ML20074A078

Forwards Electrical Drafting Std EDSB-126 Revised on 791005, Pages 2-43 Through 2-48 of Electrical Installation Spec H-2173 & Pages 8.3-29,8.3-30 & 8.3-65 of Fsar,Per Request Re Tray Loading Criteria.Related Info Encl

ML20074A078
Person / Time
Site:	Zimmer
Issue date:	02/18/1981
From:	Cotta R SARGENT & LUNDY, INC.
To:	Barrett P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20074A076	List: ML20074A078
References
FOIA-82-206 NUDOCS 8305120074
Download: ML20074A078 (36)

Text

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SARGENT O LUNDY E N G,1 N E E R S S S C A S T M O N FeO E ST R L E T CHIC AGO 8LLINOIS 60603 TELEPHONE 312-269-2000 February 18, 1981 Project No. 4130-00 The Cincinnati Gas & Electr;ic Company Wm. H.

Zimmer Nuclear Power Station-Unit 1 Cable Tray Loading Desigh Griteria U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attn:

Mr. Paul Barrett Gentlemen:

En clos ed, please find a copy of Sargent & Lundy's Electrical Drafting Standard, EDSB-126, Rev. 10/5/79; pages 2-43 through 2-48 of Sargent & Lundy's Electrical Installation Specification H-2173; and pages 8.3-29, 8.3-30 and 8.3-65 of the Wm. H. Zimmer FSAR.

The above documents are being sent to you at your request to aid the Region III office in understanding the tray loading criteria and the meaning of design index numbers.

The basic design index of 1.00 means that the cables assigned to that particular review-ing point tray section gives a fill, if stacked diametrically, which will equal 40% of the depth of the tray.

In reality, a 40%

fill of the cross-section area of the tray is, in fact, a design index of 1.25, as the computer program works on a diameter squared basis rather than a pi x r2 on a cross-section of the cable.

Therefore, to stay within the maximum fill of 50% as noted in Section 8. 3. 3.1.3 of the FSAR, we keep all power trays below a design index of 1.5625 which meets this criteria.

In extrene cases, instrument trays or controlled cable trays are allowed to fill to 60% as noted in the FSAR, however, this would be a design l

index of 1.875 and we do not have any tray sections approaching I

this quantity of fill.

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8305120074 830321 PDR FOIA DEVINE82-206 PDR

I SARGENT O LUNbY EN GIN EEDO CHIC &G3 U.. S. Nuclear Regulatory Commission February 18, 1981 Attn:

Mr. Paul Barrett Page 2 Theoretically, it would be possible with a regimented lay to fill a tray to'h design index of 2.5 and still bo below the top of the tray.

This is not a good practice, however, particularly in the case of power cables as a reghnented lay concentrates the cables and does not allow the air movement through the cable groupings as a random lay will.

If you have any further questions regarding the above, please do not hesitate in contacting me.

Yours very truly,

% L COTfA R. E. Cotta Senior Electrical Project Engineer REC:wg In duplicate Enclosures Copies:

E. A. Borgmann (3)

J. D. Fl?nn (1)

RFS/R. J. Pruski (1)

L. J. Szumski (1) r t

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QUAllTY ASSURANCE SARGETIT&LUIJDY PROCEDURE GQ 3.o5

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PROCEDURE

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Title:

SAFETY ANALYSIS REPORTS (PSAR's AND FSAR's)

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SARGEUT.dUHDY PROCEDURE GQ-3.05

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PROCEDURE U

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SAFET ANALYSIS REPORTS (PSAR's h'ND FS Ik's)'

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,..... -.................,...-,.-.7 3l...This procedure describes the quality assurance requirements for the pre release of those chapters / sections of the safety analysis report, both. preliminary and

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2.0 DEFIN!TIONS

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2.1 See the Glossary for the following definition:

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Commentor

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Responsible Engineer - A person responsible for one or more of the following

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Preparation of input for and resolution of comments on a sec'ti of a safety W

analysis report.

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. Revising, when requir m

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3.0 PREPARATION, COMMENT AND RELEASE

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3 External Division of Responsibility a

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A.1 The Project Manager shall initiate the preparati.on of S&L's portion of the safety

-- ---. analysis report by directing the Licensing Project Engineer to prepare the 3l external division of responsibility...-..-..--..!...........

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3l The external d'ivision of' responsibility is a listing of the chapters / sections of the

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responsibility for the preparation of each chapter /section.

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3l A.2 The Licensing Project Engineer shall prepare an external division of responsibility L

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. of the chapters / sections of the safety analysis report and shall designate the organization (Client, S&L, Vendor, etc.) that is responsible for the preparation of 3l each chapter /section of the safety analysis report.

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A.3 Each page.of the external division of responsibility shall have, as a minimum, the R

following information:

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Document identification 3

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. Project identification 4

Revision identification (The fint page shall also include the revision date)

Page identification Identification of the final or total number of pages in the document l

Page 2 of 7 1

GENERAL QUALITY ASSURANCE.

SARGEflTidVTlDY PROCEDURE GQ-3 M

<~=,~m PROCEDURE REv.3

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DESIGN CRITERIA

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2.0 DEFINITIONS

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Preparer j

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A.! If the preparation of design criteria involves more than one department, the

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Project Director or Project Manager shall desginate which department shall have

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primary responsibility for the preparation, review and approval of the design criteria.

.The Project Manager shall schedule the preparation of design criteria per the.

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project design criteria status report (see QA Procedure GQ-3.12).

a A.3 The Project Manager or Senior Project Engineer or Project Engineer or Division Head shall assign a preparer and reviewer for each design criteria.

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The Preparer shall prepare the design criteria based on the effective issues of

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applicable regulations, codes, S&L and industry standards and other input supplied by the interfacing departments, as required. Figure 3.0.B.I may be used for the g

outline in preparing the design criteria.

m Applicable " design inputs or requirements, such as design bases, regulatory 9

requirements, codes and standards, used for the development of the design

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criteria, shall be referenced in the design criteria.

Codes, standards and 8

regulatory requirements referenced shall include the. applicable issue and/or

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Any applicable regulatory requirements or design bases as specified in the license application (PSAR) at the time a design criteria is prepared or revised shall be incorporated into the design criteria.

