Revision as of 12:06, 19 March 2021

Text

Response Team Results Repts
	ML20237L203
Person / Time
Site:	Comanche Peak
Issue date:	03/12/1987
From:	; TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	;
Shared Package
ML20237K807	List: IR 05000445/1985007; IR 05000445/1985014; IR 05000445/1986008; IR 05000446/1985011; ML20237K804; ML20237L110; ML20237L125; ML20237L136; ML20237L151; ML20237L159; ML20237L179; ML20237L203; ML20237L268; ML20237L272; ML20237L298; ML20237L321; ML20237L367; ML20237L407; ML20237L453; ML20237L464; ML20237L493; ML20237L577; ML20237L797; ML20238A290; ML20238A390; ML20238A485; ML20238A535; ML20238A548; ML20238A573; ML20238A583; ML20238A596; ML20238A609; ML20238A642; ML20238A654; ML20238A667; ML20238A719; ML20238A749; ML20238A782; ML20238A833; ML20238A839; ML20238A868; ML20238A883; ML20238A903; ML20238A923; ML20238A966; ML20238A974; ML20238B015; ML20238B131; ML20238B210; ML20238B251; ... further results
References
	PROC-870312-01, NUDOCS 8708200118
	Download: ML20237L203 (344)
	v • d • e

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l TEXAS UTILITIES GENERATING COMPANY l A DIVISION OF TEXAS UTILITIES ELECTRIC COMPANY "lRS286$88588sL3 G PDR

J f TABLE OF CONTENTS

J COLLECTIVE SIGNIFICANCE REPORT Later - l' COLLECTIVE EVALUATION REPORTS

                                               - Later -

RESULTS REPORTS Electrical I.a.3 Butt-Splice Qualification - Revision 1 1.a.4 Agreement Between Drawings and Field Terminations

                                                               - Revision 2 1.a.5         NCR's on Vendor Installed Amp Terminal Lugs
                                                               - Revision 1 1.b.3         Conduit to Cable Tray Separation - Revision 1 l                                                 Civil / Structural II.b          Concrete Compression Strength - Revision I Testina III.a.2       JTG Approval of Test Data - Revision 0 III.a.3       Technical Specification for Deferred Tests
                                                               - Revision 0 III.a.4       Traceability of Test Equipment - Revision 0 III.d         Preoperational Testing - Revision 1 Mechanical V.a           Inspection for Certain Types of Skewed Welds in NF Supports - Revision 1 V.c           Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings -

Revision 1 l V.e Installation of Main Steam Pipes - Revision 1

TABLE OF CONTENTS (cont.) 0A/0C I.d.2 Guidelines for Administr4 tion of QC Inspector Test Revision 1 I.d.3 Craft Personnel Training - Revision 1 VII.a.4 Audit Program and Auditor Qualification - Revision 1 VII.a.5 Periodic Review of QA Program - Revision 1 VII.a.6 Exit Interviews - Revision 1 VII.a.8 Fuel Pool Liner Documentation - Revision 1 VII.b.2 Valve Disassembly - Revision 1 DSAPs Later - l l

I.-

.t.

COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP I.a.3

Title:

Butt-Splice Qualification I Revision No. 4 Keflects Comments Descrir;tica On Plan , Prepared and . Recommended by: Review Team-Leader [M Date Approved by: Senior Review Team / % _y b,j Date i/2 4 /tt

Revision: 4 Page 1 of 6 j u ! ISAP I.a.3 Butt-Splice Qualification

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG 0798, Supplement ' l Number 7, Page J-28) 1 "The practice of butt-splicing cables in panels was allowed on a limited basis, as specified in Section 8.1.5.2.4 of Amendment 44 to the Final Safety Analysis Report (FSAR). The NRC staff reviewed Texas Utilities Electric Company's (TUEC's) justification for permitting butt-splices inside panels (correspondence from M. Srinivasan, NRC Power Systems Branch to B. J. Youngblood, NRC Licensing Branch, July 30, 1984), and concluded that the practice is acceptable on a limited basis, subject to the following' conditions:

              -     That adequate provisions be included in the installation procedures to verify operability of those circuits for which splices are being used,
              -     That the wire splices used are qualified fer anticipated service conditions, and
              -     That splices are staggered within the panel so that they are not adjacent to each other in the same wire bundle and pressing against one.another."

2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7. Item 6.(b), page J-31)

              "TUEC shall accomplish the following actions prior to fuel lead:

Develop adequate installation and inspection procedures to reinspect all existing butt-splices to ensure (1) the operability i of those circuits which contain butt-splices in panels, (2) that the wire splicing materials and methods used are qualified for anticipated service conditions, and (3) that splices are staggered within the panel so that they are not adjacent to each other in the same bundle."

3.0 BACKGROUND

In order to address the issues identified by the NRC, the following should be considered:

                      -     During plant preoperational and startup testing all electrical circuits are required to be tested end retested, if reworked, in accordance with Startup

1 4 Revision: 4 Page 2 of 6 l 4 I ISAP I.a.3 (Cont'd)

3.0 BACKGROUND

(Cont'd) i Administrative Procedures (SAP)-6 " Control of Work on Station Components After Release From Construction to ; TUGC0"; SAP-22 " Retest Control"; and XCP-EE8 " Control " Circuit Functional Testing". These tests provide the necessary verification that the spliced circuits are functional. FSAK amendment 44 was issued to encompass the use of I butt-splices in panels. The NRC's "The Safety Evaluation Of Field Splices Inside Control Panels", dated September 14, 1984, sets forth the NRC guidance that splices be staggered in panels. This additional guidance from the NRC will be used in the implementation of this action plan. 4.0 CPRT ACTION PLAN 4.1 Scope And Methodology The objectives of this action plan are to develop adequate procedures to assure that continuity ch?cks are made en all circuits in which splices are placed, and that splices are staggered or separated to comply with the additional NRC guidance. The objectives of this action plan also include the review of the qualification of the AMP Pre-Insulated Environ = ental Seal Splice to assure it is qualified for its expected service condition. The following tasks will be implemented to achieve the above objectives: Procedural revisions

                                       -        Additional craft and inspector training Inspection of cable bundles for touching splices 1

Review of qualification data )

R6 vision: 4 Page 3 of 6 ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.1 Procedure Revisions The following specific subtasks will be completed:

                                                            -      Revise Construction procedure EEI-8, " Class 1E and non-Class 1E Cable Terminations" to require a continuity check of all circuits in which splices are placed and to require that splices are staggered or separated to comply with the additional NRC guidance.
                                                            -      Inspection procedure QI-QP-11.3-28. " Class 1E Terminations" to add the attributes necessary to ensure that continuity checks are made and that splices are staggered or separated.

l 4.1 '. 2 Craft and Inspector Training The following subtasks will be implemented:

                                                            -      Train craft personnel using the revised l                                                                   procedures.
                                                            -      Train and certify inspectors.

4.1.3 Inspections In accordance with the requirements of Action Plan I.a.2 cable bundles containing splices will be inspected to ensure that no splice in a bundle is adjacent to and pressing upon another splice. Corrections to the configuration of the bundles will be made where splices are found to be adjacent to and l pressing upon one another. d 4.1.4 Qualification Data A qualification data package, based on vendor documentation and site specific requirements, will be developed for the butt-splices. A third-party l engineering review of the qualification data package will be conducted. If it is determined that the AMP insulated butt-splices are not qualified for the i Comanche Peak service conditions the butt-splices will 1 be replaced with qualified butt-splices.

o Revision: 4 Page 4 of 6-s ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.5 Use of Results l Results of the actions under this plan will be evaluated to establish root causes and to identify appropriate corrective action. 4.2 Participants Roles'and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope. 4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Revise construction and inspection procedures. Retrain craft and inspection personnel. 4.2.1.2 Process NCRs that may be generated due to this action plan. 4.2.1.3 Prepare qualification data package. 4.2.1.4 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Review the revised inspection and construction procedures to assure that the requirements for a continuity check and staggered splices are included. 4.2.2.2 Review of training documentation to ensure that adequate retraining of craft and inspection personnel was performed. 4.2.2.3 Review the NCRs and Inspection Reports, if any. 4.2.2.4 Determine root cause, generic implications and safety significance. 4.2.2.5 Personnel (prior to October 18, 1985) Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator

r, Revision: 4 Page. 5 of.6

    '4 ,

ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.6 Personnel (starting October 18, 1985) Mr. J. J. Ma11anda, Revietw Team Leader Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Inspect cables containing but't-splices for compliance with acceptance-critetia. 4.2.3.2 Personnel Mr. J. L. Hansel, Review Team Leader - QA/QC 4.2.4 Third-Party Adviser . 4.2.4.1 Review the qualification data package to ensure that the splices are qualified for the Comanche Peak service conditions. 4.2.4.2 Personnel Mr. L. D. Bates, Electrical Engineering Adviser 4.3 Qualification of Personne1' L'here tests or inspections require the use of certified inspectors, qualification at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel for Nuclear i Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the CPRT Progra= Plan. Third-party participants in the implementation of this action plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing i procedures. 1

   ,s, I

Revision: 4

     ..                                                                             Page                           6 of 6 e

l ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) , Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K. " Assurance of CPRT ] Program Quality", of the CPRT Program Plan. 4.4 Procedures I Instruction QI-002, "CPRT Action Item I.a.2, Inspection Reports on Butt-Splices and Item I.a.3, Butt-Splice Qualifications". 4.5 Acceptance Criteria 4.5.1 The acceptance criterion for butt-splice stagger in cable bundles is that splices are either staggered or separated so that they do not touch one'another. 4.5.2 The acceptance criteria for the qualification ~ data package are that it provides justification for the use i of butt-splices for their specified service cor.ditions and meets the revised TUGC0 procedural requirements and the applicable IEEE standards for equipment qualification. Third-party engineering review and l concurrence is required. 4.5.3 The applicable IEEE Standards are: 323-1974, 383-1974 and 344-1975. 4.6 Decision Criteria 4.6.1 If any cable bundles have splices which are not staggered or separated, the bundle configurations will l be corrected. 4.6.2 If it is determined that the splices are not qualified for their service conditions, they will be replaced with qualified splices.

a m_______._______._

c; g N-I COMANCHE PEAK RESPONSE TEAM

RESULTS REFORT ISAP: I,a.3

Title:

Bute-Splice Qualification REVISION 1 i N ssus Coordinator Dap!e 4 diewTopLeader 1 knM 4/n/r4 Dati / Y - N. ' -

                                                                   $kof SS Joh FW. Beck, Chairman CPRT-SRT            Date s

a

Revision: 1 Page 1 of 10 0 RESULTS REPORT ISAP I.a.3 Bute-Splice Qualification

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7, Pages J-28 and J-29)*

           "The practice of butt-splicing cables in panels was allowed on a limited basis, as specified in Section 8.1.5.2.4 of Amendment 44 to the Final Safety Analysis Report (FSAR). The NRC staff reviewed Texas Utilities Electric Company's (TUEC's) justification for permitting butt-splices inside panels (correspondence from M.

Srinivasan, NRC Power Systems Branch to B. J. Youngblood, NRC Licensing Branch. July 30, 1984), and concluded that the practice is acceptable on a limited basis, subject to the following conditione:

           -      That adequate provisions be included in the installation procedures to verify operability of those circuits for which splices are being used,           ,
           -      That the wire splices used are qualified for anticipated service conditions, and
           -      That splices are staggered within the panel so that they are not adjacent to each other in the same wire bundle and pressing against one another.
            "The TRT inepected butt splices in safety-related pan ~els...
            "The TRT found ths splices to be in conformance with all procedural requirements set forth by TUGC0 which did not include the three conditions for acceptability stated above, which the NRC considers to be important to assure the adequacy of these splices..."

2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7. Item 6.(b), Page J-31)*

            "TUEC shall accomplish the following actions prior to fuel load:

Develop adequate installation and inspection procedbres to reinspect all existing butt-splicas to ensure (1) the operability of those circuits which contain butt-splices in panels, (2) that the wire splicing materials and methods used are qualified for anticipated service conditions, and (3) that splices are staggered within the panel so that they are not adjacent to each other in the same bundle." ,

NRC concerns involving the inspections of butt-splices are presented and addressed in ISAP I.a.2, " Inspection Reports on Butt Splices" 4

Revision: I Page 2 of 10 RESULTS REPORT ISAP I.a.3 (Cont'd)

3.0 BACKGROUND

The following information should be considered in addressing the issue identified by the NRC:

                                    - The type of butt-splice used by TUGC0 in control panels at Comanche Peak Steam Electric Station (CPSES) is the AMP Pre-Insulated Environmental Seal (PIES) splice. It is used     in these panels when conductors are not long enough to reach their termination points (due to design changes, equipment repair, etc.), and it is not judged reasonable to pull a new field cable.
                                    - Most of the existing AMP PIES splices in the Unit 1 control panels had been installed by craft personnel from late 1982 through mid-1983.
                                    - FSAR Amendment 44 was issued in October 1983 to encompass the use of these splices in panels. Ths NRC evaluation, "The Safety Evaluation Of Field Splices Inside Control Panels",

dated September 14, 1984, set forth the guidance on staggering of these splices in panels. Thus, this guidance from the NRC .! was received by TUGC0 after the installation of the subject splices.

                                    - During plant preoperational and startup testing, all electrical circuits are required to be tested in accordance with Startup Administrative Procedures SAP-6, " Control of Work on Station Components After Release from Construction to TUGC0"; SAP-22 " Retest Control"; and XCP-EE8. " Control Circuit Functional Testing". These tests provide the necessary verification that the spliced circuits are functional.

4.0 CPRT ACTION Pl.AN 4.1 Scope And Methodology The objectives of this action plan were to revise craft construction and QC inspection procedures: (1) to assure that continuity checks are made at the time of installation of all butt-spliced Class IE essential and associated circuits in ) control panels, and (2) to assure that Class 1E cables l containing butt splices in these panels are bundled such that ) the splices are staggered or separated to comply with the NRC { guidance.

                                                                                                   --_______________u

Revision: 1 Page 3 of 10

RESL*LTS REPORT ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)- A further objective of this action plan was to review the qualification data for AMP PIES splices to assure that they are qualified for the expected service conditions at CPSES. These splices are the only insulated splices authorized for Class 1E circuits at CPSES. Uninsulated butt-splices are covered by RayChem heat-shrinkable material, which is environmentally qualified for Class 1E applications. (Safety-related electrical equipment requiring application of this material is the subject of ISAP I.a.1, " Heat Shrinkable Insulation Sleeves.") The folleving tasks were implemented to achieve the above objectives: Procedure revisions

                 -     Craft and inspector training
                 -     Review of qualification data                                                                            -

4.1.1 Procedure Revisions The following specific subcasks were completed:

                           -       Construction procedure EEI-8 " Class lE and non-Class 1E Cable Terminations" was revised                                                  I to include a continuity check of all circuits                                                 j in control panels in which splices are placed                                                 I and to require that splices are staggered or                                                  I separated to comply with the NRC guidance.
                            -      Inspection procedure QI-QP-11.3-28. " Class 1E Terminations" was revised to add the attributes necessary to ensure that continuity checks of butt-spliced Class 1E essential and associated circuits in control panels are made, and that these splices are                                                   l staggered or separated.

l 4.1.2 Craft and Inspector Training l l The following subtasks were implemented:

                             -      Craft personnel were trained using the revised procedures.

i

A Rovision: 1 Fage 4 vf 10 RESULTS REPORT ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

                           -      Inspectors were trained and certified to the revised procedures.

4.1.3 Qualification Data A qualification data package, based on site specific requirements and previously existing vendor documentation was assembled for the AMP PIES splices. TUGC0 reviewed and approved this package as required by 10CFR50.49. A third-party engineering review of the qualification data package was conducted. 4.1.4 Use of Results Results of the actions under this plan were to be , evaluated to establish root causes and to identify appropriate corrective action, if required. 4.1.5 Related Activities In accordance with ISAP I.a.2, " Inspection Reports on Butt-Splices," all Class 1E cables found to contain AMP PIES splices will be inspected for any such splices that are not staggered or separated. Upon completion of these inspection activities, and any required rework, CPRT will have ensured that all such splices in safety-related cables are staggered or separated. The results of these activities will be presented in the Results Report for ISAP I.a.2. 4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective work scope. 4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Revised construction and inspection procedures. Trained craft and inspection personnel. 4.2.1.2 Processed NCRs that were generated due to this action plan. As discussed in Section 5, none was generated. 4.2.1.3 Prepared qualification data package. t

Revision: 1 Page 5 of 10 l RESULTS REPORT ISAP I.a.3 (Cont'd) j

4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.4 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed the revised inspection and construction procedures to ensure that requirements for continuity checks and staggered or separated splices were included. 4.2.2.2 Reviewed the training documentation to ensure that adequate training of craft and inspection personnel was performed. 4.2.2.3 Review NCRs that were generated due to this action plan. As discussed in Section 5, none was generated. 4.2.2.4 Performed root cause, generic implications and saf ety significance evaluations, if necessary. 4.2.2.5 Personnel (prior to October 18, 1985) Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.6 Personnel (starting October 18, 1985) Me. J. J. Ma11anda, Review Team Leader Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 Third-Party Adviser 4.2.3.1 Reviewed the qualification data package to ensure that the AMP PIES splices are qualified for the expected service conditions at CPSES, s I

e Revision: 1 Page 6 of 10 RESULTS RE? ORT ISAP I.a.3 (Cont'd) 4.0 CPRTACTIONPLAN(Cont'dh 4.2.3.2 Personnel Mr. L. D. Bates. Electrical Engineering Adviser 4.3 Qualification of Personnel Third-party participants in the implementation of this action plan met the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel were governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan. 4.4 Procedures Not applicable. 4.5 Acceptance Criteria 4.5.1 The acceptance criteria for the qualification data package were that it provided justification for the use of AMP PIES splices for their specified service conditions; and met the applicable TUGC0 procedural requirements, the applicable IEEE standards for environmental qualification and the requirements of NUREG 0588, Category 1, " Environmental Qualification of Safety-Related Electrical Equipment." Third-party engineering review and concurrence was required. 4.5.2 The applicable IEEE Standards applied were:

                           -      IEEE 323-1974 "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations"
                           -      IEEE 383-1974, "IEEE Standard for Type Test of Class IE Electric Cables, Field Splices and Connections for Nuclear Power Generating Stations" s
                                                                                           .__.__________o

4 Revision: 1 Page 7 of 10 RESULTS REPORT ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'dl

                                                                       -      IEEE 344-1975, "IEEE Recommended Practices far Seismic Qua)Afication of Class 1E Equipment for Nucles: Poser Generating Stations" 4.6 Decision Criteria 4.6.1             If it had bean determined that the splices were not qualified for their service conditions, they would have                 !

been replaced with qualified splices. As discussed in ! Section 5, this was not necessary. 5.0 DISCUSSION OF RESULTS The following discussions are limited to the results of tasks performed in accomplishing the objectives of this action plan. (All hardware reinspection and documentation review findings related to AMP Pre-Insulated Environmental Seal (PIES) splices will be discussed in the Results Report for ISAP I.a.2.) Procedures QI-QP-11.3-28 " Class 1E Terminations" and EEI-8 " Class . 1E and Non-Class IE Terminations" are ref erred to as the QC (inspection) and craft (installation) procedures, respectively, in the following discussion. 5.1 Summary of Implementation The activities performed under this ISAP consisted of: (1) revising craft and QC procedures to ensure that all installation requirements are clarified and to include the additional NRC guidance (i.e., staggering / separation requirements and continuity checks following installation of l AMP PIES splices), (2) providing training of craft and QC personnel to the revised procedures and (3) preparing and reviewing qualification data for the AMP PIES splices. 5.2 Procedure Revisions The procedures were revised to reflect the NRC guidance for the AMP PIES splices in control panels. Specifically: !

                                                    -               Continuity checks 4 1 procedurally required on all                     i Class 1E conductors. iiewever, craft and QC procedures have been revised to ensure that continuity checks are                 j performed at the time of installation of the subject                   j splices,                                                               j l

4 l

Revision: 1

   .                                                                               Page 8 of 10 l

t ! RESULTS REPORT ISAP I.a.3 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd) Craft and QC procedures have been revised to require that the AMP PIES splices be staggered or separated. Quality Control " hold points" have been incorporated into the craft procedure, and the QC procedure has been revised to clearly state the attributes that the inspector must verify or witness, as appropriate. In the past, installation of AMP PIES splices was limited to areas outside the containment building (see drawing 2323-El-1701, Details 18, 185 and 18C). The current QC procedure further limits the installation of these splices by prohibiting their use in harsh environmental areas, unless authorised by Design Change Authorization, even though qualification has been established for all service conditions at CPSES (see Section 5.4). The revised procedures have been reviewed by third-party Electrical .. Review Team personnel and found to be acceptable. 5.3 Craft and Inspector Training Training of craft and QC inspection personnel to the revised procedures was conducted in accordance with applicable site procedures. Lesson plans for the revised QC procedure training have been reviewed by third-party Electrical Review Team personnel. Craft training was accomplished using the actual revised procedures. Third-party Electrical Review Team members also reviewed methods for tracking and ensuring proper training for both craft and QC personnel for the applicable procedure revisions for this ISAP. The methods and records of training were found to be acceptable. 5.4 Review of Qualification Data A qualification data package was assembled, reviewed and approved by TUCC0; and reviewed by the third-party electrical engineering adviser and the Electrical Review Team Leader (RTL). This review concluded that the AMP PIES splices are qualified for all expected service conditions at CPSES, and that adequate documentation had existed at AMP since at least 1982 to demonstrate qualification.

4 . Revision: 1 ' Page 9 of 10 RESULTS REPORT ISAP I.a.3 1 (Cont'd) 5.0 DISCUSSION OT RESULTS (Cont'd) Although qualification has thus been established, CPRT found no evidence that TUGC0 had previously reviewed the ; qualification data in accordance with 10CFR50.49 and applicable site procedures prior to installation of the splices. The details of the third-party review are discussed below. 5.4.1 As stated previously, the third-party adviser review concluded that the AMP PIES splices are qualified for the expected service conditions at CPSES. This determination was based upon a review of the AMP Qualification Test Report 110-11004, "ANP Insulated Terminals and Splices for Class 1E, Inside Containment Service in Nuclear Power Generating Stations". This report shows that the CPSES plant-specific environmental and seismic parameters have been bounded by AMP's qualification testing. The Electrical RTL also reviewed the qualification data package and found it to be accaptable. 5.4.2 The TRT had questioned the qualification of AMP PIES splices. Although actions performed for this ISAP demonstrated that these' splices are qualified for their intended service conditions, a remaining issue involves the potential use of components without a complete engineering review of applicable qualification documentation. The generic aspects of this concern are included in the program for DSAP XI, " Electrical /I6C Systems and Components Discipline Specific Action Plan." 5.4.3 Since the AMP PIES splices have been shown to be qualified for the intended service condition, no safety-significant condition existed. 5.5 Non-conforming Hardware Conditions Since no non-conforming hardware conditions were identified by the activities performed for this action plan, no NCRs were generated. 5.6 Root Cause and Generic Implications Since no safety-significant deficiency was identified, no root cause or generic implications evaluation was performed. In a related activity, however, DSAP XI will evaluate whether there are any programmatic deficiencies that involve qualification j of site-initiated procurement of electrical components. j I

Revision: 1 Page 10 of 10 l I RESUI.TS REPORT ISAP I.a.3 (Cont'd) 1

                                                       .                                             l

6.0 CONCLUSION

S l The AMP PIES splices are qualified for the expected service conditions at CPSES. Craft and QC procedures have been revised to specify both staggering / separation requirements and continuity l checks at the time of installation of these splices in centrol 1 l panels. Craft and QC personnel have been trained to these revised . procedures. 7.0 ONGOING ACTIVITIES The procedure revisions discussed above have incorporated the NRC l guidelines on stagger / separation, and have required continuity checks at the time of installation, for AMP PIES splices in control l i panels. Though this resolves the issue identified by TRT, CPRT considers that the same procedures should be further revised to l include the same requirements for all safety-related installations of AMP PIES splices. These procedure changes have been recommended to, and accepted by, TUGC0 for incorporation. Results of the actual reinspection and staggering / separation activities will be discussed in the Results Report for ISAP I.a.2. - A general evaluation of the engineering review of qualification of site-initiated electrical component procurement is being performed as part of DSAP XI. 8.0 ACTIONS TO PRECLUDE OCCURRENCE IN THE TUTURE A qualification data package for AMP PIES splices was assembled and , reviewed. This review demonstrated that the subject splices are ! qualified for the expected service condition at CPSES. As such, no } further corrective actions regarding qualifications are necessary j for this ISAP. Any corrective actions of a programmatic nature i determined necessary by the activities being performed as part of J DSAP XI will be reported in the Results Report for that DSAP. The i procedure revisions and associated training discussed above will provide assurance that all future AMP PIES splice installations will include the continuity check and stagger / separation requirements in accordance with the NRC guidelines. I

e 4[ .' COMANCHE PEAK RESPONSE TEAM-ACTION PLAN ISAP I.a.4

Title:

Agreement Between Drawings and Field Terminations Revision No. 4 Reflects Comments Description On Plan Prepared and Recommended by: mf, , Review Team p Leader Date E Ob Approved by: Senior Review Team (hd,b / I Date 1 4ll l l 1 1 1

                                                                                                                                                                             ._______-w

r Rsvision: 4 Page- 1 of 8 ISAP I.a.4 Agreement Between Drawings and Field Terminations

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-29)

                                                                "...the TRT. selected 380 cables, involving 1600 individual terminations, and inspected them in detail with respect to drawing requirements. This inspection revealed that six cables (five of which are safety-related) were not terminated in accordance with current drawings. These six cables are:

E0139880 in panel CP1-ECPRCB-14* ; E0110040 in panel CP1-ECPRTC-16, ! E0118262 in panel CP1-ECPRTC-16 NK139853 in panel CP1-ECPRCB-02 (non-safety), EG104796 in panel CP1-ECPRTC-27, and EG021856 in panel CPX-ECPRCV-01." 2.0 ACTIO" IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7. Item Number 6 (c), Page J-31)

                                                                "TUEC shall accomplish the following actions prior to fuel load:

Reinspect all safety-related and associated terminations in the control room and in the termination cabinets in the cable spreading room to verify that their locations are in accordance with all current design documents. Should the results of this reinspection reveal an unacceptable level of nonconformance to design documents, the scope of.this reinspection effort shall be expanded to include all safety-related and associated terminations at Comanche Peak Steam Electric Station (CPSES)."

3.0 BACKGROUND

l The specific cables identified above have been re-inspected and the "as-built" configurations reviewed by TUGC0 l } Engineering. The engineering review has considered design changes and temporary modifications authorized prior to the TRT identification. L The TRT notified TCEC that the panel identified as CP1-ECPRCB-14 ; should be CPI-ECPRCS-04 i l

( Revision: 4 Page 2 of 8 4' ISAP I.a.4 I 4 (Cont'd) l t

3.0 BACKGROUND

(Cont'd) The results of this review are as follows: One cable (E0139880) was terminated correctly, but the color-code table on the drawing had not been correctly reflected in the conductor termination details. This drawing was corrected, and other similar drawings were checked to ensure that this condition does not exist elsewhere. One cable (E0110040) was found to be properly connected in accordance with the document revision in effect at the time the termination was made. However, a subsequent drawing revision changed the color code of the conductor for no apparent reason. This drawing error was detected and corrected prior to the September 18, 1984, letter from the NRC to TUGCO. One cable (E0ll8262) contained a drafting error at the time of the TRT inspection, (two green conductors shown). The' cable was functionally correct as landed, The drawing error has been corrected. 2 l One cable (EG104796), a two conductor cable, was found to have wires interchanged on the terminal points. This connection has no polarity requirement. Thus, the interchange of wires had no affect on the operability of the circuit. The physical terminations have been corrected to match the drawing. One cable (EG021856) was found to be a designated " spare" per a properly issued design change document (DCA 19948, Revision 1). However, the interconnection drawing for one end of the cable still showed the cable to be terminated which indicates that the review and drawing update cycle was incomplete at that time. The cable has been deleted from the current revision of the interconnection drawing. One cable (NK139853), a non-safety cable, the erange and yellow / orange pair of conductors had been designated as spare, but left te rmina ted . However, the vendor-side conductors had been removed from the terminal blocks. The subject conductors have also been renoved from the terminal blocks. l In summa ry, E0139860 Drawing error - correctly terminated E0110040 Drawing error * - correctly terminated q E0118262 Drawing error - correctly terminated < t Correcr.ed prior to September 18, 1984

Revision: 4 Page- 3 of 8 8 ISAP I.a.4 (Cont'd)

3.0 BACKGROUND

(Cont'd) EG104796 Interchanged conductors - functionally correct EG021856 Incomplete Design Change Authorization - cable not required NK139853 (non-safety) spara conductors terminated - functionally correct. In the course of normal practices, afteg construction has been completed and the equipment is in the startup cycle, a wiring check is done per Prerequisite Test Instruction XCP-EE-8. Any design changes required as a result of this testing are controlled and requested in accordance with the Startup Procedure for Design Requests (CP-SAP-14). Additionally, the change may be implemented as a temporary modification which is controlled by CP-SAP-13, Startup Procedure For Temporary Modifications. 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to assure that the ' saf ety-related and associated cable terminations in the control room and cable spreading room are in accordance with current design documents. The following task will be implemented to. achieve this objective: Inspection of terminations l 4.1.1 Inspection Program l 6 An inspection program employing randem sampling will be j initiated which will enable a determination to be made ; with reasonable assurance of whether the essential l Class IE conductors in the control room and cable spreading room which interface with the Alternate Shutdown Panel are terminated in accordance with the ; applicable drawings. j i

                                                                                                          ..e___________________.________m___-.___.___-__-_A

I Rsvision: 4 Page 4 of 8 ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) A sample inspection is considered to be'a reasonable approach for the following reasons:

1) No programmatic deficiencies have been identified in this population to date.

2) The population is homogeneous with respect to the attribute of agreement with drawings.

4.1.1,.1 . Population Identification The first step in the sampling program will be to identify the population of all essential Class 1E terminations in the control room and cable spreading room that l are in circuits which interface with the Alternate Shutdown Panel in Unit 1. This population of " safe shutdown" terminations will be taken from over 14,000 Class 1E terminations in these two rooms. The " safe shutdown" terminations have been chosen as a sub-group of the population of all Class IE terminations due to their i crucial role in plant safety. Since there I are no product or process differences between I this sub-group and the remainder of the Class 1E terminations, this approach will allow for : an investigation, which focuses on safety, while still attaining an engineering assessment of the quality of the larger population. 4.1.1.2 Random Sampling I The sa=pling plan will be designed in accordance with the guidelines of Appendix D, and will result in reasonable assurance that programmatic deficiencies do not exist in the population. 1 This plan employs a 95/1 screen, which is i significantly more conservative than the 95/5 l screen which is used in the majority of the ISAP's in which a sampling program is employed. The decision to enforce this higher standard (which increases saeple sizes by approximately a factor of five) was made by the Electrical Review Team Leader.

y---,- ,,-

       .     - r Revision:   4 Page   5 of 8 ISAP I.a.4                                                                                                               ?

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Based on the preliminary determination of a population size of 3812, the minimum sample size according to Appendix D is 300 with a rejection number of zero (i.e., the critic 1 region is one or more deficiencies found in the sample). If one (1) deficiency is found, a root cause evaluation of-the deficiency - will be performed, and a sample expansion in accordance with Appendix D will be undertaken. If the number of deficiencies discovered in f the original sample is two (2) or more, or a potential root cause is identified as programmatic, e '.00% reinspection of all ' essential and associated terminations in the Control Room and Cable Spreading Room of Unit I will be performed. 4.1.2 Use of Results Results of the actions under this Plan will be evaluated to establish root causes and to identify appropriate corrective action. 4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope. 4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Assist the Review Team Leader in identifying the Class 1E terminations which interface with the Alternate Shutdown Panel. 4.2.1.2' Process NCRs, if any, generated as a result of this action plan. 4.2.1.3 Personnel Mr. W. I. Vogelsang, TUCCO Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Review sample plan. NCRs and inspection reports, if any. I

9 Rovision: 4 Page 6 of 8 ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Evaluate inspection results and specify additional inspections, if required. 4.2.2.3 Determine root cause, generic implications and safety significance. 4.2.2.4 Personnel (prior to October 18, 1985) Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985) Mr. J. J. Ma11anda, Review Team Leader l Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr.' E. P. Stroupe, Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Inspect termination for compliance to acceptance criteria. 4.2.3.2 Personnel Mr. J. L. Hansel, Review Team Leader - QA/QC 4.2.4 Third-Party Adviser 4.2.4.1 Provide input to the Sampling Plan. 4.2.4.2 Personnel Dr. F. A. Webster, Statistics Adviser 4.3 Oua11fications of Personnel Where tests or inspections require the use of certified inspectcrs, qualifications at the appropriate level.will be to the requirements of ANSI N45.2.6 " Qualification of Inspection, Examination, and Testing Personnel at Nuclear i Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and specifically trained to the CPRT Program Plan.

