of the liner during refueling outages, there would be.no safety significance due to the pitting. This'DR was therefore determined to be NSSD. The NRC inspector agreed with this since the population report and trending analysis required all liners in this population to be continuously examined and monitored.
The SSEs for I-S-LINR-071-DR02 and 089-DR01 were similar to the above.
Other than the open items discussed above, the NRC inspector identified no additional open items from the review of the SSEs for this population, z. Structural Steel (STEL) I-S-STEL-GEN-DR01 I-S-STEL-101-DR07 R-S-STEL-GEN-DR01 R-S-STEL-120-DR01 R-S-STEL-GEN-DR02 I-S-STEL-120-DR02 I-S-STEL-010-CI I-S-STEL-120-DR03 I-S-STEL-010-DR01 I-S-STEL-120-DR05 I-S-STEL-010-DR02 I-S-STEL-146-DR01 7.-S-STEL-010-DR05 R-S-STEL-146-DRO1 , I-S-STEL-010-DR07 I-S-STEL-146-DR03 ' I-S-STEL-086-CI I-S-STEL-146-DR04 R-S-STEL-086-DR01 R-S-STEL-189-DR02 I-S-STEL-086-DR02 I-S-STEL-189-DR03 I-S-STEL-086-DR03 I-S-STEL-189-DR04 I-S-STEL-086-DR04 I-S-STEL-208-DR02 I-S-STEL-086-DR06 I-S-STEL-208-DR03 I-S-STEL-086-DR07 I-S-STEL-208-DR06 I-S-STEL-086-DR09 I-S-STEL-287-DR04 I-S-STEL-086-DR15 I-S-STEL-534-DR02 I-S-STEL-101-DR02 _ _ - _ - _ _ - _ _ _ - _ _
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. The NRCtinspector:noted the following findings during
'these; reviews:
R-S-STEL-086-DR01 and R-S-STEL-120-DR01' TheselDRs concerned missing documentation. .The'
. inspection attribute required verification that.a QA/QC inspection package existed; however',ino documentation could.be. located for the structural steel items being.
reviewed. . ' These were additional examples of where the lack of-required documentation for. review resulted in no
. conclusion; however, the ccmdition'was determined to beca NSSD. See paragraph 3.a tv ve.
Other than the &bove open. item, the NRC inspector identified no additional open items for these SSEs.
aa. Equipment Supports (EOSP) I-S-EQSP-001-DR01 R-S-EQSP-027-DR04 I-S-EQSP-003-CI I-S-EQSP-042-DR02 R-5-EQSP-007-DR02 I-S-EQSP-043-DR01-I-S-EQSP-008-CI- I-S-EQSP-052-CI I-S-EQSP-011-DR02 I-S-EQSP-057-DR01 I-S-EQSP-011-DR04 I-S-EQSP-070-DR01 R-S-EQSP-018-DR04 R-S-EQSP-075-DR03 I-S-EQSPa019-DR03 ;I-S-EQSP-077-DR03-I-S-EQSP-020-DR02' I-S-EQSP-081-DR01-I-S-EQSP-024-CI-The NRC inspector noted the following findings during these reviews:
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I-S-EOSP-011-DR02 ; k' The DR dealt with a 5/16" fillet weld being undersized by 1/16" for most of its length. The SSEG extracted what they thought was the weld stress from the original G&H calculation performed in 1983 and, based upon the actual and design weld sizes, calculated a'new weld stress. The ' new weld stress was compared to the weld base metal allowable stress and was shown to be a NSSD.
The NRC inspector determined that the information " extracted by the SSEG from the 1983 G&H analysis was not' ) a weld stress but a force on the weld. The.SSEG, j assuming the extracted..value was the weld stress, did not i go through the process of converting this weld force into 'I a weld stress. Therefore, a weld force was incorrectly 1 compared to the weld. allowable stress. See j
. paragraph 3.b. j
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Another problem identified by the NRC inspector dealt with the weld allowable stress utilized by the SSEG. In the analysis performed by the SSEG, the stresses were to be derived for-the actual weld configuration while treating the weld configuration as a line. In this type of analysis, the units of stress are force / unit length.
Additionally, the allowable weld stress must take into account the type of analysis performed. The allowable weld base metal stress (21,000 psi) should have been transformed into~the allowable 1/4" (5/16 minus 1/16 undersize) fillet weld stress by multiplying the allowable weld base metal stress (21,000 psi) by the fillet weld size effective throat (.25 x .707). This particular number (3712 lb/in) would then be used as the allowable weld stress and compared to the actual weld stress. The SSE did not convert the base metal allowable stress into the weld size allowable stress. It should i also be noted that this particular analysis was checked per Section 5.3.1 of Procedure CPP-016. This is another example of inadequate calculation checking. See paragraph 3.b.
When these errors were brought to the attention of the SSEG lead discipline engineer, the process of correcting, revising, and reissuing the packages was initiated. The NRC inspector reviewed the reissued SSE packages and agreed with the calculation process and the NSSD j determination. l
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I-S-EOSP-019-DR03 I The DR for this package was issued because two Hilti bolts on the same piece of equipment did not meet the inspection procedure minimum spacing requirement of 10 anchor bolt diameters. If this minimum spacing requirement is not met, then the published Hilti allowables are to be reduced. The SSEG performed an ! evaluation to determine the bolt capacity applicable to l the actual bolt spacing and, based upon the new capacities, showed this to be a NSSD. The SSEG analytical approach was based upon Section 4.8 of Stone and Webster Engineering Company (SWEC) Procedure CPPP-7.
l The NRC inspector determined that Procedure CPPP-7, of which the SSEG was not on controlled distribution, was utilized by SWEC for their requalification program for pipe supports within the Design Adequacy Program (DAP).
The NRC inspector concurred with utilizing analytical < , approaches contained in procedures from different CPRT l programs provided the procedures were used and interpreted correctly; in this case, the procedure was interpreted incorrectly. The procedure states, in part, l , L,
._ - _ _ . _ _ _ __ _____ _ _ _ . _ - - _ _ _ _ _
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. 34 " . . . reduce the allowable loads to the square of the ratio of the actual to required' spacing . . . . "
This was done correctly ~by the SSEG and the load reduction factor was determined to be 0.28. The next step by the SSEG was to increase this 0.28 factor to 0.50. The NRC
' inspector inquired why the factor was increased from 0.28 to 0.50, and was informed by the SSEG lead discipline engineer that the last' sentence in Section 4.8 implies, if the ratio is less than 0.50, increase it to 0.50. The . sentence reads, " Minimum spacing reduction shall not-exceed 50 percent of the required spacing." The SWEC project manager for the pipe support requalification program, in conversation with the NRC inspector, however, verified that the sentence means that if the Hilti spacing is less than 50% of the minimum specified spacing, the reduction should not be used; an alternate method of analysis chould be used. This was contrary to the SSEG interpretation.
When this error was brought to the attention of the SSEG - lead discipline engineer, the process of correcting, revising, and reissuing the package was initiated. The NRC inspector reviewed the reissued SSE package and concurred with the calculation process and the NSSD determination. However, the inspector questioned the generic applicability of the SSEG interpretation. This is an open item (445/8704-0-18).
R-S-EOSP-018-DR04, R-S-EOSP-027-DR04, and R-S-EOSP-075-DR03 The DRs for R-S-EQSP-018-DR04 and R-S-EQSP-027-DR04 were issued because there were no irs in the support packages confirming QC verification of bolt torques. The DR for R-S-EQSP-075-DR03 was issued because there was no documentation in the support package for the required welding verification. All three of the SSEs concluded that missing information alone was not evidence of ; unacceptability of hardware and that these evaluations q were NSSDs. l These items are three more examples where a lack of required documentation for review resulted in no conclusion; however, the condition was determined to be a ;
'1SSD. See paragraph 3.a above. j
Other than the above open items, the NRC inspector identified no additional open items from the review of the SSEs for this population. f
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ab. HVAC Duct Supports (HVDS) I-S-HVDS-002-DR02 R-S-HVDS-046-DR02
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R-S-HVDS-003-DR03 I-S-HVDS-053-DR02.
'R-S-HVDS-009-DR01' I-S-HVDS-053-DR04 I-S-HVDS-011-DR01' I-S-HVDS-056-DR06 I-S-HVDS-013-DR03' I-S-HVDS-068-DR07 I-S-HVDS-017-DR05~ I-S-HVDS-079-CI I-S-HVDS-021-CI I-S-HVDS-079-DR01 I-S-HVDS-021-DR01 I-S-HVDS-079-DR03-I-S-HVDS-021-DR02 I-S-HVDS-091-DR07 I-S-HVDS-027-DR02 'I-S-HVDS-105-DR03 R-S-HVDS-027-DR05 R-S-HVDS-110-DR01 R-S-HVDS-029-DR02 R-S-HVDS-118-DR03 I-S-HVDS-L.',1-DR03 I-S-HVDS-127-CI
~I-S-HVDS-043-DR03 I-S-HVDS-127-DR03 I-S-HVDS-044-CI I-S-HVDS-334-DR01 I-S-HVDS-044-DR04 I-S-HVDS-349-DR01 I-S-HVDS-044-DR08 l'
The NRC inspector noted.the following findings during' these reviews: R-S-HVDS-009-DR01 and R-S-HVDS-110-DR01 For R-S-HVDS-009-DR01 and R-S-HVDS-110-DR01',1the DRs were issued because the duct support irs could not be located in Brown & Root-(B&R) turnover Packages 3201 and.1701 respectively. The SSEs concluded that, "The effect of the deviation _ reported on lack of an available inspection report is indeterminate and missing documentation alone does not necessarily make the deviation safety significant." Therefore, this SSE was a_NSSD. These are j two more examples where a lack of required documentation i for review resulted in no conclusion; however, the i condition was determined to be a NSSD. See paragraph 3.a ] above. ') Other than the above open items, the NRC inspector identified no additional open items for the above SSEs. I J Instrument Pipe / Tube Supports (INSP) I ac.