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The fo!!owing information shall a' pear on the first page of all design criteria:

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~.o, GENERAL

....m OljdLITY ASSURANCE SARGEilT& LUf!DY PROCEDURE GQ-3.15 O.'

PROC $ DURE E.

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nPPROVED PROCEDURAL DEVIATIONS

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GENERAL

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..QUAllT( ASSURANCE 2.:

SARGENT&l. UNDY PROCEDURE GQ 3.15 G PEGIN3 t! A

- PROCEDURE

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APPROVED PROCEDURAL DEVIATIONS

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. This procedure describes the quality assurance requirements for the identification and approval of a deviation from the requirements of an S&L quality assurance procedure or.

.;. project instruction on a project...

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..su-2.1 App' roved Procedural Deviation - A deviation from the specific requirements of an 1,,

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. S&L quality assurance procedure or project instruction which 1); meets the Y

f:. '... requirements of the S&L Quality Assurance Program, 2) adequately specifies all,'

. i quality procedural requirements and 3) has been approved by authorized project M...'.r..... and quality assurance personnel. Unapproved procedural deviations are noncon-Od; formances.

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3.0 IDENTIFICATION AND APPROVAL u

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To initiate the request for approval of.M 3

A.1 Requestor shall complete the following'ei'tYm, proposed procedural deviation, the Q

s on Form GQ-3.15.1, Procedural Deviation:

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A description of the proposed procedural deviation, including the rea, sons for, the deviation

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' List the documents affected by the deviation

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The S&L quality assurance pr'ocedure or project instruction and the quality t 9 assurance requirements tha

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8 Form GQ-3.15.2 shall be used if additional space is required for.the descrip' tion of.'

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' the deviation.

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., The Requestor shall sign Form GQ-3.15.1 and forward it to the Project Manager.

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GENERAL Q'UAliW ASSdRAN'CE T SARGEfjTELUilDY PROCEDURE GQ-3.is

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c 1 A.2 The' Project Manager shall review the proposed procedural deviation to determine

v '"?.'.?.'~. whether or not the deviation is required and to consider the affect the ' deviation

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^?3' 'will have on th' conduct of the project. Any comments shall be resolved with the e

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After reviewing the proposed procedural deviation, the Project Manager shall determine which Senior Project Engineers are affected by the deviation. if the Electrical or Structural engineering disciplines are not affected by the deviation

~ the. Project Manager shall insert the words "not applicable" -(N/A) in the 1

appropriate Reviewed by space on Form CQ-3.15.1. The Project Manager shall forward copies of the proposed procedural deviation,iRC?

to those Senior Project Engineers affected by the deviation.

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The Senior Electrical Project Engineer and/or the Senior Structural Projec't 5'-

Engineer shall each review the proposed procedural deviation for its adequacy and acceptability within his area of responsibility and forward comments to the Project Manager.

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1 B.2' The Project Manager shall ' resolve the comm'ents with th appropria'te Senio'r' Project Engineer and shall forward the procedural deviation form to the Quality.

Assurance Coordinator.

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B.3 The Quality Assurance Coordinator shall review the; escription of the proposed procedural deviation to assure that it does nqtyg'u.riflict with the S&L Quality o

Assurance Program and to determine that thej'g ality assurance requirements specified are adequate. The procedural devidion shall not diminish the integrity

, O o'f the S&L Quality Assurance Program.

1. {Eomments shall be forwarded to the Project Manager.

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B.4 The Project Manager shall resolvgt e comments with the Quality Assurance Coordinator and redraft the descridtlio'n of the procedural deviation accordingly.

If the content is altered, the Senior Project Engineers shall review the redraf t.

-i ---. With all comments resolved, the Project Manager shall forward the master of the procedural deviation to the Senior Project. Engineers and the Quality

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Assurance Coordinator.

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1 l d.1 The Senior Electrical Project Engineer, and/or Senior Structural Project Engineer n

, y and Quality Assurance Coordinator shall sign the procedural deviation as re-g

..... l.', viewers and return it to the. Project Manager.

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.C.2 ' The Project' Manager shall assign a number to the procedural deviation, sign as' l

approver and distribute copies to the individuals involved in the activities covered by the deviation, including the Quality Assurance Coordinator. At the time of 6

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. distribution, a copy of the approved procedural deviation shall be forwarded to the

',, Quality. Assurance Records Section for microfilming in accordance with QA Procedure GQ-17.02.

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GENERAL

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QUALITY ASSURANCE SARGEitT& LUTlDY PROCEDURE GQ-3.15 1E N GIN e ttsa ts REV.1 PROCEDURE

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The Project Manager shall maintain a record of all deviations issued for the project. This record shall include the deviation number and the quality assurance procedure or project instruction involved for each deviation. Each page of the record shall be identified by a page number, with at least the first page also identified by the project name and number.

~ i 4.0 REVISION s.

s Not app'licable.

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S&L QA Program, Section 03.

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NRC's 10CFR50 - Appendix B.

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NRC's Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of

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Nuclear Power Plants."

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1l ANSI /ASME N45.2 " Quality Assurance Program Requiremer.ts for Nuclear Facilities."

ANSI N45.2.ll, " Quality ' Assurance Requirements for' the Design of Nuclear Power

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' 6.0' ' FLOW CHART

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,,. Figur.: 6.0 is the flow chart ior Approved, Procedural Deviations.

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GENERAL QUAUTY ASSURANCE l SARGENT4tUNDiPROCEDURE C0-2.15 PROCEDURE REtl. I h

Aequest Approval for Proposed OUTPUT DOCUMDITS RFQUTRED Procedural Devaatton by a

corpleting Form co-3.15.1 10.T FORM NO.

TfffR W-3.15.1 A

(1.15.2)

Proposed Procedural Deviation

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@- 3.15.1 B

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Approved Procedural Deviation

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' Review to Determine if Proposed Deviation to Required & Determine which Senior Project engtaeers effected

'r e.1 noview and Comment on the Adequecy within their Area of Responalbility if p.2 assolve Comments PM LErl!tITIONSg 6f. s' o

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- Project Manager h'I" o**n Does "No"t Conf 11CE with A[/j[

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- Quality Assurance Coordinator

1. 1 Deviati QARS - Quality Aeourance Records Section n,e ca program and CA sequiremento y'[/

Are Adequate

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SEPE - Senior Electrical Project Engineer e

N SSPE - Senior Structural Project Engineer f*,,

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- of all Deviatione for the Project c.2 Sign as Approver, Maintain Record 8

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/ OAc. CARS 6 Including all other individuals affected by the devietton FIcuas 6.0 - FLOW ClfART FOR APPROVED PROCEDURA!. DEVIATIONS Page $ of 3 L

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SARGENT & LUNDY

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L to the extent. that either may perfom the required function Supp.4 regardless of the state of operation or failure of the other.