Rsvision: 4 Page 7 of 8 ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Third-party participants in the implementation of this action plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan. 4.4 Procedures 4.4.1 Instruction QI-001, " Procedure for Class lE Cable Terminations Inspection - CPRT Action Item I.a.4". 4.5 Acceptance Criteria 4.5.1 Inspections The acceptance criterion for the termination inspection is that either: The termination is physically in agreement with the drawing (a conductor of a larger size than that shown on the drawing is also acceptable), or

                               -      The termination is not in agreement with the drawing but is functionally correct (e.g.,

connected to an electrically common point, wires reversed in circuits with no polarity requirements) 4.6 Decisien Criteria 4.6.1 If any terminations are not acceptable per Section ' 4.1.2, the sample size will be increased, in accordance with Appendix D or a 100% reinspection will be performed, as described in Section 4.1.1.2. 4.5.2 For cases where terminations are not in agreement with the drawings, either the drawings or the terminations . I will be corrected. 1 i l - - - - -

a Revision: 4 Page 8 of 8 ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.6.? If the number of deviations in the original sample is two (2) or more, or a potential root cause is identified as programmatic, such that it is required to reinspect all " Safe Shutdown" terminations, then all Class 1E essential and associated terminations in the Unit 1 Control Room and Cable Spreading Room will be inspected. 4.6.4 If it is necessary to reinspect all Class IE essential and associated terminations in the Unit 1 Control Room and Cable Spreading Room and more than 14 (0.1% of approximately 14,000 Class 1E essential terminations) defective terminations are found, then all Class IE essential and associated terminations in Unit 1 Unit 2, and common will be reinspected.

1 COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.a.4

Title:

Agreement Between Drawings and Field Terminations REVISION 2 A Oh Issue Coordinator Date ' 1 W . A b - YA Y$3 f$ view ' p Leider D&fe '

                     ? Y_ - N.                            7   $!S N John F. Beck, Chairman CPRT-SRT
                                                 ~                        )

Data i l 3

( i l , Revision: 2 j Page 1 of 16 { 1 i

RESUI.TS REPORT ISAP I.a.4 l Agreement Between Drawings and Field Terr.inations J

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-29)

                          "...the TRT selected 380 cables, involving 1600 individual termina.tions, and inspected them in detail with respect to drawing requirements. This inspection revealed that six cables (five of which are safety-related) were not terminated in accordanc.a with current drawings. These six cables are E0139880 in panel CPI-ECPRCB-14*

E0110040 in panel CP1-ECPRTC-16 E8118262 in panel CP1-ECPRTC-16, NK139853 in panel CP1-ECPRCB-02 (non-safety), EG104796 in panel CP1-ECPRTC-27, and EG021856 in panel CPX-ECPRCV-01." 2.0 ACTION IDENTIFIED BY NRC (NiTREG-0797, Supplement Number 7 Item Number 6 (c) Page J-31)

                         "TUEC shall accomplish the following actions prior.to fuel load:

Reinspect all safety-related and associated terminations in the control room and in the termination cabinets in the, cable spreading room to verify that their locations are in accordance with all current design documents. Should the results of this reinspection reveal an unacceptable level of nonconformance to design documents, the scope of this reinspection effort shall be expanded to include all safety-related and associated terminations at Comanche Peak Steam Electric Station (CPSES)."

3.0 BACKGROUND

The specific cables identified above have been re-inspected and the "as-built" configurations reviewed by TUGC0 Nuclear Engineering (TNE). The engineering review has considered design changes and temporary modifications authorized prior to the TRT identification. The results of this review are as follows: One cable (E6139880) was terminated correctly, but the color-code table on the drawing had not been correctly reflected in the conductor termination details. This drawing was corrected, and T The TRT notified TUEC that the panel identified as CP1-ECPRCB-14 should be CP1-ECPRCB-04 5

e Revision: 2 Pcge 2 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd)

3.0 BACKGROUND

(Cont'd) all other drawings with the same type of cable were checked to ensure that this condition does not exist elsewhere. No errors ; were found. One cable (E0110040) was found to be properly connected in accordance with the document revision in effect at the time the termination was made. However, a subsequent drawing revision changed the color code of the conductor for no apparent reason. This drawing error was detected and corrected prior to the September 18, 1984, letter from the NRC to TUGCO. One cable (E6118262) contained a drafting error at the time of the TRT inspection, (two green conductors shown). The cable was functionally correct as landed. The drawing error has been corrected. One cable (EG104796), a two conductor cable, was found to have wires interchanged on the terminal points. This connection has no l polarity requirement. Thus, the interchange of wires had no affect . ) on the operability of the circuit. The physical terminations have, I however, been corrected to match the drawing. One cable (EG021856) was (ound to be a designated " spare" per a properly issued design change authorization (DCA) document (DCA 19948, dated March 21, 1984). However, the interconnection drawing for one end of the cable still showed the cable to be terminated. The cable has been deleted from the current revision of the j interconnection drawing. One cable (NK139853), a non-safety cable, had the orange and yellow / orange pair of conductors designated on the drawing as i

        " spare", but these conductors were left terminated. However, the corresponding vendor-side conductors had been removed from the terminal blocks. The subject conductors have subsequently also been removed from the terminal blocks.

In summary, all of the cables identified by TRT were found to be l functionally correct as landed. The causes of the discrepancies l identified by the TRT are as follows: 1 E0139880 Drawing error E0110040 Drawing error l 9

Revisien: 2 Page 3 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd)

3.0 BACKGROUND

(Cont'd) E0118262 Drawing error EG104796 Interchanged conductors in a circuit with no polarity requirements EG021856 Interconnection drawing not revised to incorporate a DCA NK139853 Spare conductors terminated (non-safety) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan was to assure that the safety-related and associated cable terminations in the control room and cable spreading room are in accordance with current design documents. To achieve this objective, a program to inspect terminations was implemented. 4.1.1 Inspection Program An inspection program employing randow sampling was initiated which enabled a determination to be made with reasonable assurance of whether the essential (i.e.,

                                   . safety-related) Class 1E conductors in the control room and cable spreading room that are in circuits that l

interface with the Alternate Shutdown Panel were terminated in accordance with the applicable drawings. A sample inspection was considered to be a reasonable approach for the following reasons:

1) No programmatic deficiencies had been identified in this population to date.

2) The population was homogeneous with respect i to the attribute of agreemant with drawings.

l 4.1.1.1 Population Identification The first step in the sampling program was to identify the population of all essential Class 1E terminations in the control room and cable spreading room that are in circuits l t

Rcvision: ; Page 4 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) which interface with the Alternate Shutdown Panel in Unit 1. This population of " safe shutdown" terminations was taken from over 14,000 Class IE terminations in these two rooms. The " safe shutdown" terminations were chosen as a sub-group of the population of all Class 1E terminations due to their crucial role in plant safety. Since there are no product or process differences between this sub-group and the remainder of the Class 1E terminations, this approach allowed for an investigation that focused on safsty while j still attaining an engineering assessment of the quality of the larger population. 4.1.1.2 Random Sampling The sampling plan was designed in accordance with the guidelines of Appendix D, to test for reasonable assurance that programmatic

                                    . deficiencies do not exist in the population.

This plan employed a 95/1 screen, which was significantly more conservative than the 95/5 screen which was used in the majority of the ISAPs in which a sampling program was employed. The decision to enforce this higher standard (which increases sample sizes by approximately a factor of five) was made by the Electrical Review Team Leader (M. B. Jones, Jr.). Based on the preliminary determination of a population size of 3812, the minimum sample size according to Appendix D was 300 with a rejection number of zero (i.e., the critical region was one or more deficiencies found in the sample). If one (1) deficiency had been l found, a root cause evaluation of the deficiency would have been performed, and a sample expansion in accordance with Appendix D undertaken. l l s

Revision: 2 I Page 5 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) l l 1 l i 1 4.0 CPRT ACTION PLAN (Cont'd) ] i" If the number of deficiencies discovered in the original sample had been two (2) or more, or a programmatic root cause had been ; identified, then a 100% reinspection of all j essential and associated terminations in the ' control room and cable spreading room of l Unit 1 would hcve been performed. 4.1.2 Use of Results If the CPRT inspection program had identified any deficiencies, then a root cause and generic implications evaluation would have been performed, and appropriate corrective action determined. 4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective work scope. 4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Assisted the Koview Team Leader in identifying the essencial Class 1E terminations which interface with the Alternate Shutdown Panel. 4.2.1.2 Prepared sample inspection list using input I provided by the third-party statistics adviser. 4.2.1.3 Processed NCRs, if any, generated as a result i of this action plan. 4.2.1.4 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator . 4.2.2 Electrical Review Team I 4.2.2.1 Reviewed sampling plan, inspection procedure, j NCRs (if any) and inspection reports. j l 4.2.2.2 Evaluated inspection reruits and specified additional inspections, if required. 4 l 1

Revision: 2 Pege 6 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 4.0 CPRT ACT7.ON PLAN (Cont'd) 4.2.2.3 Performed root cause, generic implications and safety significance evaluations, if required. 4.2.2.4 Personnel (prior to October 18, 1985) Mr. M. B. Jones, Jr. Review Team Leader Mr. E. P. Stroupe Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985) Mr. J. J. Mallanda Review Team Leader Mr. J. R. Pearson Issue Coordinator Mr. M. B. Jones, Jr. Third-Party Adviser Mr. E. P. Stroupe Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Prepared procedure for inspecting terminations.

                   , 4.2.3.2   Inspected terminatio 3s for compliance with acceptance criteria.

4.2.3.3 Personnel Mr. J. L. Baha21 Review Team Leader - QA/QC 4.2.4 Third-Party Statistics Adviser 4.2.4.1 Provided input to the sampling plan. 4.2.4.2 Personnel Dr. F. A. Webster Statistics Adviser 1 i f

                                                                                                              .-_____-______2

1 Revision: 2 Page 7 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Qualifications of Personnel Where tests or inspections required the use of certified inspectors, qualifications at the appropriate level were to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors were certified to the requirements of the third-party employer's Quality Assurance Program, and specifically trained to the CPRT Program Plan. Third-party participants in the implementation of this action plen met the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities perfor=ed by other than third-party personnel were governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan. 4.4 Procedures 4.4.1 Instruction QI-001, " Procedure for Class 1E Cable

                               ' Terminations Inspection - CPRT Action Item I.a.4".

4.5 Acceptance Criteria 4.5.1 Inspections The acceptance criterion for the termination inspection was that either: The termination was physically in agreement with the drawing (a conductor of a larger size than that shown on the drawing was also acceptable), or

                                      -     The termination was not in agreement with the drawing but was functionally correct (e.g.,

connected to an electrically common point, or wires reversed in circuits with no polarity requirements). I

Revision: 2 Pago 8 of 16 ! RESULTS REPORT ISAP I.a.4 (Cont'd) I l 4.0 CPRT ACTION PLAN (Cont'd) ] 1 0 4.6 Decision Criteria 1 If any terminations had not been acceptable per Section 4.5.1, a further investigations would have been performed including / either sample expansion in accordance with Appendix D or a ' 100% reinspection. As discussed in Section 5, no further I investigations were necessary. j i i 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS l 1 5.1 Summary of Implementation The actions carried out under this ISAP consisted of a sample ! inspection of " safe shutdown" terminations, analysis of the l results of that inspection and a further investigation of the - specific NRC-TRT findings. The inspection program was performed using the methodology specified in Section 4.1. No deviations from the acceptance criteria of Section 4.5 were found. Two minor errors were discovered, which did not affect the adequacy of the . terminations. The identification of additional population members necessitated an additional sample inspection, which was also completed without finding any deviations from the l acceptance criteria. The results of the entire inspection progriun are presented in Section 5.2. For the purposes of this ISAP, the population of terminations consisted of all conductors (including spares) that were in cables that contained " safe shutdown" circuits. Spare conductors were included because some of the original TRT findings involved spara conductors, and because of the possibility of functional deficiencies that involve spare conductors. As discussed in Section 5.2.1, sufficient samples were drawn to ensure that at least 300 functioning conductors were inspected. The results of the further investigation into the specific NRC-TRT findings are presented in Section 5.3. i }' ..

Revision: 2 Page 9 of 16 RESULTS REPORT . ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2 Results of the CPRT Inspection Program 5.2.1 Original Population and h4pection Results Initially there were 3,812 terminations in the control room and cable spreading room identified as being in Unit 1 essential Class IE circuits which interface with the Alternate Shutdown Panel. The population was identified by drawing review. Though the initial minimum sample size was to be 300, a list of 383* randomly-selected terminations from the l population was created. This list was generated in I accordance with the guidelines in Appendix D to the CPRT Program Plan. The extra 83 terminations in the l list were included to cover duplicate numbers (inherent in the random selection process), physically-inaccessible terminations (i.e., spare conductors located in wireways that were not disassembled for this inspection), or any unforeseen problems that might later have required additional terminations to be inspected, and to provide for at least 300 functioning conductors in the sample. This list of 383 terminations yielded 347 valid samples ** (thus still in excess of the 300 required to meet the 95/1 screen if no deficiencies were found). The CPRT inspection of these 347 terminations uncovered [ one (1) drawing error and one (1) cable-tagging error. Both errors were judged to be minor, and neither violated the acceptance criteria of Section 4.5. These two errors are discussed in detail in Section 5.2.2. 5.2.2 Discussion of Specific Findings As noted in Section 5.2.1, two errors were found during the inspection of the terminations. Neither error j constitutes a deviation from the acceptance criteria of Section 4.5, since in each case the conductor involved ) l was terminated correctly. Those errors are discussed 1 below. l J 350 in an initial list plus 33 in a supplemental list.

                               **  The term " valid samples" refers to randomly-selected terminations which were found to be accessible and were reinspected. In this case the 347 valid samples consisted of 309 functioning conductors and 38 spart conductors.

i Revision: : : Page 10 of 16 i-RESULTS REPORT l ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.2.1 Drawing Error The CPRT inspections revealed a cable number drawing error. On drawing 2323-El-0172-17 cable EG120248 was shown as "EC 20248". Since all cable numbers have six digits, a five-digit number would have been recognized as a drawing error by maintenance or operations personnel who would have been using the drawing. The proper number could then have been determined by a drawing review-of this and other related drawings. (It is also noted that the subject cable was in Unit 1, and cable numbers beginning with "2" are assigned to Unit 2 cables, a convention well-known to maintenance and operations personnel.) A drawing error of this type would not have an adverse impact on the adequacy of safety-related terminations, since it did not lead to an incorrect te rmination . The specific drawing has been reissued with the number corrected. 5.2.2.2 Cable-tagging Error The CPRT inspections also revealed an error in the prefix of a field-applied cable identification number (cable EG145725 was tagged as "EC145725"). "C" is not a valid character for the prefix of a cable number. As such, this tag number would be recognized as an error in the sleeve identification.

    .                           Also, the six-digit number alone provides unique identification of the cable. An error of this type does not violate the acceptance criteria of Section 4.5 and would not have an adverse impact on the adequacy of safety-related terminations, since it did not lead to an incorrect termination. The specific tag has been corrected.

1 s

Revision: ; Page 11 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESCLTS (Cont'd) 5.2.3 Population Changes and Additional Inspection Results As part of the CPRT overview of activities performed for this action plan, two types of anomalies in the CPRT sample identification process were uncovered. The first type consisted of errors in the process of

                          " mapping" random digits to the correct terminations to be inspected. These errors were due to a tedious manual method for performing this work, which was easily subject to human error. The entire mapping process has subsequently been checked by third-party personnel. Each incorrectly-mapped selection was inspected and found to be functionally correct.

Additionally, the correct selections were subsequently l inspected and found to be functionally correct. The final count of 347 valid samples includes only the correctly-mapped selections. The second anomaly was in the determination of the total population (originally 3,812). A review by third-party personnel uncovered an additional 105 terminations that were not included in the original population. These 105 omissions were due to: (1) l l incorrect count of conductors within some cables; and l (2) entire cables missing from the population list.

If the entire population of 3,917 terminations had been identified originally, the required sample size per Appendix D would still have been 300. However, due to the actual sequence of events, none of the additional 105 terminations could have been selected for 4 inspection. Therefore, CPRT instituted an additional !

inspection program, which consisted of a random sample ) being drawn from the additional terminations. The 4 l sample size was chosen to be in equal proportion to the I additional population as the originsi sample size was to the original population. This approach restored an original premise of the sampling approach - that each population item hed an equal chance of being selected , for inspection. The additional sample size was thus i calculated to be nine (9). l l s _______._______o

( Revision: ; Page 12 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) The 9 terminations were selected at random from the population c' 105 in accordance with the method specified in Appendix D. These 9* terminations were inspected in accordance with the action plan l requirements a,d no deviations were found. 5.2.4 Other Findings During the CPRT inspections, it was noted that two conductors had a low chromatic blue color. The inspection reports noted the color as " greenish-grey and as such the color code is indeterminate". This finding was investigated by a third-party consultant and the Electrical Review Team Leader (RTL). It was determined that the blue conductor would not have been confused with any other conductor. The subject conductors were terminated correctly, and the Electrical RTL considers that the conductors are sufficiently discernible from one another to ensure that other cables of this type will not be incorrectly terminated due to the low chromatic purity of their conductors. 5.3 Further Investigation of the NRC-TRT Findings The results of a review by TNE of the six (6) cables, which had been identified by NRC-TRT as not being terminated in accordance with current drawings, are presented in Section 3.0. A further review of these cables by CPRT was performed during implementation of this action plan. A discussion of the review for each of the 6 cables follows: 5.3.1 Cable E0139880 This cable was terminated correctly, but the color-code table on the drawing had not been correctly reflected l in the termination details. This multi-conductor cable l was supplied with a different color code than shown on the design documents. This drawing has been corrected, and other drawings, which had this type of cable and color-code table, were checked by CPRT to ensure that they had also been corrected. No errors were found. 9 functioning conductors and no spara conductors. f i

Revision: ; Page 13 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.2 Cable E0110040 The drawing and termination were in agreement at the time the termination was made. However, a subsequent drawing revision mistakenly changed the color code of the conductor. The drawing has been corrected. This was an isolated drafting error, and did not adversely impact the adequacy of the termination. 5.3.3 Cable E0118262 This cable was properly connected in accordance with the document in effect at the time the termination was made. However, the drawing contained a drafting error at the time of the TRT inspection, i.e., two green conductors were shown for this cable. The drawing error has been corrected. This is an isolated drafting error, and did not adversely impact the adequacy of the termination. 5.3.4 Cable EG104796 This two-conductor cable was found to have its conductors reversed at the terminal block. The specific circuit had no polarity requirement and thus l the reversal did not have any functional impact on the

circuit operation. The physical terminations have been corrected to match the drawing.

5.3.5 Cable EG021856 , This cable was found to be a designated " spare" per a ! properly issued design change document (DCA 19948, J dated March 21, 1984). However, the interconnection drawing for Panel CPK-ECPRCV-01 still showed the cable to be terminated. The cable has subsequently been deleted from the current revision of the 3 l interconnection drawing and is not terminated. There J l is no potentially adverse impact on the adequacy of the l l termination, since the DCA had been preperly used in . determinating the cable, and the cable was not 1 terminated at the time of the NRC-TRT inspection. i l . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _

Revision: 2

                                               ,                                                Page 14 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Since the cause of this finding appeared to be a delay in updating the interconnection drawing to reflect a DCA, the Electrical RTL requested a third-party review of the drawing update process. This review indicated that delays had been caused by the volume of changes and by priority having been given to activities necessary to support the Unit 1 start-up effort. The review also found, however, that an effort had been initiated by TUGC0 in September of 1984 to significantly reduce the volume of open design change documents. 5.3.6 Cable NK139853 The drawing for this non-safety cable had the orange and yellow-orange pair of conductors designated as

                                                  " spare", but the conductors were lef t terminated.

However, the corresponding vendor-side conductors had correctly been lifted from the terminal blocks and thus there was no functional deviation. The subject spare conductors have subsequently also been lifted from the terminal blocks. 5.4 Root Cause and Generic Implications Since the activities carried out during the implementation of this action plan did not reveal any deficiencies, neither a root cause nor a generic implications evaluation is necessary. t 5.5 Discussion of Related CPRT Activities ISAP I.a.2, " Inspection Reports on Butt Splices," includes the j inspection of all AMP preinsulated environmentally-sealed butt ! splices in saf ety-related circuits in the control room and cable spreading room of Unit 1. A necessary step in I identifying the location of these butt splices is to trace conductors from terminal points to butt splices (and vice-versa). While not an attribute of the ISAP I.a.2 inspection procedure, the correctness of these terminations is verified by this process. In inspecting over 500 conductors with butt splicas, no functionally-incorrect terminations were discovered. One cable (A6130852) was noted to have two conductors reversed at the terminal points. As in the case of the conductor reversal discovered by NRC-TRT, these conductors were in a single circuit with no polarity requirement, and i

                     -                                                                          Rovision:             2 Page 15 of 16 RESULTS REPORT                                               -

ISAP I.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) thus were functionally correct. These conductors, however, have been reterminated to match the drawing. The details of all findings discovered during implementation of ISAP I.a.2 and other ISAPs will be presented in either the Results Report or the working files for those ISAPs. ISAP VII.c, " Construction Reinspection / Document Review Program," will include an inspection of 60-120 cables (including at least 60 in circuits that are important to safety). One of the inspection attributes is the correctness of terminations, and thus all conductors in each of these cables will be checked to ensure that they are correctly terminated. The results ot' this inspection will be included in the results report for ISAP VII.c. 5.6 Out-of Scope Findings During the sample inspections, the inspectors found four (4) white conductors terminated at points that drawing [ 2323-El-0156, Revision CP-4, showed to be vacant. These conductors were not part of the sample. TNE reviewed this drawing and determined that the subject conductors had been deleted (by draf ting error) during incorporation of a DCA. The terminations were in accordance with the DCA and are functionally correct. The subject drawing has subsequently been corrected to show these terminations. 4

6.0 CONCLUSION

S A CPRT inspection of 356 randomly-selected " safe shutdown" termins' ions found all to be functionally in accordance with the l applicable design documents. Further, of the six cases identified by NRC-TRT involving cables not being terminated in accordance with drawing requirements, none was found to be in functional {' disagreement with design requirements. It is noted that the KRC-TRT inspection included 1600 terminations consisting of both safety-related and non-safety-related cables. Functional i correctness of an additional 500-600 terminations was assured as a necessary step in completing Action Plan I.a.2 involving butt-splice inspections. Inspection of the terminations of all conductors in 60-120 cables is being performad by CPRT as part of the Quality of Construction program (specifically within Action Plan VII.c). This inspection is not limited to only the " safe shutdown" terminations.

1 . Revision: 2 j Page 16 of 16 RESULTS REPORT ISAP I.a.4 (Cont'd) 6,0 CONCLUSIONS (Cont'd) The rigorous sample inapaction program performed under this Action Plan, together with the added screens provided by the related inspections and tests discussed herein, provide reasonable i assurance that there are no undetected safety-significant or ! programmatic deficiencies that involve correctness of safety-related electrical terminations. l The small number of anomalies, none of which adversely affected the adequacy of safety-related terminations, is within the bounds to be expected, given the number of destinations reviewed. i 7.0 ONGOING ACTIVITIES There are no activities still ongoing with respect to CPRT effort for this action plan. Rslated inspections will be reported in the Results Report for ISAP VII.c, " Construction Reinspection / Documentation Review Plan." 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Since no programmatic deficiencies were found, there are no corrective actions required. I

J. 9 COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP I.a.5

Title:

NCRs On Vendor Installed Amp Terminal Lugs Revision No. 4 Reflects Comments Description On Plan Prepared and Recommended by: '

                                /, k         -

Review Team D Leader Date Y Approved by: Senior Review Team O sf_ d, v,ee v h-+ leu i

'                                                                                            Rsvision;                    4
  '                                                                                          Pcga                   1 of 7 4

ISAP I.a.5 NCRs On Vendor Installed Amp Terminal Lugs

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NURIG-0797, Supplement Number 7, Page J-30)

                       " Allegation AQE-36 involved vendor-installed AMP Product Corporation (APC) ter=inal lugs in ITT (sic) Gould-Brown Boveri,                                     l 6.9 Kv switchgear being excessively bent in the area between the ring and the barrel. The TRT discovered 16 NCRs (E-84-01066 through E-84-01081) issued early in April 1984, which documented this condition. The TRT review of TUEC action taken regarding.

these NCRs revealed the following:

                          -   The NCRs described the APC lugs either as being bent in excess of 60 degrees or twisted.
                          -   The documented record of a telephone conversation between TUEC and the representative of the lug manufacturer (reference letter VBR-16624) stated that lugs bent to 90 degrees one time were to be considered acceptable; that lugs bent to 120 degrees could be acceptable after utilizing an engineering evaluation by the end-user; and that although lugs bent to 120 degrees would not maintain their full mechanical strength, they would maintain their electrical characteristics. This acceptance criteria for field bent lugs was changed by APC due to the dispositioning of NCR E-84-00972 regarding the General Electric (GE) motor control center (MCC) thermal overload relay replacement program.

The TRT findings regarding the disposition of these NCRs were as follows:

                                 -     The disposition block of the NCR form stated that many of the lugs were " determined not to pose an equipment serviceability problem." However, there was no reference to or evidence of an engineering evaluation, as required by the lug manufacturer prior to a charge in the acceptance criteria en NCR E-84-00972.
                                  -    Only the " bent" condition of the lugs was addressed by both the vendor representative and TUEC engineering.

Neither the mechanical strength nor the electrical characteristics were ever addressed with respect to "tvisted" lugs. The TRT determined that these NCRs were improperly dispositioned in that the full scope of the identified problem was not addressed and the "use-as-is" dispositions were not adequately justified." {

i

R: vision: 4 Page 2 of 7 ISAP I.a.5 (Cont'd) 2.0 ACTION IDENTIFIED BY NRC (NURIG-0797, Supplement Number 7, Item

6. (a), Page J-31)

                                                                                                                        )
             "TUEC shall accomplish the following actions prior to fuel load:

Reevaluate and predisposition all NCRs related to vendor-installed terminal lugs in ITT (sic) Gould-Brown Boveri switchgear, taking l into consideration the effects of twisted as well as bent lugs, and perform and document the results of engineering analysis to justify any resulting "use-as-is" dispositions."

3.0 BACKGROUND

The issue involves bending of AMP ring tongue terminals. In 1981, during the process of terminating (landing) conductors it became obvious that under certain configurations it was i=possible to land conductors without bending the AMP ring tongue terminal. Accordingly, Brown & Root Engineering I contacted AMP Special Industries, a subsidiary of AMP Incorporated, for guidance in bending of AMP ring congue terminals. The response (vendor letter VBR-16624), which formed the basis for acceptance criteria at CPSES, stated that AMP terminals could be bent one time to 60*. In the first quarter of 1984 when a GE thermal overload relay was being replaced, it was noted by TUGC0 that the AMP ring l tongue terminals had to be bent 90' to 120' to install the relay. Because this violated the criteria for bending established in 1981, a Non-conformance Report (NCR E-84-00972) was issued. Shortly thereafter, during a scheduled TUCCO QC inspection of ITE Gould-Brown Boveri Switchgcar, it was noted that some of the vendor-installed AMP ring tongue terminals were bent in excess of 60' and/or twisted. NCRs were issued to document the condition (NCRs E-84-01066 i through E-84-01081). These are the NCRs identified by TRT as giving rise to this issue. , In responding to the NCRs, in April 1984 AMP ence again was contacted and the existing situation (including the criteria established in 1981) was discussed. AMP responded that the ring tongue terminals could be bent two (2) times to 45' or i one (1) time to 90'. Further, AMP stated that bending more l[ than 90' and up to and including 120' is acceptable if the product user evaluated the specific application by considering the length of conductor to be supported by the terminal and l

R vision: 4 Paga 3 of 7 ISAP I.a.5 (Cont'd)

3.0 BACKGROUND

(Cont'd) the susceptibility of the final installation to vibration. AMP also advised that, while a ring tongue terminal bent more than 90' still maintained electrical characteristics, it would not maintain full mechanical strength. This information was documented in telephone conversation record CPPA 38,241, which was provided to AMP for review. TUCCO judged that the AMP criteria gave appropriate guidance to the concerns raised regarding bent and/or twisted lugs. In applying these criteria, TUGC0 decided that the terminals in question would be replaced if the bending was in excess of 90' or the teminal showed signs of f atigue (e.g., flaking, cracking or other physical discontinuities). At the time, TUGC0 did not discuss the term "tvisted" with AMP. This was due to TUCCO Engineering's evaluation that the term " bent" appropriately described the physical configuration of the small AMP ring tongue terminals and that TUGC0 QC's description of " bent and twisted" connoted a situation to which the AMP criteria applied. (As it turns out, anything other than bending requires excessive force and could not be done by hand. Terminals described as being tvisted were judged by TUGC0 Engineering as being bent in a manner not exactly perpendicular to the axis of the terminal, a condition consistent with physically landing the conductors by hand.) Based on this information, the NCRs were dispositioned as follows prior to the TRT review:

               -     NCR E-84-00972 - An engineering evaluation was                                I conducted by TUGC0 as part of the NCR disposition approving bending the AMP terminals associated with the                       l GE relay in excess of 90' but less than 120'.     (The TRT                    l did not state any concern with this evaluation.)                              1
                -    NCRs E-84-01066 through 01081 - Each terminal in                            ;

question had been inspected by Engineering and where it i, had been reflected in resulting docu=entation that the l bending had been in excess of 90' or the terminal j showed signs of fatigue (e.g., flaking, cracking or ;l other physical discontinuities), the terminal had been ;l

                                                                                                 'I replaced. The decision to replace all of the terminals bent in excess of 90' had been based on the fact that                       'I it was not necessary for installation to bend the                              l terminals more than 90*, and replacing them would negate the need for an engineering analysis to justify their acceptance. However, the vast majority of the terminals, including most noted in the NCRs to

   +                                                                                                                                                                        R2vicion:   4 Pegs   4 of.7 l

l ISAP I.a.5 (Cont'd) - i

3.0 BACKGROUND

(Cont'd) be " twisted", had been dispositioned "use-as-is". The basis for the "use-as-is" disposition had been stated in the NCRs as follows:

                                                  "The current Manufacturer's position is that
                  ,~

terminals may be bent one time to 90', and up to 120*.with engineering evaluation. Engineering has reviewed the following terminals in question .... It is our determination that these terminals do not pose an equipment serviceability problem and may be used as is." Because all terminals bent greater than 90* had been replaced, engineering evaluations were not required. (Note that TUGC0 QE approved the above disposition.) While it was TUGCO's position that the stated dispositions were technically correct, and that the AMP criteria on bent lugs encompassed the concerns regarding bent and/or twisted lugs, the TRT was concerned that the NORs did not clearly provide justification for the "use-as-is" disposition. To resolve its concerns, the TRT directed that the NCRs related to the bent and/or twisted terminals in the ITE Gould-Brown Boveri switchgear be reevaluated and redispositioned. 4.0 CPRT ACTION PLAN 4.1 Scooc and Methodology The objective of this action plan is to reevaluate and predisposition all NCRs related to vender-installed terminal lugs in ITE Gould-Brown Boveri switchgear to take into consideration twisted as well as bent lugs, confir= the acceptability of the "use-as-is" dispositions, and have AXP substantiate their change in acceptance criteria.