I-S-INSP-003-DR08 R-S-INSP-036-DR03 l I-S-INSP-003-DR10 I-S-INSP-040-CI ! I-S-INSP-004-CI I-S-INSP-040-DR02 I-S-INSP-005-DR01 I-S-INSP-040-DR03 I-S-INSP-007-CI R-S-INSP-040-DR03 I-S-INSP-008-DR25 R-S-INSP-040-DR04 I-S-INSP-010-CI I-S-INSP-040-005 R-S-INSP-013-DR02 I-S-INSP-043-CI I-S-INSP-013-DR01 I-S-INSP-049-DR07
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. ' ' ' .36 I-S-INSP-013-CI I-S-INSP-053-DR22 I-S-INSP-015-DR08 I-S-INSP-059-DR08 I-S-INSP-017-DR12 I-S-INSP-062-DR02 I-S-INSP-017-DR13 I-S-INSP-062-DR03 I-S-INSP-017-DR14 R-S-INSP-062-DR03 I-S-INSP-020-DR09 R-S-INSP-062-DR04 I-S-INSP-024-DR04 R-S-INSP-062-CI R-S-INSP-027-DR05 I-S-INSP-065-DR06 I-S-INSP-034-DR01 I-S-INSP-069-DR11 I-S-INSP-034-DR02 I-S-INSP-073-DR04 I-S-INSP-034-DR03 I-S-INSP-081-DR03 i R-S-INSP-034-DR02 I-S-INSP-085-DR06 I R-S-INSP-034-DR03 1 i
The NRC inspector also reviewed the CI of the SSEs on a )j selected basis as indicated. The NRC inspector noted the following findings during these reviews: ) R-S-INSP-036-DR03 The DR was written because six items identified on the support drawing were found to exhibit a lack of material traceability. Technical Information Request (TIR) 372 was initiated to resolve the DR by inspecting the six items in order to identify heat numbers and establish a ; verifiable material specification. Only one of the six support items was identified as A36-77A based on traceable documentation. The evaluation states that "due to nonavailability of documents on traceability for the items listed in the deviation report (except s 4" x 4" x 3/8" cap plate), the effect of the deviation is considered indeterminate. However, missing documentation alone will not result in the inability of the support to , perform its' design intended function." This item was another example of a lack of required documentation for review resulting in no conclusion; however, tle ondition was determined to be NSSD. See paragraph 3.a , 'e .
.R-S-INSP-040-DR03 and R-S-INSP-040-DR04 These SSEs were additional examples where the lack of required documentation for review resulted in no conclusion being drawn, but the condition was determined to be a NSSD. See paragraph 3.a above.
The above two document reviews were not included in the , cumulative evaluation of this item. While these two SSEs were indeterminate, they should have been included in the list of-SSEs considered in the CI evaluation. ERC personnel stated that the procedure (CPP-016) was being revised to exclude the no determination SSEs from the CI evaluations. (Review of Revision 5 to CPP-016 shortly j
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after the close of this report period verified this' l change had'been incorporated.)
I-S-INSP-059-DR08 ExcessiveanchorboltsfopewasevaluatedintheSSE.
' A measured slope of 6 g/2 was determined to be beyond the procedure limit of 6 . The anchor bolt was reanalyzed using a " state-of-the-art report on steel embedments." j
.The evaluation concluded that the revised tension / shear j interaction for the anchor bolts met the appropriate i acceptance criteria. The NRC inspector agreed with the j evaluation approach, but noted that the SSE had not been i sigried by a checker as required by paragraph 5.2.3 of ERC l Procedure CPP-016, Revision 4, dated January 16, 1987. j The SSEG 1ead engineer for supports informed the NRC ]
inspector that paragraph 5.2.3 states that small ) calculations which are part of the evaluation text may be signed by the SSE reviewer as "both the checker and . s reviewer." 'The NRC inspector interpreted the procedure I to require the SSE reviewer to sign in both the checker j and reviewer lccations as was done in SSE ^ I-S-INSP-049-DR07.
.The above was one of several evaluations which were not signed as being checked by an independent checker or i signed as checked by the reviewer. This condition was 1 also discovered in SSEs I-S-INSP-008-DR25 and I-S-INSP-015-DR08. See paragraph 3.b above. ] I-S-INSP-062-DR02
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The inability of the ERC inspector to verify that the anchor bolt nuts on a base-plate had not bottomed out was evaluated in this SSE. The evaluation attempted to show ; that, based upon the measured length of the thread projecting above the nut, the nut had not bottomed out.
The worst condition inspected (1 3/16" of projected thread) indicated that the nut was located at the last i
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thread of the bolt; therefore, the SSE concluded that the nut had not bottomed out. Based on this information the NRC inspector concluded that the evaluation demonstrated r that one nut had possibly bottomed out. The NRC inspector also concluded that the SSE had not established I a verifiable basis to conclude that the deviation was not an SSD as required by paragraph 5.2.2(e) of ERC Procedure CPP-016. Additional information is required to prove more conclusively that the nut had not bottomed out and that the Hilti had, theiefore, been properly set. This is an open item (445/8704-o-19).
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R-S-INSP-062-DR04
.This DR described the inability of the ERC inspector to verify the, recorded bolt torque setting because the number and size of the Hilti bolts existing in the field did not match the Hilti bolts identified in the IR. The evaluation' concluded that, since.the documents reviewed were.not adequate to establish specific bolt torquing for each support, the torquing had not been assured. The SSE i also concluded that the inadequate information alone is !
not evidence of unacceptability of the hardware. .This j item was another example of a lack of required J
documentation for review resulting in no conclusion; however, the condition was determined to be NSSD. See paragraph 3.a above.
Other than the above open items, the NRC inspector ) identified open items on the reviewed SSEs for this l population. 1 ad. Large Bore Supports - Non Rigid (LBSN) i l I-S-LBSN-000-GEN-DR02 I-S-LBSN-034-DR04 l I-S-LBSN-001-DR05 R-S-LBSN-034-DR04 ; I-S-LBSN-001-DR07 I-S-LBSN-034-CI l
.I-S-LBSN-002-DR05 I-S-LBSN-039-DR03 j I-S-LBSN-005-DR03 I-S-LBSN-043-DR04 i I-S-LBSN-005-DR05 I-S-LBSN-050-DR01 1 I-S-LBSN-006-DR02 I-S-LBSN-060-DR07 I-S-LBSN-006-DR04 I-S-LBSN-241-DR02 j I-S-LBSN-015-DR02 I-S-LBSN-241-DR04 l R-S-LBSN-018-DR02 I-S-LBSN-241-DR06 j I-S-LBSN-023-DR01 R-S-LBSN-241-DR03 ;
I-S-LBSN-023-DR12 I-S-LBSN-241-CI I I-S-LBSN-026-DR03 I-S-LBSN-249-DR01 l I-S-LBSN-027-DR02 I-S-LBSN-253-DR02 I-S-LBSN-034-DR02 I-S-LBSN-260-DR01 . l The NRC inspector reviewed the SSEs on a selected basis as indicated. The NRC inspector noted the following findings during those reviews: I-S-LBSN-023-DR01 A DR was written because of the lack of an ID number on welded attachments. The SSEG evaluator found a heat number and a support identification number on one pipe welding pad, but found nothing on the other pad. The evaluation stated that a missing support ID number on one pad does not appear to be a safety concern, since no relationship exists between the support identification and the function of the support other than to identify j
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y the support during construction / installation. The NRC'
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inspector did'not agree.with this statement since'the use of incorrecEPmater,ial or items may' impede"the function of a' support and1must be identified as required by paragraph 5'.2.2(c) of ERC " Procedure CPP-016. The.NRC "l
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inspector <dethrmined that the conclusion.should probably.
have been indeterminate. This is an open item (445/8704-0-20).
-I-S-LBSN-034-DR02 The DR was written to docement that the ear's of a pipe o clamp were not parallel. 'The evaluation analyzed the , pipe clamp ears and load bolt.in order to account for the'
.additionalystresses induced into the ,c1mnp as , a result of ,
the: deviation. The NRC inspector. agreed with the methodology which accounted for the additional stresses induced <intottne clamp due to the deviation. The SSE C concluded that the additional stresses due solely to the' '"
. nonparallel clamp ears were acceptable based upon the appropriate allowable stresses. The NRC inspector noted t that no, attempt was made to determine from the clamp ~
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~h-manufacturer whether his stress report accounted for stresses.at the same clamp' location evaluated for the devia~ tion.
.The NRC, inspector discussed this-with the CPRT engineer'ing nanager and was' informed'that this condition
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had:beenTidentified as a'SSD, and.that all deviations of' this type will be identified and the clanips replaced or repaired as part of the Hardware Validation) Program (HVP). The.NRC inspector was concerned that the condition where an evaluation is made on a vendor supplied item without interfacing with the vendor on either functional or stress requirements / limits was a generic condi! tion. The above is one of several evaluations that were made without vendor interface.