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Safety Class Structures.

Structures designed to protect Class lE equipment against the effects of the design basis events.

NOTE: For the purpose of this document, separate saf'ety class structures can be separate rooms in the same j

building.

The rooms' can share a com:ron vall.

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Separation Distance.

Space without interposing structures, equipment, or materials that could aid in the propagation-of fire or that could disable the Class lE system.

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General Separation Criteria:

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Methods of Separation: The separation of circuits and equip-

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ment shall be achieved by safety class structures, distance, or barriers, or any combination thereof.

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Compatibility With Mechanical System:

The separation of Class I

lE circuits and equipment shall be such that the required independence will not be compromised by the failure of mechanical systems served by the Class lE systems.

For

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example, Class lE circuits shall be routed or protected such j

that failure of related mechanical equipment of one redundant

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system cannot disable Class 1E circuits or equipment essential to the operation of the other redundant system (s).

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Specific Separation Criteria:

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Non-Missile Areas:

The minimum separation distance between 3

redundant Class 1E cabic trays or between Class lE trays and Class lE conduits of a redundant division, shall be 3 feet

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horizontally and 5 feet vertically.

Conduits assigned to N

different Clacs lE divisions may have a minimum separation of 1 inch.

Conduits of two different safety divisions may not N

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occupy a common hanger. Where separation cannot be maintained, Constructor may proceed with work but must notify Sargent &

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Lundy of the actual clearances involved for required design action.

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SARGENT & LUNDY C N G lN C C R S.

cmeAce H-2173 Supp. 7. 01-12-81 C

s Channelized RPS (orange) circuits are essential but are not Engi-Suppc neered Safety Feat.ure cables.

Conduits containing sensor channel Al/B1 cables should not be supported on a common hanger with con-duits containing sensor channel A2/B2 cables.

Conduits containing cables of the four actuation groups G1, C2, G3 and G4 (to Hydraulic modules) may be commonly supported.

" Orange" raceway may be sup-ported by a common hanger with Yellow, Blue or Green divisional

raceway, dl.1 In general plant areas where the 3 f t. horizontal and 5 f t.

vertical Supp.i separation between redundant divisional trays, or conduit and trays cannot be cet, qualified fire barriers shall be installed.

Husky Products, Inc. have developed two piece panels with intumescent material as described and tested per Husky Products Engineering Report No. 77-7-FP-1, certified August 22, 1977.

These panels or tray covers are acceptable as fire barriers as defined in 202.33bl.

When barriers are required due to insufficient space separation, tray covers on the lower tray are acceptable as fire barriers.

In,

cases of crossovers, these tray covers should extend 18 inches either side of the extremities of the upper tray.

dl.2 C

Where redundant division conduit cross parallel to or below a cable tray, one (1) inch air space provides acceptable separation. Where conduits cross above the tray, a single ventilated baf fle protective cover, Husky Products, Inc. qualified in test report, 77-7-FP-1, applies provided:

dl.2.1 The air space between cover and conduit is at least on'e (1) inch.

dl.2.2 The tray cover extends at least 18 inches beyond the conduit.

dl.3 Locations and sizes of fire barriers will'be indicated on a series of electrical cable tray drawings which will have an FB suffix.

This work will be done at such time that basic issue of EI drawings is co:plete.

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Missile Area:

Redundant Class 1E conduits and cable trays Supp.5 shall have a minimum separation of 20 feet.

Where this separation cannot be maintained, Constructor may proceed Supp.4 with work, keeping the maximum separation possible, but must notify Sargent & Lundy of the actual clearances involved for required design action.

d3.

High Energy Pipe Areas: High energy pipe lines are those lines which have an operating pressure exceeding 275 psi for more than 1 percent of plant operation.

Redundant Class lE conduits and/or cable trays shall have a minimum separation of 20 feet when one is less than 20 feet from a high energy pipe.

Class 1E conduits or cable trays shall maintain a minimum separation of 20 feet to high ene.rgy pipes which are in piping systems in divisions redundant to the conduits or cable trays.

The 20 feet separation does not apply to pipe and conduit or tray of the same division.

Where 20 feet separation cannot be main-tained, Constructor may proceed with work, keeping the maximum separation possible, but must notify Sargent. & Lundy of the distances involved for r-auired design action.

d4.

Fire Hazard Areas: Redundant Class 1E circuits shall'not be routed through fire hazard areas.

If this type of routing

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cannot be avoided, only one of the two redundant circuits may be run in conduit through this area.

d5.

Special Circumstances:

Any special circumstances not ecvered by the above descriptions or not indicated on the electrical conduit drawings shall be brought to the attention of the Consultant Engineer for resolution.

e.

Segregation Codes:

The following coding system has been established to identify cables, and the raceways with which they are associated, for separation purposes.

el.

Cable Tray and Conduit Segregation Codes:

Power Control Inst.

Engineered (ESF Yellow lYP lYC

~ - lYK s s, Safety Features (ESF Blue IBP 1BC 1BK.

(ESF)

(ESF Green-ICP 1GC IGK Non-Essential Tray White IWP lWC lWK

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Non-Essential White NSP NSC NSK

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SARGENT & LUNDY cNGINEcRS H-2173

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SUPP 4-Power Control Inst.

Reactor' (RPS Channel Al AlC AIK A2C A2K Protection (RPS Channel A2 System (RPS Channel B1 BlC BlK

. Inputs (RPS Channel B2 B2C B2K Reactor (RPS Group G1 GlC Protection (RPS Group G2 G2C System (RPS Group G3 G3C Outputs (RPS Group G4 G4C Reactor (RPS Trip Logics Al&A2 NAK Protection (RPS Trip Logics Al&B1 NBK s

System (RPS Trip Logics A2&B2 NCK NDK Trip Logics (RPS Trip Logics Bl&B2 e2.

Cable Segregation Codes:

ESF and RPS Cables Identical to ESF6RPS Tray Codes Above C.