                                                                                                                                                                                           ,            )) F
                                                                                                                                                                                                      .-3 ,

l

                                                                                                                                                                       ~ Rtvi$1cb:                                       I
                                                                                                                                                                                                    '.(4N
                                                                                /                                                                         j-            Pagej, 5 of #
                                                                                                     -                                                 >j                            '
         '                                                                                                                                                                                                    .l >-

ISAP.I.a.5 , (Ccat'd) t

a. - e 0 ,.

4.0 CPRT ACTION PLAN (CecS'd) . The following tas% will he imphaented to achiev this t objective: 1 , , Predisposition all NCRs tUjustify the actua":; .; disposition. 7 n ' ;t

                                                                                                                                                                       .,   e i ,   '

y

                                                                               'h.
                                                                                                       -        Obtain a vender. analysis,g.

of the bent ,and, twiste-{ lugs.M g( 4.1.1 DispositionofNon-hgnfor$ances All Non-conformance P$ ports on bent and twisted ring h' C tongue terminals (NRCs E-84-01066 thru E-84-01081) will O

                                                                                                   '            be redispos:! stoned. ' The reflispositioned NCRs will more
                                                                                                               ' clearly state the observei condition of ths. ring tongue terminals and the engineering justification for-
                                                                                                                "use-as-is". The initial disposition of these NCRs
                                                                                                               ' did not allow any ring tongue terminal which were ",beint or twisted" more than 90^ to remain in service.- '. t;                                       .

a p/ ,, q 4.1.2 Vendor Analysis n ' , l

                                                      '                                                          AMP will be request'ed to provide documented analysis to substantiate the change from a 60* bend being .*
                                                        -                                                        acceptable to a 90* bend being acceptable. ,This
                                   /                      '

analysis will .incluc'e un evaluation of " twisted" ring

                                 '                                                        i                       tongue terminals.        ,

t j<*4.1.3 Use of Results s s Results of the acciomjurl der this Plau'vi33 be 4 evaluated to establiub root caus w and to (dentify appropriate corrective action, if, required. J j t 4.1.4 Related Activities'

                                   ;                                     [i                                       An evaluation cf thu general practice et dispositioning of NCRs is included in Action Plan VII.a.2, "Non-conformance at.d Corrective Action Systems".
         /

F ,

                                                                  ,a,
                                                                              =4.2                   Partic19 ants i. oles and Resocusibilities
                                     ,a                                                                              a>

The organizations and persoanil,' that .dH participate int this 2 ef fort are described below wnh their re: pective work scope.

                                              '                                                      . 2.1 TIJGC0 Comanche Peak ?toject                           >

1<

p 4.2'. b l Process NCRs identified in this action plan.

                                                  '                              ,gi k   ,

[

                                      ]                                                   j i
                                                                                     ,2 e

A t-p s, c;

                                                    .h                                 4

_

a " l - . R: vision: 4 Pcg3 6 of 7 A ' W of F ISAP I.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) [I ..e t

                   .c 4.2.1.2     Personnel                                                     ;

Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Review the final disposition of the NCRs. 4.2.2.2 Review and approve the AMP analysis. 4.2.2.3 Determine root cause, generic implications, and safety significance. 4.2.2.4 Personnel (prior to October 18, 1985) I Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985) Mr. J. J. MsIlanda, Review Team Leader Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.3 Qualification of Personnel Where tests or inspections require the use of certified inspectors, qualification at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Huclear Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance program, and specifically trained to the CPRT Program Plan. Third-party participants in the implementation of this action plan will meet the personnel qualification requirements of the CPRT Program Plan and its i=plementing procedures. Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed ' by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Progra= Quality", of the CPRT Program Plan. I _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . l

l' , Revision: 4

  '                                                                                                                                Page   7 of 7 ISAP I.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.4  Procedures Not applicable 4.5 Acceptance Criteria The acceptance criteria are as follows:

The NCRs must be properly dispositioned by either justifying the "use-as-is" disposition or requiring replacement of.the terminal lugs. 4.6 Decision Criteria The decision criteria are: 4.6.1 If the justification for using ring tongue terminals bent up to 90* can not be provided, they will be replaced. 4.6.2 If the justification for using twisted ring tongue terminals can not be provided, they will be replaced. j

9 COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.a.5

Title:

NCRs on Vendor Installed Amp Terminal Lugs REVISION 1 rer ~

                                                                             ? 16 sc ssue Coordinator                            Date M 1.}t.M+ JA.

Eview T p Leader 7/a/sc Date'

WM.M Johf W. Beck, Chairman CPRTeSRT 7/24ll4 Date 1 __________________.__.________________U

9

 . 4 Revisien:    !

Pegs 1 of 9 l RESULTS REPORT ISAP I.a.5 NCRs On Vendor Installed AMP Terminal Lugs 1

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement l Number 7, Page J-30)

            " Allegation AQE-36 involved vender-installed AMP Product Corporation (APC) terminal lugs in ITT (sic) Gould-Brown Boveri, 6.9 Kv switchgear being excessively bent in the area between the ring and the barrel. The TRT discovered 16 NCRs (E-84-01066 through E-84-01081) issued early in April 1984, which documented this condition. The TRT review of TUEC action taken regarding these NCRs revesled the following:

The NCRs described the APC lugs either as being bent in excess of 60 degrees or twisted. The documented record of a telephone conversation between TUEC and the representative of the lug manufacturer (reference letter VBR-16624) stated that lugs bent to 90 degrees one time , were to be considered acceptable; that lugs bent to 120 ' degrees could be acceptable after utilizing an engineering evaluation by the end-user; and that although lugs bent to 120 degrees would not maintain their full mechanical strength, they would maintain their electrical characteristics. This acceptance criteria for field bent lugs was changed by APC due to the dispositioning of NCR E-84-00972 regarding the General Electric (CE) motor control center (MCC) thermal overload relay replacement program. The TRT figdings regarding the disposition of these NCRs were as follows: The disposition block of the NCR form stated that many of the lugs were " determined not to pose an equipment serviceability problem." However, there was no reference.to or evidence of an engineering evaluation, as required by the lug manufacturer prior to a change in the acceptance criteria on NCR E-84-00972. Only the " bent" condition of the lugs was addressed by both the vendor representative and TUEC engineering. Neither the mechanical strength nor the electrical characteristics were ever addressed with respect to

                          " twisted" lugs.

The TRT determined that these NCRs were improperly dispositioned in that the full scope of the identified problem was not addressed and I the "use-as-is" dispositions were not adequately justified." l

l 1 . l Rovision: ! Page 2 of 9 4 RESULTE REPORT ISAP I.a.5 (Cott'd) l 2.0 ACTION IDENTIFIED BY NRC (NUREC-0797, Supplement Number 7 Item

6. (a) , Page J-31)

                                                   /
        "TUEC shall accomplish the follocing actions prior to fuel load:

Reevaluate and predisposition all N;Rs related to vendor-installed terminal lugs in ITT (sic) Gould-B;own Boveri switchgear, taking into consideration the effects of twisted as well as bent lugs, and perform and document the results of engineering analysis to justify any resulting "use-as-is" dispositions." 3.0 BACKCROUND The issue involved bending of AMP terminal lugs (also known as ring tongue terminals). In 1981, during the process of terminating (landing) conductors it became obvious that under certain configurations it was impossible to land conductors without bending the AMP terminal lug. Accordingly, Brown & Root Engineering contacted AMP Special Industries, a subsidiary of AMP Incorporated, for guidance on bending of AMP terminal lugs. The response (vendor letter VBR-16624), which formed the basis for acceptance criteria at CPSES, stated that AMP terminal lugs could be bent one time to 60*. In the first quarter of 1984 when a GE thermal overload relay was being replaced, it was noted by TUGC0 that the AMP terminal lugs had to be bent 90' to 120' to install the relay. Because this violated the criteria for bending established in 1981, a Non-conformance Report (NCR E-84-00972) was issued. Shortly thereaf ter, during a scheduled TUGC0 QC inspection of ITE Could-Brown Boveri Switchgear, it was noted that some of the vendor-installed AMP terminal lugs were bent in excess of 60* and/or twisted. NCRs were issued to document the condition (NCRs E-84-01066 through i E-84-01081) . These are the NCRs identified by TRT as giving rise to this issue. In responding to the NCRs, in April 1984 AMP once again was contacted and the existing situation (including the criteria established in 1981) was discussed. AMP responded that the terminal lugs could be bent two (2) times to 45' or one (1) time to 90'. Further AMP stated that bending more than 90' and up to and including 120' is acceptable if the product user evaluated the specific application by considering the length of conductcr to be l 1 1

Revisien: 1 Page 3 og 9 4 RESULTS REPORT ISAP I.a.5 (Cont'd)

3.0 BACKGROUND

(Cont'd) supported by the terminal and the susceptibility of the final installation to vibration. AMP also advised that, while a terminal lug bent more than 90' etill maintained electrical characteristics. it would not maintain full mechanical strength. This information was documented in telephone conversation record CPPA 38,241, which was provided to AMP for review. TUGC0 Nuclear Engineering (TNE) judged that the AMP criteria gave appropriate guidance to the concerns raised regarding bent and/or twisted terminal lugs. In applying these criteria, TNE decided that the terminal lugs in question would be replaced if the bending, was in excess of 90' or the terminal lug showed signs of f atigue (i.e., flaking, cracking or other physical discontinuities). At the time TNE did not discuss the term " twisted" with AMP. This was due to TNE's evaluation that the term " bent" appropriately described the physical configuration of the small AMP terminal lugs and that TUGC0 QC's description of " bent and twisted" connoted a situation to which the AMP criteria applied. (As it turns out, anything other than bending requires excessive force an,d could not be done by hand. Terminal lugs described as being twisted were judged by TNE as being bent in a manner not exactly perpendicular to the axis of the terminal lugs, a condition consistent with physically landing the conductors by hand.) Based on this information, the NCRs were dispositioned as follows prior to the TRT review: NCR E-84-00972 - An engineering evaluation was conducted by TNE as part of the NCR disposition approving bending the AMP terminal lugs associated with the GE relay in excess of 90' but less than 120'. (The TRT did not state any concern with this evaluation.) NCRs E-84-01066 through 01081 - Each terminal lug in question had been inspected by TNE and where it had been documented that the bending had been in excess of 90' or the terminal lug showed signs of fatigue (i.e., flaking, cracking or other physical discontinuities), the terminal lug was to be replaced. The decision to replace all of the terminal lugs bent in excess of 90' had been based on the fact that it was not necessary for installation to band the terminal lugs more l than 90', and replacing them would negate the need for an engineering analysis to justify their acceptance. However, the vast majority of the terminal lugs, including most noted n

R: vision: i . Pego 4 of 9 4 RESULTS REPORT ISAP I.a.0 (Cont'd)

3.0 BACKGROUND

(Cont'd) in the NCRs to be " twisted", had been dispositioned "use-as-is". The basis for the "use-as-is" disposition had been stated in the NCRs as follows:

                       "The current Manufacturer's position is that terminals may be bent one time to 90'. and up to 120' with engineering evaluation. Engineering has reviewed the following terminals in question .... It is our determination that these terminals do not pose an equipment serviceability problem and may be used as is."

Since the TNE disposition was that all terminal lugs bent greater than 90' were to be replaced, engineering evaluations were not required. (Note that TUGC0 QE approved the above disposition.) While it was TNE's position that the stated dispositions were technica11-y correct, and that the AMP criteria on bent terminal lugs encompassed the concerns regarding bent and/or twisted terminal lugs, the TRT was concerned that the NCRs did not clearly provide justification for the "use-as-is" dispoettion. To resolve its concerns, the TRT directed that the NCRs related to the bent and/or twisted terminal lugs in the ITE Gould-Brown Boveri svitchgear be reevaluated and redispositioned. 4.0 CPRT ACTION PLAN J ( 4.1 Scope and Methodology l l The objective of this action plan was to reevaluate and predisposition all NCRs related to vendor-installed terminal lugs in ITE Gould-Brown Boveri switchgear to take into consideration twisted as well as bent terminal lugs, confirm the acceptability of the "use-as-is" dispositions, and have i AMP substantiate their change in acceptance criteria. l l The following tasks were implemented to achieve this ; objective: i The sixteen (16) identified NCRs were redispositioned to justify the actual disposition. A vendor analysis of the bent and twisted terminal lugs was obtained. i

Revision: ; Page 5 of 9 J RESULTS REPORT l ISAP I.a.5 i (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) I 4.1.1 Disposition of Non-Conformances The Non-conformance Reports on bent and twisted terminal lugs (NCRs E-84-01066 thru E-84-01081) were l redispositioned. The redispositioned NCRs more clearly state the observed condition of the terminal lugs and the engineering justification for "use-as-is". The initial disposition of these NCRs did not allow any terminal lugs which were " bent or twisted" more than 1 90' to remain in service. j i 4.1.2 Vendor Analysis AMP was requested to and did provide documented analysis to substantiate the change from a 60* bend being acceptable to a 90" bend being acceptable. This analysis included an evaluaticn of " twisted" terminal lugs. 4.1.3 Use of Results If the results of this Action Plan had identified deficiencies in the "use-as-is"' dispositions by TNE, then a root cause and generic implications evaluation would have been performed and appropriate corrective action determined. 4.1.4 Related Activities An evaluation of the dispositioning of NCRs including the adequacy of the technical justification is the subject of Action Plan VII.a.2, "Non-conformance and Corrective Action Systems". 4.2 Participants Roles and Responsib111 ties The organizations and personnel that participated in this effort are described below with their respective work scope. i 4.2.1 TUGC0 Comanche Peak Project i l 4.2.1.1 Processed NCRs identified in this action { plan.

4.2.1.2 Obtained AMP analysis of bent and twisted terminal lugs. l l

Revision: 1 Page 6 of 9 4 RESULTS REPORT ISAP I.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.2 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed the final disposition of the NCRs. 4.2.2.2 Reviewed the AMP analysis. 4.2.2.3 Performed root cause, generic implications, and safety significance evaluations, if required. J 4.2.2.4 Personnel (prior to October 18, 1985) Mr. M. B. Jones, Jr. Review Team Leader Mr. E. P. Stroupe Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985) 1 M . J. J. Mallanda Review Team Leader Mr. J. R. Pearson Issue Coordinator

Mr. M. B. Jones, Jr. Third-Party Adviser Mr. E. P. Stroupe Third-Party Adviser 4.3 Qualification of Personnel Third-party participants in the implementation of this action plan met the personnel qualification requirements of the CPRT Program Plan and its implementing procedures.

Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel were governed by the applicable principles of Section III.K. " Assurance of CPRT Prograa Quality", of the CPRT Program Plan. s

4 Revision: 1 Page 7 of 9 l l RESULTS REPORT - ISAP I.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Procedures i Not applicable ) 4.5 Acceptance Criteria The acceptance criterion is as follows: The NCRs must be properly dispositioned by either justifying the "use-as-is" disposition or requiring replacement of the terminal lugs. 4.6 Decision Criteria The decision criteria are: 4.6.1 If the justification for using terminal lugs bent up to 90* can not be provided, they will be replaced. This was not necessary as described in.Section 5.0. 4.6.2 If the justification for using twisted terminal lugs cannot be provided. they will be replaced. This was ' not necessary as described in Section 5.0. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS Each of the NCRs dispositioned "use as is" for bent and twisted terminal lugs in the ITE Gould-Brown Boveri switchgear was reviewed

                          'by TNE and redispositioned to provide a more complete justification for the "use as is" determination. Significantly, the TNE review reflected that no terminal lug originally dispositioned "use as is" showed signs of fatigue or was bent in excess of 90*. Accordingly, based on the vendor-provided criteria, the terminal lugs were acceptable without further analysis or rework.

i ANP provided an Engineering Evaluation Report (including testing and analysis) supporting its 1984 position that bending an AMP terminal lug one time up to 90* was acceptable. This testing and analysis concluded that even with " moderate vibrations such as that j set up by heavy equipment running., we feel that the testing proves that the terminations will withstand such a condition without any detrimental affects". The ITE Gould-Brown Boveri switchgear terminations are not installed near vibrating equipment and will i

Revision: I Page 8 of 9 RESULTS REPORT ISAP I.a.5 (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) experience little, if any such vibration during their lifetime. Also, a metallurgical analysis of bent or twisted terminal lugs was performed by AMP to demonstrate that the mechanical strength of the terminal lugs was not degraded in such a way that the seismic , qualification of the terminal lugs was negated. ] i The AMP testing and analysis also reflected that terminal lugs I twisted to 45' (approximately the maximum possible twist without risking damage to the terminal lug *) were acceptable given the

                                                 " moderate" vibration described above.

The Electrical Review Team Leader (RTL) has reviewed the AMP Engineering Evaluatien Report and associated metallurgical analysis and confirmed that the original qualification of the subject terminal lugs is supported by AMP for terminal lugs that are bent to 90' or twisted to 45*. The Electrical RTL, using the redispositioned NCRs, performed an evaluation of the dispositions by a visual examination of all terminal lugs listed in the applicable NCRs written on the Unit 1 ITE Gould-Brown Boveri switchgear. All terminal lugs designated "use-as-is" were not bent more than 90* or twisted more than 45*. However, some of the "use-as-is" terminal lugs appear to have been replaced. The new terminal lugs also meet these criteria. One l terminal lug (NCR E-84-01074, terminal lug attached to terminal point PR-1) was dispositioned by TNE to be replaced. Even though this NCR has been closed by QE, the RTL has concluded that this terminal lug has not been replaced. NCR E-86-100831S was issued by TUGC0 to document this deviation. Closure of this NCR will specifically be examined by the RTL in accordance with Section 7.0 below. 1 Since the "use-as-is" dispositions of the referenced NCRs do not involve any discrepancies, safety significance, root cause and generic implications evaluations were not performed. However, the deviation noted above on NCR E-86-100831S has been forwarded to the QA/QC RTL in accordance with Appendix B, " Quality of Construction and QA/QC Adequacy Program Plan," to be included in the collective I evaluations of that plan. I 1 The Review Team Leader (M. B. Jones, Jr.) was informed by AMP that ! in preparing " twisted" specimens for testing, the maximum twist ' achievable without risking damage (e.g., cracking of the terminal lug's plating) was approximately 45'. l

Revision: 1 Page 9 of 9 RESULTS REPORT l ISAP I.a.5 l (Cont'd) J

6.0 CONCLUSION

S 1 In April 1984 AMP advised TNE that bending up to 90' of the subject l terminal lugs was acceptable. AMP further stated that bending from

j 90*-120* could be acceptable subject to an end-use engineering review. Prior to the TRT review, TNE determined that all terminal lugs that were bent in excess of 90* should be replaced. The actions performed by CPRT, augmented by AMP's testing and analysis of bent and twisted terminal lugs, showed that the original dispositioning of the NCRs at issue was technically acceptable. TNE's decisions pertaining to the appropriateness of l the April 1984 AMP criteria appear validated. The NCRs have all been redispositioned to provide a clear documented basis for acceptance of the existing equipment condition. 7.0 ONGOING ACTIVITIES Additional NCRs have been written by TUGC0 on bent and twisted lugs , on various equipment in Units 1 and 2. TUG.~0 has identified and l will review the NCRs that were written prior to February 1,1986. l Any that have the "use-au-is" disposition will be evaluated to assure that all non-conforming conditions have been addressed and , that required engineering justifications are adequate. CPRT will ! overview this activity and will issue a Supplementary Report when ! the overview is complete. The deviseien noted in Section 5.0 on NCR E-86-100831S was forwarded to the QA/QC RTL in accordance with Appendix B. " Quality of Construction and QA/QC Adequacy Program Plan," to be included in the collective evaluations of that plan. The evaluation of dispositioning of NCRs including the adequacy of technical justification is the subject of Action Plan VII.a.2, "Non-conformance and Corrective Action Systems". 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE The installation specification (2323-ES-100) has been revised to incorporate criteria for inspecting vendor furnished terminal lugs. This revision utilized the results of AMP's testing and analysis and provides assurance that bent and twisted terminal lugs will be appropriately addressed in the future on Units 1 and 2. 4

,5 . (-

  .g                                                                          i i

COMANCHE PEAK RESPONSE TEAM

                                                                          ~
                                                                            .k ACTION PLAN ISAP  I.b.3 i '

Title:

Conduit to Cable Tray Separar,1on Revision No. 4 Reflects Coments Description On Plan Prepared and Recomended by: .hM-Review Team , Leader Date 2 Approved by: Senier Review Team _ c 1 k,/ _ Date #/ /u /ri l

74- Revision: 4 Pago 1 of 5 ISAP I.b.3 Conduit to Cable Tray Separation

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Page J-42)

                                                                                                  "The TRT found no evidence that the existing G&H analysis for establishing the criteria for a 1-inch separation between rigid conduits and cable trays, as stated in G&H Electrical Erection Specification 2323-ES-100, had been evaluated by the NRC staf f for Comanche Peak. This analysis should have been referenced in the FSAR."

2.0 ACTION IDENTIFIED BY N'RC (NUREG 0797, Supplement No. 7 Item 6(e), Page J-44)

                                                                                                  "TUEC shall accomplish the following actions prior to fuel load:

Submit to the NRC the analysis substantiating the acceptability of the criteria stated in G&B electrical erection specification governing the separation between separate conduits and cable trays. This analysis shall be supported with the necessary documentation in sufficient detail to perform an independent evaluation of how these criteria were established based on the analysis."

3.0 BACKGROUND

Raceway separation criteria utilized in Gibbs & Hill electrical drawings and specifications were based upon the requirements of IEEE 384-1974 and Regulatory Guide 1.75 (Revision 1, 1/75). Although very specific criteria are provided in the standard and regulatory guide for separation between cable trays, the interpretation and application of that criteria for separation between conduits and cable trays is not specified. Documents internal to Gibbs & Hill were prepared to establish the engineering interpretation of required separation between j conduits and cable tray in accordance with es.'ablished criteria in the standard and regulatory guide. These documents were not submitted to the NRC staff for review because the interpretation was not considere2 a deviation to the standard or regulatory guide, but was c.,nsidered documentation supporting the implementation of these requirements. It is industry practice to act submit such i=plementing documents to the NRC.

R2 vision: 4 Pego 2_of 5 t ISAP I.b.3 (Cont'd) 4.0 C?RT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to substantiate the acceptability of the criteria governing the separation between l conduits and cable trays, and submit the evaluation and l supporting documentation to the NRC. To achieve this objective, the following tasks will be implemented

               -       Prepara Gibbs & Hill report compiling criteria
               -       Review report to substantiate separation criteria
               -       Submit report to NRC 4.1.1  Report Preparation l

Gibbs & Hill will prepare a report for TUGC0 presenting the methodology and criteria used in applying IEEE-384 (1974) and Regulatory Guide 1.75 (Revision 1, January 1975) to conduits requiring separation from redundant cable trays. Included will be a copy of a Sandia Report (" Cable Tray Fire Tests", SAND 77-1125C) which is the primary reference used in establishing the separation criteria. 4.1.2 Report Review The above report will be submitted to the Review Tean Leader and his third-party adviser for review. , 4 I l l

a. ,

Rsvision: 4 Page 3 of 5

ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 Report Submittal to NRC After the report has been reviewed and approved, it and any supporting documents will be submitted by TUGC0 to the NRC for review. An FSAR Change Request will be initiated to provide a description of the cable tray-to-conduit separation criteria in the FSAR.

4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope. 4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Assist the Review Team Leader in reviewing the report compiling the Gibbs & Hill criteria. 4.2.1.2 Submit, upon approval, the report to the NRC. 4.2.1.3 Personnel Mr. W. I. Vogelsang, T'JGCO Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Review the report compiling the Gibbs & Hill criteria. 4.2.2.2 Review NCRs and inspection reports, if any. l 4.2.2.3 Personnel (prior to October 18, 1985) Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.4 Personnel (starting October 18, 1985) Mr. J. J. Ma11anda, Review Team Leader Mr. R. J. Bizzak, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser l l

R3vicion: 4 4 , Pegs 4 of-5

     '                                                                            ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3   Gibbs & Hill                                                  l Prepare a report compiling the criterfa used      j 4.2.3.1 in confirming the adequacy of conduit-to-cable tray separation.

4.2.3.2 Personnel Mr. S. P. Martinovich, Senior Electrical Engineer l 4.2.4 Third-Party Adviser 4.2.4.1 Review the report compiling the Gibbs & Hill criteria. 4.2.4.2 Personnel Mr. L. D. Bates, Third-Party Adviser l 4.3 Qualification of Personnel Where tests or inspections require the use of certified ' inspectors, qualifications at the appropriate level vill be to the requirements of ANSI N45.2.6, " Qualification of Inspection. Examination, and Testing Personnel at Nuclear Power Plants." CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and specifically trained to the CPRT Program Plan. l l Third-party participants in the implementation of this action plan vill meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing .

procedures. I Other participants will be qualified to the requirement 3 of { the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan. I l 4.4 Procedures Not applicable. i l l l

       .                                                                              I w     -                                                              Revision:   4 f

Page 5 of 5 j ISAP I.b.3 i (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Acceptance Criteria The acceptance criterion for the report is that it demonstrate that the cable tray-to-conduit separation criteria meet the. intent of IEEE-384 (1974) and Regulatory Guide 1.75, Revision l

1. January 1975.

4.6 Decision Criteria If compliance with IEEE-384 (1974) and Regulatory Guide 1.75, Revision 1, January, 1975 cannot be adequately demonstrated, the conduits and cable trays will be modified, as appropriate, to achieve compliance. i

5 , T l CCMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I.b.3 !

Title:

Conduit to cable Tray separation REVISION 1 W Ab h Y$eAh> 9%blY 2d /f86 Issus Coordin e r // Date LA 1. htd4 A f4:n Lea'de r 3/zo/n Date / RJview Ti1,/ 0= U k Joh& W. Beck Chair =an CFRT-SET 3 /2 <. h <. Date 1 s

 .                                                                                                               3 Revision:      1 Page    1 of 13 3'

RESULTS REPORT ISAP I.b.3 Conduit to Cable Tray Separation il

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Page J-42)

                                     "The TRT found no evidence that the existing G6H analysis for establishing the criteria for a 1-inch separation between rigid conduits and cable trays, as stated in G&H Electrical Erection            i' Specification 2323-ES-100, had been ovaluated by the NRC staff for Comanche Peak. This analysis should have been referenced in the FSAR."

2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement No. 7, Item 6(e). I Page J-44)

                                     "TUEC shall accomplish the following actions prior to fuel load:

Submit to the NRC the analysis substantiating the acceptability of the criteria stated in C&H electrical erection specification governing the separation between separate conduits and cable trays. This analysis shall be supported with the necessary decurentation in sufficient detail to perform an independent evaluation of how these criteria were established based on the analysis."

3.0 BACKGROUND

Raceway separation criteria utilized in Gibbs & Hill electrical drawings and specifications were based upcn the requirements of IEEE 384-1974, "IEEE Trial-Use Standard Criteria for Separation of a Class 1E Equip =ent and Circuits", and Regulatory cuide 1.75, ) Revision 1, January 1975, " Physical Independence of Electric Systems". Although very specific criteria are provided in the standard and regulatory guide for separation between redundant

cable trays, the same degree of specificity is not provided for separation between conduits and cable trays.

All separation requirements in this report are for redundant cable trays and/or conduits. The vord " redundant" as used herein means that the cable trays and/or conduits requiring separation belong to different trains, i.e., Class 1E train A. Class IE train B, or non-Class 1E train C. Note that cable trays and/or conduits of the same train require no separation. i

Revis6cn: 1 7 Page' 2 of 13-3 RESCLTS REPORT ISAP I.b.3 (Cont'd) i

3.0 BACKGROUND

(Cont'd) Since Regulatory Guide 1.75, Revisien 1 January 1975, and IEEE 384-1974 do not specifically provide criteria for conduit-to-cable tray separation Gibbs & Hill originally interpreted these documents to require a one-inch mini =um separation between a safety-related conduit and an open cable tray when the conduit is below the top of the side rails of the cable tray. This interpretation was included in a Gibbs 6 H111 document entitled " Criteria for Separation of Class 1E Equipment and Circuits". This document was transmitted to the TUGC0 project for their information and use via. letter GTN-2441, dated February 19, 1973. The above criterion, along with separation requirements for safety-related conduits above cable trays, was added to Electrical Erection Specification 2323-ES-100 in the form of Design Change Authorization (DCA) 6132, dated November 16, 1979. This DCA also included all separation criteria for non-safety related_ conduit. Specification 2323-ES-100, Revision 2. dated January 1981, which incorporates DCA-6132, states in Section 4.11.1 that the Engineering drawings showing the plant layout utilized the separation criteria transmitted via Gibbs.4 Hill letter GTN-2441. The separation criteria, as stated in 2323-ES-100, are to provide "the necessary information for assisting the contractor in field routing the conduit . . . ." During the Gibbs & Hill review of DCA-15917, which authorized a reduction in the separation criterion for a conduit above an enclosed raceway from four inches to one inch, the adequacy of the existing one-inch separation criterion for safety-related cenduits and open cable trays was questioned. This issue was resolved by Gibbs & Hill memo EE-863, dated January 17,.1984, which included the Gibbs & Hill report and simplified analysis that the NRC-TRT reviewed on site (See Section 1.0). The' purpose of the memo was to establish the engineering interpretation of required separation between conduits and cable trays in accordance with established criteria in the standard and regulatory guide. This supporting documentation was not submitted to the NRC staff for review because the interpretation was not considered a deviation to the standard or regulatory guide, but was considered documentation supporting the implementation of these requirements. s

 .                                                                                                                          Revasion:                             ;

Page 3 of 13 6- RESULTS REPORT ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scoce and Methodology The objective of this action plan was to substantiate the acceptability of the criteria governing the separation between corduits and cable trays and to submit the evaluation and ; supporting docu=entation to the NRC. l To achieve this objective, the following tasks were implemented:

                                                                  -    Gibbs & Hill prepared a report compiling criteria and                                        j supporting analyses 1
                                                                  -    The Electrical Review Team reviewed the report substantiating the separation criteria                                                        ,
                                                                  -    The TUCCO Coordinator initiated the submittal of the report to the NRC 4.1.1  Report Preparation Gibbs & Hill prepared a report for TUGC0 presenting the methodology and criteria used in applying IEEE 384-1974 and Regulatory Guide 1.75. Revision 1 January 1975, to cenduits requiring separation from cable trays. Included was a copy of a Sandia Report
                                                                                                 ~

(" Cable Tray Fire Testr , SAND 77-1125C), which documents a series of tests funded "by the Nuclear Regulatory Com=1ssion to provide data needed for confirmation of the suitability of current design standards and regulatory guides for fire protection and control in water (cooled) reactor power plants". 4.1.2 Report Review The above report was submitted to the Electrical Review Team for review. 4.1.3 Report Submittal to NRC The TUCCO Coordinator submitted an TSAR Change Request to TUCCO Nuclear Engineering for submittal to the NRC for review. The FSAR Chtngs Request provides a q i description of the existing conduit-to-cable tray j separation criteria. Supporting documents are attached j to the FSAR Change Request. l l t

Revisien: 1 Page 4 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective work scope. 4.2.1 TUCCO Comanche Peak Project 4.2.1.1 Assisted the Electrical Review Team in reviewing the report compiling the Gibbs & Hill criteria. 4.2.1.2 Will submit, upon approval, the FSAR Change Request and supporting documents to the NRC. 4.2.1.3 Personnel Mr. W. I. Vogelaang, TUCCO Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed the report compiling the Gibbs & Hill criteria. 4.2.2.2 Personnel (prior to October 18, 1985) Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe. Issue Coordinator 4.2.2.3 Personnel (starting October 18, 1985) Mr. J. J. Hallanda, Review Team Leader Mr. R. J. Bizzak, Issus Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 Cibbs & Hill 4.2.3.1 Prepared a report compiling the criteria used in confirming the adequacy of conduit to-cable tray separation. i l

Revision: 1 Page 5 of 13 RESL'LTS REPORT ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3.2 Personnel Mr. S. P. Martinovich, Principal Engineer-Electrical 4.2.4 Third-Party Adviser (prior to October 18, 1985) 4.2.4.1 Reviewed the report compiling the Gibbs & Hill criteria. 4.2.4.2 Personnel Mr. L. D. Bates, Third-Party Adviser 4.3 Qualification of Personnel Third-party participants in the implementation of this action plan met the personrel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel were governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan. l 4.4 Procedures Not applicable. 1 4.5 Acceptance Criteria The acceptance criterion for the report was that it demonstrate that the conduit-to-cable tray separatien criteria meet the intent of IEEE 384-1974 and Regulatory Guide 1.75. Revision 1 January 1975. This was met as discussed in Section 5.0. 4.6 Decision Criteria If compliance with IEEE 384-1974 and Regulatory Guide 1.75 Revision 1, January 1975 could not be adequately demonstrated, the conduits and cable trays would have to be modified, as appropriate, to achieve ccepliance. This was not necessary as diaeussed in Section 5.0.