Additional exsmples are contained in paragraphs 4.ae and 4.ah. .This-type of condition will be indicated as."the lack of sufficient vendor information required to'make'a determination of' safety significance." This subject has been identified as an.open item in paragraph 3.c above.
R-S-LBSN-034-DR04 A DR was written because the reviewer could not verify the unique heat number.for a rear bracket. The Material
: Record idanti'fied/a bracket' heat-No. "NF831;" however, the Mater'ial Identification Log (MIL) listed."NF83." The SSE'conclnded'that the number was incorrectly entered on l the MIL as "N?rJ" snd the rear bracket seems to be traceable; therefore, this is a NSSD. After reviewing i
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this SSE, the NRC inspector questioned the NSSD determination because of a lack of supporting 4 ' r documentation. Subsequently, the supports lead engineer
>' supplied the inspector with the CMTR for the rear bracket.. Handwritten on the top of the CMTR was the t alphanumeric annotation "NF831." The NRC inspector did not concur that this was conclusive documentation to support traceability of heat No. "NF831" to the CMTR.
This matter is an:open item pending the SSEG' supplying
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more conclusive documentation relative to the rear
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bracket heat number (445/8704-0-21).
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'11-5-LBSN-027-DR02, I-S-LBSN-249-DR01, I-S-LBSN-253-DR02, [[dI-S-LBSN-260-DR01 These SSEs are additional examples which were reviewed
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accordaned with Procedure CPP-016. See paragraph 3.b, above. j A Other than the above open items, the NRC inspector identified nb additional open items for the above SSEs.
' ae. Large Boge Supports - Rigid (LBSR) I-S-LBSR-00'6-DR03 I-S-LBSR-050-DR03 I-S-LBSE-010-DR03 R-S-LBSR-050-DR03 I-S-LI4GR7011-DR01 I-S-LBSR-050-CI I-S-LBSR-01123R01 R-S-LBSR-054-DR02 s- I-S-LBSR-016-DR01 I-S-LBSR-060-DR03 I-S-LBSR-021-DR01- I-S-LBSR-070-DR03 I-S-LBSR-023-DR01 I-S-LBSR-201-DR04
I-S-LBS2-023-DR02 I-S-LBSR-206-DR02 I-S-LBSR-023-DR04 I-S-LBSR-210-DR01 I-S-LBSR-023 'CI R-S-LBSR-211-DR01 I-S-LBSR-039-DR03 I-S-LBSR-212-DR01 I-S-LBSR-041-DR03 I-S-LBSR-219-DR02 I-S-LBSR-050-DR01 I-S-LBSR-224-DR03 The NRC: inspector also reviewed the CI of the SSEs on a selective basis as indicated. The NRC inspector noted the following findings during those reviews: I-S-LBSR-039-D203 s The deviation described a contaminated spherical bearing.
The bearing was inspected by the SSEG and found to be painted, but properly engaged and the extraneous material j (paint)'was concluded not to interfere with the bearing rotation. The evaluation concluded that based upon the inspection, no condition of safety significance existed.
The NRC inspector questioned whether the basis for the { v -- - . ~ .
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conclusion would 'lx3 valid at some time in the future, if the paint was not removed. The SSEG lead discipline engineer for supports did not think that leaving the paint on the bearing would affect the bearing operation over time. To the NRC inspector's knowledge, no attempt was made to contact the bearing manufacturer to confirm this. This is another example of lack of sufficient vendor information required to make a determination of safety significance. See paragraph 3.c above.
I-S-LBSR-050-DR03 The DR documented that the center-to-center spacing of Hilti anchors violated the minimum spacing requirements.
The spacing was 1/8" less than the specified minimum of 7 1/2". This DR was considered a NSSD for the following reasons: 1) minimum factor of safety of 4:1 for the specified Hilti allowables, 2) conservatism'in minimum concrete strength, and 3) the conservatism involved with the support design loads. After review of the SEE, the NRC inspector determined, that because of the subjective nature of the SSE, adequate justification to arrive at a NSSD determination had not been provided. This was not a consistent approach since SSEs of a similar type (e.g., I-S-INSP-065-DR06) arrived at a more adequate technical justification of the conclusion based upon analytical techniques. This is an open item (445/8704-0-22).
R-S-LBSR-050-DR03 This deviation concerned an inability to verify traceability of the rear bracket of a sway strut. The SSE simply stated " . . . for resolution of this DR, see the validity block of DR R-S-LBSR-050-DR03." The SSE did not present the evaluation in the format required by paragraph 5.2.2 of ERC Procedure CPP-016. The NRC inspector indicated to the SSEG lead discipline engineer that the current format of SSE R-S-LBSR-050-DR03 was unacceptable since it did not conform to the requirements of CPP-016. The SSE lead discipline engineer agreed to revise this SSE to agree with CPP-016. This is an open issue pending NRC verification of compliance with CPP-016 (445/8704-0-22). See I-S-LBSR-050-DR03, above.)
I-S-LBSR-212-DR01 The DR identified pipe clamp ears that were not parallel.
This was identical to previously evaluated inspections I-S-LBSN-241-DR04 (paragraph 4.ad). This was another example of the lack of sufficient vendor information required to make a determination of safety significance.
See paragraph 3.c above.
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>d - The: DR' described two items shown on.the drawing to be
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welded together (Item 6, t:TItem.7); however,.the
A t inspection of the as-butit condition showed that thcEweld O: 1 , was made from ene of the items on the drawing to a-The evaluation:
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different member.'T. tem 6 to Item 3).
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w o reviewed the existing calculations which reflect tho' l I
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as-built condition; Item 6 should=be welded to Item 3.
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Since the calculations w'ere not attached to the SS2 for review, the NRC inspector could'not verify what.the'
"x 3) calculations should have ref.locted. This is an example j ,
of the lack of required inforsnation necessary)to s,upport i o the evaluation'bei.ng included in the SSE file. This is
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1 an open item-(445/8704-0-23).
' - I-S-LBSR-016-DRO.1 and R-S-G3SR-054-DR02 i 3 Taese SSEs were' reviewed and found to be additional acamples that did not contair< the appropriate calculation
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b checking verifications as required by Procedure CPP-016. ' See paragraph 3.b, above.
~ s The NRC inspcctoi:~ identified no open items for.the above t i s SSEs except for th% generic open items listed.
af. Nonpressure Boundary Welds (NPBW) ,
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I-S-NPBW-115-DR01-l I
.s. There were only three SSEs issued for this population; s.
the NRC inspector identified no open items for the above 1 SSE. - L 5 ag. Pipe Whip Resttairts'(PWREj,
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; I-G-PWRE-003-CI I-S-PWRE-065-DR01 R-S-PWRE-008'-DR02 R-S-PWRE-067-DR01
< I-S-PWRE-008-DR04 I-S-PWRE-003-CI <
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I-S- PWE 2-013- DR01 - I-S-PWRE-501-DR01 ! s^ , I S-PWRE- 013-DR03 'I-S-PWRE-501-DR02 I-$-PURE 014-DR01 I-S-PWRE-507-DR02
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4' 1-S-PWRE-015-DR08 I-S-PWRE-519-DR04
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I-S-PWRE-023-DR02 I-S-PWRE-519-CI s- I-S-WRE-029-DR02 R-S-PWRE-527-DR04 I-S-PWRE-039-DR01. I-S-PWRE-529-DRC4
, I-S-PWRE- 03 9-DR07 I-S-PWRE-531-DRO1 I S-PWRE-039-CI R-S-PWRE-542-DR01 I S-PWRE-046-DR06 I-S-PWRE-545-DR01 5 The NRC inspector ident ified d20 open items for the above y SSEs.
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ah. Small Bore Pipe Supports (SBPS) I-S-SBPS-017-DR04 I-S-SBPS-254-DR01 I-S-SBPS-017-DR03, I-S-SBPS-254-DR02 I-S-SBPS-033-DR01 R-S-SBPS-254-DR01 I-S-SBPS-053-DR05 .I-S-SBPS-254-CI R-S-SBPS-247-DR02 I-S-SBPS-268-DR01 l I-S-SBPS-251-DR03 The NRC. inspector also reviewed the CI-of the SSEs as indicated during the review of the SSEs for this-population. The NRC inspector noted the following findings during these reviews: I-S-SBPS-251-DR03 The ears of a pipe clamp were not parallel. The evaluation applied the same methodology as the SSE for I-S-LBSN-034-DR02 (see paragraph 4.ad) to account for stresses in the clamp ear resulting from the deviation.
This is another example of where there was a lack of sufficient vendor information to make a determination of safety significance. See paragraph 3.c.
Except for the above open item, the NnC inspector identified no additional open items for the above SSEs.
5. Reinspection of Initial Review Open Items (92719) The open items noted in the Teledyne Engineering Services (TES) trip: report (see paragraph 2) were reviewed during this inspection period to determine if appropriate action had been taken by the SSEG to enable the NRC inspectors to close these items. The populations re-reviewed were: CATY COSP FPLR INSP LBSR LIhR STEL CONC EQSP HVDS LBCO LBSN SBPS
1 The open items from 1986 in the EEIN and ININ populations were discussed in paragraphs 4.d and 4.e above.
J All of the open items were resolved or addressed by the examples discussed in paragraph 4, with the following exceptions: i
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R-S-LBSR-016-DR02 This DR was written for the lack of a Material Identification ! Log (MIL) in the inspection package. The evaluation analyzed the support structure assuming the lowest strength available material was used. The analyses concluded that stresses will l I - - - _ _ _ - - - _ _ _ _ . -
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be within allowable limits. Therefore, the deviation is nonsafety significant.