Non-Essential Cables in Non-Essential Trays Identical to Non-Ess. Tray Codes Above Non-Essential Cables in ESF Yellow Trays llP llc llK Non-Essential Cables in ESF Blue Trays 12P 12C 12K Non-Essential Cables in ESF Green Trays 13P-13C 13K Non-Essential Cables in Non-Ess.

Junction Boxes but no trays NSP NSC NSK ESF and RPS Cables shall be run in their own trays or conduits only.

A Non-Essential Cable may be run in Non-Essential or ESF Trays, but shal?

not occupy more than one ESF division tray system.

'N i

l

'NS - No Seg. check made by CIS3.

Non-Essential Cables not in any tray.

' s(NOTE:

This is not a division, but an identification for computer programming convenience.)

e3.

Segregation Check Truth Table:

Segregation check determines whether the cable segregation code is identical to the tray segregation code or should. 3 follow the following truth table:

Tray Codes 1YP 1BP ICP lYC IBC 1GC lYK 1BK l jK NSP NSC NSK Cable Codes

(:;

llP 1

0 0

0 0

0 0

0 0

1 0

0 12P O

1 0

0 0

0 0

0 0

1 0

0

\\

b IO 2-46 Supp.7

S ARGENT & LUNDY 11-2173 ENGINEERS Supp. 7, 01-12-81 c mc ac.o Supp.!

N' P NSC NSK S

o a 1YP 1BP_

1CP 1YC IBC 1GC 1YK 1BK 1CK Cable Codes 13P O

O 1

0' O

O O

O O

1 0

0 11C 0

0 0

1 0

0 0

0 0

0 1

0 12C 0

0 0

0 1

0 0

0 0

0 1

0 13C 0

0 0

0 0

1 0

0 0

0 1

0 11K 0

0 0

0 0

0 1

0 0

0 0

1 12K 0

0 0

0 0

0 0

1 0

0 0

1 13K 0

0 0

0 0

0 0

0 1

0 0

1 1WP 0

0 0

0

'O O

O O

O 1

0 0

1WC 0

0 0

0 0

O O

O O

O 1

0 1WK 0

0 0

0 0

0 0

0 0

0 0

l

Supp.

2222 u u u 4 O O O O C.

y o o o s a s s

- N m *

< < m m o o o O A1 (C or K)

X X

Input A2 (C or K)

X X

Circuits B1 (C cr K)

X X

B2 (C or K) x X

G1C Output C2C Circuits G3C G4C RPS Circuits (x = may be run in same enclosure) s s

RPS field cables may be bundled with related Note:

ESF cables within panels

,f

,~

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s 2-47 i

,c

e SARGENT & LUNDY

=

ENGINEERo H-2173 i

Supp. 7, 01-12-81 C

Supp.6 Essential locally mounted safety related instruments installed by the electrical contractor shall be provided with color coded plastic tags identifying the separation division of the instrument.

The separation divisions for the safety related instruments are shown on the Piping and Instrumentation Diagram (P61D) and the Control and Instrumentation Detail (C&ID) : drawings and should be the same as that of the cable (s) associated with an instrument.

The color code for the tags shall be as follows:

~ ~.,

Separation Tag Tag Division Color Inscription N

ESS-1 Yellow ESS-2 Blue ESS-3 Green RPS-Al Orange Al*

RPS-A2 Orange A2*

RPS-B1 Orange Bl*

RPS-B2 Orange B2*

• Black characters on orange field.

Tags shall be 1-7/16" X 2-1/8" in size.

The alpha-numeric identifica-tion number of the instrument will be embossed on the tag with 3/16" high black characters.

Tags will be secured to instruments with nylon

-\\

cable ties in such a manner that the tag will remain with the instru-

' ment if the instrument is removed from its installed location.

N e

7

=

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s 2-48 Supp.7 l0' 5

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Project No. 4130-00 The Cincinnati Gas & Electric Company Wm.

H. Zimmer Nuclear Powcr Station-Unit I l

l l

Cable Tray Loading Design Criteria l

U.

S. Nuclear Regulatory Commission 79 Roosevelt Road i

d G cn Ellyn, Ellinois 60137 V

ttn:

Mr. Paul Barrett u

I Gentlemen:

Enclosed, pleasc find a copy of Sargent & Lundy's Electrical Draf ting Standard, EDSB-126, Rev. 10/5/79; pages 2-43 through g

2-48 of Sargen t & Lundy 's Electrical Installation Specification H-2 L 7 3 ; and pages 8.3-29, 8. 3-30 and 8. 3-65 of the Wm. H.

Zimmer N

FSAR.

c ')

The above documents are being sent to you at your request to aid the Region III of fice in understanding the tray loading critoria g

\\

and the meaning of design index numbers.

The basic design index 4

hof1.00means that the cabics assion ing point tray section gives a fili,ed to that particular review-

/1 -

if stacked dianctrically, which will equal 40% of the depth of the tray.

In reality, a 401 fill of the cross-section area of the tray is, s

in fact, a design

\\

index of 1.25, as the computer program works on a diameter squared basis l

rather than a pi x r2 on a cross-section of the cabic.

I g'

Therefore, to stay within the maximum fill of 50t as noted in Section 8. 3. 3.1. 3 of the FSAR, design index of 1.5625 which meetswe keep all power trays below a this criteria.

In extreme cases, ins trumen t trays oricontrolled cable trays are allowed to fill to 60% as noted in the FSAR, however, this would be a design index of 1.875 and we do not have any tray sections approaching this quantity of fill.

.2 19Ni e

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4 y,

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.u rtII a tray to a cessyn anarx.n

.r. 2 men

.s...

v top of the tray.

This is not a good practice, however, particularly in the case of power cables as a regimented lay concentrates the cables and does not allow the air movement through the cable groupings as a random lay will.

If you have any further (fucstions regarding the above, please do not hesitate in con tac ting' me.

.v, o

.:3.e 2.M,

Yours very truly,

-i.-

.ls '..

a

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,,-fc' ft..? O

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R.

E. Cotta Senior Electrical Project Engineer REC:wg In duplicate

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E.

A.

Borgmann (3)

J.

D. Flynn (1)

RTS/R.

J.

Pruski (1)

L.