~* Revision: 1 Page 6 of 13 i RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summarv A report based on the information contained in Cibbs & Hill memo EE-863 was prepared by Gibbs and Hill. This report addressed those separation distances between a conduit and an ! cpen cable tray which did not meet the criteria given in IEEE 384-1974 for open cable trays. The primary reference used to substantiate the conduit-to-cable tray separation criteria was a Sandia report documenting a series of electrically initiated cable tray fires. One case which is not directly evaluated in the Sandia report is the case of a safety related conduit one inch beside or below an open cable tray. The justification presented in the Gibbs & Hill report for the one inch separation case =entioned above was a simplified analysis from EE-863 which utilized cold wall heat flux values from the Sandia report. The above Gibbs & Hill report, originally issued in September 1984, was reviewed by the Electrical Review Team during the late 1984/early 1985 ti=e frame and revised several ti=en to incorporate co==ents. Subsequent to the above review cycle, questions re=ained on the simplified analysis presented in the report. To alleviate these concerns, Gibbs & Hill perfor:ed computer analyses in the su=cer of 1985, using an alternate methodology, to substantiate the si=plified analyses. Although the computer analyses were in agreement with the results of the si=plified analysis, a subsequent review of the report and analyses in the last quarter of 1985 by the Electrical Review Team identified inconsistent assumptions in the simplified analysis which required subsequent ! justifications. A final report utilizing a revised ce=puter analysis was completed and issued to TUGC0 by Cibbs & Hill. The final report and analyses have been reviewed by the Electrical Review Team Leader and Issue Coordinator. The conclusion is that the above documents provide adequate justification of the existing conduit-to-cable tray separation; therefore, no plant modifications are required. A su= mary of the report is given in the following section. 5.2 Conduit / Cable Trav Separation Criteria The separation criteria in Gibbs & Hill Electrical Erection Specification 2323-ES-100 are graphically presented on Drawing 2323-El-1702-02, Revision 2. " Cable and Raceway Separation Typical Details". l 5 l

l t Revision: 1 Page 7 o f 13 - l 5 RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCL'SSION OF RESL*LTS (Cont'd) The separation criteria shown on Gibbs & Hill Drawing j 2323-El-1702-02 apply only when hatards are limite'd to electrically-initiated fires due to failures or faults internal to electrical equipment or raceways. This is consistent with the definitions given in IEEE 384-1974 for the I cable spreading area and general plant areas. 1' l The criteria given in IEEE 384-1974 for separation of L redundant ecble trays for the above areas are: Cable Spreading Area - Both I foot horizontally l cable trays are open ventilated 3 feet vertically trays. General Plant Areas - Both 3 teet horizontally cable trays are open ventilated 5 feet vertically j trays. Cable Spreading Area and 1 inch horizontally General Plant Areas - Both 1 inch vertically cable trays are enclosed. The IEEE standard also allows the separation distances to be alternative established by analyses / testing "to deter =ine the fla e retc-dant characteristics of the proposed cable j installation. . . ." Although the above specific criteria for redundant, open cable trays are provided in IEEE 364-1974 and Regulatory Guide 1.75, Revision 1, January 1975, the sa=e degree of specificity is not provided for separation between conduits and cable trays. However, the above separation distances for open cable trays could be reduced when one train of circuits is in conduit since a barrier

now exists between the two redundant trains.

The current CPSES conduit-to-cable tray separation criteria are depicted in Details 45 thru 49, $2 thru 55, and 57 of Drawing 2323-El-1702-02. A su= mary of these criteria follows: The IEEE 364-1974 definition of a barrier is "a device or structure interposed between Class IE equipment or circuits and a potential source of da= age to limit da= age to Class lE systems to an acceptable level." i

 ,                                                                                                           Revision:      1 Page    8 of 13 RESL*LTS REPORT ISAP I.b.3 (Cont'd) 5.0 DiPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESL*LTS (Cont'd)

Cable Spreading I foot horizontally When conduit Area 2 feet vertically elevation

is above the top of the cable tray side rails or when the cable tray is vertical.

General Plant 3 feet horizontally When conduit Area 3 feet vertically elevation

is above the top of the cable tray side rails or when the cable tray is vertical.

Cable Spreading i inch horizontally When conduit Area and General 1 inch vertically elevation

is below Plant Are.as the top of the cable tray side rails (cable tray horizontal), conduit is non-safety related, or cable i

tray is enclosed. In comparing the conduit-to-cable tray separation criteria y given above to the criteria provided in IEEE 384-1974 for open l cable trays, the following three categorfas of differences are noted: Category 1 - Non-Safety Related Conduit Separation between conduit and cable tray is one inch when conduit is non-safety-related. Category 2 - Safety-Related Conduit Above Cable Trays Vertical distances are 2 feet /3 feet f or safety-related conduits over open cabic trays in the cable spreading / general plant areas, respectively. l l Category 3 - Safety-Related Conduit Below the Top of the Cable Trey Side Rails feparation between conduit and cable tray is one inch when conduit elevation is below the top of the cable tray side rails. Conduit IIevation is top of conduit. 3 1 l

[ ! Revision: ; Page 9 of 13 p

                                                                                                                                     RESULTS REPORT ISAP I.b.3 l                                                                                                                                                  (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Category 1 - Non-Safety-Related Conduit The CPSES minimum separation for non-safety-related conduits adjacent to safety-related cable trays is one inch, regardless of orientation. The non-Class IE circuits in the conduit do not have to be protected from a cable fire in the cable tray since the non-Class 1E circuits do not provide a safety function. However, the Class IE cables in the cable tray do have to be protected from a fire in the conduit. The cenduit in combination with a one inch air space vill provide adequate protection to the safety-related cable tray. This configuration is similar to Figure 5 of IEEE 384-1974 It should be noted that a fire in a conduit represents a less severe source of damage than a fire in an enclosed cable tray since: Conduit size is limited to five inches thus limiting the volu=e of cables contained. Threaded connections provide an essentially air-tight

                                                                                                                          =edium which inhibits internal combustion and effectively isolates internal events frem the surroundings.

The curved surface of the conduit provides a radial distribution of radiant heat and, therefore, less favorable heat transfer characteristics to or frem an adjacent cable tray than a flat surface of equivalent area. Category 2 - Safety-Related Conduit Above Cable Trays The basis for the adequacy of vertical separations given in this category is electrically initiated fire tests conducted by Sandia Laboratories and presented in Report SAND 77-1125C.

                                                                                                               " Cable Tray Fire Tests." One of the objectives of these tests was to use cables representative of those used in the nuclear industry. An industry survey of 13 leading architect-engineering fir =s, 13 utility companien, and 13 cable manuf acturers was perfor=ed. Twenty (20) different cable types were screened on the basis of popularity of use, small scale eleecrically initiated cable insulation fire tests. UL FR-1 flame test, and pyrolyzer and thermal chromatograph testing (which measured insulation outgassing as a function of temperature). The cable constructions tested are i

 .                                                                                             Revision:     1 Page  10 og 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) representative of those used at CPSES. The cables used at CPSES comply with IEEE 383-1974, " Standard for Type Test of Class IE Electrical Cables, Field Splices, and Connections for Nuclear Power Generating Stations". The cables used in the Sandia tests " vere capable of passing IEEE Standard 383-74".

Therefore, the Class 1E cables at CPSES and the cables used in the Sandia tests have similar flame-retardant characteristics. The Sandia testing showed that, for an electrically initiated ceble tray fire, cables in an open tray located 10.5 inches vertically above the tray with the fire did not burn. All circuits in the cables above the fire remained functional. As noted above, the CPSES criteria for safety-related conduits located above cable trays is a minimum of two feet. It should be emphasized that the Sandia tests were performed using exposed cable; therefore, the CPSES criteria are even more conservative since the cables at CPSES are enclosed in a barrier. Some of the more significant observations of the nature of electrically initiated fires noted in the Sandia Report are: The fire characteristics do not vary greatly from one , cable fire to another. 1 i The intense period of the fire at a particular locacion l lasts between 40 and 240 seconds before die-out begins to occur.

                                               -   The luminous zone of the fire is optically thin which means that t? sajor heat transfer mechanis: is convection versus radiation.

Based on the above, given a specified separation, the worst configuration is conduit over the cable tray since the conduit will be exposed to both convective as well as radiation heat i transfer. Since the exposed cable 10.5 inches above the fire j remaina 1 functional, any cable enclosed in a conduit (which j provides additional heat protection for the cable) 10.5 inches 1 or more from an electrically initiated fire vill also remain i functional. l t

7-Revision: 1 Page 11 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) Category 3 - Safety-Related Conduit Below the Top of the Cable Tray Side Rails The only case where a safety-related conduit at CPSES can be less than 10.5 inches from an open cable tray is when the conduit elevation is below the top of the cable tray side rails. The major heat transfer mechanism for this configuration is radiation. Based on the above noted characteristic of the Sandia test fires (i.e. the lu=inous zone of the fire is optically thin), radiation is a minor part of the heat transferred from the fire to objects immersed in the flame. In order to quantify the response of a conduit beside or below a cable tray, a computer analysis was performed by Gibbs & Hill for the case of a conduit one inch directly below the fire. (Note that conduits alongside cable trays are partially blocked from the radiation from the flame by the cable tray side rails.) Cable fire parameters taken frem the Sandia Report were used as inputs to this analysis. The above analysis included the following conservatism:

                    -  The fire data used in the analysis was for the October 5, 1976, fire test, one of the most intense and longest duration fires studied.
                    -  The radiation heat flux applied to the conduit was taken just slightly above the burning tray (i.e., in the flame) rather than ore inch away from the flame.
                    -  The radiation heat flux, based on the maxi =um flame temperature, was held constant from 30 seconds to 240 seconds. The test data showed that temperatures measured by a thermocouple in the flame varied from 1150*F to 700*F during this period.
                     - The flame diameter was held constant at eight inches.
                     - No blockage was assumed by other cables in the cable tray with the fire.
                     -  The cable enclosed in the conduit was assumed to be at the same temperature as the conduit. No credit was taken for the cable acting as a haat sink, f

k _____________________j

Revision: 1 Page 12 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) The results of the analysis showed that the conduit exceeded 302*F (150*C) for approximately 4-1/4 minutes with a maximum i temperature of 357'T (181*C), assuming an ambient temperature l of 122*F (50*C). The Electrical Review Team reviewed the manufacturers' data for the cables used at CPSES. All cables are qualified for 302*F (150'C) for a minimum period of one week. Additionally, the cables with silicone insulation were tested at a minimum temperature of 392'T (200*C) for seven days and remained functional. Anaconda FR-EP cables were qualified for a LOCA l environment by testing at 385'T (196'C) for two twelve-minute l periods. The remaining cables were LOCA tested at a minimum of 345'T (174*C) for a minimum of four hours. The cabirs subjected to the abore tests to simulate LOCA envirenzental conditions remained functional. Additional evidence which supports the adequacy of CPSES conduit separation one inch below cable trays is provided in the results of the propane-fueled exposure fire tests also conducted by Sandia in which conduits and trays were included. In these tests, fourteen (14) trays were stacked seven (7) high by two (2) wide separated vertically 10.5 inches. Directly below each tray (except for the bottom tray exposed to the propane-fueled source) was a conduit containing additional cables. Although all circuits in the conduits above the third tray failed during the exposure fire (the higher conduits experiencing heat input from all fires below them), circuits in the lower two (2) conduits maintained circuit integrity throughout the duration of the fire. Considering that the fire in the lower two (2) trays was more severe than in an electrically initiated fire, being larger in size and ef longer duration, the results provide an indication of the adequacy of protection offered by conduits installed with an air gap of one inch during the less severe electrical firt. ; I 5.3 FSAR Change Recuest Submittal The TUCCO Coordinator submitted an FSAR Change Request to TUGC0 Nuclear Engineering for submittal to the NRC for review. The FSAR Change Request provides a description of the existing conduit-to-cable tray separation criteria. Supporting documents were attached to the FSAR Change Request. s

                                                                            .___._.___.____________________m

Revision: 1 Page 13 of 13 RESULTS REPORT ISAP I.b.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.4 Classification and Evaluation of Discrepancies No design deviations were noted in the implementation of this action plan. However, two design observations were noted. The first observation was that analyses did not exist at the time that the criteria for conduit-to-cable tray separation were placed in design and construction documents. The basis for the criteria appeared to have been engineering judgment based on experience with other nuclear projects. The second observation was that inconsistent assumptions used in the Gibbs & Hill simplified analysis verifying the one-inch separation criteria were not discovered during the design verification process. Since no deviations were found, no root cause analysis was p e rf o r=e d . The observations were too few in number and too li=ited in scope to identify a trend. Therefore, the facts relating to these observations were transmitted to the Design Adequacy Review Team Leader in accordance with Appendix A.

                         " Design Adequacy Program Plan", to be included in the collective evaluations of that plan.

6.0 CONCLUSION

S The established conduit-to-cable tray separation criteria meet the intent of IEEE 384-1974 and Regulatory Guide 1.75, Revision 1 January 1975. No corrective actions are required. 7.0 CNGOING ACTIVITIES The TSAR Change Request and supporting documents have been issued to TUGC0 Nuclear Engineering (TNE) by the TUCCO Coordinator. TNE will transmit the information to TUCCO Licensing, which is the for=al channel for submitting information to the NRC. The design observations noted ir. Section 5.4 vers forwarded to the DAP RTL in accordance with Appendix A. "Cesign Adequacy Program Plan", to be included in the collective evaluations of that plan. 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Since no design deviations were found, no corrective actions were required.

s s- . ( I

      .                                                  COMANCHE PEAK RESPONSE TEAM ACTION PLAN                                          )

i ISAP II.b I I

Title:

Concrete Compression Strength I' Revision No. 0 1 2 3 Revised to Reflect Incorporates Reflects Cerment: Description Original Issue NRC Comments SSER on Dlan ( .#I

                                               /0 6 - f6 Prepared and Recommended b.y:      gj
                                                                                             /           /f.,'I'/

g'A , Review Team Leader . j J .< , w-Date l0 ~~S ' 0 k 1 i f b'( 012 !S$ *'I! b ./ wu 1 ^::::r A re.= d%4 7 - w o. h n m o. n Oe e \ n A+s l 'n L W wr!rr~ bh+ha

                                                       /      i 1

. Rcvision: 3 Pcgs 1 of 11 ISAP II.b . Concrete Compression Strength

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TRT investigated allegations that concrete strength tests were falsified. The TRT reviewed an NRC Region IV investigation (IE Report No. 50-445/79-09; 50-446/79-09) of this matter that included interviews with fifteen individuals. Of these, only the alleger and one other individual stated they thought that falsification occurred, but they did not know when or by whom. The TRT also reviewed slump and air entrainment test results of concrete placed during the period the alleger was employed (January 1976 to February 1977) and did not find any apparent variation in the uniformity of the parameters for concrete placed during this period. Although the unifermity of the concrete placed appears to minimize the likelihood that low concrete strengths were obtained other allegations were raised concerning the falsification of records associated with slump and air content tests. The Region IV staff addressed these allegations by assuming that concrete strength test results were adequate. Furthermore, a number of other allegations dealing with concrete placement problems (such as deficient aggregate grading and concrete in the mixer too long) were also resolved by assuming that concrete strength test results were adequate. The TRT agrees with Region IV that, while the preponderance of evidence suggests that falsification of results did not take place, the matter cannot be resolved completely on the basis of concrete strength test results, especially if there is any doubt about whether they may have been falsified. Due to the importance of the concrete strength test results, the TRT believes that additional action by TUEC is necessary to provide confirmatory evidence that the reported concrete strength test results are indeed representative of the strength of the concrete installed in the Category I concrete structures. 2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall determine areas where safety-related concrete was placed between January 1976 and February 1977, and provide a program to assure acceptable concrete strength. The program shall include casts such as the use of Schmidt Ha=mer Tests on a random sample of the concrete in areas where safety is critical. The program shall include a comparisen of the results with the results of tests perfor=ed on concrete of the same design strength in areas where the strength of the concrete is not questioned, to determine if any significant variance in strength occurs. TUEC shall submit the program for perfor=ing these tests to the NRC for review and approval prior to performing the tests.

q

R vision: 3 Pege 2 of 11 ISAP II.b (Cont'd)

3.0 BACKGROUND

f 1 l Falsification of concrete strength tests is alleged to have 1 occurred between January 1976 and February 1977. Air ] entrainment and slump tests have been reviewed, and no I apparent variations were found in the the uniformity of the parameters for concrete placed during the allegation time frame. Because these parameters were in accordance with the laboratory approved concrete mix designs this reduces the chances that low concrete strengths were obtained. Concrete compressive strength tests have been used to resolve allegations of falsifications of slump and air entrainment ] tests and allegations dealing with concrete placement problems j (such as deficient aggregate grading and concrete in the mixer " too long). Due to the importance of concrete compressive

                                           . strength tests, the.TRT requested that additional testing be performed by TUEC to confirm that concrete strength tests performed on the concrete in question are representative of the actual concrete strength. Therefore, TUEC has decided to                    3 implement a program to test the concrete in question for verification of acceptable strength.

4.0 CPRT ACTION PLAN 4.1 Scoce and Methodology The objective of this action plan is to verify the quality cf i the concrete in question. The CPRT tasks to be i=plemented to I achieve this objective are: ! I

                                              -      Define the population of concrete poured during the time period in question and a second population outside of this time period for comparison.
                                              -      Perfor= Sch=ide Hac=er Tests on a random sample of concrete frem each population.

s Revision: 3 Pega 3 of 11 l ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

                -        Compare the results of the Schmidt Hammer Tests of the two populations and assess the significance of any differences observed relative to the design value of the concrete compressive strenFth.

These tasks are described in more detail in the following paragraphs. The relative strengths of concrete poured during the period in l question (concrete at issue, or CAI) and the concrete poured ! outside this period (control concrete, or CC) will be compared l using the Schmidt Hammer Test as a measure of strength. The Schmidt (Rebound) Hammer Test, a non-destructive test, will be conducted in accordance with ASTM-C805-79 " Standard Test l Method For Rebound Number of Hardened Concrete". The Schmidt Ha=mer is essentially a concrete hardness tester which measures the rebound of a spring loaded plunger after it has struck a smooth concrete surface. Using this indirect test of strength, the two populations of concrete will be compared empirically and statistically. In addition to reporting the raw rebound number data, statistical su=maries such as means and variances will be computed. Both parametric and non-parametric distributions may be considered for the two populations. For parametric distributions, goodness-of-fic tests will be performed on the samples. l Concrete cylinder data for the two populations will also be obtained, reviewed, and used for reference. The two populations of hac=er rebound values will be ce= pared at the tenth percentile level. The tenth percentile level is selected as a point of comparison based on ACI Standard 214-65, " Recommended Practice for Evaluation of Compression Test Results of Field Concrete", which gives the general guideline that no more than one in ten cylinder ce=pression tests fall below the design strength. The populatten of rebound numbers from the control concrete will be used to establish a target tenth percentile rebound number. The tenth percentile rebound value of the concrete at issue will then be compared with this carget value and other target values which are fractions of the tenth percentile of the control concrete. Hypotheses that the tenth percentile rebound number for the CAI is greater than or equal to various target values will be tested at a minimum level of significance of 5 percent. The reason for considering more than one target value is based on a preliminary review of data (including cylinder data) which indicates that at the repulation tenth percentile level ] l l i I i J

     ^
  '-                                                                                    Rsvision:-        3 Pcgn     '4 of 11 ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) the CAI may be lower than the CC.         How much lower may be quantified by testing hypotheses using different target values which_are fractions of the CC tenth percentile rebound value.

In addition, the significance level at which a hypothesis is just accepted will be determined. A higher significance level passed indicates a greater confidence that the hypothesis is true. If it-is determined that the tenth percentile of the CAI rebound values is not sufficiently close to that of the CC, either further testing will be performed to verify that_the tenth percentile concrete strength for the concrete at issue is greater than the minimum' design strength, or an evaluation will consider the significance of a lower strength concrete. 4.1.1 Test Program 4.1.1.1 Engineering shall determine the areas where concrete was placed in Category I structures _ between January 1976 and February 1977. 4.1.1.2 From these areas, engineering shall determine the number of concrete truck loads for which part of the concrete of that truck load is exposed and testable. 4.1.1.3 Each truck load identified as exposed and' testable will be assigned a unique number. 4.1.1.4 Grid areas corresponding to these truck loads will be selected at random to be tested. 4.1.1.5 The concrete surface in a selected area shall be prepared for testing per ASTM C805-79. 4.1.1.6 The prepared areas shall be tested in accordance with ASTM C805-79. 4.1.1.7 Engineering shall determine the areas where concrete was placed in Category I structures between March 1977 and August 1977. 4.1.1.8 Trom these areas, engineering shall determine the nu=ber of concrete truck loads for which part of the concrete of that truck lead is exposed and testable. 4.1.1.9 Each truck load identified as exposed and testable will be assigned a unique number. { I i

R3 vision: 3 Pass 5 of 11 f ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.1.10 Grid areas corresponding to these truck loads will be selected at random for testing. 4.1.1.11 The concrete surface in a selected grid area shall be prepared fer testing per ASTM C805-79. 4.1.1.12 The prepared areas shall be tested in accordance with ASTM C805-79. 4.1.1.13 If necessary, concrete of known strength (determined by compression testing of core samples) will be Schmidt Hammer tested to calibrate hammer rebound numbers with concrete strength. This contingency is described below. 4.1.2 Sampling Plan At Comanche Peak concrete placement quality procedures were based on required air entrainment and slump tests to be performed on each truck load. Test cylinders from the first truck load and every tenth truck load thereafter were required to verify quality. These procedures were based on ASME-ACI 359 and ACI 318 which reference appropriate ASTM standards. Since the original quality control program was based on the unit I of a truck load, TUEC will use a truck losd as the unit to be tested in the present quality evaluation. This is consistent with the implicit assumption that a truck lead represents the smallest unit of concrete with uniform =aterial properties. The area for testing will be limited to the exposed surface area where the Schmidt Ha=cer Test can be performed. The determination of the number of truck loads which were placed as exposed testable concrete will be determined as fo11ews:

                              -      Number of truck loads (slabs on ground) =

(l'0" depth X surface area) / 10 yd3 per truck

                              -      Number of truck loads (suspended slabs, columns, valls) = Total cubic yards / 10 yd                                                            8 per cruck For deep slabs placed against the ground, a depth of one foot is used because during placement vibrators were used causing the concrete to flow and level out.

Thus only the truck loads placed the last foot of the

                                                   . -__-____ ___-._____-__________-_ __ ____                                                  a

Rsvision: 3 Pege 6 of 11 ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) slab would be exposed. For suspended slabs between 18 and 24 inches, the total number of truck loads is distributed equally to the top and bottom halves of the slab. For suspended slabs between 24 and 46 inches, the volume of concrete is split into three equal quantities, with one third at the top, one third on the bottom, and one third in the middle of the slab. Only the top and bottom layers are assumed to be testable. Engineering has determined that there were 326 concrete placements in Category I structures between January 1976 and February 1977. Of these, 198 vers identified l as being accessible for surface testing. It has been determined that the total number of truck loads corresponding to exposed surface concrete is approximately 1305. A similar number of truck loads ! will be used to define the population of concrete not in question. Both concrete populations will be randomly sampled to a sanple size of at least 100. The number 100 was chosen as an upper bound on a practical sample size for the statistical comparison of the two populations and is not based on Appendix D. i 4.2 Participants Roles and Resoonsib111 ties The organizations and personnel that will participate in this effort are described below with their respective scopes of work. 4.2.1 TUCCO Nuclear Engineering (TNE) - Civil / Structural Discipline i I 4.2.1.1 Scope

                                                                          -     Concrete population determination
                                                                          -     Sample selection
                                                                          -     Locate test areas and prepare operational 1
                                                                          -     Assistance in evaluation of test         )

data and preparation of Results l Report 4.2.1.2 Personnel Mr. R. Hooton TNE Civil / Structural Discipline Supervisor l J

                 ..                                                                                                                                                                                            Revision:      3 Page    7 of 11 ISAP II.b                                     '

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Mr. C. Corbin Civil Engineer 4.2.2 Brown & Root 4.2.2.1 Scope l

                                                                                                                                                                               -     Prepare concrete test surfaces 4.2.2.2   Personnel Craft personnel as required 4.2.3                                                    Third-Party Activities 4.2.3.1   Scope
                                                                                                                                                                               -      Review of sample selection
                                                                                                                                                                               -      Perform ha=mer tests
                                                                                                                                                                               -      Document tests
                                                                                                                                                                                -     Review test data
                                                                                                                                                                                -     Review and statistical evaluation of test results
                                                                                                                                                                                -     Preparation of Results Report 4.2.3.2   Personnel Mr. H. A. Levin        TERA, CPRT Civil /

Structural Review Team Leader Dr. J. R. Honekamp TERA, TRT Issues Manager Dr. F. A. Webster JBA Associate (CPRT Statistics Advisor) Dr. D. Veneziano MIT Professor of Civil Engineering (Engineering Statistical Consultant) Mr. G. Lagleder S'n'RI . Manager (Testing and Inspection)

R: vision: 3 Pcge 8 of 11

          -                                              ISAP II.b (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Personnel Qualification Requirements Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of                ,

Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT t.tird-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and trained to the applicable inspection procedures. i Third-party participants in the implementation of this Action Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K " Assurance of CPRT Program Quality", of the CPRT Program Plan. 4.4 Acceptance Criteria Three possible hypothesis tests will be considered for the evaluation of ha==er rebound data, and one (or ones) selected with the most power. The three test methods include: 4.4.1 Method A tests whether the tenth percentile rebound 4 value of the CAI is greater or equal to the target value of the CC, where both populations are assumed to ] i be normally distributed. j i NOTE: The target value is defined as the tenth l percentile or a fraction of the tenth ) percentile value. ! 4.4.2 Method 3 tests whether the percentage of rebound values in the CAI population above the target value of the CC is greater or equal to 90 percent. In this test the CC l population is assumed to be normally distributed for purposes of establishing the target value (which may be i defined as the tenth percentile or a fraction thereof), l but the distribution of CAI rebound values is unspecified (non-para =etric). l 4.4.3 Method C tests whether individual CAI rebound data

values belong to the same distribution as the centrol l

L__ ________

Ravision: 3-

        -                                                                                                                                               Pagn   9 of 11 i                                                                                         ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) concrete rebound values. No assumptions are made regarding either population distribution (non-parametric).

Although the power functions for these three methods.are not directly comparable, preliminary indications are that both Methods A and 3 should be utilized, since they are of similar power when the CAI rebound data is assumed normally. distributed in Method B. Method C appears co have very little power, and will therefore not be used to evaluate the data. Based.on the sample outcomes for the two concrete populations, a test statistic will be computed and the hypotheses regarding the concrete at issue will either be accepted or rejected at the 5 percent level of significance. In addition,'the level of significance at which the hypotheses would just be accepted will be' determined. If after reviewing the results of these hypothesis tests and I the cylinder data, the CAI population is found to be significantly lower than the CC population at the tenth percentile level, then a decision will be made to either calibrate the Schmidt Hammer Test to concrete of known strength, or to test cores from the CAI. If it is decided to calibrate the Schmid; Hammer Test, concrete samples of known strengths and of similar age as the concrete in question will be used to calibrate the hammer rebound values. The rebound values for the concrete in question, will then be converted to cylinder strengths taking into account the uncertainty in the conversion. If the tenth percentile strength is greater than the minimum specified the design strength, f', it will be concluded that the strength of the concrete in question is acceptable. If not, additional alternatives (e.g. analysis or further testing) will be considered. Any such decisions will be documented as a revision to this action plan. I I l l l l l 1

Revision: 3 Pcgs 10 of 11

ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Decision Criteria The action identified by the NRC (Sectibn 2.0) will be considered complete after all Schmidt Hammer Tests have been completed, the results statistically analyzed, and the two concrete populations compared.

r. If the comparison indicates a significant difference in the two populations, then a decision will be made to further evaluate the CAI in accordance with Section 4.4 1

l l i i i m__________________ . . _ _ _ _

    ,,                                                                                                                                                                                           Revision:               J
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    '                                                                                                                                                          ISAP II,b (Cont'd)

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q s l i l l COMANCHE PEAK RESPONSE TEAM RESULTS REPORT I i l ISAP: II.b

Title:

Concrete Compression Strength

i REVISION 1 l

l N 1/ 1 JIull4 1ss~e Cderfin(tor ' 1b7lf4 Date/ /- w s4 n

w~ 1 I D ReviefTeai Leabr* V Date' '

                 %           o 2w-JohpW. Beck, Chair =an CFRT-SRT
                                                   ~            t/z r O c.

Date ' l j

1 s Revisi: : ) p Page 1 cf 3; !

 ,                                                                                                    i RESULTS REPORT r

ISAP II.b Concrete Co:pression Strength f i

1.0 DESCRIPTION

OF ISSUE ' 1 The TRT investigated allegations that concrete strength tests were falsified. The TRT reviewed an NRC Region IV investigation (IE i Report No. 50-445/79-09; 50-446/79-09) of this matter that included j interviews with fifteen individuals. Of these, only the alleger and one other individual stated they thought that falsification occurred, but they did not know when or by whom. The TRT also i reviewed slu=p and air entrainment test results of concrete placed during the period the alleger was employed (January 1976 to February 1977) and did not find any apparent variation in the unifor=1ty of the parameters for concrete placed during this period. Although the uniformity of the concrete placed appears to minimize the likelihood that low concrete strengths were obtained, other allegations were raised concerning the falsification :f records associated with slu=p and air content tests. The Region IV staff addressed these allegations by assu=ing that concrete strength test results were adequate. Furthermore, a number of other allegations dealing with concrete placement problems (such as deficient aggregate grading and.cencrete in the mixer too leng) were also reselved by assuming that concrete strength test results were adequate. The TRT found that the preponderance of evidence suggests that falsification of results did not occur. However, since a nu:ber of other allegations were resolved on the basis of concrete strength results, the TRT believes that action by TUEC is recuired to provide confir=atory evidence that the reported concrete strength test results are indeed representative of the strength of the concrete placed in the Category I concrete structures. 2.0 ACTION IDENTIFIED Accordingly. the NRC outlined the folleving action: TUEC shall determine areas where safety-related concrete was placed between January 1976 and February 1977, and provide a program to assure acceptable concrete strength. The program shall include tests, such as Schmidt Ha==er tests, on a rando: sa:ple of the concrete in areas where safety is critical. The program shall include a comparison of the results with the results of tests perfor=ed on concrete of the sace design strength in areas where the strength of the concrete is not questioned, to determine if any significant variance in strength occurs. TUEC shall submit the progra: fer performing these tests to the NRC for review and approval prier to perf or=ing the tests. ___ _.._._..___..m_-_..._..J

l f g Revist: : ; 1 Page 2 :f 3; RESULTS REPORT ISAP II.b (Cont'd) l

3.0 BACKGROUND

1 Falsification of concrete strength tests is alleged to have occurred between January 1976 and February 1977. Air content and l slump data were reviewed by the TRT and no apparent variations were i found in the the uniformity of the parameters for concrete placed during the allegation time frame. However, concrete compressive strength tests have been used by the NRC to resolve previcus allegations of falsifications of slump and air entrainment tests and allegations dealing with concrete placement problems (such as deficient aggregate grading and concrete in the mixer too long). Due to the importance of concrete compressive strength tests in assessing the allegations the TRT requested that additional testing ] be performed by TUEC to confirm that concrete strength tests l l performed on the concrete in question are representative of the l actual concrete strength. Therefore. TUIC implemented a program to test the concrete-at-issue for verification of acceptable strength. 4.0 CPRT ACTION PLAN 4.1 'Sceee and Methodology , I This action plan was designed to verify the quality ef the concrete-at-issue. It was proposed that the relative 3 strengths of concrete poured during the period in questier ] (concrete-at-issue. or CAI) and concrete poured during the j

                                                   'six months im=ediately following this paried (control             l concrete. or CC) be co= pared using the Schmidt Hammer test as    1 a relative measure of strength. This ti=e period for the CC was selected to minimize any effect of aging on the comparison of the two sets of hammer data and to provide approximately equal volumes of concrete for the CAI and CC. The Schmidt (Rebound) Hammer test. a non-destructive test, was conducted in accordance with ASTM-C805-79 " Standard Test Method Fer Rebound Number of Hardened Concrete" (Reference 7.1). The Schmidt Ha=cer is essentially a concrete hardness tester which measures the rebound of a spring loaded plunger after it has struck a smooth cencrete surface.