The following concerns still exist with this evaluation: a. The SSE further discovered that~the original computer run results were not available in the calculation package.
Therefore, a complete new analysis had to be performed.
This appears to be another document deviation.
b. After the new analysis was performed, it was discovered that the member properties of the tube steel were input i incorrectly and the Joint Loading was input in the wrong i direction. The SSE makes the statement that the above conditions will have a negligible effect on the computer results. Since the SSE package did not include a model, the impact could not be assessed by the reviewer.
c. In order to identify the problems (with the analysis) the SSE appears to hasJ done more than was required by QI-028 (Document Review of Large Bore Pipe Supports Rigid). The concern raised in the TES, April 28-May 1, 1986, audit report was - will this type of document deviation (incomplete analysis package) be discovered if it exists elsewhere? It was discovered in this case only because the SSE engineer did more than what was required.
d. The original deviation (material traceability) has not been explicitly addressed.
This is an open item pending resolution of these concerns (445/8704-0-24).
I-M-LBCo-069-DR01 The original inspection expressed concern vith the hand calculations used in this evaluation. Although these ! calculations were not consistent with the more detailed analyses performed elsewhere (e.g., I-M-LBCO-063-DR01), the approach used appeared to the NRC inspector to be appropriate. 1 The concern regarding the SSEG taking exception to and changing the findings of the ERC inspection team required further clarification. For this DR, the NRC inspector concurred with the SSEG determination that the ERC inspection team's findings were inaccurate. There are other similar cases where the deviations reported were changed or voided by the SSE. Additional review of SSEG invalidation of ERS will be made during a planned NRC inspection of the DR validation process.
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I-S-EOSp-045-DR04 i The DR was written because the torque for the bolts that i attach the equipment junction box, 1-LCS-5803, to the unistrut i support structure was found to be 100 in-lbs instead of the 228 in-lbs required. The SSE indicated that the required torque was not achieved because the mounting lugs on the junction box began to bend at 100 in-lbs of torque. The i evaluation went on to demonstrate that the existing torque was adequate to support the junction box and to note that a field inspection confirmed that, although the. lugs were bent slightly, neither the lug welds nor junction box were damaged or cracked. The evaluation concluded the deviation was NSSD.
Although the NRC inspector agreed with the SSEG assessment of this specific deviation, the evaluation does raise questions as to: (1) the possibility of damage to the lug welds and/or component in this and other similar equipment where the required installation torque of 228 in-lbs was applied, and l (2) a need for washers on all slotted hole connections of this i type to ensure the proper bearing surface between the bolt head and lug. The evaluation did discuss the latter issue but no definitive action was specified. This is an open item pending receipt of information which appropriately addresses these concerns (445/8704-0-25).
! I-S-HVDS-057-DR01 The DR was written because of weld deviations on HVAC duct support A-SGI-852-1J-1E. These involved (1) undersized welds , on the angle to angle connections and (2) stitch welding of the duct to support that was not specified on the drawing.
The SSE concluded that the deviations were not safety significant; however, the NRC inspector did not agree that the evaluation was conclusive for the following reasons: a. The duct support was strictly a lateral support and did not contain a brace to provide load resistance in the axial (in this case the vertical) direction. ,
b. The evaluation treated the' support as a lateral support and did not consider that the duct-to-support stitch welds could introduce axial forces and bending loads to the support.
c. The two anchor bolts attaching the support to the building structure were loaded up to their design j allowables from the lateral loads. There was little or no margin left for axial applied loads.
One assumption in the evaluation was that axial loads would be resisted by an adjacent axial restraint; however, no inspection was performed at the time to confirm this. As a
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! result of. discussions with the SSEG, a field check was performed by ERC to determine the proximity of an axial support. It was discovered that there was no axial support close to the subject support; the nearest axial support was some 35' away. Consequently, the possibility of an axial load.
contribution should have been addressed in the evaltation.
This is an open item (445/8704-0-26).
6. SSE Pe"sonnel Qualifications (36700) Neither CPP-016, Revision 4, " Safety Significance Evaluations of Deviation Reports," nor CPP-003, Revision 4,
" Indoctrination Training and Certification of Personnel,"
address specific experience and education requirements (qualifications) for personnel performing SSEs. Procedure CPP-016 specified that personnel participating in the SSE process should be technically competent and knowledgeable in the applicable discipline to assure SSEs were consistent with the requirements of CPP-016. Since no detailed prerequisite qualifications had been identified for personnel involved in the SSE process, the NRC inspector reviewed 20 of 96 SSE indoctrination and training files to determine if personnel experience, education, and training were consistent with CPP-016 requirements.
Of the 20 files reviewed, 12 were supervisory and lead discipline enginOers; 8 were for individuals performing SSEs.
The average nuclear engineering experience was 10 years and the average experience in the engineering industry was 15 years. Verification of previous experience was documented.
Nine engineers were licensed and registered professional engineers. All engineers were college graduates with Bachelor of Science degrees in related engineering disciplines; ten engineers had masters degrees in related fields. Verification of college dugrees was accomplished and documented by ERC for all but one engineer. Attempts were made to verify this individual's college degree obtained in India, but without success. Offered as evidence of the individual's l qualifications were verification of past experience and l current job performance. The NRC reviewed a sample of the l work performed by this individual and found it to be acceptable.
Indoctrination and training of the SSE personnel was documented and accomplished by both classroom presentations and assigned reading. Indoctrination was specific to the CPRT Program Plan and its overall objectives. Training was specific to the SSE and process related disciplinary procedures.
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In summary, based on the_ review of 20 SSE personnel qualifications, it appeared that SSE personnel were qualified to perform SSEs in accordance with CPP-016.
7. Open Items open items;are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in paragraphs 3, 4 and 5. For convenience.all open items are being tracked by a' Unit 1 number although some items may be applicable to Unit 2.
8. Exit Interview (30703) An exit interview was conducted March 3, 1987, with the applicant's representatives identified in paragraph 1 of this report. During this interview the scope and findings of the inspection were summarized. The applicant acknowledged the findings.
Attachments: TES letter dated July 1, 1986.
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DISTRIBUTION:
'i Docket ; Files [( 50T445/44'6 )I NRC 'l PDR ' ;g Local"PDR" ' '"~ '
CPPD Reading (HQ) Site Reading
*CPRT Grcup * SRI-OPS * SRI-CONST * MIS System *RSTS Operator RPB RIV File *DWeiss, RM/ALF JKeppler/JAxelrad CIGrimes PFMcKee HSchierling JLyons LChandler, OGC CPPD-LA, OSP *w/766 L- - - -
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ENGINEERING SERVGS
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h h7 130 SECOND AVENUE
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b[8~/O WALTHAM, MASSACHUSETTS 022549195
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(617) 890 3350 TWx (710) 324-7500
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July 1, 1986
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, j Mr. Ian Barnes United States Nuclear Regulatory Commission y* 7g k 611 Ryan Plaza Drive, Suite 1000 1 6 Arlington, TX, 76011 'g.a ; gqqg, Subject: Trip Report No. 2236
Dear Mr. Barnes,
Attached please find the subject trip report which . summarizes the efforts of TES personnel involved in the safety significance evaluation audit at CPSES from April 28, 1986 through May 1,1986.
If you have any questions, please do not hesitate to contact Messrs.
Bob Hookway, Jim Rivard or the writer.
Very truly yours, TELEDYNE ENGINEERING SERVICES M Donald F. Landers President b i DFL:mid I attachment cc: V. Noonan (NRC) C. Tranrnell (NRC) A. Vietti-Cook (NRC) D. Jeng (NRC) G. Bagchi (NRC) R. D. Hookway (TES) J. J. Rivard (TES) 6410 File l
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ENGSEERNGSBMCES l
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Concerns /Coment_s
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A. General 1. There seems to be a problem with tne definition of " Safety Significance". The process to determine safety significance is irreversible. The determination of safety significance is ! dependent upon the population you are investigating. That is, the same support evaluated in a piping configuration popula-tion may be deemed non safety significant whereby, if it were in a supports population it would be safety significant.
2. There is also a concern, as expressed in the past in meetings, with the use of "old" design data to perform the safety sig-nificance evaluations. New design data is being generated, for example, for piping, pipe supports, and cable trays as a minimum. Evaluations made using "old" data must be revisited when the new data is available.
B. Piping (related) Populations The review of the 29 S.S. Reports indicated thoroughness, complete-ness and general compliance with the procedures except: 1. R _-S-LBSR-016-DR2 Deviation is lack of material traceability. In the process of evaluation the analyses package was reviewed and found to be incomplete. This evaluation completed the analyses package in addition to tracking the material.
This evaluation is thorough and okay. However, since this evaluation (for material traceability) uncovered a document deviation in the analyses package of the support. The ques-tion is; with the system in place, will this type of document deviation be found if it exists for other supports or com-ponents? Note: A QI review may resolve this.
2. 1-S-PWRE-006-DR-4 Deviations include two pipe whip restraints located outside the tolerance for the dimension shown on the drawing. The evaluation discovered a letter to TUGC0 from G&H allowing the relocation. Therefore, the evaluation is okay and concludes , non-safety significance.