J. Szumski (l}

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' 1X 3330 SECTION !!!, APPENDIX IX IX.3334.5(a)

IX-3330 TECIINIQUE FOR RADIOGRAPlilC Table IX 3325.1 or IX-3325.2 shall be placed on EXAMINAT,10N OF WELDED the side nearest the radiation source. Where it is JOINTS impractical to do this, a film-side penetrameter shall be placed on the film side of thqjoint, its thickness y

IX 3331 Preparation of Weld Surfaces shall conform to Table IX-3325'.! and a lead letter

..g., at least as high as the identification numbers Welds to be radiographed shall have the weld lP aced adjacent to the penetrameter.

ripples or weld surface irregularities, on both the inside and outside, removed by any suitable mechamcal process to such a degree that the resultmg IX 3334.3 Number of Penetrameters to be Used.

radiographic image due to any irregularities cannot Except as required in IX-3334.5(b). one penetrameter mask or be confused with the image of any shall be used for each exposure, to be placed so that unacceptable discontmuity.

the plane of the penetranieter is normal to the radiation beam. Each perietrameter shall represent an area of essentially uniform radiographic density IX-3332 Required Sensitisity of Radiographic as judged by density comparison strips. or a Technique densitometer. If the film density through the Radio.c. rap ) shall be Performed with a technique diagnostic area varies by more than minus 15 or h

which will have sufficient sensitivity to mdicate the plus 30 percent from the density throuch the

~

features in IX-3334.5 of a penetrameter of the penetrameter, then an additional penetrameter is thickness specified for the thickness of the weld required for the exceptional area or areas. If the being examined as shown in Table IX-3325-1 or requirements of IX 3334.5 are met by two g

IX-3325-2.

melud/

weld reinfortem2r7f penetrameters, one penetrameter appearing in the lichtes: area of a film and the other in the darkest,

• Mr sh US d4cMr.

th'e intervening densities on the film shall be

~

considered acceptable. Ity.not nece,ssary.that th_ese Diameter Butt Welds additional penetrameters be normal to the radiation

{

IX 3333 Radiographic Technique for Small.

source at their locations. The film. den _sig_through In the case of small-diameter butt welds, such the weld metal shall be 2.0 minimum for single as nozzle attachments, piping and appurtenances, viewing, ahd 2.6'rsinimum'for composite viewing of where the source is on the outside and the film is on double film exposures, e,a,ch filmalaxomposite set the opposite outside surface, only that portion of the to have a minimum density of 1.3 weld adjacent to the film and readable on the film 3

shall be considered to have been examined and the X-3334.4 Placement of Penetra meters. The penetrameter thic.kness shall be based on the single-penetrameter shall be placed adjacent to the weld wall thicknessyingle wall radiography shall be used

. seam except in instances when the weld metalis not when practicalNncNdinj vA 8 reinhet. men'tradiographically similar to the base material or the G5 &Lnec/ in IUS-4h. geometric configuration makes it impractical, in IX-3334 Use of Penetrameters to Check which case. the penetrameter may be placed over Radiographic Tecimique the weld metal. The shim thickness shall be selected so that the total thickness beine radiocraphed under As a check on the radiocraphic techm.que employed, penetrameters. as herein descrRed. shall the penetrameter is the same as the total weld be used as stipulated in the following subparacraphs thickness. and backing strip if used and not removed.

to determine whether the requirements are being met.

gA IX 3334.5 Images Which Shall.\\ppear on Radiographs.

IX 3334.1 Eialuation of Radiographie Quality. The radiocraphic quality shall be evaluated by the image (a) Except as permitted in IX-3335.3 and in Tab.le of a properly located penetrameter IX-3325.2 the imaces of the identifying numbers. the v

penetrameter outline a'nd of the 2T hole are all essential indexes of imace quality on the radiograph, IX-3334.2 location of Penett.imeter. A standard and they shall appear on the radiograph: escept that source side penetrameter of the thickness shown in for penetrameters 5,7. and 10. either the 2T hole or 520

l k.

i

)

_h t)

J

,% f-:g ra ryg ra n g r:w-usx.a 9.isn p:

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r,="'N n @ F".

u U L. c a# u n u u b( Fi =

i

%'e u u u d umwg u TO:

MR. A.E. ROTHENBERG DATE:

August 26, 1973 FROM:

E.C. PANDORF

SUBJECT:

WM. H. ZIIFER NUCLEAR POWER STATION QUALITY ASSURANCE AUDIT W.O.

57300-957, JOB E-55c0 Attached is a i epo:t of a Quality Assurance Audit at M.W. Kenogg Company, Willia sport, Pennsyliania plant on August 13, 1973 by I'r. W.W. Schwiers.

i This audit was performed to evaluate the Quality Assurance program of M.W. Kellogg as a vendor of essential components on Phase II Piping.

In compliance with AEC requirements, this report is to be reviewed and initialed by persons having responsi-bility in the area being audited.

Please review this report, initial the report, and forward to the next recipient.

The completely initialed report will be returned to the QA&S Section and retained in the Quality Assurance Records.

L<b$te i

A7Th NOTth ECP:dsb

/

,q c(

7g--

3 Enclosure r

' " O d"5Er -

JDFj_]Q_,l cc:

KEI - Site Document Center C '\\ 'V L.fh.

H ct%.Y'{" %"

• 4 6 m P. l t.M..

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k t.i.t.t.a_ P_., __o_._

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THE CINCINNATI GAS & ELECTRIC COMPANY The Union Ught, Heat and Power Company

U U

August 17, 1973

Subject:

Phase II Piping Fabrication Quality Assurance Audit of M. W Kellogg Williamsport, Pennsylvania On August 15 and 16, a Quality Assurance Audit of the Williamsport, Pennsylvania facilities of M. W.

Kellogg was conducted.

The purpose of this audit was to assure that the implementation of their Quality Control Program was consistent with the manual sub-mitted by M.

W.

Kellogg.

Prio; to conducting this audit, the Quality Assurance Program o~f M. W. Kellogg was reviewed by Cincinnati Gas & Electric and also the Quality Control group of Sargent & Lundy.

Various comments were generated by the two organiza:icns and a le::er was submitted to Kellogg for clarification.

There were five items under consideration and Kelloze answered these cuestions to the satisfaction of both CG&E an'd' &L.

If future revisions are necessary to comply with AEC requirements, M. W. Kellogg has indicated that they will supplement their program to our satisfaction.