Using this indirect test of strength, those portions of the two populations of concrete that were accessible for surface I testing have been compared empirically and statistically. In addition to recording the raw rebound number data and averste indication for each test, statistical se=maries such as means I and variances. have been computed for both CAI and CC l l l l t

s

   . .                                                                             nevisi: :

Page 3 ef *. RESUt!S rep 0RT I ISAP II.b 1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l populations._ Both normal and unspecified (non-parametric) distributions have been considered for the populations. { Fer 1 the nor=al distribution assumption, goodness-of-fit tests of the sample data were performed. Concrete cylinder data for the two populations have also been obtained, reviewed, and used for reference (see Section 4.4). The tu~ <opulations of average hammer indications have been compared at the tenth percentile level. The tenth percentile is selected as a point of comparison based on the American Concrete Institute (ACI) Standard 214-65, " Recommended Practice for Evaluation of Compression Test Results of Field Concrete" (Reference 7.2), which gives the general guideline that no more than one out of ten cylinder co=pression tests shall fall below the design strength. The population of average han=er indications for the control concrete was used to establish a tenth percentile target and the tenth percentile average hammer indications for the concrete-at-issue was then compared with this target value. Other CC target values (i.e., fractions of the CC tenth percentile) were also used for comparison. Hypotheses that the centh percentile for the CAI is greater than or equal to various target values were tested at a minimum significance level of l five percent. In addition, the significance level at which an hypothesis is just accepted was deter =ined. A higher significance level passed indicates a greater confidence that the hypothesis is true. 4.1.1 Test Progra: 1 4.1.1.1 TUGC0 Nuclear Engineering Civil Structural ' (TUCCO) deter =ined the areas where concrete was placed in Category I structures between ; January 1976 and February 1977 (Reference l 7.3). 4.1.1.2 Fron these areas. TUCCO determined the nu:ber of truckloads of concrete for which part of the concrete of that truckload !* expesed and testable (Reference 7.3). 4.1.1.3 Each truck 1 cad identified as exposed and testable was assigned a unique number (Reference 7.3). s t.________________

s 'evis : : . Pago e cf 3-. RESULTS REPORT ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.1. 4 Grid volu=es corresponding to these truckloads were selected at rande= to be tested (Reference 7.3). 4.1.1.5 The concrete surface for each selected velure was prepared by Brown & Root Craft personnel for testing per ASTM C805-79. Southwest Research Institute (SWRI) personnel were responsible for inspecting and accepting the prepared surfaces before testing. 4.1.1.6 The prepared areas were tested by SWRI personnel (Reference 7.4) in accordance with ASTM C805-79. 4.1.1.7 TUCCO determined the areas where concrete va - placed in Category I structures between Maren 1977 and August 1977 (Reference 7.3). 4.1.1.8 Fro: these areas. TCCCO deter =ined the nurrer of truckloads of concrete for which part of the concrete of that truckload is exposed and testable (Reference 7.3). 4.1.1.9 Each truckload identified as expesed and testable was assigned a unique number (Reference 7.3). 4.1.1.10 Grid volumes corresponding to these truckloads were selected at rande: fer testing (Reference 7.3). l 4.1.1.11 The concrete surface for each selected grid volu=a was prepared by Craft personnel fer testing per ASTM C805-79 and inspected by SWRI prior to testing. i 4.1.1.12 The prepared areas were tested by S*.TI l (Reference 7.4) in accordance with ASTM C803-79. 4.1.1.13 Third-party overview consisted of review and check of activities in 4.1.1.1 threugh 4.1.1.5 and 4.1.1.7 through 4.1.1.11 (Reference 7.5).

s Rovts;:r: ; Page 5 ef 3; RESL*LTS REPORT ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Sampling Plan At Comanche Peak, concrete placement quality procedures were based on the required air content and slump tests being performed on each truckload. Test cylinders frc the first truckload and every tenth truckload thereafter were required to verify quality. These procedures were based on ACI-ASME 359 and ACI 318 (References 7.6 and 7.7, respectively), which reference appropriate ASTM standards. Since the original quality control program was based on the unit of a truckload, the truckload was employed as the unit to be tested in the present quality evaluation. This is consistent with the inherent assumption in the ACI code that a truckload represents the smallest unit of concrete with unifer: material properties. Since Sch=idt Ham =er tests can only be perfor=ed en exposed surface area, the determination of the number of truckloads which were placed as exposed testable concrete was deter =ined as follows:

                                                                                                                                -       For slabs on grade, the number of truckloads was calculated as:

(l' depth X Surface Area)/!O yd' per truck A depth of one foot was used, because, during placement, vibrators caused the concrete to flow and level out. Thus, only truckloads placed in the last foot of the slab would be expesed. Tor colu=ns and walls the number of truckloads was calculated as: Total Voluee/10 yd8 per tru:k For suspended slabs up to 28 inches thick, the nu=ber of truckloads was calculated as: Total Volu=e/10 yd8 per truck Each truckload was considered to be accessible on either surface for slabs less than 15 inches thick. For slabs between 16 s

   .-                                                                  Re.:si:::         .

Pane 6ef3; !* RESULTS RE? OPT ISAP II b I (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) and 28 inches the total number of truckloads were distributed equally between the top and bottom halves of the slab. l l

                               -     For suspended slabs between 28 and 46 inches l                                     thick, the volume of concrete was split into I                                     three equal cuantities, with one third at the l                                     top, one third on the bottom and one third in the middle of the slab. The tcp and better layers were considered as exposed and testable. The middles layer was included if it could be tested from the side.

Slabs not falling into the above categories were handled on a case by case basis. For example, a portion of a thick slab on grade below the one foot depth was accessible from a tunnel and hence was included. Of the 326 Category I concrete pours placed between January 1976 and February 1977, 103 were for seal slabs, shoterate, grout, or concrete backfill, and are inaccessible for surface testing. Of the remaining 23 pours, 197 vere found to be at least partially accessible for Scheidt Han=er testing (Reference 7.3), which corresponds to a testable CAI populatien of approxiestely 1300 truckloads. A tetal of 119 rando:1y selected truckload units was tested fro = this population. Table 1 gives a breakdevn of the Category I concrete pours placed in the allegation ti e frame. Cocparable numbers of truckloads define the populatien of testable control concrete and the sample of the truckload units that were tested (see Table 2). 4.1.3 Concrete cylinder Data The 28-day cylinder strength data (Reference 7.8) were l obtained from the TUCCO Records Center for the time period in question and the control concrete time frare. The data, which represents all Category I concrete pours except seal slabs, etc., were statistically evaluated and used as ref erence information in the ha==st data evaluation. The completeness of the data list was checked by the third-party (Reference 7.5). s

Revist:r: '! Page 7 of ); RES'fLTS REPORT ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Partietoants Roles and Restensibilities The organizations and personnel that have participated in this effort are described below with their respective scopes of work. I 4.2.1 TL'C00 Nuclear Engineering Civil Structural 4.2.1.1 Scope Concrete population. determination

                                                                         -      Sample selection-Location of test areas and preparation of operational traveler Acquisition of 28-day cylinder data
                                                                         -      Assistance in evaluation of test data and preparation of Results Report 4.2.1.2   Personnel Mr. R. Hooton           Project Discipline Supervisor Mr. R._ Willia:s        Supervising Engineer Mr. C. Corbin           Civil Engineer 4.2.2   Brown & Root 4.2.2.1   Scope
                                                                         -      Prepare concrete test surfaces 4.2.2.2   Personnel Craft personnel as required                        j 4.2.3   Third-Party Activities 4.2.3.1   Scope
                                                                          -     Review of sample selection 1

l l

Fevist:n: . Paee 8 cf 2. RESL*LTS REPORT ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Perfor= ha=mer tests (S'RI) Document tests (SWRI) Review test data Review and statistical evaluatien ef test results

                                                         -     Preparation of Results Report 4.2.3.2     Personnel Mr. H. A. Levin        TERA, CPRT Civil /

Structural Review Tea: Leader Dr. J. R. Honeka:p TERA Manager TRT Issues Dr. F. A. Webster JBA. As s o cia t e (Engineering Statisti:a1 Consultant) Dr. D. Veneziano MIT Professor of Civil Engineering (Engineering Statistical Censultant) Mr. G. Lagleder SWRI. Manager (Testing and Inspection) 4.3 Qualifications of Personnel Where inspections required the use of certified inspecters, qualification were to the requiracents of ANSI F45.2.6 (Reference 7.9) at the appropriate level. CPSES personnel were qualified in accordance with applicable project requirements. Third-party inspectors were certified to the requirements of the third-party employer's quality assurance program and in accordance with USNRC Regulatory Guide 1.58 Revision 1 (Reference 7.10). The third-party inspectors were specifically trained to the requirements of SWRI Procedure X-FE-108-1, Revision 1 (Reference 7.11). Other participants were qualified to the requirements of the CPSES Quality Assur&nce Program or to the specific require ents of the CPRT Progra= Plan (Ref erence 7.12), as appropriate. l l l 1

Revist:r: , Page 9 cf 3; RESL*LTS REPORT ISAP II.b (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.4 Acceptance Criteria A review of the historie 28-day cylinder strength data for both time frames (see Figure 1 or Table 3) indicated that, regardless of whether falsification of data occurred during the allegation period or not, it is likely that the CAI is lower in strength than the CC. This observation is not unusual, since under normal construction processes, there is only a 50 percent chance that the concrete strength (and hammer indication) in the allegation period would be equal to or greater than that in any other comparable period. There is also a 50 percent chance that it would be less than that in any ether co= parable period. Therefore, the appropriate acceptance criterion was determined to be that of accepting the CAI population if the tenth percentile hammer indication was not "significantly lower" than that of the CC population. In this case "significantly lower" means not more than about ten percent. This is based on the fact that the design strength of 4000 psi is 18.6 percent lover than the CC tenth percentile 28-day cylinder strength (see Table 3), and this chanFe in co=pressive strength (psi) corresponds to a relative change in ha==er indication of approximately ten percent (see References 7.13 and 7.14). Thus, the hypothesis that the Schmidt Ha==er indication tenth percentile for the CAI is net "significantly lover" than that of the CC was tested at a minimum statistical significance level of five percent. 4.5 Decision Criteria Three hypothesis tests were considered for the co parisen of the Schmidt Ha==er data, with the understanding that the one (or ones) with the most pover* would be used to test the tvc populations. The three test methods include: 4.5.1 Method A tests whether the tenth percentile hat =er indication of the CAI is greater or equal to the target value of the CC where both populations are assured to be nor= ally distributed (see Reference 7.20). Note, the target value is defined as the CC populatien tenth percentile or a fraction thereof. Power is defined as the probability of rejecting the hypethesis when it is not true. The power function gives the pever as a l function of disparity vich the hypothesis. l

     .                                                                                                                \
    ,.                                                                                                 Pevis'--*
                                     ,                                                                 Page IC cf 3; 1,

RESULTS REPORT ISAP II.b I (Cont'd) 4.0 CPRT ACTIOS PLAN (Cont'd) 4.5.2 Method B tests whether the percentage of ha=er j indications in the CAI population above the target ' value of the CC is'graatar or equal to 90 percent. In this test the CC population is assumed to be normally distributed for purposes of establishing the target value (which may be defined as the tenth percentile or a fraction thereof), but the distribution of CAI hammer indications is unspecified. 4.5.3 Method C tests whether individual CAI hauer indication data values belong to tha same distribution as the control concrete rebound values. No assumptions are made regarding either populrtien distribution. Although the power functions for these three methods are t.et directly comparabic, Methods A and E are of similar power and are beeter than Method C (References 7.15, 7.20, and 7.21). Therefore. both Methods A and 3 vere retained to compare the two populations. 4i

                                       . Eased on the sample outcomes for the two concrete population..

test statistics were computed and the hypotheses regardirt the CAI population were either accepted or re,Jected at the 5 percent level of significance. In addition, the levels of significance at which the hypotheses are accept.ed vere also determined. ( The action identified by the NRC (Section 2.0) is cusidered l 4" complete nov that all Schsidt Hamer tests have been co=pleted, the results statistically analyzed, and the two concrete; populations compared. Since the comparison indicates that the CAI population of hamer indications is net "significantly lover" than the CC, no further eva10nion of the CAI is necessary, nor is it necenary to calibrate the Schmidt Ha=c t test to concrete of known ttrength and a p or test cores from the CAI, 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OT RESULTS j 5.1 Sy=arv of Imolemen_ta tion i The implementation of this action plan followed the flow chart

         \                                                                                                             l shown in Figure 2. with the four major aspects of thre preeram being: 1) identification of all CAI and CC Categery I pours 1

-L-_---_-_______.-----_--- _- . . _ - .

nev:st: : , Page 11 ef 3

 .                                                                                                                                                                                                                                                               l RESULTS REPORT ISAP II.b (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cent'd) and surface testable truckload populations; 2) the randem selection of truckloads; 3) the preparation and testing of selected areas; and 4) the test data evaluatien.

s Detailed descriptions of the population identification and rando: selection processes are contained in Reference 7.3. In i su==ary, all Category I concrete pours in the two time frs=es l vere identified and an esti= ate of how many and which l truckloads are surface testable was made. These esti=ated l testable truckload populations vete randomly sampled for l , testing with the Sch=1dt Ha==er, tl 9 'r accessibility verified, and the selected accessible areas were prepared for testing. Once the test areas were prepared., certified SWRI personnel verified the surf ace preparation, perfor=ed the Sch=ide Ha==er j tests, su==arized the ha==er readings, deter =ined the average ha==er indicetion for each test area, and submitted a report (Reference 7.4) to TUCCO containing these data. The third-party statistically evaluated the ha==er data (Reference 7.16), ar.d perfor=ed the hypothesis tests which vere used to ce= pare the two testable populations (References 7.17). A copy of the average ha==er indications, as su==arized fro the SWRI raw data sheets, is listed in Appendices A and B of this Results Report. Cu=ulative frequency plots of the two sample data sets are sho-?. in Figure 3. In addition to the ha==er data, the reporttd 28-day concrete cylinder strength data for both populations were obtained fre= the TUCCO Records Center (Reference 7.8) and statistically evaluated (Reference 7.18). Cu=ulative frequency plots for these two data sets are shewn in Figure 1. 5.2 Data Evaluatien Before comparing the two populations using Methods A and B. the ha==er data were first evaluated (Reference 7.16) by calculating =ean values, standard deviations, coefficients of variation (see Table 4), and cumulative frequencies (see Figure 3). The two data sets were tested for goodness-ef-fit to the nor=al distribution (References 7.17 and 7.19). Nor=ality of the two populations is accepted at the five percent significance level, s

                                        - _ - _ _ _ - - _ _ - - - - - - - - - - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ' - - - - - - - '- ' - - " - - - - ' - -                             ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ' ~ ~ ~

Reeist: : . Page II cf 3; RESULTS REPORT ISAP II.b (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cert'd) To compare the two testable concrete truckload populations, Methods A and B hypothesis tests were perfor:ed using t'ar,et values of 1.0, 0.975, and 0.95 times the CC population tenth percentile value. The hypothesis that the CAI population tenth percentile is greater or equal to 1.0 times the CC population tanth percentile is rejected at the five percent significance level. The hypothesis that the CAI population tenth percentile is greater than or equal to 0.975 times the CC population tenth percentile is accepted at the five percent significance level, and is also accepted at the ten percent significance level. The hypothesis that the CAI populatien tenth percentile is greater than or equal to 0.95 times the CC population tenth percentile is accepted at the five percent significance level, and is also accepted at the 95 percent significance level. This means that, alcheugh there,is not a high confidence that the CAI population of hammer indications is equal to or better than the CC population, there is a high confidence that the CAI is within five percent of the CC population at the tenth percentile value and therefore well within the ten percent range required by the acceptance criteria (see Section 4.4.). The 28-day cylinder compressive strength data for the 223 Category I concrete pours (see Section 4.1.2) in the CAI ti:e frame and comparable data in the CC time frame were statistically analyzed. The mean values, standard deviatiens, and coefficients of variation are listed in Table 3. These data were also ordered and cumulative frequency plots were constructed (see Figure 1). The results of the cylinder data evaluation are consistent with the Schmidt Ham =er tests it that both show a slightly higher mean value and tenth percentile value for the control concrete. In fact, the cylinder data indicate that the compressive strength of the l CAI is 9.3 percent lower than that of the CC at tha populatien tenth percentile value (see Table 3). This corresponds approximately to a five percent differerce in hammer indications (Reference 7.13). Thus, the results show that, not only are the compressive strengths of both the CC and CAI well above the 4000 psi design value, but that the reperced 28-day cylinder data truly represents the CAI at the population tenth percentile value. Regarding potential falsification of 28-day cylinder recerds, there are two general categories of interest. Of greater concern is the masking of out-of-specification concrete by recording it to be within specification. Of lesser cencerr is the recording of within-specification concrete when the tests

i Revisice: Page 13 ef 2. RESULTS REPORT ISAP II.b (Cont'd) 5.0 IMP'.EMENTATION OF ACTION PLAN AND DISCUSSION OT RESCLTS (Cont'd) were not performed. *either of these two types of l falsification appears to have occurred in a systematic way, since thsre is no obvious bimodal behavior in the ham =er indication data and the shift between the CC and CAI populations for the cylinder data is consistent with that of the ham =er indication data. During third-party review (Reference 7.5) of the Schmidt Hac=er test program development, some errors were found due to arithmetic, accessibility determinations, and volume modeling assumptions. A portion of these errors, if cer ected, would result in fewer truckloads being included in the populations; the other portion would result in more truckloads being added to the population. However, no systematic errors were found. The total error in the CAI truckload volume is three percent underestimated. For the CC population the estimate is less than half of one percent overestimated. Considering only those truckloads which were not included in the testable populations, but should have been (i.e., were not in the population frem which the. sample was drawn), the error rate is about six percent for the CAI and less than one percent fer the CC. The samples do not strictly represent the excluded truckloads. However, these error rates are not si gnific ant , and even if additional samples were obtained to represent the excluded truckloads, the conclusions veuld not be affected. 6.0 COSCLCSIONS Although the present strength of the concrete in question has net been measured directly, based on the ha==er indication data obtained, in association with the 28-day cylinder d.sa for the control concrete, it is concluded that the tenth percentile value of the CAI testable concrete is well above the design strength of 4,000 psi. The 28-day cylinder strength data are consistent with the hammer indicatien data. There is no evidence that syste=atic falsification of cylinder data or the non-performance of required tests occurred. Finally it is cencluded that the reported 28-day cylinder strength data represents the testable CAI populatien, thus validating the ut111:stien of these data to address other allegations of concrete records falsification.

i l

 .                                                                                              Rev si: :                                 ,

Page N et 3; RESL1TS REPORT ISAP II.b l (Cont'd) j 7.0 RETERENCES

7.1 ASTM Comittee C-9, " Standard Test Method for Rebound Number of Hardened Concrete", (ASTM C805-79), American Society for j Testing and Materials, Philadelphia, PA, 1979. j

( 7.2 ACI Comittee 214, "Recomn. ended Practice for Evaluation of ] Compression Test Results of Field Concrete", (ACI 214-65), ) American Concrete Institute, Detroit, MI, 1965.

7.3 " Test Program Development Report", CPRT Tile No. II.b.6.C.1, j October, 1985. ! 7.4 " Testing to Confirm Acceptability of Concrete Strength Data for the Comanche Peak Steam Electric Station, Units 1 and 2", Final Report. Proiset 8478 Southwest Research Institute, San Antonio, TX, September, 1985. (CPRT Tile No. II.b.6.C.2) 7.5 " Third-Party Review and Verification of Sar'eling Activities and Procedures for CPRT Issue II.b Concrete Compressive Strength", CPRT File II.b.6.C.3, October, 1985. 7.6 ACI-ASME Comittee 359, " Code for Concrete Reactor Vessels and Containments" (ACI-ASME 35?-83), A=erican Society of { Mechanical Engineers, New York, NY, 1983. 7.7 ACI Coc:mittee 318, " Building Code Requirements f or Reinf orced l Concrete", (ACI 318-83), American Concrete Institute, Detroit, j MI, 1983. ) 7.8 " Cylinder Data" CPRT Tile No. II.b.6.C.1.1. 7.9 ASME Comittee on Nuclear Quality Assurance, " Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants", (ANSI /ASME N45.2.6-1978), American Society of Mechanical Engineers, New York, NY, 1978. 7.10 Office of Standards Development. " Qualification of Nuclear Power Plant Inspection, Examination, and Tasting Personnel". (USNRC Regulatory Guide 1.58 Revision 1), U.S. Nuclear Regulatory Comission, Washington, DC. September,1980. 7.11 "Schmidt Hamer Test on Concrete at the Comanche Peak Steam i Electric Station", Nuclear Pro _4ects Operatine Precedure j X-TE-108-1. Revision 1 Southwest Research Institute, San l Antonio, TX, January, 1985. (CPRT File No. II.b.6.A) j s

Revis:: : , Page !! ef ;. RESULTS REPORT ISAP II.b (Cont'd) 7.0 RETERENCES (Cont'd) 7.12 " Comanche Peak Response Team Program Plan and Issue-Specifi: Action Plans", Revisien 3. TUGCO, Glen Rose, TX, January ' . 1986. (CPRT Tile No. II.b.1) 7.13 Operating Instructions Cenerate Test Ha==er Types N and NR, Copyrigne 1977, PROCEQ, Zurich, Switzerland. (CPRT File No. II.b.11) 7.14 Attachment A of T. Webster, " Target Tenth Percentile", CPRT File II.b.4a-003, February, 1985. 7.15 T. Webster, " Slides on Data Evaluation Methods Presented at NRC-TRT Meeting of 1/7/85", Memo to Tile, CPRT File II.b.10-004, January, 1985. 7.16 A. Boissonnade, "Schmidt Haemer Data Statistical Evaluation", CPRT Tile II.b.4a-010 August, 1985. 7.17 T. Webster, " Ham =er Data Hypothesis Tests", CPRT Tile II.b.4a-011, July, 1965.

                 '7.18 A. Boissennade, " Statistical Evaluation of Cylinder Data",

CPRT Tile II b.4a-012, August, 1985. 7.19 F. Webster, " Chi-Square Goodness-of-Fit Test of Hammer Oata", CFRT File II.b.4a-013. September, 1985. 7.20 D. Veneziano, " Comparison of the Tractiles of Two Nermal Populations: A Large Sample Test and Its Power", CPRT File II.b.4a-001, December, 1984 7.21 F. Webster, " Additional Background for TUCCO-NRC Meeting of 3/6/85", CPRT File II.b.4a-008, May, 1985.

I' , Revisi: : . l Page 15 ef 2', l - RESCLTS REPORT ISAP II,b (Cont'd) TABLE 1 CHARACTERI:ATION OF CATEGORY I CONCRETE PLACED IN ALLEGATION TI.ME FRAw.I NLtBER OF NUM3ER OT POURS TRCCKLCADS All Category I 326 31 50G* 1780 50G Catescry I (Other Than 223 4,080 Seal Slabs, Sheterete, 192 C.V,ES* 2300 C.W.ES Grout, or Backfill) 19 50G 315 SOG

            -Testable Category I               197                    1,305 178 C W.ES               990 C.W,ES

SOC = Slabs on Grade C = columns V = Walls ES = Elevated Slabs l

1 l 1 s

                 .       J                 .

Rev;s::t: 1

                                                                                                                                     .Page !! cf 3; RESL1TS REPORT .

ISAP II,b (Cont d ) TABLE 2 CHAP.ACTERIZATION OF CATEGORY I CONCRETE PLACED IN CONTROL CONCRETE TIME FRV.E NLY.EER OF NL?.!ER OF P OL*R S TR'.*C KLO AO S All Category I 324 24 SOG* 920 SCC Category I (Other Than 291 2,715 Seal Slabs, Shocerete, 267 C.W,IS* 1,795 C.W.ES Grout, or Backfill) 24 50G

353 SOG Testable Category 1 282 2,090 256 C.V,ES 1,737 C.W.IS

                                                         *SOG = Slabs on Grade C = Colu:ns V = Walls ES = Elevated Slabs 4

8.evisi- : Page li :f 2' ,

   ,                                   RESL1TS REPORT ISAP II.b (Cont'd)

TABLE 3 28-DAY STANDARD CURE CYLINDER DATA STATISTICAL SLT.AP.!ES l l l

 -                   Cencrete at Issue                    Control Concrete Number of Data    509                                 372 Mean Value       5158 psi                            5441 psi Standard          475 psi                             383 psi Deviation.

Coefficient of 0.09 0.07' Variation Tenth 4457 psi 4913 psi Percentile Minieu: 40/.7 psi 4540~ psi i i I l

.j

              -       J Revisi: :    ,

Page '9

                                                                                                                  . cf 3, RESL*LTS REPORT ISAP II.b (Cont'd)

TABLE 4 SCHMIDT HAMMER DATA STATISTICAL SL'MMARIES Concrete at Issue Control Concrete Number of Data 119 132 Mean value 48.57 49.14 Standard 3.13 2.87 Deviation Coefficient of 0.06 0.06 Variation Tenth 44.1 45.3 Percentile Mini =u: 38.5 39.7 l e 6--m________._______________ _

Revisi:r: 1 Page..:C ef 3;.

            ,                                                                                               RESULTS REPORT ISAP II.b (Cent'd)                                              ,

I FIGURE 1 i i CAI and CC CYLINDER DATA CUMULATIVE FREQUENCIES i i 3

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j Page 22 ef 2; ! RE5t't.TS REPORT ISAP II.b (Cont'd) TICURE 3 CAI and CC HA.W.ER DATA CUMULATIVE FREQUENCIES 3 , - -

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30 35 60 (S 1: 55 10 Aver =ge Sch-1dt Hom-er Ind1:::1en 4

Revis;:.: . Page 23 ef 3' ..- RESL*LTS REPORT ISAP II.b (Cont'd) APPENDIX A CAI AVERACE HAMMER INDICATIONS HA.T.ER TEST , DATA SHEET POUR PACKAGE No.- MEAN REBOUND VALUE No. CRID AREA TEST LOCATION HORIZ. UP DOWN 8 002-2790-004-H TR-85-066-8904 44.38 10 002-4790-005-I TR-85-005-8904 47.67 13 002-4790-037-HH TR-85-100-8704 44.0 24 002-4792-005-B TR-85-029-8904 38.5 37 002-2778-002-WW TR-85-060-8904 46.1 46 002-5778-001-D TR-85-123-8904 43.9 72 002-4792-008-P TR-85-001-8904 42.9

73 002-5778-001-Q TR-85-079-8904 47.4 74 002-5778-001-R TR-85-0?2 8904 46.0 76 002-5778-001-Z TR-33-095-8904 46.6 77 002-5778-001-AA TR-L5-096-8904 46.6 79 002-6778-005-A TR-Ba-204-8904 43.8 80 002-2778-002-X TR-85-056-8904 42.0 81 002-2778-002-KK TR-85-12G-8904 44.1 88 105-4785-003-C TR-84-101-8903 46.2 89 002 4790-016-1 TR-85-009-8904 48.3 92 002-6778-010-A TR-85-122-8904 48.3 118 002-6790-001-A TR-85-017-8904 44.6 127 002-7792-003-B TR-85-103-8904 44.4 128 002-2778-002-L TR-85-119-8904 42.8 129 002-4792-018-A TR-85-028-8904 39.1 130 002-4790-037-0 TR-85-188-8904 44.1 131 002-4790-037-C TR-85-104-8904 43.0 145 101-5805-003-M TR-85-162 8902 4? 3 153 002-4778-001-D TR-85-149-8904 6d.2 154 002-5778-007-C TR-85-092-8904 49.4 157 101-5805-003-D TR-85-161-8902 48.4 163 002-5790-002-A TR-85-207-8904 47.4 165 002-4792-003-A TR-85-146-8904 43.0 166 002-7792-001-P TR-SS-150-8904 46.4 167 002-4792-009-A TR-85-191-8904 47.4 168 002-7792-001-BB TR-85-151-8904 45.8 169 002-5778-006-A TR-85-099-8904 47.6 211 105-5790-005-I TR-85-113-8903 30.4 214 101-5805-002-P TR-85-160-8902 50.7 . 215 101-5805-003-Q TR-85-163-8902 49.0 l 217 002-2778-002-T TR-85-057-8904 44.4 218 002-2778-002-P TR-85-058-8904 46.1 219 002-2778-002-Q TR-85-059-8904 43.- 1 220 002-5776-001-X TR-85-094-8904 49.9

   . 4   .