My concern is why wasn't the information in the letter incorporated onto a revision to the drawing!! And why didn't this become a document deviation report? __
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l C. Civil Structural Populations j 1. Concrete - Cast-in-place anchor bolts were installed out of l j tolerance. The evaluation states that the analysis of the anchor bolts and attachment uses the as-installed locations.
This should be verified by a review of project procedures and specific calculations. l
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2. Similar deviations identified in a number of the populations, ' including weld deficiencies, support locations, brace con-figurations, may be safety significant if occurring at other locations. The adverse trending should be reviewed to deter-mine how this will be addressed.
3. Equipment Supports - The torque of Unistrut bolts holding an j Electric Control Box was determined to be 100 in-lbs instead of 228 in-lbs as required by the installation procedure. The evaluation demonstrated that 100 in-lbs were adequate to sup-port the control box. However, during the reinspection of the torque, it was noted that the mounting lugs began to bend at 100 in-lbs. The concern is that, if in fact 228 in-lbs was used at similar applications, the control box may be damaged.
This attribute should be reviewed in the Elec. Equipment Pop-ulation. This may be significant.
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TN ENGN!ERNGSERVICES
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:. No. of S.S. Eval : Deviation Reports Avail. No. Evaluations : Population Reports (1) for Review (2) ' Reviewed / Reviewer ,
GENERAL 4 4 4/JJR' LBC0 58 16 10/RDH
; LBSN 266 5 5/RDH . LBSR '198 7 6/RDH >
PWRE 116 2 2/RDH SBPS 85 2 2/RDH i SBC0 63 11 3/RDH
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Conc 58 12 10/JJR Cond. Spts 428 75 6/JJR
, Eq'T Spts 100 31 3/JJR Fuel Pool Liners 19 3 3/JJR ; Instr. Spts 549 40 1/JJR Liners 88 81 3/JJR Steel 230 42 4/JJR HVAC Spts 249 93 6/JJR Cable Tray 1/JJR Back Fill 610 78 0/JJR Electric Cable (CABL) 75 11/L.S.
Cable Tray (CATY) 62 16/L.S.
Conduit (CDUT) 36 5/L.S.
, Electric Equip. (EEIN) 59 12/L.S.
Instrumentation Control (ININ) 72 15/L.S.
Nuclear Instru. (NTST) 2 2/L.S.
Total 123 1. As of this Audit date.
2. This includes only those that have been completed since 3/1/86 using a "new" report format. .
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TM ENGSEERNGSEMCES l ! Attachment I Page 1 of 9 l' I. Larg; r Jore Configuration Population (LBCO) o There are 58 Deviation Reports (DR's) for this population.
o Only 16 SSE reports have been completed since 3/1/86, 10 were re-viewed during this audit.
I-M-LBC0-039-003
Six deviations on the CCW system isometric dealing with clearances. The evaluation considers pipe motion based on G&H analyses to justify the small (less than tolerance) clearance. Okay.
I-M-LBC0-063-001 This deviation is a 3" M.S. pipe not centered in a wall penetration. The evaluation looks carefully at the predicted (based on G&H computer analyeses) movements. These movement.s are smaller than the gaps existing. This eval-uation is okay. (Note: the new write-ups, since 3/1/86 uses 20 pages to do what a 9/85 write-up did in about 4).
I-M-LBCO-069-001
, Deviations (4 of them) are clearance problems.
o All of these are evaluated by the use of simple hand calculations (e.g. L= ) with no apparent regard for restraints on the system.
(Without a thorough understanding of the restraints and their lo-cations, this type of analysis should not be used.)
o This (hand calc) is not necessarily wrong but it is terribly incon-sistent with the evaluation of 1-M-LBCO-063-001 o Calculations have not been checked.
o The S.S. Eval takes exception to the findings of the inspection team (specifically on the penetration clearances where inspectors found the insulation cracking and S.S. evaluater found a gap?!! I don't know what this means!! o Consider these (above conrnents) together with others after going through more reports.
I-M-LBC0-079-DR1 The two deviations are clearance problems. They have been evaluated with hand cales. This time, however, the evaluation does consider restraints and there locations. It looks okay.
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ENGHEERNGSBMCES Page 2 of 9 I-M-LBC0-098-DRI i I Clearance violations are deviations. The evaluation considers movements as predicted by G&H. Evaluation looks okay.
Tuesday 4/29/86 l I-N-LBCO-102-002 i This DR indicates the piping is located outside of tolerance. The dimensions used are those on the isometric. It was found that the isometric dimension is in error. The piping is not affected. This evaluation is okay.
I-M-LBC0-103-002 i
"I This deviation is an interference (Rx Coolant Spray Line) with the steam
' i generator upper support.
i che evaluation is very difficult to follow with the information in the evaluation report. Discussion with the evaluation eliminated any concerns.
The evaluation is Ok.
I-M-LBCO-104-DR3 i The deviation is with respect to pipe run lengths. The, discrepancy is
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minimal. The evaluation is Ok.
f I-M-LBC0-118-DRI
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The deviations are interferences with other pipe and supports.
For concern #1, the evaluation used the maximum displacements listed on the support detail. The concern is two horizontal pipes with a potential vertical interference when operating. The evaluation assumes both systems operate at the same time. Can one operate while the other doesn't? The evaluation doesn't consider this and the evaluation report does not provide enough information to make that decision.
This evaluation report needs more work, at least for presentation. If all operating conditions were not considered, then other work is definitely required.
General Question: What would have been done if this evaluation did indicate that interferences would exist for the other pipes? I-M-LBCO-119-002 Concern is valve was installed with stem downward instead of upward.
Evaluation looks okay.
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ENGNERNGSERVICES i 3 Page 3 of 9 II. Large Bore Supports - Non Rigid Population l
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Of the approximate 266 DR's listed on the SSEG Status Report (dated
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4/5/86) only 5 have been completed since 3/1/86. Therefore only these five i will be looked at.
t R-S-LBSN-046-004
] The deviation is a document deviation. The Hilti Bolt Inspection Report i could not be retrieved. 2
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i The evaluation found that the bolts were torqued and okay as shown in the Hilti Bolt Torque Reinspection Program. The S.S. evaluation is okay, I-S-LBSN-239-DR2 The deviation is an irregular shaped fillet weld.
' Evaluation includes weld sizing cales. Evaluation is okay.
I-S-LBSN-210-DR2-Deviations consist of three catalog items on this support are not within dimensional tolerances. All variations were evaluated properly. Evaluation is okay.
I-S-LBSN-249-DR1 Deviation in Tube steel is 2" shorter than the 22" dimension called for on the drawing. Evaluation is okay.
I-S-LBSN-260-2 Deviation is support member length is long. Evaluation performed with STRUDL - Evaluation is okay.
I-S-LBSN-260-3-The deviation is ungrouted base plates for a snubber support frame.
The evaluation included re-inspection of the baseplates to verify bear-ing surfaces for the plates in addition a "BAP' reanalysis to qualify the plates for less than intended bearing area. The evaluation is okay.
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WTEUH7mE , M i Page 4 of 9
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III. Large Bore Supports - Rigid Population Of the approximate 198 DR's listed on the 4/15/86 SSEG Status Report, only 7 have~been completed since 3/1/86. Six of these will be looked at. )
1 R-S-LBSR-016-DR2 Deviation is lack of material traceability. In the process of evalua- l tion, the. analysis package was reviewed and found to be incomplete. This i evaluation completed the analysis package in addition to tracking the 4 material.
This evaluation is thorough and okay. However, since this evaluation 1 (for material traceability) uncovered a document deviation in the analyses
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package of the support, the following question is raised: With the system in place, will this type of document deviation (i.e., incomplete analysis pack-age) be found if it exists for other supports or components? Note: A QI review may resolve this.
I-S-LBSR-069-DR4 This deviation includes MPT tag missing and base plate anchor bolt holes located out of tolerance. The evaluation shows that the NPT tag is not needed and a reanalysis of the base plate indicates all loads and stresses' to be within code allowables. Okay.
I-S-LBSR-069-DR6 Deviation is damaged concrete in the vicinity of other base plate anchor bolts. Evaluation is thorough and complete. Okay.
I-S-LBSR-202-DR6 Deviation is an out of tolerance angle (6 )0 between strut and clamp.
Analysis considers the effect of the change in axial and transverse load in the clamp etc. Evaluation is okay. In addition, I believe an NCR will be . i written for this DR and a construction modification will be made to correct ! it. 1 I-S-LBSR-217-DR1 This deviation includes dimensions not shown on dwg and proper signature are not provided on the Materials Info List (MIL). The evaluation is complete and okay.
l I-S-LBSR-204-DR-5 ' This deviation is the inability to verify thread engagement
The evaluation verified there is sufficient thread engagement. The
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WTEEDGE ENGNERINGSOMCES Page 5 of 9 IV. Pipe Whip Restraint Population Of the approximate 116 deviation reports listed in the 4/15/86 SSEG -{ status report only 2 safety significant evaluations have been completed since 3/1/86.
I-S-PWRE-006-DR-4 Deviation includes two pipe whip restraints located outside the toler-ances for the dimension shown on the drawing. The evaluat' ion discovered a letter to TUGC0 from G&H allowing the relocation. Therefore, the evaluation i is OK and concludes non-safety significance. j My concern is why wasn't the~ info in the letter incorporated onto a revision to the drawing!!! And why didn't this become a document deviation report?? I-S-PWRE-507-DR1 The deviation is that washers do not completely cover the bolt holes.