The Quality Assurance Manual submitted by Kellogg was basically generated to comply with Section #3 of the ASME code.

In order to comply with 10CFR50, individual supplements to the manual are prepared in accord-ance with requirements for each project site and request from the subject licensee.

Attached is a check list titled, " Evaluation of Vendor Quality Assurance Program".

The check list is generally self-explanatory, however, there are individual items which require clarification.

Item #2-7, concerning the Quality Control Procedures, should be clarified to indicate that there is a program specific to ASME, Section #3 and a separate. Quality Control Program which is appli-cable to Section 1 and Section 8.

The Section #3 program will include those supplements to the manual required by regulatory or owner requests.

Items #8-5 and #8-6, concerning Acceptance Processing and Withholding Stamps, is not applicable since a tagging system is used rather than a stamp system.

Item #10-3, concerning In-Process Inspections, is implemented by the use of a Shop Traveler.

The shop traveler is always reviewed by the Quality Assurance Group prior to its implementation.

Item # 17-4 and 17-5, concerns Documentation, and Kellogg was agreeable to supply documentation in accordance with our requirements.

If this docu-mentation, reference in these two items concerns material that they receive, the documentation is always available upon receipt of the item shipped.

MTN_ jj[

The internal audits performed by M. W.

Kellogg of their own AOI - Ib-Quality Assurance Program were reviewed.

The audits reflected 3~ H 0/ IG-that there were certain deficlencies and corrective action was 3 n c_

jf.._.

recommended.

In most cases, the c.orrective action was that the Quality Assurance Manual required it and therefore,. an appropriate g3p]@}CG letter was submitted to the division responsible for the deficiency.,.'tT m-One audit indicated that various shop travelers had not been "C

E1,T approved by Quality Assurance.

It was recommended that an item bc pm

. p" M U '."..".' '.

r. o c. 5

9 U

included in the inspection requirements, that no work will be started until an inspector verified that Quality Assurance had reviewed the shop trave'ler.

This required adding an additional check off.on the shop traveler and Kellogg agreed that this would eliminate the possibility of shop travelers being implemented without appropriate review.

The control of weld rod was reviewed and the procedure was properly implemented and included adequate controls.

During the review of the weld rod control, the acceptance and hcid tag procedures were also reviewed and were found to be adequately implemented.

In addition to the tagging procedure, a quarantine system was established which did not necessarily indicate that the material had been rejected, but that a deficiency existed which required disposition.'

The records on welders including approved procedures, qualifications and performance were reviewed with the plant weld engineer.

The records were neat, adequate and demonstrated good control of such items.

Individual performance records and requalification on a three month basis, when required, were included with this documentation.

Also, recorcs of calibration of all welding machines were reviewed.

During the tour of the plant facilities, various welding machines were reviewed to see if calibration labels were attached.

The calibration tag attached to each machine indicates only a date of calibration.

It was requested that evidence of the person performing the calibra-tion should also be included on the machine.

Kellogg's present procedure requires that for all other equipment and that which is sent to a foreign source for calibration, the person performing the calibration signs the record which is attached to the equip-ment.

Kellogg feels that their present procedure is adequate and they indicated that the AEC had previously accepted the procedure applied to welding and magna-flux machines.

The procedure for identifying materials received and trans-ferring the necessary information to smaller size pieces which are generated from the piece shipped was reviewed.

The purchase order issued for material purchased by M. W.

Kellogg requires that all material be marked with the purchase order and item number assigned by M. W. Kellogg.

The purchase order and item are stamped on each piece of equipment by the supplier and as smaller pieces are made, this purchase order number and item are transferred by M. W.

Kellogg to the subsequent piece.

Our project will be assigned a consecutive set, of purchase order numbers.

Documentation, which is of a repetitive nature, that is, a'pplies to more than one piece within several spool pieces will be sent,to us for review upon receipt of the material.

All documentation of stock type material will be filed by this same purchase order and item number.

If there is stock material purchased by M. W. Kellogg for more than one project it will reflect the purchase order and item number.

All documenta-I tion will reflect the purchase order number and item number, and h--

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can be filed by piece number if one of a kind or separately by purchase order number.

This system provides adequate means of tracing the documentation for all parts and components of a system.

As indicated cn the attached chec.'t sheet, there are crese..:1e approximately 350 total employees at the W.lliamsport plah.:.

Thih total includes Accounting, Management, Supervision, etc.

The total nunber of personnel assigned to Quality Assurance is approximately 30.

All inspection reports directly to Quality Assurance.

The mana:er of the Quality Assurance secticn has been tith M.

Kellogg approximately "O years, most of which time has been spen:

in Quality Control.

Two other Quality A'ssurance Ingineers ha te a combined service of 25 years.

These personnel dentnstra:ed a superior rating concerning the M. W. Kellogg Quality Assurance Program.

Their attitude was one of conscientious, with the realization that any of the deficiencies which could result within the program would be a direct reflection on themselves and the program which they have established and for which they are responsible.

In conclusion, M. W.

Kellogg has been audited by many other utilities and the AEC.

As a result of these audits, refinement of their procedures has resulted in a very acceptable program.

The audit conducted on the 15th and 16th of August similarly demonstrated the implementation of a satisfactory Quality Assurance program and it is recommended that their Quality Assurance Program be accepted relative to the award of the Phase II Piping Fabrication contract.

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Till" INCINNATI_ CAS & El.ECTitlC CdfVil'ANY EVAL.UATION OF VENDOlt OUALITY.ASTiUlaNCE Pl<OGl%M Veridor's Name M. W. Kellogg Co.

Report No.

Address Williamsport, Penn.

Report Date i

Date of Visit 8-15-73 Telephone 717-323-9291 Purchase Crder !! umber Ver. dor's Req. No.

Material er Iquipme.. of Ir.:eres: :o CG&E Co.

Phase, II Piping Tabrication 1

Ger. era 1 Ir.formstien

']

Management Level

Contact:

Title QA Manager W. J. Mitchell Iy Personnel Contacted:

Titles QA Engineer K. Morgan General Product Line:

Pipe Fabrication Distribution of Work:

Nuclear 70 %

Government Commercial 30 %

Total Number of Personnel in Quality Assurance:

30/34 6 Total,(Mg ' t. Acc ' t.etc.:

General Comments:

~

W. W. Schwiers

. Auditor's Name QA Engineer Title n.c-...