Revist: : ; Page 24 et 3; RESULTS REPORT - ISAP II.b (Cont'd) APPENDIX A (Cont'd) CAI AVERAGE HAMMER INDICATIONS (Cont'd) HAMMER TEST DATA SHEET POUR PACKAGE No.- MEAN REBOUND VALUE No. CRID AREA TEST LOCATION HORIZ. UP D C '.'N 226 101-2808-004-A TR-85-105-8902 44.3 230 101-2808-003-5 TR-85-110-8902 42.0 236 002-4790-046-A TR-85-006-8904 44.2 238 002-4790-037-AA TR-85-101-8904 47.0 239 002-5790-009-B TR-85-091-8904 47.7 240 002-6790-012-B TR-85-014-8904 49.7 248 002-4792-008-D TR-85-192-8904 44.0 249 002-4792-001-C TR-85-121-8904 44.8 262 105-5773-001-U TR-85-329-8903 45.9 263 105-5773-001-N TR-85-331-8903 47.4 264 105-5773-001-T TR-85-328-8903 54.2 265 105-5773-001-X TR-85-330-8903 50.6 266 105-7785-001-Q TR-85-268-8903 49.3 267 105- 5 7 7 3-001- KK TR-85-341-8903 50.4 268 105-5773-001-JJ TR-85-342-8903 52.2 269 105-5773-004-N TR-85-267-8903 50.4 270 105-4785-001-D TR-85-269-8903 47.8 271 105-5773-001-RRRR TR-85-338-8903 46.2 272 105-4773-003-B TR-85-332-8903 49.0 273 105-5773-001-LLL TR-85-333-8903 52.8 274 105-5773-001-BBBB TR-85-334-8903 43.3 275 105-5773-001-DDDD TR-85-335-8903 48.7 276 105-5773-001-NNNN TR-85-336-8903 48.5 277 105-5773-001-ZZ TR-85-343-8903 52.3 278 105-5773-001-DDD TR-85-366-8903 47.6 279 105-5773-001-TTT TR-85-344-8903 50.3 280 105-5773-001-G00 TR-85-345-8903 56.1 282 105-5790-001-BB TR-85-350-8903 47.8 283 105-5790-001-T TR-85-339-8903 47.1 288 105-5773-004-T TR-85-327-8903 52.6 289 002-2790-001-WW TR-85-315-8904 44.0 290 002- 5790-001- E TR-85-323-8904 50.8 291 002-2790-001-YY TR-85-325-8904 48.4 293 002- 2790-001-UU TR-85-320-8904 45.- 294 002-4790-004-Q TR-85-314-8904 48.2 296 002-4790-016-A TR-85-319-8904 51.8 297 002 4790-026-B TR-85-318-8904 49.3 298 002-4790-038-C TR-85-317-8904 50.1 299 002-279C=001-II TR-85-316-8904 43.3 300 002-4790-004-J TR-85-322-8904 49.7 303 002-7792-001-X TR-85-353-8904 46.6 l l , i

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Page 25 of 3' . RESULTS REPORT ISAP II,b (Cont'd) APPENDIX A (Cont'd) CAI AVERAGE HAMMIR INDICATIONS (Cont'd) HAMMIk TEST DA*A SHEET POL *R PACKAGE No.- MEAN RESOUND VALUE No. CRID AREA TEST LOCATION HORIZ. UP DO*i5 304 002-7792-001-B TR-85-354-8904 47.3 306 101-5805-001-T TR-85-265-8902 50.2 307 101-5805-001-5 TR-85-278-8902 53.6 308 101-5805-002-V TR-85-363-8902 51.0 309 101-5805-002-X TR-85-361-8902 51.9 310 101-5805-004-N TR-85-371-8902 53.4 313 101-5805-004-U TR-85-373-8902 50.8 314 101-5805-003-X TR-85-360-8902 50.9 , 315 101-5805-005-5 TR-85-372-8902 51.2 317 002-2785-001-KK TR-85-368-8904 51.1 318 002-2785-001-YY TR-85-369-8904 53.3 319 002-2785-001-Q TR-85-260-8904 51.6 320 002-2785-001-BB TR-85-266-8904 51.1 321 002-2785-001-SS TR-85-270-8904 50.5 322 002-2785-001-BBB TR-85-263-8904 53.0 323 002-2785-001-Z TR-85-262-8904 52.6 324 035-5782-003-T TR-85-280-8906 50.8 325 035-5782-003-C TR-85-279-8906 49.1 326 035-5782-001-L TR-85-264-8906 50.9 327 035-5782-001-I TR-85-259-8906 49.6 328 002-4790-038-G TR-85-324-8904 45.7 330 002-2790-001-R TR-85-321-8904 45.5 333 002-5778-013-H TR-85-358-8904 43.4 334 002-5778-013-5 TR-85-359-8904 55.7 370 101-5805-004-BB TR-85-364-8902 48.5 374 101-5805-004-FF TR-85-362-8902 52.4 377 101-5805-001-M TR-85-275-8902 49.7 378 101-5805-001-P TR-85-276-8902 50.3 379 101-2808-003-L TR-85-349-8902 50.0 383 101-2808-003-E TR-85-348-8902 45.8 390 101-2808-002-F TR-85-370-8902 50.0 391 101-2808-002-C TR-85-347-8902 48.5 394 002-7807-001-P TR-85-356-8904 46.8 395 002-7807-001-W TR-85-357-8904 47.0 396 002-7792-001-MM TR-85-351-8904 44.8 397 002-7792-001-TT TR-85-352-8904 44.3 398 105-5773-001-CCGG TR-85-337-8903 55.0 405 101-5805-005-J TR-85-365-8902 50.0 l i t

Rens t- : . Page 26 et 3- ,

  .5                                                                                                                              RESCI.T5 REPORT ISAP II.b (Cont'd)

APPENDIX A (Cont'd) l CAI AVERACE HA.tER INDICATIONS l l-1 P

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R e vi s i e r.: ; Page 27 cf 2; RESULTS REPORT ISAP II.b (Cont'd) APPENDIX B CC AVERAGE HA.W.ER INDICATIONS SHEET CONCRETE POUR MEAN REBOL*ND VAL'JE No. PACKAGE No. TEST LOCATION HORIZ. U?' D0' 'N OTHER 15 002-7810-002-X TR-85-078-8904 40.7 20 002-7810-001-EE TR-85-126-8904 42.3 25 002-4792-007-B TR-85-030-8904 41.3 34 002-7810-003-DD TR-85-127-8904 44.2 35 105-4810-021-J TR-85-051-8903 45.5 54 105-4790-016-C TR-85-038-8903 43.9 57 101-5805-012-P TR-85-186-8902 49.9 96 105-4790-015-C TR-85-114-8903 45.7 110 105-4810-021-D TR-85-048-8903 43.4 115 101-5805-010-E TR-85-169-8902 48.2 116 101-5805-012-E TR-85-176-8902 49.0 124 002-5807-002-G TR-85-157-8904 48.1 125 002-5807-002-E TR-85-027-8904 40.9 137 003-4785-002-111 TR-85-200-8901 47.8 139 003-4785-007-U TR-85-201-8901 46.9 140 003-4785-002-FF TR-85-202-8901 45.6 141 003-4785 002-0 TR-85-204-8901 43.7 142 003-4705-002-N TR-85-203-8901 48.6 143 003-2810-004-E TR-85-141-8901 46.6 144 105-5790-002-E TR-85-196-8903 46.2 148 002-5810-004-H TR-85-116-8904 45.3 149 101-5805-012-0 TR-85-185-8902 52.1 150 101-5805-012-K TR-85-184-8902 49.1 151 101-5805-006-F TR-85-168-8902 50.3 155 003-2810-005-D TR-85-093-8901 49.7 156 003-2810-002-D TE-85-040-8901 48.4 158 101-5805-010-G TR-85-171-8902 48.7 162 105-4810-021-5 TR-85-208-8903 43.9 164 002-5810-001-GG TR-85-019 8904 46.5 170 201-5805-002-F TR-85-190-8902 48.2 171 002-5807-002-Y TR-85-156-8904 39.7 179 101-5805-013-U TR-85-179-8902 50.6 180 101-5805-012-V TR-85-183-8902 50.6 182 101-5805-013-BB TR-85-180-8902 53.0 185 105-4810-021-B TR-85-050-8903 45.9 186 003-4785-002-RRR TR-85-206-8901 50.9 187 003-4785-00;-B TR-85-205-8901 48.5 188 101-4808-009-I TI-85-158-8902 52.2 191 101-4812-005-J TR-85-135-8902 50.0 193 105-7810-002-N TR-85-229-8903 51.3 194 105-7800-001-B TR-85-210-8903 48.1 a l l l i

Revici: : ,

Page 28 cf 3; L RESL"T5 REPORT ISAP II.b (Cont'd) APPENDIX B (Cont'd) CC AVERACE HAMMER INDICATIONS (Cont'd) L SHEET CONCRETE POUR MEAN REBOUND VALUE No. PACKAGE No. TEST LOCATION HORIZ. CP D0'a5 CTHER 199 002-7810-003-LL TR-85-222-8904 48.5 200 002-7810-001-W TR-85-220-8904 53.0 207 105-7810-001-D TR-85-227-8903 45.6 209 105-7810-007-A TR-85-133-8903 52.9 210 105-5790-002-I TR-85-039-8903 46.4 212 105-4810-021-I TR-85-049-8903 49.8 213 105-4810-021-G TR-85-148-8903 50.7 221 101-5805-011-G TR-85-173-8902 49.7 ' 222 101-5805-011-K TR-85-174-8902 50.8 223 101-5805-Oll-L TR-85-175-8902 52.0 225 101-4808-004-D TR-85-139-8902 48.5 241 105-4790-Oll-B TR-85-043-8903 47.8 244 002-4807-002-F TR-84-153-8904 47.7 245 201-5805-002-D TR-85-187-8902 53.4 252 002-7807-002-G TR-85-085-8904 50.4 255 002-7807-003-A TR-85-086-8904 46.8 256 002-7807-002-Q TR-85-155-8904 48.0 257 002-4810-020-I TR-85-020-8904 47.9 281 105-4790-008-G TR-85-236-8903 48.3 284 105-4800-001-F TR-85-235-8903 48.5 285 105-7810-007-S TR-85 .237-8903 58.8 i 286 105-5790-003-L TR-85-238-8903 48.9 287- 105-7790 002-D TR-85-306-8903 48.5 292 002-7810-001-000 TR-85-300-8904 49.2 295 002-7810-001-CCC TR-85-305-8904 52.1 301 002-5830-001-N TR-85-312-8904 47.7 302 035-3790-001-8 TR-85-257-8906 49.4 305 002-5807-003-L TR-85-242-8904 49.9 311 101-5805-007-U TR-85-378-8902 53.0 312 101-5805-008-Z TR-55-272-8902 52.4 316 002-7810-001 '~.! TR-85-301-8904 52.9 329 002-7810-002-00 TR-85-302-8904 49.9 331 002-7810-003-SS TR-85-303-8904 44.6 332 002-4790-027-P TR-85-258-8904 43.1 335 002-7810-001-RR TR-85-291-8904 49.9 336 002-5810-001-A TR-85-367-8904 53.2 337 002-7810-001-I TR-85-295-8904 43.2 338 002-4810-015-H TR-8 5-2844904 49.1 339 002-4810-015-M TR-85-283-8904 50.0 340 002-7810-002-P. TR-85-285-8904 46.1 l

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, , Revisi: : ; Page 29 ef 3. j l REstLTS REPORT - ISAP II.b (Cont'd) l APPENDIX B (Cont'd) CC AVERACE HAMMER INDICATIONS (Cont'd) SHEET CONCRETE POUR MEAN RESOUND VAtti No. PACKAGE No. TEST LOCATION HORIZ. UP DOWN OTHER 341 002-7810-003-DD TR-85-294-8904 47.3 342 002-5810-002-MM TR-85-232-8904 50.7 1 l 343 002-5810-002-5 TR-85-282-8904 48.8 344 002-7810-003-CCC TR-85-290-8904 44.9 345 002-7810-003-EEE TR-85-281-8904 47.9 346 002-7810-003-XX TR-85-293-8904 48.7 1 347 002-4810-002-V TR-85-233-8904 48.1 1 348 002-7810-002-C TR-85-286-8904 45.9 349 002-4810-002-H TR-85-288-8904 46.5 350 002-7810-002-EE TR-85-292-8904 44.2 352 002-5810-014-C TR-85-287-8904 48.6 353 003-2810-007-H TR-85-326-8901 46.7 354 003-2813-002-AA TR-85-254-8901 46.5 355 003-2810-007-BB TR-85-246-8901 48.2 . 356 003-2810-001-M TR-85-253-8901 48.7 f 357 003-2810-002-T TR-85-249-8901 51.3 j 358 003-2810-002-VV TR-85-248-8901 51.6 l 359 003-2810-002-L TR-85-251-8901 51.2 ' 360 00!-2810 002-AA TR-85-250-8901 51.2 361 003-2210-007-CC TR-85-247-8901 51.7 362 003-2813-001-N TR-85-252-8901 52.8 363 003-2813-001-U TR-85-244-8901 54.4 364 003-2813-001-T TR-85-243-8901 52.9 365 003-2810-004-R TR-85-245-8901 47.8 366 201-5805-002-V TR-85-374-8902 52.4 367 201-5805-001-R TR-85-377-8902 52.0 368 003-2813-002-0 TR-85-256-8901 48.7 369 003-2813-001-AA TR-85-255-8901 52.2 371 101-5605-010-HH TR-85-376-8902 52.7 37,2 101-5805-012-LL TR-85-375-8902 53.4 i 373 101-5805-009-JJ TR-85-274-8902 51.4 I 375 105-7810-001-B TR-85-304-8903 44.3 376 105-2810-001-D TR-85-234-8903 48.2 380 101-2812-001-BBB TR-85-239-8902 50.5 381 101-6808-008-A TR-85-355-8902 48.4 382 101-2812-001-00 TR-85-241-8902 48.7 384 101-2812-001-C TR-85-240-8902 53.3 385 101-4812-001-M TR-85-309-8902 51.2 386 101-4812-001-J TR-85-310-8902 50.3 387 101-4812-001-B TR-85-311-8902 52.3 w____._._______ _ _ _ _ . - -

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Page 30 ef.3;

       .                                                                                                         1 1

RESULTS REPORT ISAP II.b (Cont'd) APPENDIX B (Cont'd) CC AVERAGE HAMMIR INDIC//1 EONS (Cont'd) SHEET CONCRETE POUR HEAN REBOUND VAttE No. PACKAGE No. TEST LOCATION HORIZ. UP DOWN OTHER 388 101-4812-002-H TR-85-307-8902 49.6 389 101-4812-002-K TR-85-308-8902 51.3 392 002-5807-001-L TR-85-346-8904 49.3 393 002-5807-001-E TR-85-296-8904 47.4 399 los 3805-008-K TR-85-271-8902 51.1 400 101-5805-009-0 TR-85-273-8902 53.2 i 401 002-6807-008-A TR-85-297-8904 51.0 402 002-6807-009-C TR-85-313-8904 50.2 403 002-7807-002-0 TR-85-299-8904 47.3 404 002-7807-002-R TR-85-298-8904 48.6 406 002-7810-002-A TR-85-289-8904 47.7 l

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Page 31 of 3; RES'.1TS REPORT ISAP II,b (Cont'd) I

AVERAGE SCNMIDT HAMMER Ib'DICATION )

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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.a.2

Title:

Joint Test Group (JTG) Approval of Test Data Revision No. 0 1 2 3 Revised to Reflect Incorporates Reflects comments Description Original Issue NRC Comments SSER On Plan Ac~ -ln

                                                                                                        /$/f/8'1' Prepared and                                                                                                                                                                                                       '

Recommended by: p/ Review Team Leader . \f (A.M s U, e)N c Date l0 ff if / f?$ Lf 3 L / f 2 2 /- & b

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Revision: 3 y Page 1 of 2 ISAP III.a.2 Joint Test Group (JTG) Approval of Test Data

1.0 DESCRIPTION

OF ISSUE The NRC-TRT originally described this issue in NRC letter, D. G. Eisenhut to M. D. Spence, dated September 18, 1984, Enclosure 1 at Page 13, as follows:

                                                                                                              "The TRT noted during a review of HTT completed test data that the JTG did not approve the data until after cooldown from the test. The tests are not considered complete until this approval is obtained. In order to complete the proposed post-fueling, deferred preoperational HTT, the JTG, or a similarly qualified group, must approve the data prior to proceeding to initial criticality. The TRT did not find any document providing that TUEC is committed to do this."

l 2.0 ACTION IDENTIFIED BY THE NRC l The NRC-TRT originally identified the action required to resolve l this issue in NRC letter, D. G. Eisenhut to M. D. Spence, dated September 18, 1984, Enclosure 1 at Page 13, as follows:

                                                                                                              "Accordingly, TUEC shall com=it to having a JTG, or similarly qualified group, review and approve all post-fueling preoperational test results prior to declaring the system operable in accordance with the technical specifications."

and subsequently modified in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-77, as follows:

                                                                                                              "TUEC has informed the TRT that the Station Operation Review Co==1ttee (SORC) will review deferred preoperational test data. Since the review of data obtained from the deferred preoperational tests is a function of the SORC, TUEC shall amend the FSAR to reflect their commitment to the TRT that the i

SORC and not the JTG will perform these reviews. This requirement, not included in the September 18, 1984 letter to TUIC, is necessary because the current version of the FSAR states that the JTG is responsible for reviewing preoperational test data." 3.0 BACKCROUND The NRC-TRT expressed concern that formal Joint Test Group approval of the preoperational hot functional test results occurred after cooldown from operating pressure and temperature i.e., after proceeding through a major testing evolution. With this concern and being aware that TUEC had NRC-NRR approval to defer some

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     -                                                                               Revision:   3 I

Page 2 of 2 3 ISAP III.a.2 L (Cont'd) l 4 3.0 EACKGROUND (Cont'd) preoperational testing into the interval between fuel loading and initial criticality, the NRC-TRT examined TUEC's FSAR commitments related to post-fuel load testing. The FSAR indicated that TUEC l had committed the SORC to review and approve post-fuel load test results and that it was appropriately qualified to perform the review and approval. The FSAR had not specifically addressed the l situation of deferred tests which were classified as preoperational. TUEC amended the FSAR to clarify the specific situation with preoperational tests which may be deferred beyond fuel load but prior to initial criticality. 4.0 CPRT ACTION PLAN TUEC filed Amendment 54 to the CPSES FSAR on January 21, 1985 which provides the information identified as necessary by the NRC-TRT. The CPRT considers the action required of TUEC for this issue complete. I i ! l

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COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: III.a.2

Title:

JTG Approval of Test Data REVISION O i

                                                                                        /                                      /

I f is .1 o , g g Issue Coordinator Date l F

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i w w.cc 10 96 Review Team Leader Date

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N. JohnLA. Beck, Chairman CPRT-SRT lC /hY D Date'

Kevision: 3 Page 1 of S RESCLTS REPORT ISAP III.a.2 Joint Test Group (JTC) Approval of Test Data

1.0 DESCRIPTION

OF ISSUE The NRC-TRT described this issue in NRC letter D. G. Eisenhut to M. D. Spence, dated September 18, 1984 Enclosure 1 at Page 13, as follows: The TRT noted during a review of HTT completed test data that the JTG did not approve the data until after cooldown from the test. The tests are not considered complete until this approval is obtained. In order to complete the proposed post-fueling, deferred preoperational HTT, the JTG, or a similarly qualified group, must approve the data prior to proceeding to initial criticality. The TRT did not find any document providing that TUEC is committed to do this. 2.0 ACTION IDENTIFIED BY THE NRC The NRC-TRT originally identified the action required to resolve this issue in NRC letter. D. G. Eisenhut to M. D. Spence, dated September 18, 1984, Enclosure 1 at Page 13, as follows: Accordingly, TUEC shall costit to having a JTG, or similarly qualified group, review and approve all post-fueling preoperational test results prior to declaring the system operable in accordance with the technical specifications. and subsequently modified in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-77, as follows: TUEC has informed the TRT that the Station Operation Review Ccmmittee (50RC) will review deferred reoperation.a1 test data. Since the review of data obtained from the deferred preoperational tests is a function of the SORC, TUEC shall amend the FSAR to r:aflect their commitment to the TRT that the SORC and not the J7G will perform these reviews. This requirement, not included in the September 18, 1984 letter to TUEC, is necessary because the current version of the FSAR states that the JTG is responsible for reviewing preoperational test data. 5

   ,                                                                                                                                                   Revicien:     O Page   2 of S RESULTS REPORT ISAP III.a.2 (Cont'd) 3.0 BACKCEOUND The NRC-TRT expressed concern tFat farmal Joint Test Group approval of ths preoperational hot functional test results occurred after cooldown from operating pressure ano temperature,                         i.e., after proceeding through a major casting avolution. With this concern, and being aware that TUCCO had NRC-NRR approval to defer some preoperational testing into the it.terval between fuel loading and initial criticality - during which oil reviews and approvals are required prior to proceeding to th next plateau - the NRC-TRT examined TUCCO's FSAR commitments related to post-fuel load testing.

The FSAR indicated that TUGC0 had committed the SORC to review and approve post-fuel load test results and that it was qualified to perlorm the review and approval. The FSAR had not specifically addressed the situation of deferred tests which had been classified as preoperational. 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan was to ensure that the C?SES FSAR and identified implementing procedures contain requirements which address the NRC-TRT concern as discussed in Sections 1.0 and 2.0. The following tasks were implemented to achieve this objective: 4.1.1 The CPRT reviewed the C?SES FSAR to ensure that the commitment for SORC review of deferred preoperational test data is included. 4.1.2 The CPRT identified and reviewed Station procedures which implement the commitment specified in Sectien 4.1.1 to ensure that the commitment is addressed. 4.2 Participants Roles and Responsibilities l The CPRT Testing Program Review Team Leader, Mr. J. E. Rushwick, and tha Issue Coordinator. Mr. T. M. Broad, were responsible for the reviews described in Section 4.1. 4.3 Qualifications of Personnel 4.3.1 The CPRT Testing Programs Review Team Leader meets the qualifications as described by the CPRT Proe, ram Plan. I l

                                                                                     .                                                                                 l

Revisien: O Page 3 of 3 RESULTS REPORT ISAP III.a.2 (Cont'd) 4.0 CP!C ACTION PLAN (Cont'd) 4.3.2 The Review Team Leader was responsible for ensuring that other personnel providing assistance in the conduct of this Action Plan are appropriately qualified. 4.4 Acceptance Criteria Review responsibility for deferred preoperational test results is acceptable if the CPSES FSAR specifically identifies the c aview be conducted by the 50RC, and implementing Station procedures reflect this commitment. 1.5 Decision Criteria The Action Plan will be considered complete when the CPRT has determined that the commitment in Section 4.1.1 is included in the FSAR And that applicable administrative procedures are consistent with this commitment. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The CPRT revinved the CPSES FSAR and procedures contained in the Station Administration Manual as described in Section 4.1. The following presents the results of the review. 5.1 FSAR Revi.w 5.1.1 Observations TUGCO's commitments regarding the SORC review of deferred preoperational test results are contained in Section 14.2, " Initial Test Program." of the FSAR. The references specifically quoted in this section address deferred preoperational testing, its inclusion in the Initial Startup Program, and its review by the SORC. Section 14.2.1, " Summary of Test Program and Objectives," states in part : Preoperational testing will be completed , prior to fuel lotd with certain limited l exceptions where tests or parts of tests vill l be deferred to the Initial Startup Test Program. 1 _____________.________o

  '                                                                                                                I

Revisien: 0 1

Page 4 of 3 l RESULTS REPORT ISAP III.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) Initial startup tests will be performed beginning with activities leading to fuel l loading and ending with full power operation. i The intent of these tests is to assure that j tests deferred from the preoperational test i program are performed; that fuel loading is effected in a safe manner; that the plant is safely brought to rated capacity; that plant performance is satisfactory in terms of established design criteria; and to demonstrate, wher6 practical, that the plant is capable of withstanding anticipated transients and postulated accidents. Section 14.2.4.5 " Phase Evaluation " states in part: Between each major phase of the test program the test results for all tests that have been performed will be reviewed by the JTG (for preoperational tests) or SORC (for initial startup tests). This review ansures that all required systems have been tested satisfactorily and that test results are approved before proceeding to the next stage of testing. This review is described in Section 14.2.5. Section 14.2.5, " Review, Evaluation, and Approval of Test Results," states in part: Preoperational test results vill be reviewed by appropriate members of the JTC and Initial Startup test results will be reviewed by members of the SORC. The responsibility for final approval of preoperational test reaults rests with the Chairman of the JTG. The responsibility for final approval of initial startup test rests with the Chairman of the SORC.

1 1

j Revision: O Page 5 of S I

RESULTS REPORT ISAP III.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) Following each major phase of the test program test results and/or test status will be reviewed to ensure that all required tests have been performed and that the test results have been approved. This review will onsure that all required systems are operating properly and that testing for the next major phase vill be conducted in a safe and efficient manner. This type of review will be performed to the extent required before major test phases such as fuel load, initial criticality, and power escalation. During the power escalation phase, review and approval of initial startup test procedure results will be completed for each of these plateaus (30 percent, 50 percent, and 75 percent) prior to proceeding with power ascension testing the next plateau. and Section 14.2.12.2, " Initial Startup Tests," states: The initial startup phase of the test program consists of preoperational tests deferred to the Initial Startup Program, Initial Startup Tests prior to and including fuel loading, precritical tests, initial criticality, low power physics tests, and power ascension tests. 5.1.2 Conclusions As noted in the FSAR Sections quoted above, specific commitment to review deferred preoperational test results by the SORC is contained in the CPSES FSAR. Clarification of the commitment was made in FS AR Amendment 54 subsequent to the NRC-TRT review. 5.2 Station Procedure Review Deferred preoperational testing is the subject of this ISAP and ISAP III.a.3, " Technical Specifications for Deferred Tests." Technical specification review is one element in the process of deferring testing from the preoperational test program into the initial startup test program. The following presents a discussion of the process of deferring t* sting activities while the Results Report for III.a.3 deals exclusively with the aspects of technical specificar. ion review l perferned according to STA-707, " Safety Evaluations." l

{

Revision: Page 6 of 6 RESUL*$ REPORT - ISAP III.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.1 Observations The administrative requirements established by TUGC0 to control the review and approval process for defected preoperational tests are contained in the following CPSES procedures: STA-805, " Deferred Testing." STA-707, " Safety Evaluations." STA-801, " Initial Startup Program," and ISA-005, " Initial Startup Test Package Preparation, Review, and Approval." l These procedures were in effect and properly implemented prior to the NRC-TRT's identification of this issue. This is evidenced by the submittal to NRC-NRR by TUGC0 of requests for deferral of certain preoperational tests in May and June of 1984, and NRC-NRR's subsequent approval of the requested deferrals. The approvals are contained in letters to l TUCCO from NRC-NRR dated June 19, 1984, and August 17, 1984 Sections of the above procedures applicable to SORC review and approval of deferred preoperational testing are quoted as follows: STA-801, " Initial Startup Program." in Paragraph 3.0, " Definitions," states: Initial Startup Test - Those tests conducted to insure that: deferred preoperational tests are performed; fuel leading is conducted in a safe manner; the plant is safely brought to rated capacity and sustained power operation; plant performance is satisfactory in terms of established design criteria; and plant systema are capable of withstanding and adequately responding to anticipated transients, s

l Revision: 0 I , Page 7 of S la RESULTS REPORT ISAP III.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) and Paragraph 4.0, " Instructions," states in part: The initial startup program shall meet the licensing requirements contained in CPSES Final Safety Analysis Report (FSAR) Chapter 14... All Test Packages shall be reviewed and approved in accordance with ISA-005, " Initial Startup Test Package Preparation, Review, and Approval." The initial startup testing shall be performed in phases. The major phases are defined as: fuel loading, initial criticality / low power testing, and then power ascension with plateaus at 30%, 50%, 75% and 100% power. Review and interim approval of ISU test results shall be complaced for each major phase prior to proceeding to the next phase or prior to proceeding with power ascension testing to the next plateau. ISA-005, " Initial Startup Test Package Prep

ration, Review, and Approval," in Paragraph 4.5, "Tsse Package Review and Approval." states:

The SORC shall review and approve all initial startup test packages in accordance with STA-401, " Station Operations Review Committee." 5.2.2 Conclusions The CPSES procedures referenced above completely address the implementation of the commitment for 50RC approval of deferred preoperational testing. 5.3 Root Cause and Generic Implications No testing deviation or deficiency was identified and no generic condition exists which indicates that there is inadequate review of deferred preoperational testing. Accordingly, no root cause determination is required. O _ _ . _ _ _ _ _ _ - _ - _ - _

Revision: C Page 8 of 5 RESL*LTS REPORT ISAP III.a.2 (Cont'd)

6.0 CONCLUSION

S Based on the discussion presented in Si cion 5.0, it was concluded that the CPSES FSAR has been amended to provide the information identified as necessary by the NRC-TRT, and that Station procedures provide for the implementation of the FSAR commitment. 7.0 ONGOING ACTIVITIES There are no ongoing activities. 8.0 ACTION TO PRECLUDE OCCURRENCE IN TiiE TUTURE No action was required as a result of this issue. I 1

l

.o.

4 f. te COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.a.3

Title:

Technical Specification For Deferred Tescs Revision No. 0 1 2 3 Revised to Reflect Incorporates Reflects Comments Description Original Issue NRC Comments SSER On Plan 1 to/S/M - b Prepared and /l I Recommended by: Review Team Leader d dy )[q

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Revision: 3

 "',                                                                      Page   1 of 2 i

ISAP III.a.3 Technical Specifications For Deferred Tests

1.0 DESCRIPTION

OF ISSUE The NRC-TRT originally described this issue in NRC letter, D. G. Eisenhut to M. D. Spence, dated September 18, 1984, Enclosure 1 at i Page 13, as follows: I "The TRT pointed out that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel load, certain limiting conditions of the proposed technical specifications cannot be met, e.g., all snubbers will not be operable since some will not have been tested." 2.0 ACTION IDENTIFIED BY NRC The NRC-TRT originally identified the following action in NRC I letter, D. G. Eisenhut to M. D. Spence, dated September 18, 1984, l Enclosure 1 at Page 13, as being necessary to resolve this issue: i "Accordingly, TUEC shall evaluate the required plant conditions for the deferred preoperational tests against limiting conditions in the proposed technical specifications and obtain NRC approval where deviations from the technical specifications are necessary." and subsequently modified in CPSES Safety Evaluation Report, Supplccent No. 7 at Page J-18, that the action identified cited above:

                        "...is no longer applicable sirce the TRT has been inforced by TUEC that these tests will be conducted prior to fuel load."

l 3.0 BACKGROL'ND Following completion of preoperational hot functional testing, the i results of certain tests indicated that the deficiencies identified ! vould require design modifications, component repair or I replacement, or initial installation and subsequent testing. The nature of the retesting would require the primary plant to be at normal operating pressure and temperature. The next planned primary plant heatup was scheduled in the interval between fuel i load and initial criticality. Therefore, TUEC sought and received ! NRC-NRR approval to defer these retests until the primary plant heatup following initial fuel loading.

, ,3 ..

                                  '                                                                     Revision:   3 Page   2 of 2       )

ISAP III.a.3 (Cont'd)

3.0 BACKGROUND

(Cont'd) TUEC had prepared administrative controls to address the review and approval process in preparation of its request to defer seven preoperational tests to NRC-NRR. Formal approval of this request was received in NRC-NRR letters dated June 19, and August 17, 1984 The processing of this request was in accordance with Station Administrative Procedure STA-805, " Deferred Preoperational Testing." which is briefly described as follows. During this process, technical specification requirements are evaluated and the need for technical specification execptions considered. The evaluation addresses the operability requirements of the technical specifications and the impact of incomplete preoperational testing on equipment operability. The required plant conditions for conducting deferred preoperational tests are assess $d against the CPSES technical specifications including the limiting conditions for eperation. Subsequently, TUEC planned a second heacup to operating pressure and temperature and would attempt to complete the deferred [ preoperational testing before fuel load. In correspondence dated b September 30, 1985 to NRC-NRR, TUEC reported the results of the second plant heatup conducted during the interval from October 1984 to January 1985 in which the deferred preoperational tests were performed. Although many of the individual testing items were completed, there remain four items open pending completion of satisfactory testing and one item open pending NRC approval of a proposed technical specification change. 4.0 CPRT ACTION PLAN Although TUEC has five remaining open items in the current , NRC-approved preoperational test deferral, the methods by which TUEC identifies and obtains NRC approval for technical l specification deviations is, in the judgment of the CPRT, adequate to address the concerns identified by the NRC-TRT. l l

-1 . s COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: III.a.3

Title:

Technical Specification For Deferred Tests REVISION O

                                      ,'    &                   Ye 8(

Issue Coordinator Date

           \                                         '

Mww

      # 3eview Team Leader tu b v           L       I C- IO' b6 Date
          ~

d / / i~ f'l. Joh '4j Beck Chairman CPRT-SRT Date

i

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Revision: r Page l of 3 i RESULTS REPORT ? ISAP III.a.3 Technical Specifications For Deferred Tests

1.0 DESCRIPTION

OF ISSUE The NRC-TRT described this issue in NRC letter, D. G. Eisenhut to M. D. Spence, dated September 16, 1984 Enclosure 1 at Page 13, as ' follows: The TRT pointed out that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel load, certain limiting conditions of the proposed technical specifications cannot be met, e.g., all snubbers will not be operable since some will not have been tested. 2.0 ACTION IDENTIFIED BY NRC The NRC-TRT originally identified the following action in NRC letter, D. G. Eisenhut to M. D. Spence, dated September 18, 1984 Enclosure I at Page 13, as being necessary to resolve this issue: Accordingly, TUEC shall evaluate the required plant conditions for the deferred preoperational tests against limiting conditions in the proposed technical specifications and obtain NRC approval where deviations from the technical specifications are necessary. and subsequently modified in CPSES Safety Evaluation Report. Supplement No. 7 at Page J-18, that the action identified above:

                                             ...is no longer applicable since the TRT has been informed by TUEC that these tests will be conducted prior to fuel load.