The evaluation relies on the fact that these connections are Bearing Type connections (Type X) and the washers do not play a role in the transfer of loads. The evaluation does not present enough info to verify the above contentions. It appears like some tension loading would probably exist in these locations. ! I V. Small Bore Pipe Supports Population Of the approxmiate 85 deviation reports listed in the 4/15/86 SSEG status report, only 2 safety significant evaluations have been completed since 3/1/86.
I-S-SBPS-249-003 This deviation is paint on the spherical bearing of a strut support.
Field inspection in the evaluation assured that the bearings are free to move.
Evaluation is okay.
I-S-SBPS-272-1 Deviation is box-frame gaps. The evaluations considered radial growth due to temp. and pressure. The growth is still less than the gap. The evaluation is okay.
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WTEUDNE ENGDEERNGSEmOES i Page 6 of 9 VI. Small Bore Piping Configuration Sample Of the approximate 63 deviation reports listed in the 4/1/86 SSEG status report,11 SSEG reports have been issued since 3/1/86. Three will be reviewed in this audit.
I-M-SBCO-004-DR-1 These deviation reports are run of pipe evaluation out of tolerance by 1/16". . The evaluation assured that nothing more significant than that ; existed on the piping and wrote this deviation off as insignificant with ' respect to stress and loads. The evaluation is okay. l
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The deviation is a clearance violation with other piping. (Note: the i clearances noted are to insulation). The clearances of concern are vertical direction. Rigid vertical supports exist on all of the lines effected here.
Therefore, the mininial clearance will have no impact on stress or support ,
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loads. The evaluation is okay.
I-M-SBCO-024-DR1 The deviation is interference with another line. The evaluation considers the analytical displacement prediction (which are very small) and concludes that resulting loads and stress will be insignificant. The evalua-tion is okay.
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Page 7-of 9 _DR's Found to be Safety Significant Five Generic Evaluation reports applicable to all support samples (i.e.
LBSN, LBSR, SBPS) In addition .
I-S-LBSR-019-DR2-069-DR2 I-S-LBSN-259-DR5-252-DR4-261-DR1 I-S-SBPS-054-DR2
. -044-DR1 I-S-LBSR-019-DR2 Deviation is Safety Significant. The deviation is the jam nut and strut barrels on a rigid strut turn simultaneously. "In this situation the eval-uation claims that a displacement will be imposed on the pipe." Since (1)
this is a support popul.a ,ai and (2) the rigid support will not act strictly as a rigid support, the devit. on is deemed safety significant.
I-S-LBSR-069-DR2
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Deviation in pipe clamp halves installed out of parallel.
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Page 8 of 9 i
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! Look at Number of Dimensional Discrepancies Discovered to Date (i.e., the 2nd day of this audit) [ 1 j LBSN i 21 of.160 in " dim out of Tol" category. j LBSR 20 of 1191ri "dic out of Tol" category. <
i PWRE 20 of 101 in " dim out of Tol" category.
i l SBPS 5 of 50 in " dim out of Tol" category.
I INSP 33 of 250 in " dim out of Tol" category.
l Instrument Pipe / Tube Sup.
'! ' HVDS 44 of 232 in " dim out of Tol" category.
- HVAC Duct Supports
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Sub Total 143 of 920 in " dim out of Tol" category.
exceeds 15% of the DR's These 143 were found on total population of 655
' supports! = 25% (i.e. 25% of 655 supports looked at were found ^!
to have dimensions out of tolerance). This
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must be looked at in the trending evaluation.
i t LBSN 82 I' LBSR 89 PWRE 135 l SBPS 76
INSP 130 HVDS 143
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Page 9 of 9 4 l Sumary as of 4:30 PM 4/29/86 Piping & Supports
. i Of the 6 population to be reviewed, two have been completed and the third is in process. These populations include:
i Sample Size DR's SSE Rpts Avail. Looked At 3 LBC0 101 58 16 10 LBSN 82 266 5 5 LBSR 89 198 7 7
,' Others -
PWRE 135 116 2 2
. SBPS 76 85 2 2 ,- SBC0 88 63 11 3 i i i
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Notes:
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For LBC0 most deviations looked at are clearance.
For LBSN most deviations are dimensional.
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WTELEDGE ENGNEERNGSERVCES < Page 1 of 9 j ATTACPJ4ENT II Concrete Placessent (CONC) I-S-CONC-79-DR1 i A 5/8" diameter hole with a depth greater than the required concrete Cover.
The evaluation assumed a 5/8" diameter x 12" deep void in a 12" (wide) x 4' (thick) wall. The section is reduced 1.3% and rebar was not exposed. Note: Agree with evaluation.
s I-S-CONC-79-DR2 Deviation: Cast-in-place anchor bolts installed out of tolerance.
The evalual .on stated that the actual loading on cast-in-place anchor bolts is determined as part of the design of the specific attachment loading and is based on the actual installed locations.
Agree with the evaluation. The procedure for cast-in-place anchor bolts should be reviewed to confirm evaluation. ! I-S-CONC-90-DR1, The deviation is a 21/2" deep void in the concrete in an area where ! the required cover is 4".
The evaluation states that a small localized reduction in cover will not adversely af.fect the protection of rebar. Agree with the evaluation.
I-S-CONC-90-DR2 An area of the thickened portion of the concrete at the equipment hatch is 2'-113/8" instead of 3'-0" as shown on the concrete draw-ings. The evaluation states that this localized deviation will not adversely affect the structural capacity of the concrete. Evaluation okay.
I-S-CONC-071-DR1 Similar connent as I-S-CONC-079-DR2.
I-S-CONC-123-DR2 Two cast-in-place anchor bolts were cut and the elevation of the top of the bolts did not conform to the design drawings. The bolts were I cut per a DCA for the equipment setting. Evaluation okay. j l
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ENGNEERNGSBMCES Page 2 of 9 l I-5-CONC-091-DR1 i Three cored holes were drilled in a concrete wall which were not shown on either design drawings and DCA's. Evaluation accounted for reduc-tion in concrete and rebars. The design margin is adequate. Evalu-ation okay.
. I-S-CONC-108-DR1 Similar to I-S-CONC-079-DR2.
I-S-CONC-115-DR1 . A cored hole was not shown on design drawings. However, this cored hole was authorized per a DCA. Evaluation okay.
I-S-CONC-113-DR1 The deviation consists of the identification of a S/8" diameter, 2 1/2" deep hole in a 3' x 3' column. The evaluation states that this is an 0.12% required cover. section reduction and that 2 1/2" is less than the Evaluation okay.
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WM ENGNEERNGSEmOES , I l Page 3 of 9 Conduit Supports (COSP) I-S-COSP-090-DR1 The deviation was undersized welds - 5/32" compared to 3/16" required.
The structural capacity of the support .is controlled by Hilti allow-ables and the as-found weld capacity is adequate. Evaluation okay.
I-S-COSP-086-DR1 There is a gap between conduit clamp and strut. The required torque of the bolts on this support was okay. Therefore, the desired clamp-ing force was obtained. Evaluation okay.
I-S-COSP-039-DR1 Same as I-S-C03P-086-DRI.
I-S-COSP-038-DR1 The connection nuts were misaligned and one nut was damaged. Since . . ' the threads in question are not damaged and the required torque was t obtained, the evaluation demonstrates that the connections will func-tion as intended and will develop sufficient capacity. Evaluation okay.
I-S-COSP-027-1 The spacing between. supports is greater than that shown on the design ! drawings. The evaluation shows that this condition is okay. Evalu-ation okay.
I-S-COSP-071 The deviation states that the 1/2" diameter Hilti has bottomed on its 1 thread length. The length of exposed thread was measured from the end of the bolt and should have been measured from the first thread cut.
This demonstrates that the nut is actually not bottomed out. Evalu-ation okay.
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ENGNEERNGSERVICES Page 4 of 9 Equipment Supports (EQSP) _I-S-EQSP-045-DR4
'39 torque was found to be 100 in-lbs instead of 228 in-lbs as required. It was noted during.the reinspection that at.100 in-lbs the control box mounting lugs began to bend. The evaluation demonstrates that the existing torque is adequate to support the control box.
I Concern: Since the mounting lugs began to bend at 100 in-lbs, the lugs and/or the component may have been damaged by applying the required installation torque of 228 in-lbs. This attribute should be checked in the equipment population.
. I-S-EQSP-045-DR1
.The deviation was that a Unistrut connection angle was not installed correctly. The installation configuration does not affect the capacity of the connection. Evaluation okay.
I-S-EQSP-002-DR1 A member location shown on the design drwings as 13/4" i 1/8" is actually 1 1/2". Support was evaluated for this condition and shown to be adequate. Evaluation okay.
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WM ENGNERNGSERVICES Page 5 of 9 Fuel Pool Liner (FPLR)
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I-S-FPLR-180-DR1 I-5-FPLR-006--DR2 l I-S-FPLR-149-DR1 Rust-colored corrosion noted on weld seams. A chemical test was con- I ducted and the results were that the condition was not active cor- ) rosion.
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Page 6 of 9
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Liners (LIg), j R-S-LIM-59-DR3 4, ' / One polar crane support bracket was not. listed on the Receipt Inspec-tion Report ' (RIR) which covered -all the other brackets. It was covered in another RIR. Evaluation okay. !