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y

'Yes No N/A Comment 1-1 A the Vendor's Quaff ty Control functio.:

fo'mally organized in accordance with X

ree:,,gnized procedures or applicuble Slo'er:1fications ?

l-2 De,,,3 the Quality Control organization ht. s X

suf ficient authority and ort.;anizational frHiom to l'!cntify quality, problems, to recom:.t-d or provide solutions and verify Impicmen nion of nolutions ?

1-3 Is the Quality Contro! crc.inization Independent of the individual or group directly respor.n-le X

for performing the specific acti.ity?

Reports to Plant Str.

2-1

'Is the Vendor's Quality Control manual cc apl:11 cable specifications approved and X

sulil)orted by management? VP Power Piping (T D Landale) 2-2 Givo date of manual and last revision.

X 7/25/72 2-3 Doos the Quality Control manual recognirs (a) 10Cl R50 Appendix B, f 8'QA Criteria ?

X (b) AshlC Boller 6 Pressure Vessel Code, Secan III?

X 2-4 Arc activities affecting quality accomplissad lX uncler controlled condition::?

2-5 Does the Inspection Organt$ation have authority to withhold accep:ance'of prodt:-ion X

itetus when quality is compromised?

2-6 Does the program consider special contrc:5, processes, test equipment. tcols and skins e X including proper training and qualification of 'orsonnel?

l 2-7 Are the quality control pro. idures implemen:ed throughout the manufacturing area ?

[X (Soct.III), (Sect. 1 a VIII) g 3-1 Aro measures established :' assure that I

appropriate quality standar.is are specified and included in design do.. norits and X

that deviations from such :,:andards are con rolled?

3-2 Is a system in effect to co'::rl customers I

X furnished drawings and sp. :fications ?

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Yes No N/A Comment B

3-3 Is the adequacy of design verified or X

j c.hecked by individuals or groups other than those who performe'd the original design?

QA approves all procedures 3-4 Arc design changes including field changes subject to design control measures commensurate with the original design?

X 3-5 Are ceasures established for the iden:ification and control of design interfaces and for coordination among participating design X

organinations including the review, approJal, release, distribution and revision of design documents ?

4-1 Are measures necessary to assure adequate quality, included or referenced in all procure-X ment documents when purchasing from subcontractors ?

QA approves all specifica-tions 4-2 Are subcontractors required to provide quality assurance programs consistent

~

X with 10C1'R50 App?endix B and ASME Code Section III as applicable 4-3 Is a procedure used to assure that subcontractors and suppliers have up-to-date drawings and X

specifications ?

5-1 Are activities affecting quality prescribed by documented instructions, procedures, X

or drawings, which include quantitative or qualitative acceptance criteria?

All specs., spool dwgs. reviewed by QA 5-2 Is inspection and shop planning reviewed against contract and specification requirements ?

5-3 Are detailed work instructions and procedures available at the work and inspection X

locations ?

5-4 Does Quality Control review and app, rove X

acceptance and test procedures against contractual compliance?

6-1 Are measures established to control issue of documents such as instructions, procedures X

and drawings including all revis' ions ?

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Yes No N/A Comment

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6-7 Are 'the proceduren reviewed for adequacy, 3

approved for release by authorized personnel X'

and distributed to and used at the location where the prescribed activity is performed ?

6-3 Arc inspection personnel promptly and properly notified of changes to drawings, specifications and purchase order requirements ?,

X 7-1 Are purchased materials, equipment and services verified to assure confermance to the procure-X ment documents ?

7-2 Are subcontracters selected based upon source evaluations which demonstrate objective X

evidence of quality in those products to be supplied ?

No expediting 7-3 Will documentary evidence that material and equipment conform to the procurement require-X ments be available upon delivery of such products ?

P.O.

& Item. for identification 7-4 Is quality controlled consistent with the importance, complexity and quantity of the X

product or services ?

7-5 Does receiving inspection check incoming shipments to the requirements of the purchase x

order, referenced specification and applicable drawings ?

7-6 Is material, when accepted on test reports

{

and/or specifications of conformance, subject X

to verification testing ?

7-7 Is an adequate source inspection conducted ?

X 8-1

• Are materials, parts, components and partially fabricated assemblies, identified and controlled?

X 8-2 Is the identification maintained by heat number, j

serial number, or other appropriate means, X

l either on the item or records traccable to the item, during fabrication? P.O. and Item No.

8-3 Does the vendor have a formal " Hold Area" X

for unaccepted material?

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Yes No N/A Comment 8-4 Does the vendor segregate material or articles X

waiting inspection or test results from those which already have been accepted or rejected?

8-5 Are acceptance, processing and withhold )

X stamps in use ?

)Tacging system 8-6 Are stamps controlled and traceable?

)used

)

X 9-1 Have measures been established,to assure that special processe.c, including welding, heat treeting, and non-destructive testing, X

are centrolled and accomplished by qualified personnel using procedures in accordance with applicable codes, stand'ards, specifications and other special requirements ?

9-2 Are special process procedures available at work stations?

X 9-3 Do records reflect items tested and procedures X

and operations used?

10-1 Has a program of inspection been established to assure those activities affecting quality X

conform to documented instructions, procedures and drawings ?

10-2 Are inspections performed by individuals X

other than those performing the activity?

10-3 Are in-process inspections preplanned with.

X check lists, so as to be compatible with manufacturing operations ?

Shop Traveler 10-4 Is design change incorporation verified as part of the final acceptance process ?

X 10-5 ' Are inspection findings immediately recorded ?

X 10-6 Arc specific hold points beyond which work x

may not proceed without consent of contractor indicated in appropriate documents 1,ssued to subcontractors?

10-7 Are rework procedures reviewed by Quality X

Control ?

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Yes No N/A Comment

.'10-8 Does final inspection assure that all contractual requirements have been satisfied X

before shipment?

11-1 Are test procedures written by responsible personnel? By whom?

OA 11-2 Are testing personnel qualified?

X 11-3 When outside test facilities must be used, are adequate instruction issued?

By Whom?

OA 11-4 Do test records reflect actual measurement X

values ?

12-1 Are procedures in effect to control tools, X

gages and test equipment?

12-2 Does the system provide for mandatory recalibration of all calibrated tools, gages'and X

test equipmerit?