3.0 BACKCROUND Following completion of preoperational hot functional testing, the results of certain tests indicated that the deficiencies identified would require design modifications, component repair or replacement, or new installations and subsequent testing. The nature of the ratesting would require the primary plant to be at l normal operating pressure and temperature. The next planned primary plant heatup was scheduled in the interval between fuel load and initial criticality. Therefore, TUGC0 sought and received NRC-NRR approval to defer these retests until the primary plant heatup following initial fuel loading. The processing of these requests was in accordance with Station administrative procedure STA-805, " Deferred Testing." s i

1- - Revision: O Page 2 of 5 e RESULTS REPORT ISAP III.a.3 (Cont'd)

3.0 BACKGROUND

(Cont'd) Subsequently, TUGC0 planned a second pre-fuel-load heatup during which they would attempt to complete the deferred preoperational testing. In correspondence dated September 30, 1985 to NRC-NRR. TUGC0 reported the results of the second plant heatup conducted during the interval from October 1984 to January 1985 in which the deferred preoperational tests were performed. Although many of the individual testing items were completed, there remain several open items pending completion of satisfactory testing at operating temperature and pressure. 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan was to ensure that Station ' I administrative procedures contain requirements which address the concern discussed in Sections 1.0 and 2.0. In order to achieve this objective Station procedures were identified and reviewed to ensure that evaluation of preoperational testing deferrals provides for assessment of the requirements of the CPSES Technical Specifications. 4.2 Participants' Roles and Responsib111 ties The CPRT Testing Programs Review Team Leader, Mr. J. E. Rushwick, and the Issue Coordinator. Mr. T. M. Broad, were responsible for the review described in Section 4.1. 4.3 Qualifications of Personnel 4.3.1 The CPRT Tacting Programs Review Team Leader meets the qualifications as described by the CPRI Program Plan. 4.3.2 The Review Team Leader was responsible for ensuring that other personnel providing assistance in the conduct of the Action Plan are appropriately qualified. 4.4 Acceptance Criteria Station administrative procedures are acceptable if they specifically require that evaluation of deferred preoperational test procedures includes the consideration of Technical Specification requirements. 1 l 4

3 Revisi=n: 0 Page 3 of 5 4 RESL*LTS REPORT ISAP III.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Decision Criteria The Action Plan will be considered complete when the CPRT has determined that CPSES Station procedures include the I requirements stated in Section 4.1. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS Deferred preoperational testing is the subject of this ISAP and ISAP III.a.2, " Joint Test Group (JTC) Approval of Test Data." l Technical specification review is one element in the process of deferring testing from the preoperational test program into the 1 initial startup test program. The process of deferring testing activities is discussed in the Results Report for III.a.2, while the following deals exclusively with the aspects of technical specification review performed according to STA-707, " Safety ') Evaluations." 5.1 Station Procedure Review The administrative requirements established by TUGC0 to control the review and approval process for deferred preoperational tests are contained in STA-805, " Deferred Testing," and STA-707, " Safety Evaluations." These procedures were in effect and functioning prior to the NRC-TRT's identification of this issue. This is evidenced by the submittal to NRC-NRR by TUGC0 of requests for deferral of certain preoperational tests in May and June of 1984, and NRC-NRR's subsequent approval of the requested deferrals. The approvals are contained in letters to TUGC0 from NRC-NRR dated June 19, 1984, and August 17, 1984 STA-805 requires, in part, that a safety evaluation be performed according to STA-707, " Safety Evaluations," and that other engineering analyses necessary to support proper dispositioning of a proposed deferral be performed. STA-707, " Safety Evaluations," is the administrative procedure which establishes requirements to determine if a proposed procedure, procedure revision, station modification, test, or experiment would create an unreviewed safety question, or require a change to the technical specifications. 1

Rovision:

                    .                                                Page   4 of 5 3

RESULTS REPORT ISAP III.a.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) In STA-707, paragraph 4.0, " Instructions," specific requirements are established and pertinent paragraphs state in part: A safety evaluation shall be considered a prerequisite, to be performed prior to the approval of any change, test, or experiment to determine if the change, test, or experiment can be safely implemented. Changes, test [s), or experiments that involved unreviewed safety questions or changes to the Technical Specification shall not be implemented until authorized by the Operations Review Committee (ORC) and the NRC in accordance with 10CFR50.59. Review the station license and Technical Specifications to determine which specifications and bases are related to the item being evaluated and the degree to which they would be affected by the implemented item. Decide if the change, test, or experiment involves an unreviewed safety question by reducing the margin of safety as defined in the basis for any Technical Specifications. Analyze the appropriate Technical Specifications associated with the change, test or experiment and determine if a change to the Technical Specifications is required. 5.2 Root Cause and Generic Implications No testing deviation or deficiency was identified and no generic condition exists which indicates that there are inadequate controls with regard to review of deferred preoperational testing for adherence to the requirements of the Technical Specifications. Accordingly, no root cause determination is required.

6.0 CONCLUSION

S Based on the discussion presented in Section 5.0, it was concluded that Station procedures provide for evaluation of deferred preoperational testing and includes, among other things, consideration of the requirements of the Technical Specifications.

Revision: C

                       .                                                                                                  Page                 5 of 5 RESL1TS REPORT ISAP III.a.3 (Cont'd) 7.0 ONGOING ACTIVITIES There are no ongoing activities.

8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE No action was required as a result of this issue. 1 l l l l l l l l l l . l _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ - _ _ _ ~

?;

4 COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.a.4

Title:

Traceability of Test Equipment i Revision No. 4 Reflects Comments. Description On Plan b Prepared and Recou: mended by . I Review Team Leader Date I" O Approved by: Senior Review Team (kA d . J V Date ZfL1 fIL

34 . Revision: 4 1i Page 1 of 4 ISAP III.a.4 Traceability of Test Equipment

1.0 DESCRIPTION

OF ISSUE The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-72 and 73, Item 4, " Assessment of Safety Significance," as follows:

                                                  "...although temperatures were taken and logged during the test (1CP-PT-55-11. " Thermal Expansion,"), the specific

[ temperature] measuring device used at each monitored location was not logged. As a result the calibration of the measuring device could not be traced to the monitored location with the information contained in the test data packages. The TRT found that the completed test data packages did contain the calibration data for the measuring devices used, but as alleged, the devices could not be traced directly to specific monitored locations. While pursuing this matter, the TRT interviewed TUEC personnel who participated in the testing and found that a test coordinator maintained a log which tied the devices to the specific monitored locations; however, the log was not made a part of the test data package. The TRT pointed out to TUEC that while the direct connection was not required by the test procedure as written, the data must be included as

                    -                             part of the test data package."

2.0 ACTION IDENTIFIED BY NRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report. Supplement No. 7 at Page J-17. Item 4.2.1, " Hot Functional Testing," as being necessary to resolve this issue are as follows:

                                                  " Incorporate the information necessary to provide traceability between thermal expansion test monitoring locations and measuring instruments. Also establish administrative controls to assure appropriate test and measuring equipment traceability du:ing future testing and plant operations."

3.0 BACKGROL*ND The traceability between the calibration of temperature measuring instruments and the monitored locations was not documented in the 1CP-PT-55-11. " Thermal Expansion," test data package. The approved test procedure used for conduct of the test did contain requirements for recording pertinent data relating to the calibration of temperature measuring instruments.

's Revision: 4 j3 Page 2.of 4 ISAP III.a.4 (Cent'd)

3.0 BACKGROUND

(Cont'd) The requirements of the aperoved test procedure were not complied with during conduct of ine test as required by CP-SAP-21. " Conduct of Testing." The data was readily available but not in the format

required by the approved test procedure. The personnel responsible

  -          for conduct of the test elected to create a separate log which related the temperature measuring instruments to the monitoring teams that used the instruments. The monitoring teams were assigned specific test packages which identified the locations that were monitored. Therefore, the instrumentation used could be correlated to the location by the known assignments of monitoring teams and specific test packages. The data obtcined by the temporary temperature measuring instruments was used for information only and was not used to judge acceptability of the test or to substantiate any engineering calculations.

The cause of this error is attributed to the engineering personnel temporarily assigned to Startup for thermal expansion testing not being thoroughly indoctrinated in Startup administrative requirements for conduct of testing. The individuals were not adequately familiar with processing Test Procedure Deviations as required by CP-SAP-12 when they desire to deviate from approved procedural requirements. Possible generic implications are that other test personnel may have deviated from approved test procedures without complying with Startup administrative procedure requirements to document approved devintions from those procedures. The test data package in question was incomplete and had not received final approval by the Joint Test Group. One of the objectives of the review process is to assure the test data package is complete in accordance with administrative procedure requirements. 4.1 Scope and Methodology The objective cf this action plan is to ensure that 1CP-PT-55-11 has traceability of measuring and test equipment and that administrative controls are in place to assure such traceability during future testing and plant operation. The following tasks were or will be implemented to achieve the above objective: 4.1.1 Test Procedure Deviation (TPD) No. 36 was issued to include information that related specific test instruce.t identification numbers to the locations where the test instruments were used in the test data package. Test Deficiency Report No. 3418 and TPD No. 37 vere issued to provide traceability to calibration

e.

Revision: 4 i.s Page 3 of 4 ISAP III.a.4 (Cont'd). 4.0 CPRT ACTION PLAN of the instruments and to include the required calibration data relating to the instrument identification numbers in the test data package for ICP-PT-55-11. l 4.1.2 All Startup persont.51 responsible for conduct of l testing were reinstructed on the existing Startup administrative requirements applicable to the traceability of measuring and test equipment. 4.1.3 Startup personnel responsible for conduct of testing I were reinstructed on the existing Startup administrative requirements applicable to the use of Test Procedure Deviations. 4.1.4 Administrative controls applicable to documentation requirements for measuring and test equipment which have been established for the Initial Startup Test program will be reviewed for adequacy and improved if necessary. 4.1.5 Administrative controls applicable to documentation requirements for measuring and test equipment which have been established for station operation and maintenance activities will be reviewed for adequacy and improved if necessary. ( 4.1.6 Startup Administrative Procedure requirements for indoctrination and training of Startup personnel will be reviewed to ensure that lessons learned from this activity, if any, are inecrporated. If procedure changes are made, applicable Startup personnel will be reinstructed on the changes. 4.1.7 Identified discrepancies, if any, will be processed according to Appendix E. "CPRT Procedure for the Classification and Evaluation of Specific Design or Construction Discrepancies Identified by CPRT." Corrective Action, if required, will be implemented according to Appendix H, "CPRT Procedure for the Development. Approval and Confirmation of Implementation of Corrective Action." 4.2 Participant's Roles and Responsibilities 4.2.1 The Startup Special Projects Group Supervisor was responsible to ensure that the information on measuring

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Revision: Page 4

   ,                                                                                                                                                   4 of 4 i      .

ISAP III a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) and test equipment used for thermal expansion testing is included in the completed test data package for l 1CP-PT-55-11. 4.2.2 The Startup Manager was responsible for ensuring that l all Startup personnel had been adequately reinstructed on the requirements for measuring and test equipment traceability and proper utilization of test procedure deviations. . 4.2.3 The CPRT Testing Programs Review Team Leader is responsible for reviewing existing administrative controls for documenting the traceability of measuring and test equipment used for Preoperational Testing, Initial Startup Testing, Operation and Maintenance activities and assuring necessary corrective actions are taken. 4.3 Qualifications of Personnel The CPSES Startup Manager and Startup Special Projects (. -- 4.3.1 Group Supervisor are qualified to the highest level provided in CP-SAP-19, " Training / Qualification Requirements for Startup Personnel." 4.3.2 The CFRT Testing Programs Review Team leader meets the qualifications as described by the CPRT Program Plan. 4.3.3 The Review Team Leader assures that other personnel providing assistance are appropriately qualified. 4.4 Acceptance Criteria Administrative control for measuring and test equipment traceability will be acceptable if applicable administrative procedures require identification and calibration information for measuring and test equipment used to obtain acceptance data be entered on the permanent test results record. 4.5 Decision Criteria The action plan will be considered complete when the CPRT determines that applicable administrative procedures are adequate to control measuring and test equipment traceability documentation and there is reasonable assurance that measuring q and test equipment information is being properly handled. {

l s: 1- c,. .

3 COMANCHE PEAK RESPONSE TEAM . I RESUL.TS REPORT l ( ISAP: III.a.4 ! l-1

Title:

Traceability of Test Equipment i REVISION 0 1 l l l l l Y' -

                                                                                                   ])9 &

Isaus Coordinator Date / 1 _w C } 2 9* h { ev Team I.sader Dace og a. La uhos Date John p Seck, Chairman CPRT-SRT 1

l Rovision: O Page 1 of 14 RESULTS RIPORT ISAP III.a.4 Traceability of Test Equipment

1.0 DESCRIPTION

OF ISSUE The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-72 and 73, Item 4. " Assessment of Safety Significance," as fo11cvs

                                                             ...although temperatures were taken and logged during the test

[1CP-PT-55-11. " Thermal Expansion,"), the specific l ' (temperature} measuring device used at each monitored location was not logged. As a result the calibration of the measuring , device could not be traced to the monitored loestion with the information contained in the test data packages. The TRT found that the completed test data packages did contain tbs calibration data fer the measuring devicar used, but as . alleged, the devices could not be traced directly to specific ) monitored locations. While pursuing this matter, the TRT interviewed TUEC personnel who participated in the testing and found that a test coordinator maintained a log which tied the devices to the specific monitored locations; however, the log j was not made a part of the test data package. The TRT pointed out to TUEC that while the direct connection was not required by the test procedure as written, the data must bt included as part of the test data package. I 2.0 ACTION IDENTITIED BY NRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report. Supplement No. 7 at Tage J-17, Item 4.2.1, " Hot Functional Testing," as being necessary to resolve this issue are as follows: Incorporate the information necessary to provide traceability between thermal expansion test monitoring locations and I measuring instruments. Also establish administrative controls to assure appropriate test and seasuring equipment traceability during future testing and plant operations.

3.0 BACKGROUND

The preoperational test program is conducted according to written , procedures approved by a Joint Test Group (JTG), whose membership j reflects the major CPS 55 design, testing, and operating organizations. The prsoperational tests are conducted by the j I i I

Revision: 0 Page 2 of I' RESULTS REPORT ISAP III.a.4 (Cont'd)

3.0 BACKGROUND

(Cont'd) Startup organization according to the JTG approved procedures. Tite System Test Engineer (STE) responsible for performing a particular test also prepares the final test data package for subsecuant review and approval by the JfG. The test package for ICP-PT-55-11

                                               " Thermal Expansion," had been prepared and was in the process of being reviewed by Str.rtup prior to JTC review v!.en the NRC-TRT reviewed the package. When the concern described in Section 1.0 was expressed by the NPC-TRT, tne Startup organization revised the test package to include the requested information.

As referred to in various standards, the word " traceability" defines a requirement that seasuring and test equipment (M&TE) shall be es11brated utilizing reference standards whose calibration has a known valid relationship to nationally recognized standards such as those maintained by the National Bureau of Standards. The traceability requirement raferred to by the NRC-TRT is established when M&TE exhibits a nonconformance, that is, when a calibration check indicates the equipment was out-of-calibration. This latter requirement is discussed fully in Section 5.1,

                                            ' " Standards / Commitments Reviev."                                                                                                                                  -

CP-SAP-12. " Deviations to Test Instructions / Procedures " allows deviations from approved test procedures when certain approval and documentation requirements are met. The form used to document such deviatiens is known as a Test Procedure Deviation (TPD). < CP-SAP-16. " Test Deficiency and Nonconformance Reporting " establishes requirements for the use of Test Deficiency Reports (TDRs). TDRs are issued when unacceptable or indeterminate conditions exist in system or equipment operating characteristics, test documentation, or for any testing procedure noncompliance. TDRs contain a description of the specific problem, the corrective action required, and/or the ratesting necessary to resolve the probles. Both TDRs and TPDs become part of the completed test record reviewed by the JTG prior to acceptance of the test results. 4.0 CPET ACTION Pl.AN 4.1 scope and Methodology The objective of this action plan was to ensure that ICP-PT-55-11. " Thermal Expansion," had traceability of M&TE to the degree requested by the NRC-TRT, and that administrative controls are in place to ensure required traceability during future testing and plant operation.

A Revision: O Page 3 of la RESL*LTS REPORT ISAP III.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) The following tasks were taplemented to achieve the above objective: 4.1.1 Industry standards and TUGC0 commitments were reviewed to ascertain the degree of traceability documentation for M&TE which should be included in applicable procedures. 4.1.2 Test Procedure Deviation (TPD) No. 36 was issued to include information requested by the TRT in the test data package that related specific test instrument identification numbers to the locations where the test instruments were used. Test Deficiency Report (TDR) No. 3416 and TPD No. 37 vare then issued to include traceability (required by TUGCC) to calibration of the instruments and the required calibration date relating to the instrument identification numbers in the thermal expansion cast data package for ICP-PT-55-11, 4.1.3 All Startup personnel responsible for conduct of testing were reinstructed on the Startup administrative requirements applicable to the traceability of M&TE. 4.1.4 Startup personnel responsible for conduct of testing were reinstructed on the Startup administrative requirements applicabla to the use of Test Procedure Deviations. 4.1.5 Administrative controls applicable to documentation requirements for M&TE which have been established for the Initial Startup Test program were reviewed for adequacy. 4.1.6 Administrative controls applicable to documentation requirements for M&TE which have been established for l station operation and maintenance activities were reviewed for adequacy. 4.1.7 Startup Administrative Procedura requirements for indoctrination and training of Startup personnel were reviewod to ensure that lessons learned from this activity had been incorporated. l

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F.e vis io n : 0 ,

                     .                                                                                                  Page 4 of 14         I
 .                                                                                                                                           l RESULTS REPORT ISAP III.a.4                                       i (Cent'd)                                         l 4.0 CPRT ACTION PLAN (Co=tt's)

I 4.2 Participants' Roles and Responsibilities, 4.2.1 The Startup Special Projects Group Supervisor, Mr. S. M. Franks, was responsible for ensuring that traceability information on M&TE ured for thermal expansion testing as requested by the TRT had been included in the completed test data package for I CP-PT 11. 4.2.2 The Startup Manager Mr. R. E. Camp, was responsible for ensuring that all Startup personnel had been adequately reinstructed on the administrative requirements for M&TE traceability and proper utilization of test procedura deviations. 4.2.3 The CPRT Testing Programa Review Tasa Leader, Mr. J. E. Rushwick, and the Issus Coordinates, Mr. T. h. Broad, were responsible for reviewing existing stainistrative controls for documenting the traceability of M&TE including training requirements v:;ed for Preoperational Testing, Initial Startup Testing, Operation and Maintenance activities, and assuring necessary corrective actions vers taken. 4.3 Qualifications of Pernsenal 4.3.1 The CPSYS Startup Manager and Startup Special Projects Gro':p Supervisor are qualified to tha highest level provided in CP SAP-19. " Training / Qualification Requirements for Startup Personnel." 4.3.2 The CPRT Testing Programs Brview Team Leader meets the qualifications as describec by the CPRT Program Plan. 4.3.3 The Review Team Leader was responsibis for ensuring

that other personnel providing assistance in the conduct of the Action Plan were appropriately qualified. 4.4 Acceptance Criteria Administrative controls for M&TZ traceability are acceptable if applicable administrative procedures are used. Ther.e procedures are acceptable if they require that identification and calibration information for M&TE used to obtain acceptance l data be entered on the permanent test results record.

                       -.  - .-.c ,.. -         .       . _ . . . , _ _ _        _ . . _     ..... . . . ,,  . ; _ , _.            ,.  .

Revisien: 0 Page 5 of 14 RESL'LTS REPORT ISAP III.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Decision Criteria l The action plan will be considered complete when the CPRT has detartined that applicable administrative procedures are consistent with the commitments to be identified duriog the l conduct of this ISAP with regard to control of M&TE traceability documentation, and there is reasonable assurance that METE information is being handled in accordance with these procedures. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The CPRT reviewed this issue by examining the specific test data package in question, and performing the reviews requested by the NRC-TRT and described in Section 4.1 above. The followiss presents l the results of the review.

                                        -       5.1 Standards / Commitments Review TUGCO's commitaant relative to MATE traceability is presented in Section 17.2.12 of the CPSES TSAR:

l When test and nessuring devices utilized in activities affecting quality are found to be out of calibration, an evaluation is made and documented concerning the validity of previous tests and the acceptability of items previously tasted since the last valid calibration. The above commitment is consistent with the requirements of industry stendards and guidelines which address M&TE use, control, and calibration. In particular, IEEE Standard 496-1960, " Standard Requirements for the Calibration and Control of Measuring and Test Equipment Used in the Construction and Maintenance of Nuclear Power Generating Stations," and ANSI N45.2.6-1975, " Supplementary Quality i Assurance Requirements for Installation Inspection, and l l Testing of Machanical Equipment and Systems for the l Construction Thase of Nucisar Power Plants " discuss this subject. 1 1

Rovision: O Page 6 of te RESULTS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ALIION PLAN AND D7.SCUSSION OF RESULTS (Cont'd) Specifically ANSI N45.2.8-19'/5 states: When measuring and test equipment is found to be out of calibration, an evalt.acion shall be made of the validity of previous inspection or test results and the acceptability of mer.hanical items inspected or tested since the last cali' oration check. and IEEE 498-1980 contains the following: M&TE and reference standards found 20 be out of calibration or v41ch have not been properly saintained, or calibrated, er which have been subjected to possible damage, shall b1 identified as nonconforming and removed from service until such time as corrective measures have been taken. All equipment tested or calibrated by the item since the last calibration shall be identified and sufficient investigatices performed to either re6stablish the acceptability of the equipment or to confirm a nonconformance. TUCCO's specific f esting-related commitment concerning M&TE is established in Regulatory Guide 1.68, " Initial Test Programs for Water-Cooled Nuclear Power Plants," paragraph 1.

                                          "Documentatipu of Test Results," of Appendix C, " Preparation of Procedures," which states the followingt I

Records should identify each observer and/or data recordor participating in the test, the type of observation, the identifying numbers of test or measutting equipment, the results, the acceptability, and the action taken to correct any deficiencies. l l The recordfag of calibration data for M&TE for preoperational testing is addressed in two Startup Administrative Procedures. CP-SAP-7, " Format and Content of Test Instruction / Procedures," establishes the following requirement for M&TE used in preoperational tests: A space will be provided in this section (Section 4.0,

                                                  " Test Equipment,"] or on the appropriate data sheet to record the test equipment identification number, calibration due date. .       .

p . __. . _ . .. .. . .. . .. ,_ .. . ,

Revision: O Page 7 of la 4 RESL*LTS REPORT ISAP III.a.L (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND CISCUSSION OF RESL*LTS (Cont'd) 1 CP-SAP-21, " Conduct of Testirg." establishes the following I requirement: The STE shall ensure that the cast equipment identification number and calibration due date for test equipment used to measure and record acceptance data is recorded on the test data sheet or provided in the body of test procedures. Based on the above, it was concluded that compliance with the traceability requirements for a nonconforming situation may be achieved by various methods as long as sufficient information is available to perform the required evaluation. For example, compliance may be achieved by requiring traceability of M&TI use to a building, a room within a building, or an elevation within a building. Recognizing that various options are available, TCCCO's Startup organization established two alternatives for M&TE traceability compliance. The M&TE used may be traced to the specific test procedure by recording the calibration and idrantification information in Section 4.0,

                               " Test Equipment " of a test procedure. The M&TE used may also be traced to specific locations when the calibration and identification ir. formation is recorded on the data sheets used to record test data. Both methods are acceptable and achieve compliance with indus'ry codes and standards.

With traceability only to a test procedure, an entire test may have to be repeated if M&TE used is subsequently found to be out-of-calibration. For that reason, providing traceability for METE to each monitoring location can prove to be useful when performing the required evaluation af ter identifying a nonconformance. However, this degree of traceability, as requested by the NRC-TRT for ICP-PT-55-11, is not a requirement _; it is a matter of convenience and econymics in. order to sinimize the amount of ratesting.which may be required to be performed. 5.2 Test Data Packate, 1CP-PT-55-11. " Thermal Expansion" .. --- This test data package had been amended by the Startup organization to include the information requested by the NRC-Tir and was subsequently reviewed and approved by the JTC. The CPRT Third-Party reviewed the JTG approved test data packsge for M&TE traceability conformance with TUGC0 commitments.

     - - - . - ---,..-.       _.,,__._.       _...._...3.___ .

Re v'.s ion : O Page B of IL RESULTS RIPORT ISAP III.a.4 (Cont'd) 5.0 IMPLDfENTATION Oy ACTION PI.AN AND DISCUSSION OF RESULTS (Cont'd) 5.2.1 Observations During this review, the following were observed: a) Two pages of Table II, " Digital Thermometer Calibration Record," which were designated to contain the information required to meet TUGCO's M&TE traceability commitment, were blank at the time of the NRC-TRT review. b) The specific instrument calibration data sheets which contained the information necessary to cosplete Table II were in the data package in Section 5.0 " Miscellaneous Infocuation." c) The STE had failed to fill out Table II when the test equipment was checked out from the TUGC0 IEC group although the information was I included in Section 5.0. - d) All that was required at the time of the TRT review to be in complete compliance rich Startup administrative procedures and TUGC0 complements was to transfer the unique test equipment identifier and calibration dus date from the calibration data sheets which wars in the test data package to Table II. e) Temperature and thermal movement data vers recorded and analyzed at specific steady-state temperature plateaus during the l rise to normal operating camperature and pressure. At each plateau and at nora21 operating conditions, the actual recorded temperature and thermal movement data were correlated with those movements predicted by the stress analyses. It should be noted that previous ISAPs for III.a.4 mentioned in the background information section that the temperature data obtained from this test was used for information only and was not used to judge acceptability of the test or to substantiate any engineering calculations.

     . .._. ;... .. _ . 7 .., _ , .. ........,. _ . ..,..

Revision: O Page 9 of 14 RESULTS RE?CRT ISAP III.a.4 (Cont'd) ) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) f) Subsequent to its use in ICP-PT-55-11, calibration checks were performed on all M&TE utilized, and no items of nonconformance were identified. g) The log that is referred to tu Section 1.0 was, in essence. a test planning document developed by the STE to coordinate the efforts of more than 120 data collectors for this preoperational test. The additional information which it contained was utilized by the Startup group in responding to the NRC-TRT's request. h) During the conduct of 1CP-PT-55-11 and subsequent consolidation of data and results, thirty-eight TPDs and 636 TDRs were properly generated. The TPDs were generated to add new design information to data sheets, and most of the TDRs' vere generated due to supports not being installed, support modifications required during conduct of test, or failure of supports to meet acceptance criteria. The TDRs identified the specific discrepancy and established retest requirements.

1) All items which f ailed to meet the test acceptance criteria were either resolved by j engineering action or left as open items t which were transferred to Plant Operations for ratesting and scheduled as part of the Initial Startup Program.

5.2.2 conclusions Based on the above observations it was concluded that the appropriate information required by CP-SAP-7 and CP-SAP-21 was included in the test data package for 1CP-PT-55-11, and only an oversight on the part of the STE resulted in his' f ailure to completely fill out Table II. l

1 U-___-___________

Revision: C Page 10 of te RESULTS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) To provide an added seasure of assurance that the applicable requirements concerning M&TE were being properly implemented, a review of other test data packages was undertaken. In conjunction with the implementation of Action Plan III.a.1, " Hot Functional Test Data Packages." twenty-sevon preoperational test data packages vote reviewed for proper METE . documentation. In all of the tests, provisions for METE were found to have been ns.de in accordance with requirements of CP-SAP-7 and data were entered in accordance with the requirements of CP-SAP-21, 5.3 M&TE Reindoctrination Startup personnel were reindoctrinated in the M&TE requirements established in CP-SAP-7 and CP-SAP-21. 5.4 Test Procedure Reindoctrination l Startup persbnnel were reindoctrinated in the requirements of CP-SAP-21, " Conduct of Testing," which establishes requirements applicable to the use of Test Procedure Deviations. 5.5 Initial Startup Procedures A review was conducted of the Initial Startup procedures listed in Attachment i to this Results Report, and it was determined that M&TE traceability requirements were adequately addressed in accordance with the criterion in Section 4.4 5.6 Station Procedures A review was conducted of the Station administrative procedures listed in Attachment 2 to chia Results Report, and it was determined that M&TE traceability requirements were adequately addressed in accordance with the criterion in Section 4.4 As an additional indication of the adequacy of the M&TE' program at CPSES, it should be noted that an evaluation was conducted by the Institute of Nuclear Power Operations (INPO) of the entire CPSES Instrument and Control Program in April and May, 1985, and no discrepancies were identified. The

   ..-- ..,.~..;.,;n---..........                                                                                                                                  ,

Revision: O Page 11 of 16 RE5UI.TS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPI.EMENTATION OF ACTION Pt.AN AND DISCUSSION OF RESUI.TS (Cont'd) evaluation stated that strict, detailed adherence to the program as detailed in CPSES Procedure STA-608, " Control of Measuring and Test Equipment," was noted as well as comprehensive incorporation of the recossendations of INPO Good Practice MA-303, " Control and Calibration of Measuring and Test Equipment (M&TE)." 5.7 Training Requirements The administrative procedure which addresses paraionnel training, CT-SAP-19 " Indoctrination / Training / Qualification Requirements for Startup Personnel." defines the indoctrination and minisua qualifications that are required for Startup personnel assigned to perform testing and related activities and provides a method of documenting personnel indoctrination and qualification. The review of this procedure and the personnel training files indicated that indoctrins. tion in the requirements of CP-SAP-7 and CP-SAP-21 was requi' red, tonducted, and documented. s 5.8 Root Cause and Generic Implications No testing deviation or deficiency was identified and no generic condition exists which indicates that there are inadequate controls on M&TE trb u bility in preoperational testing, initial startup testing, or station procedures at CPSES. Accordingly, no root cause detet31 nation is required. 6.0 CONCI.USIONS Based on the discussion presented in Section 5.0 above, it was concluded that:

1. The M&TE traceability information requested by the NRC-TRT is included in the ICP-PT-55-11, " Thermal Expansion," test data pack. age.

2. Requirements exist in Startup and Station implementing procedures to ensure compliance with TUGCO's M6TE traceability comunitaants.

7.0 ONGOING ACTIVTTIES There are no ongoing activities.

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Revision: 0 Page 12 of.11. RESUI.TS REPORT ISAP III.a.4 (Cont'd) 8.0 ACTION TO PREC1,UDE OCCURRENCE IN THE FUTURE No action was required as a result of this issue, but it should be noted that subsequent to the identification of this issue by tne NRC-TRT, CP-SAP-19 was revised to provide more specific requirements for training of personnel involved in various levels of testing activities, and reindoctrination of personnel was conducted as described in Sections 5.3 and 5.4 I 2 e

 -4 Revision:                                O Page 13 of 14 P

RESUI.TS REPORT ISAP III.a.4 (Cont'd) Attachment 1 Initial Startup Procedures Reviewed STA-801 Initial Startup Program ISA-001 Initial Startup Test Procedures ISA-004 Conduct of Initial Startup Testing ISA-005 Initial Startup Test Package Preparation, Review, and Approval 1 l l

l . Revision: 0

      ,                                                                                  Page 14 of 14 RESL*LTS REPORT l

ISAP III.a.4 (Cont'd) Attachment 2 CPSES Station Procedures Reviewed STA-202 Preparation, Review, Approval, and Revision of Station { Procedures j l STA-209 Preparation, Review, Approval, and Revision of Station Instructions f \ \ l STA-608 Control of Measuring and Test Equipment ) l l STA-702 Surveillance Test Program l l EDA-105 Engineering Department Surveillance Test Procedures EDA-112 Results Engineering Testing Guidelines ! l I EDA-113 Conduct of Results Engineering Test Procedures ) ODA-206 Preparation of Operations Test Procedures and Equipment Test Procedures l ODA-207 Cuide11nes for the Preparation and Review of Operations l Procedures MDA-201 Electrical and Mechanical Maintenance Procedures and Instructions MDA-204 Maintenance Engineering Instructions INC-107 Ibc Scheduled Calibration Maintenance Program _.------..-..-----_._--_-.--.-N

l) , TO: CPRT SENIOR REVIEW TEAM TROM: Chairman, Results Report and Working File Review Committee DATE: July 24, 1986 l

SUBJECT:

Working File Verification Report for ISAP No.III.a.4, Rev. O The Working File review and verification team has completed its review of the Working file for 1 SAP No. III.a.4. Rev. O. Our conclusions and (if applicable) any remaining unresolved consents are presented below. NO YES X The ISAP was implemented as defined and approved by the SRT. X The content of the Working Tile is complete and l I organized in a manner consistent with the requirements of the CPRT Program. X The work reported in and conclusions reached in the Results Report for the ISAP are substantiated by the infomation contained in the Working Tile. Review Committee Comments: Cosesent Cont 1 nutation Sheets Attached: Tes _ No 1 No. of Sheets

                                ..       ppy         f_-- _                _-.     .

p n) g, fy ,,u m view Team Leader, Chairman, Results RepWand -- - Working File Review Committee > ISAP No. III.a.4 _ _ _ T1LT2MS

                                                                                                                            -      ---------______________a

rg s COM.A.NCHE PEAK RESPONSE TEA.M RESL'LTS REPORT ISAF: III.d

Title:

Preeperational Testing REVI5;0N 1 l _w .u 3 I?' 8d Issue Ccorcir.ator Da:e 1 m_ >-

3 l3-QC

              / Ke Tew Tea: Leader                               Date U.       '^'-                       jf/3 / tim JohW W. Eeck, Chairman CFET-5KT                Date
                                                                             )

i i 1 l

l

B Fevision: 1 o Page 1 of : REH*tTS RE? ORT I ISAP III.d Preoperational Testing I

1.0 DESCRIPTION

OP ISSCE The SRC-TRT described the issues in the CPSES Safety Evaluation Report, Supple:ent No. 7, as follows:

                                       "In TP Category 5, the TRT found that Syste: Test Engineers (STEs) were not on controlled distribution for design changes applicable to systees to 'which they were assigned; rather, they were required to obtain this infor:ation on their own initiative from the docu=ent control center prior to starting a test and were then required to incorporate that infor ation, as applicable, into the test procedure. While the TRT did not identify any specific proble=s as a result of this practi:e, it considers this practice to be weak since it relies too          j heavily on the motivations and initiatives of test personnel       l to ensure that they have current design infor:ation when they are develeping test procedures and before conducting tests.