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i R-S-LINR-038-DR3 There was no record of a weld joint being radiographer - one foot, to be RT'd for every 50' of weld. The weld was incorectly identified snd after further investigation the correct identification was determined ; , and the weld was found to be covered by the testing program. Evalu- ' ation okay. 3 R-S-LINR-013-DR2
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The piece number for a part of an assembly could not be determined. A t more extensive review was dane and th'e piece was identified. Okay.
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[tACDuctSupports(HVDS)
t i J-S-HVDS-046-DR-12 The dimension. locating the point where a diagonal brace mounts to the concrete . ceiling was found to be 581/8" instead of 91", as shown on
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the design-drawing., Since the design calculations were based on 91", !
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the as-found condition will result in- higher stress in the support j members as well as the Hilti bolts. The evaluation of the as-found 4 condition shows that the increased member stresses and anchor-bolt f loads are acceptable. Evaluation okay. j I-S-HVDS-0W-DR1 l
' ; 'Uc.darsizdd welds were identified.
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Six 1/2" fillet welds undersized up
, to 1/8".. In addition, the duct was found to be attached to the sup-
. port with 1/8" fillet welds, 2" long and approximately 6" 0.C. The
' evaluation of the undersized support welds demonstrated that the as-found condition is acceptable and is -okay. The evaluation does not address the fact that the duct-to-support welds are normally used on an axial duct support. It is noted, however, that it is doubtful that b this support could support an axial load since there is no axial brace. {
- The evaluation should further address the duct-to-support weld.
- I-S-HVDS-064-DR1 A number, of deviations were identified with support welds, including undersized, underlen questionable profile.gth, excessive undercut, incomplete fusion, and Evaluation demonstrates that the as-found con- )
;dition is acceptable. Evaluation okay. j I-S-HYD$-013-DRS T-TIMiG0.Hi-DR1 ---
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The. weld of the support angle to the concrete mounting angle was not l shown on the design drawing. A number of other support welds were ' undersized. Evaluation demonstrates that the as-found condition is acceptable. Evaluation okay.
I-S-HVDS-023-DR1 The identified deviations Belude member orientation and length. The deviations are minor and the evaluation is okay.
, gote: The project is readdressing the HVAC supports, which will cover l all above deviations. 1
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ENGNIERNGSEMCES Page 8 of 9 i Structural Steel (STEL) I-S-STEL-146-DR2 The deviation is undersized welds. The design drawing calls for a-3/8" fillet weld. A number of locations were identified as undersized by 1/16" and one area was 1/8" undersized. The evaluation shows that this condition is acceptable. Evaluation okay.
I-S-STEL-066-DR2 This deviation deals with member location. The design drawing iden-tifies the evaluation of the member as being 828'-0" i 1/8". Actual s evaluation is 828'-0 3/16". Evaluation okay.
I-S-STEL-090-DR2 The design drawing identifies a member as being located 17'-5" from a building column. The dimension is actually 17'-3 15/16". Evaluation is okay.
I-S-STEL-519-DR1 Similar to I-S-STEL-090-DR2.
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4 . Instrumentation Supports (ThSP)
7-S-INSP-020-DR7
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Undersizd weld. The design drawing calls a 5/16" weld. The total
length of the veld is undersized by 1/16". The evaluation shows that J
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this ccndition is acceptable. Evaluation ekay.
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I-E-CATY-01,1-DR2 .x ,
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y a Loose bolts in a cable tray splice plate. The evaluation showed that
? this condition is' acceptable. Evaluatian okry.
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Generic SSE's l l I-S-LBSN-GEN-DR2 (Lc Bore Spts - Non-rigid) 1 I-S-PS7N-GEN-DPI I-S-LBSR-GEN- M (Pipe Supports in Rm 77N) i
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I-S-SBPS-GET-NtT Sm((Lg BoreBore Spts) Spts - Rigid) l
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t A total of 213 deviations frave been noted in the piping populations.
The deviations have safety significance, the de~tistion being that there are no leckir.g devices which are required on these two.
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Draft R port, Audit of CPSES Sofsty Significance Evaluations of i Electrical and Instrumentation and Control Inspection and ) Documentation Deviation Reports, 4/28/86 through 5/1/86.
The purpose of this audit was to review and assess the adequacy of a' sample of completed safety significance evaluations prepared in response to construction and installation deviation reports. The deviation j reports were developed from a reinspection of installed equipment and j from a review of related construction documentation. An assessment was also desired regarding the adequacy of the implementation process used to - prepare and complete safety significa.nce evaluations.
I During the audit, the team reviewed approximately 20 percent of the currently available and completed safety significance evaluations in the electrical tabulation: and instrumentation and control area as shown in the following l [ Inspection Documentation Safety Safety Significance Significance Evaluations Evaluations i Population - Symbol Completed Reviewed Completed Reviewed
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Electric Cable CABL 56 6 19 5 Cable Tray CATY 49
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14 13 2 Conduit CDUT 36 5 0 0 Electric Equipment EEIN 59 12 0 0 Instrumentation, Control ININ 62 15 10 0 Nuclear Instrumentation NIST 0 0 2 2
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I Total 262 52 44 9 Within these six populations, the team reviewed each of the 29 inspect 2cn saf ety significance evaluations completed during the past two months. An additional sample of 23 inspection safety significance evaluations was selected for review from those completed prior to March 1986. Nine ~ documentation safety significance evaluations were reviewed from the electric cable and nuclear instrumentation populations.
The team was inf ormed that revi sion 2 of procedure CPP-016, " Safety i i Significance Evaluations of Deviation Reports," was issued on January 28, 1986. The technical requirements in the current procedure were compared with those provided in revision 1 dated August 9, 1985. Current versions of the applicable quality instructions, such as DI-008, 01-010, 0I-012, 01-014, and QI-016, were also used during the audit.
Each of the 61 safety significance evaluations reviewed by the team had been individually determined to be not-safety-significant. However, the i team did not agree with this determination for deviat on report DR-I-E-EEIN-022-DR4 dated January 24, 1986. In this instance, a stainless steel flexible conduit has'been used to provide an environmental barrier from containment atmosphere and physical support for an electrical cable l connecting a Conax seal assembly (ECSA-1-HV-2404A-1) to a steam generator ) recondary side sample solenoid valve (1-HV-2404A). This flexible conduit t j CPSES I&C Saf ety Significance Evaluation Audit Report Author and Date: L. Stanley, Zytor, Inc., rev. 1, 05-06-86 HSB TES0001.DR1, page i
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wnc found to hava torre ct occh Gnd cuch that tha environmental seal from containment atmospheric conditions was broken for both the cable and solenoid valve internal parts. This exposure to containment atmosphere violated the environmental qualification basis of the solenoid valve whose required safety function was to de,-energize (causing the fluid system sample valve to close) upon actuation of the auxiliary feedwater system. Closure of the fluid system sample valve was required in this situation to maintain a sufficient amount of water for steam generator heat removal from the reactor coolant system.
The safety significance evaluation for DR-I-E-EEIN-022-DR4 concluded that the flexible conduit installation * defect would not result in the loss of capability of the affected system and component to perform its intended safety function based on:
(1) a predicted safe failure mode for the solenoid valve electrical coil, as described in the environmental qualification report, when it has been exposed to containment atmospheric conditions; (2) the' presence of other electrical interlocks that could cause electrica! de-energization of the solenoid valve, and ,(3) an assessment that the cable was adequately supported by the .. damaged flexible conduit.
This determination for safety significance was not valid because the environmental qualification of a safety-related solenoid valve, in accordance with 10CFR50.49(j) and IEEE Std. 323-1974, has been violated
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by the flexible conduit installation defect.
The foreword of IEEE Std. 379-1977 stated that in order to obtain protection from possible common mode failures resulting from external *l environmental effects, the (safety) system components are designed, qualified, and installed to be immune to such anticipated challenges.
Appendix B of section 7.1 of the NUREG-0800 Standard Review Plan stated 1
'that the invalidation or " lack of equipment qualification may serve as a -
basis to assume failures. After assuming the failures of nonsafety-grade, nonqualified equipment and those failures caused by a specific event, a. random single f ailure is arbitrarily assumed. " In demonstrating compliance with the single failure criterion, one purpose of a failure mode and ef f ects analysis described in section 4.1 of IEEE Std. 352-1975 is to ensure that all conceivable failure modes and their effects on operati onal success of the system have been considered. Table 3 of this l latter standard identified typical failure modes of mechanical systems as corrosion, contamination, and binding. The safety significance l evaluation did not consider the possibility of mechanical binding of l solenoid valve parts that could result f rom exposure to containment i atmosphere conditions. This postulated failure mode would prevent the I solenoid valve from venting the fluid system control valve, and thus ' prevent the performance of its intended safety function. On this basis, the 9 valuation determination should have stated that the flexible conduit installation def ect was safety-si gni ficant.
t ) l CPSES I&C Safety Significance Evaluation Audit Report Author and Date L. Stanley, Zytor, Inc., rev. 2, 05-07-S6 l HSBaTES0001.DR1, page 2 '
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During tha cudit of cafGty cignificcnca ovclustions, o revicw ka performed of the adequacy of procedure CPP-016 and its implementation process. The team developed the f ollowing observations:
(1; Procedure CPP-016 secti on 5. 7.2 (b) stated that "the intended {
safety function of the item is determined." This should be ' changed to safety function (s) to reflect the fact that some components have as many as four distinct safety functions that need to be fulfilled, and that some may be mutually exclusive.