12-3 Do calibration or inspbction records reflect:

a) Item identification number and name ?

X b) Frequency of calibration ~or inspection?

y c) Procedure for calibration or inspection?

X d) Date calibrated or inspected and date due x

for next calibration or inspection?

l e) Personnel performing calibration or inspection?

X Welding & Magna-Flux machine - not on f) sticker.Identit y of master used to perform calibration?

X Records - yes

' g) Deviations from standard values ?

X 12-4 Do Standards currently used for calibration have X

l cert:fication on file traceable to National Bureau of Standards ?

12-5 Arc calibration frequencies realistic and X

compatible with environments, use and purpose of th,e instruments ?

l 13-1 Is purchased material identified by stamp or tag to shc.t inspection status prior to X

release to production or stock?

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Yes No N/A Comment

' 13-2 Is a check list used to verify shipping requirements and documentation to be X

e.nclosed in the shipment?

13-3 Are written instructions covering packaging, X

packing, marking and shipping utilized by shipping or inspection personnel?

. 14-1 Are non-conforming items identified ?

X 14-2 Are parts, supplies, assemLies identified to indicate par-ial, in pregress er final X

acceptance?

15-1 Does the vender have a procedure for the control of non-conforming material?

X 15-2 Does engineering participate in evaluating requests for waivers promptly after a X

discrepancy is discovered ?

15-3 Do written procedures provide for:

a) Identification and segregation of non-conforming material from normal production?

X b) Review of repetitive discrepancies ?

X c) Periodic management reviews ?

X 15-4 Is Quality Control represented in the review X

of non-conforming products?

15-5 hre management reports on non-conforming X

products published and acted upon?

l 15-6 Is the customer consulted on reworked material?

x l

16-1

• Does the vendor maintain a corrective action t

X system?

16-2 hre defective products and rela ~ted data analyzed X

l to determine cause and extent of disgrepant i

condition?

16-3 Is inspection data collectod and analyzed t X

l establish quality Ic', cts in processes and.

l work performance?.

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Yes No N/A Comment 16 '4 Are corrective action rottuests issued to a-supplier when a quality problem exists ?

X 17-1 Are adequate records maintained in order to trace assembly and sub2 assembly parts back X

to a specific lot of raw material?

17-2 Are pr duct quality and processing records

• x stored ?

How long?

Varies with customer requirements 17-3 Are repairs documer.ted completely and available in Quality Control files ?

17-4 Is reques:ed documer.tation supplied when ship-X ment cf r..ateria1 is made ?

17-5 If reques:ed documentation is not supplied X

with shipment, is it to be supplied?

When?

17-6 Are inspection and tdst records maintained -

which, display:

a) Receiving inspection?

X b) In-process inspection?

X c) Special processes ?

,X d) Final assembly?

X X

e) Test inspection?

i 18-1 Does vendor audit his subcontractors?

X l

18-2 Does vendor perform internal audits ?

X

(

18-3 Are audit check lists used?

X 18-4 Are audit results documented ?

X 18-5

-Are audit results and audit programs X

reviewed by management?

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o SUMMATION Ol' COMMENhS Program has been industry accepted; however, basically for ASME Section III AEC requirements covered by supplements.

Implementation appears satisfactory.

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o Wm. W.

Schwiers Signed 9

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' GOVERNMENT ACCOUNTABILITY PROJECT lostitute for Policy Studies 1901 Que Street. N.W.. Washington. D.C. 20009 (202)234 9382 April 20, 1982 Director EREEDOM OF INFORMATlott Office of Administration ACI REQUEST Nuclear Regulatory Commission

[6((YMc2O Washington, D.C.

20555 ff,l f*N'lN To Whom It May Concern:

Pursuant to the Freedom of Information Act ("FOIA"), 5 USC 5552, we request the investigative file, including all drafts, memoranda, statements, affidavits, computer printouts, notes, telephone logs, diaries, or any other information connected with NRC IE Report No.

50-358/81-13.

The documents may be at Region III Nuclear Regulatory Commission ("NRC") Headquarters, the NRC Office of Inspector and Auditor ("OIA") headquarters, or retained in the personal or office files of IE and OIA investigators'who worked on the Zimmer case.

Although the Zimmer investigation is ongoing, Report No. 80-358/81-13 is for all intents and purposes a finished agency product which chould be open for public inspection, notwithstanding exemption #5 of the FOIA.

A document that is pre-decisional at the time of prepar-ation may lose exempt status if " adopted formally or informally, as the agency position on an issue or is used by the agency in its dealings with the public."

Coastal States v. Dept. of Energy 617 F.

2d. 854,866 (D.C. Cir. 1980).

Report No. 80-358/81-13 was used by the NRC as a basis for imposition of a $200,000 civil penalty against Cincinnati Gas & Electric ("CG&E"), as well as for~ the agency's decision to delegate to CG&E the responsibility of conducting an in-house reinspection entitled "The Quality Confirmation Program."

If the NRC can use the report to make-this final agency policy commitment in its dealings with the public and the utility, then clearly the report must be post-decisional in nature.

On March 18, 1982, Mr. Bert Davis, Region III Deputy Director, told me that priorities have yet-to be established for Part II of the investigation.

As a result, it is unfair to characterize the ongoing investigation as a mere continuation of work on the previous issues.

In order to comply with the provisions of the Privacy Act, we would consent to deleting the names of any parties whose names are mentioned in the appeals and whose right to privacy would be threatened through public disclosure.

We are requesting this information as part of a monitoring project on the adequacy of the Commission's efforts to protect puclic safety at nuclear power plants.

As a result, we request that fees be waived because " furnishing the information can be considered as primarily benefitting the general public."

5USC e 552 (a) (4) (A).

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Director, Office of Administration Nuclear Regulatory Commission April 20, 1982 Page TWo For any documents or portions of documents that you deny due to a specific exemption, please provide any index itemizing and describ-ing documents.or portions of documents withheld.

The index should provide a detailed justification of your grounds for claiming such exemption, explaining why each exemption is relevant to the document or portion withheld.

This index is required under Vaughn v. Rosen (I), 484 F.2d 820 (D.C.Cir. 1973), cert. denied, 415 U.S. 977 (1974).

We look forward to your reply within ten working days.

Sincer h

Tom Devine Legal D*r Rosenthal St ff Associate TD/jr a