For example, an emergency core cooling discharge valve may have one safety function to open for safety injection flow, and may also have a second safety function to close for containment i sol ati on. As written, the procedure does not encourage the identification of multiple safety functions for a component.
(2) A f ormat variation was noted in the most recent safety significance evaluations regarding the identification of the required safety functions of a component. A number of instrumentation and control (ININ) evaluations did not ;
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clearly state the safety function in that section of the evaluation, but rather described the required safety function in the analysis objective section of the evaluation.
, ((3) The saf ety significance evaluation f or I-E-ININ-100-DR2 { l , stated that the instrument line function was to transmit i pressure to the instrument and to maintain the system pressure boundary. The issue in this deviation was the maintenance of at least 18 inches separation distance between redundant instrument lines. The objective statement did not state this separation requirement in a clear manner.
(4) The saf ety significance evaluation for I-E-ININ-082-DR2 did not identify maintenance.of the reactor coolant pressure boundary as a safety function for the instrument line.
- (5) The safety significance evaluation for I-E-ININ-082-DR1 did .
not identif y the safety function of pressuri:er transmitter PT-455 even though the objective statement stated that t he evaluation would determine if the observed deviation in instrument line slope had any impact on the transmitter.
Two cable tray connector plate bolting aspects were investigated during this audit. Eight bolt connector plates used to join cable tray sections were inspected as part of the CPRT program with a criterion that each bolt be finger tight. Gibbs and Hill documentation contained no requirement for the tightness of the bolts, such as a " snug" fit through the use of ordinary hand tools. Where one or more bolts were found to be , loose, a minimum of six bolts was determined to be suf ficient f or { structural purposes. This six bolt criterion was ambiguous in that it did not require three bolts on each sidet however, the team observed that such symmetry had been applied in the safety significance evaluation process.
I CPSES I&C Safety Significance Evaluation Audit Report Author and Date L. Stanley, Zytor, Inc., rev. 2, 05-07-86 j HSB:TES0001.DR1, page 3 j _
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* PERSONNEL CONTACTED:
Name Title Organization
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E.J. Brabaron (title unknown), SSE Group ERC J. Adam (title unknown), SSE Group ERC/SWEC G. Maddox (title unknown), SSE Group ERC A. Nevins Instrumentation and Control ERC/SWEC A. Patel Instrume6tation and Control ERC/SWEC D. Grewal Electrical ERC/SWEC A. Low Electrical Lead Engineer ERC/SWEC T. Kulaga Cable Tray Population Engineer ERC/PLC
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A. Tewfik (title unknown) ERC U. Hansel (title unknown) ERC T. Tyler (title unknown) ERC
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CPSES I&C Saf ety Significance Evaluation Audi t Report Author and Dater L. Stanley, Zytor, Inc., rev. 1, 05-07-86 HSB TES0001.DR1, page 3A -
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Appendix A: ILC Inspection Safety Significance Evaluat2cnc Rev2ewed
'Daviction R port Dsto Subj ect I-E-CABL-003-DR1, 09/24/85, Cable Minimum Spacing Within Tray.
(f2D //6 I-E-CABL-017-DR2, 04/02/86, Cable Minimum Bend Radius.
I-E-CABL-022-DR2, 09/19/85, Cable Flacc Sleeve Not Shown on Schedule.
I-E-CABL-043-DR2, 12/24/05, Cable Movement Slack Tolerance.
I-E-CABL-060-DR2, 09/19/85, Conduit Not Shown on Sthedule.
I-E-CABL-091-DR2, 01/07/86, Cable Conductor Insertion Into Barrel Lug.
I-E-CATY-011-DR2, 09/12/85, Cable Tray Plate Bolts Loose.
I-E-CATY-050-DR3, 09/18/85, Cable Tray Bottom Welding Details.
I-E-CATY-117-DR1, 10/15/85, Cable Tray Hole Plugs Not Installed.
I-E-CATY-125-DR1, 03/25/86, Cabin. Tray Plate Bolt Reversed.
I-E-CATY-146-DR1, 04/05/86, Cable Tray Plate Bolt Reversed.
I-E-CATY-172-DR1, 03/25/86, Cable Tray Plate Bolt Loose.
I-E-CATY-195-DR3, 02/17/86, Cable Tray Plate Minimum Width.
I-E-CATY-199-DR1, 03/31/86, Cable Tray Plate Locking Device Missing.
I-E-CATY-265-DR1, 04/xx/86, Cable Tray Plate Bolt Loose.
I-E-CATY-284-DR1, 04/02/86, Cable Tray Welding Inspection Documentation.
I-E-CATY-286-DR1, 04/12/06, Cable Tray Plate Bolts Loose.
I-E-CATY-287-DR2, 03/26/06, Cable Tray Plate Bolt Loose.
I-E-CATY-314-DR1, 03/20/86, Cable Tray Plate Bolt Lowse.
I-E-CATY-315-DR1, 04/12/86, Cable Tray Plate Bolt Missing.
I-E-CDUT-017-DR2, 11/06/85, Conduit Number Marking Error.
I-E-CDUT-017-DR7, 04/02/86, Conduit Color Code Marker Distance.
I-E"CDUT-040-DR1, 08/27/05, Conduit to Flexible Conduit Connection Gap.
I-E-CDUT-086-DR2, 02/19/86, Conduit to Conduit Separation Distance.
I-E-CDUT-111-DR2, 03/xx/86, Conduit to' Tray Cable Maximum Length.
I-E-EEIN-003-DR2, 10/09/85, Conax ECAS Conduit Maximum Length.
I-E-EEIN-022-DR4, 02/21/86, Conax ECAS Flexible Conduit Torn.
I-E-EEIN -043-DR1, 03/07/86, Transformer Orientation Not on Drawing.
I-E-EEI A -044-DR1, 01/15/86, Battery Rack Connection Nut Loose.
I-E-EEIN-055-DR1, 01/24/86, Lighting Panel Broken Door Latch.
I-E-EEIN-069-DR1, 03/08/86, Cabinet Orientation Not Stated on Drawing. l I-E-EEIN-069-DR2, 03/25/86, ERF Computer Cabinet Lift Ring, Hinge.
I-E-EEIN-073-DR1, 03/26/86, Cona: ECAS Rigid and Flexible Conduit. j J-E-EEIN-074-DR1, 03/10/86, Conax ECAS Rigid and Flexible Conduit. l I-E-EEIN-074-DR2, 03/07/86, Canax ECAS Identification Marking. * ' I-E-EEIN-083-DR2, 01/xx/86, Local Control Station Relocated by ECN.
I-E-EEIN-099-DR2, 01/08/86, Conax ECAS Rigid and Flexible Conduit. ; I-E-ININ-002-DR3, 03/xx /86, Instrument Line Slope Tolerance. j I-E-ININ-026-DR1, 01/xx/86, Instrument Marking Tag Missing. i I-E-ININ-050-DR1, 04/12/86, Instrument Line Separation Distance.
I-E-ININ-051-DR1, 01/xx/86, Instrument Line Slope Tolerance. , I-E-ININ-063-DR2, 04/05/86, Instrument Line Colce Code Marking.
I-E-ININ-071-DR1, 12/03/85, Instrument Horizontal Location Tolerance.
I-E-ININ-073-DR1, 04/03/86, Instrument Line Color Code Marking. ,
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I-E-ININ-082-DR1, 04/xx/86, Instrument Line Reverse Slope. l I-E-ININ-082-DR2, 04/05/86, Instrument Line Color Code Marking Spacing. l I-E-ININ-082-DR3, 04/04/86, Instrument Horizontal Location Tolerance.
I-E-ININ-084-DR1, 12/03/85, Instrument Line Slope Tolerance.
I-E-ININ-093-DR1, 04/12/86, Instrument Line Color Code Marking. ; I-E-ININ-100-DR2, 04/04/86, Instrument Line Separation Distance.
1-E-ININ-111-DR3, 03/14/86, Instrument Connection Drawing Error.
I-E-ININ-111-DR7, 04/12/86, Instrument Line Color Code Marking.
CPSES I&C Safety Significance Evaluation rudit Report Author and Date: L. Stanley, Zytor, Inc., rev. O, 05-06-86 , HSB TES0001.DR1, page 4 - l
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Appendix B: I&C Documentation Safety Significance Evaluations Review d bd i Deviation Number Date Subject
---------------- -------- ----------------------------------------- l R-E-CABL-023-DR1, 04/03/86, Cable Raceway Pu11 card Engineer Initials. ;
R-E-CABL-035-DR2, 04/04/86, Cable Raceway Pu11 card Date Missing.
R-E-CABL-052-DR1, 04/05/86, Cable Raceway Pu11 card Date Missing. ) R-E-CABL-055-DR2, 04/12/86, Cable Raceway Pu11 card Premature Signoff.
R-E-CABL-063-DR1, 04/15/86, Cable Raceway Pu11 card Not Re-signed. < R-E-CATY-125-DR1, 03/26/86, Cable Tray Welder Qualification Records. i R-E-CATY-282-DR1, 04/02/86, Cable . Tray Welding Inspection Documentation.
R-E-NIST-016-DR1, 04/xx/86, Cable Connector Installation Sequence.
R-E-NIST-027-DR1, 04/12/86, Cable Connector Inspection Report Blanks. j l l '
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j l CPSES I&C Safety Significance Evaluation Audit Report Author and Dates L. Stanley, Zytor, Inc., rev. O, 05-06-86 HSB TES0001.DR1, page 5
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