Typically, these are periods vben they could be under note than normal pressure. Additionally, because of the nu ber and l nature of the proble=s found in the docu ent control syste: by the TRT QA/QC Group, the TRT could not reasonably conclude that the docu ent control syste: proble=s identified did net affect testing activities." Page J-13, Ite: 3.2.3, "Pindings for Test Progra= Issues."

                                       "The TUEC Startup Group relies heavily on the accuracy and          j ee pleteness of the design docu=ents, which are included in         l the docu ent control systet, in its preparation of test procedures and during the conduct of testing. A nu:ber of          {1 l                                       proble:s were identified in the docu:ent contrel syste by the TRT QA/QC Group during its review. While the TRT Test Progra:      ]

Group did not find that these proble=s adversely affected those portions of the testing progra: that it included in its review, the TRT cannet conclude with reasonable assurance that the decurent control syste: proble=s had no adverse effect on testing activities." Page J-14 Ite: 3.2.4 "Overall Assess:ent and Conclusions." 1 1 l. 1-l 1 Sections 1.0 through 4.0 ef this repert are reproductions of Revision 4 to the ISAP, dated February 27, 1986. I 1 L_____-_.

Revisien: 1

 .                                                                                                  Page 2 ef 23 RESULTS rip 0FT ISAP III.d (Cent'd) 2.0 ACTICS IDENTIFIED EY NRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supple =ent No. 7 at Page J-18, Ite: 4.2.4 "Preeperational Testing," as being necessary to resolve this issue are as follows:
                  " Establish measures to provide greater assurance that STEs and other responsible test personnel are previded with current centro 11ed design docu=ents and change nottees.

Provide NRC with reasont.ble assurance that the decur.ent centrel syste probler.s identified by the TRT QA/QC Grcup did net affect the testing activities." 3.0 BACKCROUND The Startup Administrative Procedure CP-SAP-21. "Cenduct of Testing," as reviewed by the NRC-TRT, stated that the STE was required to: .

                   " Review the syste drawings and applicable design chances te determine that the as-built cc:ponent/syste: vill be adequately tested by the current precedure revision te derenstrate proper cc ponent/systee operation."

The TRT reviewers' concerns were twofold: (1) that this requirement

             =ay rely too heavily on an STE's cotivatien and initiative at the ti e when he is under more than ner a1 job pressure and is expe:ted to start testing activities and that he may not have the latest design information in his possession, and (2) that the proble:s identified by the NRC-TRT QA/QC Grcup with the Docu ent Contrel Center (DCC) for construction activities may have adversely affected the testing progra=.

The NRC-TRT QA/QC Group's findings were specifically addressed in CPSES Safety Evaluatien Report, Supplement No. 11 at Page 0-10 Ite: 3.2.2. "Docu:ent Control Issues," as follows: l "The QA/QC Group found that prior to 1984, there were nurereus recurring ad=inistrative and procedural deviations in the docu=ent control function. Many of these recurring deficiencies were identified by internal and external audits. But there was little follev up or verification by TUIC

                   =anage:ent that effective corrective actions were taken, unti".

early in 1964 when the docu=ent centrol center (DCC) menitoring team began reporting to senior canagezent. The

c-___--_ -- _ _ 1 1 i I Revisien: 1 Page 3 of 23 RESULTS rep 0RT L ISAP III.d (Cont'd) 3.0 B ACKCROUND (Cont 'd)- current docu=ent control program, with an estimated errer rate of one percent or less, was found to be adequately staffed anc effective. The. proble= of incorrect and ince:plete drawing packages appears to have been corrected. In summary, the QA/QC Group fcund the current docu:entatien control pregra: to be acceptable. However, prior to 1954, as identified by CAT (Construction Assess ent Tea =] and TUIC, there was a document control breakdewm. Although =any of the document centrol deficiencies have been corrected, the 1:plicatien of past inadequacies on construction and inspectice have potential generic significance which has not yet been fully analyzed by TUEC." Subsequent to TUEC submitting Revision 2 of the CPRT ProFra: Plan and ISAP to the NRC, sampling fro: the populatien described belew in Sectien ...l.0.4 " Prerequisite Test Population Definitien," has proceeded. The original intent was to prepare one populatien te be sa: pled, screened, and evaluated for i= pact on both the prerequisite and preeperational test prograes. The original-pepulatien identified proved adequete for prerequisite testing but not for preoperational testing. The CPRT, with SRT concurrence, proceeded to prepare a separate populatien for the preeperatienal test program evaluatien. The additional population prepared for the preoperational test pregra evaluation is described belew in Section 4.1.2.5, "Preeperational Test Pepulation Definition.' The action plan presented in Sectien 4.0 was developed to include a review of past and current ade.inistrative require =ents for use of design docu=ents during testing; a review of the technical test procedures utilizing the design documents; and a rando: sa:pling and evaluation program to deter:ine the ef festiveness of the ad:inistrative require:ents. 4.0 CPRT ACTION PLAN 4.1 Scepe and Methodeleev The objective of this action plan is to resolve the two desi;n document related issues identified by the NRC-TRT. The first issue will be investigated to deter:ine any additional measures required to insure that ST!s and other responsible test personnel are efficiently and effectively provided wit..

Revisien: 1 Page 4 of 23 RES'.*LTS REpO*T ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) current design docu ents for use in their testing activities. The second issue vill be investigated to deter =ine if the proble=s with DCC identified by the NRC-TRT QA/QC Croup had an adverse affect on the testing program activities. l j The individual objectives and tasks for each issue are discussed separately below. 4.1.1 STE's Access to Current Design Docu=ents This task will deter =ine if ad:inistrative procedures and verk practices by the Startup and DCC organi:atices are adecuate to provide for the use of current design dccu=ents in the perfor:ance of testing activities, and to identify additional requirements, if any, which need to be established to ensure compliance with this . requirement. The steps required to complete this task are: reviewing the Startup Ad:inistrative Procedures as they relate te use of current design decu:ents; reviewing the organt:atienal interface and work practices be:veen the Startup and OCC organi:ations; and interviewing individual STEs. 4.1.1.1 Startup Ad:inistrative Procedure keview Review Startup ad inistrative precedures te deter =ine if practices are likely te lead to a progra==atic discrepancy. The procedures 1 will be reviewed to deter =ine when > ad:inistrative require:ents need to be applied to the use of design docu:ents, that the require:ents are clearly stated, and indicate the ticeliness for use of current design docu:ents. The CPRT will perfer: this review. l 1 l i 1 l 1

4 Revision: 1 Page 5 of 23 RES'JLTS RE? ORT ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.1.2 Startup and DCC Interface Review the organizational interfaces and verk practices between the Startup and DCC organizations which are applicable to the acquisition and use of current design docu ents. Deter =ine the adequacy of past and present practices in eeeting the require ents of the testing progra . Identify and impleeent improvements if required. The CPRT will perfor: these reviews. 4.1.1.3 Syste: Test Engineer Interviews Interview System Test Engineers to determine their cethods of co: plying with the current design decument require:ent and to further assess the need to upgrade existing precedures and methods. The C?RT wil' . conduct these interviews. 4.1.2 Potential for DCC Proble=s to Adversely Affect the Testing Progra: This task will evaluate the effect of DCC proble:s identified by SRC-TRT QA/CC Group on the testing progra by determining the Startup erganizatien's response to properly autherized design changes initiated by Engineering, processed through the DC: l organization, and requiring a testing response by I Startup, j The Startup organization ut111:ss drawings as a primary resource in the preparation of technical test procedures and the execution of testing. Other resources are used, however they are not controlled by the DCC. Startup responds to three methods of changing the design by Engineering. The three Engineering design change procedures are: direct issuance of a revision to a design drawing which does not incorporate the other two rethods; issuance of a Design Change Authorization (DCA) which is a design drawing chante described in approved documents issued te perarily until the actual design drawings may be updated and issued; and issuance of a Component Modification Card (CMC) which is similar to the DCA. I

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     .                                                                                           Page 6 of 23 REe'JLTS REPCP T ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

An evaluation progra: v111 be developed and perfor:ed which will focus on opportunities for a DCC error to begin a chain of events which results in a testing error. Error opportunities involve design changes, co::unicated by way of changes to design docueents distributed and controlled by DCC, where the design change created a need to change a test procedure, perf or= retesting, or perf or: additional testing. This type of evaluaticn was designed to preclude the nature of DCC errors fro: affecting the results. The Startup organization utilizes only a fraction of the design docu:ents prepared for the project. This subset of design documents and the changes to the are easily identified and the beundaries of a valid populatien of design changes readily established. The CPRT decided that a saepling program te res: ve this issue veuld be appropriate because there are no pregra= atic deficiencies identified te date, the criteria by which they will be evaluated in this study will be the sare, the pepulatien of items to be sar;1ed is heregeneous (i.e., the precess by which these iters are handled by the DCC is the sa e), and thus a sa:pling pr:gra: in accerdance with Appendix D will aid in deter ining whether or net syste atic discrepancies exist. The pctential adverse effect of the DCC problers identified by the NRC-TRI QA/QC Croup on the testinc progra:s will be evaluated by: deter ining a calendar interval when DCC problers could have adversely af f ected startup; identifying and reviewing procedures and instructions which utilized DCC controlled design docu=ents; defining the population of changes to the design documents; rande: sa:pling the populatien of changes; and evaluating the sampled design charges fer adverse effects on the prerequisite and preoperati nal test progra:s. The steps which are required to accomplish this task are described below: , s

k 1 Revisten: ! ' Page 7 of 23 RES'.*LTS RE?CRT l' l ISAP III.d I (Cont'd) l l 4.0 CPRT ACTION PLA.N (Cont'd) 4.1.2.1 Period of Interest Deter =ine the period of interest during which l Startup could have been adversely affected by DCC problems. This period vill begin at the start of prerequisite testing by Startup ard the end date vill be based on the results of CPRT review and assess =ent of CPSES Moniters Tea: monitoring reports of DCC perfor:arce. These same reports were utilized by the NRC-TRT in their evaluations. 4.1.2.2 Prerequisite Test Instruction Review All prerequisite test instructions vill be reviewed to determine the types of design docurents contrelled by DCC which were used during the execution of prerequisite testing. All design docu=ents of this type vill be included in the prerequisite test populatien. The CERT will perfor= this review. 4.1.2.3 Preoperational Test Precedure Review All preeperatietal test procedures perfor:ed during the period of interest and not co:pletely reperformed thereafter vill be .i reviewed to identify the design documents referenced by the test procedures and centrolled by DCC. The design docu=ents identified will be included in the prerequisite test population. A preoperational test sub-population vill be identified free this list of referenced design docu=ents. This review will be perf erred by the CPRT. 4.1.:.4 Prerequisite Test Population Definition The pcpulation of all design drawing revisions, all DCAs, and all CMCs issued during the period of interest and used by the ! Startup organization in the preparation ef j teet procedures or during the executiet cf l testing vill be identified. The CPRT vi..

\ l Revisier: 1 ) Page 8 of 23 REcrLTS REPORT l ISAP III.d l (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) identify the prerequisite populatien with assistance from TUCCO Nuclear Engineering. Preliminary esti=ates indicate that the ~ population will include approxi=ately 73.000 items. 4.1.2.5 Preoperational Test Population Definition The preoperational test pepulation will he identified frem the design document refererce list created by Section 4.1.2.3 which includes only the flow diagra:s and centrel circuit scheeatic diagra:s. In the hierarchy of engineering design docu ents, these two classes of drawings will have the =est significant influence on preoperational testing. This popu?.ation will be identified by the CPRT. Preli inary estimates ir.dicate that the pcpulatien will include approximately 1,100 items. 4.1.2.6 Populatien Screening Criteria Each docu ent change in the prerequisite and preeperational test populations will he screened until it reets the fo11 cuing criteria: The change is to a design decurent.

                                   -     The change is issued through DCC.
                                   -     The docu=ent is refererced by a test procedure or is used during the performance of a specific test.
                                   -     The test procedures which referen:e or utilize the affected docu=ents were perfor:ed during the period cf interest and were not eo:pletely reperfer:ed following the peried of interest.

The decu ent change cecurred prict to perf ormance of the test.

Revisien: 1 Page 9 of 21 RESCLTS REPORT ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

                                                     -                   The change would require a test or retest.

The CPRT will perfor: the evaluatices with assistance free TCCCO Startup. 4.1.2.7 Sample Evaluation After random selection and screenine, testir; records will be examined for each sa:ple ite: to deter =ine the following:

                                                      -                  Whether a test was cendu:ted by Startup per the change, er
                                                      -                  Whether Startup documentation demonstrated they were aware of the change.

A negative finding in both cases vili constitute a discrepancy. The CPRT will perfore the evaluations with assistance fr:: TCGC0 Startup. 4.1.3 Identified discrepancies, if any, vill be precessed eccording to Appendix E. "CPET Precedure for the Classification and Evaluation of Specific Cesign er Censtructien Discrepancies Identified by CPRT." Corrective action, if required, vill be imple:ented according to Appendix H. "CPRT Precedure fer the Develop:ent, Approval, and Confir:ation of Imple=entation of Corrective Action." 4.2 Participants Reles and Responsibilities 4.2.1 Organizations involved 4.2.1.1 CPSES Startup Group 4.2.1.2 TUCCO Nuclear Engineering Group 4.2.1.3 CPRT Testing Programs Review Tean

Revisien: 1 Page 10 of 23 RESULTS REPORT ISAP III.d (Cent'd) 4.0 CPR7 ACTION PLAN (Cont'd) 4.2.2 Sct;e for each Organization 4.2.2.1 CPSES Startup Group

                                                           -    Revise Startup Ad=inistrative Procedures and instruct STEs en new                                                                    1 procedure require =ents.
                                                           -    I=plerent corrective actions resulting frc: the CPRT investigation into the effect en testing due to DCC problens, and
                                                           -    Provide qualified persennel to assist in the screening and sa ;1e evaluaticn.

4.2.1.0 TCO:0 Nuclear Engineering Creup Provide engineering drawing hister. data fer sa:ple preparatten. 4.2.2.3 CFR! Testing Pregra s Review Tea: Evaluate the CPSES document centrol pregra: and applicable i Startup Ad::nistrative Procedures and centrol cetheds, l

                                                           -    Review and concur with applicable l                                                                Startup Adritistrative Procedures revision,
                                                           -    Deter:ine whether the testing progra: has been adversely affected by DCC problems and specify corrective actions, if necessary, and
                                                           -    Overview the work perfor:ed by ether organizations assisting CPRT.

I t- _ - - - - - _ - - - _ _ - _ _ _ - - - - - - - - - _ _ _ _ - - - - _ - _

Revisien: 1 Page 11 of 23 ] I RES'lLTS PEPOPT ISAP III.d (Cent'd) { l 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3 Lead Individuals 4.2.3.1 Mr. S. M. Tranks CPSES Startup Group 4.2.3.2 Mr. J. E. Rushvick CPRT Testing Pregrars Review Team Leader 4.3 Persennel Oualift:stiens 4.3.1 The CPRT Testing Progra:s Review Tea: Leader meets the qualifications as described by the CPRT Progra: Plan. 4.3.2 The Startup personnel participants will be qualified in accerdance with CP-SAP-19. " Training / Qualification Require ents for Startup Pe~rsonnel." 4.3.3 The Review Tea- Leader assures that other persentel previding assistance are qualified. 4.4 Precedures The felieving precedures vill g:vern revisien of Startup Ad: nistrative Procedures: CP-SAP-1, Startup Ad:inistrative Precedures Manual CP-SAP-21, Conduct of Testing 4.5 Acceetance criteria The acceptance criteria for the two investigated issues are discussed belev: 4.5.1 STIs Access to Current Design Documents The procedures and methods are adequate to the satisf actien of the Testing Programs Review Team Leader to assure that STEs and other responsible test persennel are cognizant of and are provided with current design docu=ents. This finding rust be supported by the results of rando: sa:pling and evaluation cf the use of design change documents. I i

Revisien: 1 Page 12 ef 22 RESULT! RE?CRT ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5.2 Potential for DCC Proble=s to Adversely Affect the Testing Progra= In order for DCC proble=s identified by the NR2-T77 QA/QC Croup to be judged to have had no adverst effect on preoperational or prerequisite testing, a pr:;erly selected, screened, and evaluated design charge docu:ent sa:ple must meet the fo.'.leving criteria: 4.5.2.1 Prerequisite Test Progra: The design change was tested as evidenced by approved test data or was decurented as being eenitored by Startup as an open itet. 4.5.2.2 Preoperatienci Test Pregrae

                                                                              .                                                 A preeperational test precedure incer;; rated the design change or was docu:ented as be:r; c:nitored by Startup as an open iten.

4.6 Decisier Criteria 4.6.1 STE's Access te Current Design Decuments The ad:inistrative precedure(s) are satisfactory or, if necessary, are revised to the satisfaction of the Testing Programs Review "eam Leed:: nd ec;..wrred with by the Senior Keview Team. 4.6.2 Potential for DCC Preble=s to Adversely Affect the Testing Progra: The objective of the rando: sa:pling and evaluatier I progra: is to provide reasonable assurance that the problets identified by the NRC-TRT did not, in fact, adversely affect the test progra=. If one er ecre discrepancies are found to have adversely affected the test progra= an expanded investigation will be undertaken in accordance with Appendices D and E. i I i l l

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 .'                                                                                                 Page   13 ef 23 RES*JLTS REPCRT ISAP III.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESCLTS The following sections present a su::ary of action plan 1 ple:eetation and specific discussions of the results of each issue investigated.

5.1 Surnarv ef Action Plan I:;1erentation. The NRC-TRI issues were investigated by a combination of administrative procedure, organizational interface, and test procedure review; interviews with personnel; and rando: sa:pling and evaluation. To perfor: these analyses, the CPRT reviewed approx 1:stely 6000 docu=ents which consisted of administrative procedures, test procedures, dravits revisiens, design change decunents, and audit reports. 5.2 STE Access to Current Desien Decueents The CPRT reviewed the Startup Administrative Procedures and

                                          ,      the Startup and DCC organizational interface, and interviewed individual STEs. The require ents'for administration of the test progra: vith regard to the use of current design informacien were evaluated during these reviews.

5.2.1 Startup Administrative Procedure Review Prior to the CPRT review of the Startup ad:inistrative procedures, TUGC0 Startup had revised adrtnistrative procedures and initiated required retraining of personnel in response to the NRC letter of Septe:ber 18, 1984 The CPRT reviewed the Startup ad inistrative procedures in effect as of September,19Sh to deter ine where the activity being controlled needs ad:inistrative require ents applied to the use of design docu:ents if the requirements are clearly stated, and if they indicated the ti eliness for the use of current design decueents. k*ith respect to the above criteria, the Startup ad inistrative precedures are adequate.

j . 1 l Revisien: 1 Page 14 cf 23 - REEULTS RE?CPT ISAP III.d

                                   , v.                                       (Cont'd) 5.0 IMPLEP.ESTAT10N OT ACTICS PLAN AND DISCUSS!ON OF RESULTS (Cent'd) 1 1

5.2.2 Startup and 'CC organizational Interface Review The NRC-TRT i= plied that each STE should have a centro 11ed-distribution copy of drawings and design change documents applicable to the STE's assigned l syste s. With this concept in eind, the CPRT reviewed l the histery of the Startup DCC satellite and the evclutien of the methods by which the Startup and C;C organizations atte=pted to previde convenient access te current design docu ents. The following presents the results of this review. Prior to April 1983, the centrol and distribution cf design decurents was centralized in the main DCC facility. The main DCC provided design decurent duplication and distribution services to all the censtructien related organi:ations ensite. The STEs j found this precess burdensere in that the cain DOC was reecte frc: their work locatien and the process was ti:e censu:ing and unresponsive to their specific needs. In April 1983, the specific needs ef the Startup crganizatien, and others, were core adequately addressed by establishing DCC satellites, subordinated to the :ain DCC, in close prexicity to each organization's place of work. ] The first DCC satellite was established in the Startup facility. Initially, the DCC satellite provided the STEs with centrolled-distribution drawings of their cheice. After approxi=ately one year, a review was cceducted of the centrol of these drawings. The review found that the syste= vas working; however, the syster was cu:berse:e and an administrative burden en each organization. The DCC satellite had approxt:stely 1 I 20,0C0 centrolled drawings and design change decu:ents distributed throughout the Startup facility. DCC satellite personnel were required to replace and destrey superceded documents. STEs were held ! accountable for an item-by-ite: inventory of these l docu:ents. DCC and Startup supervision decided to elirinate centrolled- distribution drawings to j individual STEs due to the administrative burdens placed on both organi:ations. I

. Revision: 1 Page 15 ef 23 RESULTS RE?CRT ISAP III.d (Cont'd) 5.0 IMPLEy.ESTATION OF ACTION PLAN AND DISCUSSION OF RES'JLTS (Cont'd) In April 1984, Startup and DCC supervision elected te provide libraries of controlled-distribution drawings to those Startup groups performing similar activities, to provide independent user libraries within the facilities, and to expand the reference facilities near the Startup DCC satellite area. As an example, the electrical and hydrostatic test groups established reference libraries within their separate office areas. The controlled-distribution drawings and design change docu ents within these libraries are maintained current by DCC satellite personnel. The libraries contain copies of the current controlled-distribution drawings and design change documents required to perfor= their respective testing activity. 5.I.3 STE Interviews Discussions were held with eight individual STEs out of a;;rexi:stely sixty te deter ine their methcds of reviewing design do:veents and incorporating the current design infor:ation into preoperational test precedures. The STEs were selected free the Salance of Plant; Electrical; Nuclear Stean Supply; Instru:entation and Controls; and Feating, Ventilating, and Air Conditioning disciplines. For the test part, the STEs perf orcing the largest nu=ber of preoperational tests in each discipline were selected. Seven STEs stated that their method fer handling design docu:ent changes was to present a list of drawings to DCC, receive a current status repert, obtain changed documents, and review and incorporate appropriate changes into the preoperational test precedures. The eighth STE's procedures were written and approved to the sost current design documents and perf or:ed t=:ediately thereaf ter, precluding an 1: pact by design changes. From the unif or=ity of the interview respenses, it was concluded that document review offered more useful information relative to the issues being addressed,and the CPRT decided not te continue interviewing.

4

     .                                                                                                              Revisiet:   1 Page 16 of 23 P ES'.*tTS REPCe!

ISAP III.d (Cont'd) 5.0 IMPLEF.ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cent'd) - 5.2.4 Conclusions The CPRT concluded that the Startup and DCC organizations have established sufficient =easures te assure that STEs and other responsible personnel are provided access to controlled design documents. This cenclusion is based upon reviewing the startup administrative procedorest the Startup and DCC organizations' previeus experience with STEs having centro 11ed-distribution drawings fer their assigned systems; the establishing of libraries within the Startup facilities; and the results of the rand:: sarpling and evaluation progrs=. It should be noted that the results of the CPSES Mcniters Tea: activity and DCC supervisory persentel centributiens to 1:preving the perfor:ance of DCC. cerbined with establishing DCC satellite distributten centers fer user convenience, have contributed to alleviating the previous burden placed upon the STEs. Of further note is Engineering' self-established li-itatien en the nu:ber of design change decu e ts which =ay be outstanding against a drawing at any gtven tice. This factor alene contributed significantly te alleviating the previcus preble:s for STEs. 5.3 Petential Ter OCC Preble~s to Adverselv Affect the Testint Precra: The objective of this task vas to evaluate the effect the OCC proble s had on the testing prograe by deter:1ning whether the Startup organi:stion was cognizant of autherized design changes initiated by Engineering. Cegnizance was reasured by looking fer the approved test data fer the design change in TUCCO's recerds vault, or by the design change being legged in an approved Startup tracking syste:. This evaluation was designed te preclude the nature of DCC errors fre: affectit; the results by exa:ining only the origin and destination of a design change. Due to the large nu:ber of design changes and the steilarity in the process by which they were handled by the DCC, a rand:: sa:ple review of these documents was deemed by the CPRT te be an appropriate method cf investigation of potential prograc:atic deficiencies. A rande sa:ple of autheri:ed design changes requiring Startup's cogni:ance was selected f er review in accordance with Appendix D. "CPRT Sa pling Pelicy. Applications and Guidelines."

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 '                                                                                      Page    17 ef 23 RESULTS FE?0c7 ISAP III.d (Cent'd) 5.0 IMPLEP.INTATION OF ACTION PLAN AND DISCUSSION OF RESL'LTS (Cent'd)

The Startup organization utilizes only a fraction of the design docu:ents prepared for the prcject. This subset of design decu=ents and the changes to them were identified by the felleving steps: first, the calendar interval when DCC problems ceuld have adversely af fected startup was deterrined; second, the precedures and instructions which utilized OCC centre 11ed design docu ents were identified and reviewed; and l I finally, this infer:stien was used to define the populatien cf changes te the design dccuments affecting Startup. 5.3.1 Peried of Interest The period cf interest during which DCC proble s ceuld have adversely affected prerequisite testing was defined as the start of testing in =id-1979 until May 15, 1954 The peried of interest fer pree;erational testing was frc: JTG approval cf the specif1: preeperatienal test procedure until May 15. 19B'. May 15, 195; vas decided upen by the Testing Pregrars Review Tea: by evaluating CPSES Meriters Tea reports to assess the effectiveness cf the Startup LCC satellite. The CPSIS M: niters Tea: vas an auditing Freup l established by TUGC0 =anage:ent at the sa:e tire the l DCC satellites were created. The purpose of the gr:cp was to =eniter the effectiveness of the decu ent centici systems. The Meniters Tea centinues te perfor: its audit function. 1 ! The CPSES Moniters Tea: reports were aise utill:ed by the NRC-TRT QA/QC Croup in their evaluations anc were their basis fer aking the judg=ent that in July 195 . the DCC satellites supporting the censtructien organization appeared to be working preperly. i 5.3.2 Prerequisite Test Instruction Review Each of the thirty-tve prerequisite test instru:tiens in existence at the start of implementation of this ISAP vere reviewed to identify these which required utili:stien of design docu:ents during the testing I activity. Frem this review, the types of project design decurents used in preparation and executi:n ef prerequisite test instructiets were deter =inec. This ) information was utilized in identification ef the prerequisite test populatten of design thanges. i l l

[ .

   .                                                                                                                                                           Revisien:     1 Page  IB ef 13 RESULTS RE?CRT ISAP III.d (Cont'd) 5.0 IM7;Ey.I::TATION OF ACTION PLAN AND DISCUSSION OT llSULTS (Cent'd) 5.3.3 Preoperational Test Procedure Review All preeperational test procedures were reviewed to determine which test procedures were perfor ed during the pe* tied of interest and not co:pletely reperforced after May 15, 1984 The preoperatienal test procedures which :st these criteria were identified. The design drawinFs referenced by these procedures and contrc11ed by DCC were identified. These referenced drawings were used to assist in the identification of the preeperational test population of design changes.

3.3.4 Prerequisite Test Population ' Identification The prerequisite test populatten was identified by examining the types of Project desi6n docu ents, exa:1ning the project design change nethods, and uniquely identifying each design change in the pcpulatien. The design decu:ents for the project include such decurents as correspondence, calculations, analyses, reports, drawings, sketches, and specifications. These I design decurents are generated by various engineerit; ' disciplines such as architectural, civil, structural. echanical, electrical, instru:entatien and centrel, etc. These sa:e design decurents are utili:ed fer various purpeses by different organizations such as electrical construction versus electrical QA/QC, or I civil / structural construction versus Startup testing. By exa:ining the types of design documents required for test precedure preparation and/or execution, the specific types of design documents utilized by Startup were identified and included in the population. Several exa:ples of the types of design docu ents j included in the pcpulation are eechanical and electrical specifications, flow diagrams, instrurent and control logic diagra:s, electrical three line diagrams, and electrical cennection diagra:s. Several examples of the types of design docu:ents which were not an essential element of the testing activities and were excluded from the population are the architectural, civil, and structural design drawings and specifications. I l

Revisier: ' Page 19 of 23 PESULTS REPCF.T ISAP III.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSICS OF RESULTS (Cont'c) The Startup organization utilizes design docu ents as the primary resource in the preparation of test precedures and the executien of testing. Startup responds to three design change methods used by Engineering. The three Engineering design change procedures are: direct issuance of a revision to a design drawing; issuance of a Design Change Author 1 ration (DCA) which is a design document chtnge issued prior to the actual design drawings being updated and issued; and issuance of a Cc penent

f. Medificatien Card (CMC) which is si ilar to the DCA, but site oriented.

The design change population contained changes initiated by revision of Gibbs & Hill /TUGC0 Nuclear Engineering drawings, by DCA, and by CMC. Er gine e rin g specifications were changed by DCA and were t.n the DCA l chtsnge subpepulation. 5.3.5 P?crequisite Test Populatien Screening Process The following screening criteria were used to idertify design changes belonging to the prerequisite test pcpulatien:

                                                                                                                        -     The change was to a design derurent.

The change was issued threugh the DCC.

                                                                                                                        -     The decu:ent was referenced by a test procedure or was used durits the perferran:e of a specific test.
                                                                                                                        -     The test precedures whieb referenced er utili:ed the affected deturents were perfereed during the period of interest.
                                                                                                                        -     The document change ce;urred prior to performance of the tect.
                                                                                                                        -     The change required a test or retest.

Drawing revisiens which were issued to incorporate only DCAs er CMCs were exc1rded to preclude biastng the pepulatien by cultiple references te a partievlar design change.

J

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, RESULTS REPORT I ISAP III.d (Cont'd) 5.0 1MPLL*.IN!ATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cent'd) During screening, the CPRT found that design changes were initiated, logged, and tracked by the TUGC0 Design Change Request (TDCR). The TDCR is a Startup precedure which seeks Engineering review and approval of a preposed change to the design. Since Startup initiated and tracked these changes, they were excluded fre: the sample. 5.3.6 Prerequisite Test Sa:pling Results A sar;1e consisting of sixty-one approved design changes requiring Startup to perfer: a test was evaluated. The evaluation showed that each of these sixty-one samples met the following acceptance criteria: The design change was tested as evidenced by appreved test data, or was doeurented as being eenitored by Startup as an open ite:, An e;en iten reans the design change was docu:ented as I being logged in a Startup organ.1:stien tracking syste=, i.e., a tracking system such as the Master Data Base. or Startup Werk Authorization log. Since no discrepancies were identified during the evaluatien, the sa:ple size was not expanded. 5.3.7 Presperatietal Test Pregra: Populatten Definition In the overall organization of engineering drawings, the flew and centrol circuit schematic drawings are the ; definitive design doeurents specifying system and j ee penent functionality; the other engineering drawings are required te implement the design presented in these drawings. The objective of preoperatienal testing is to test and verify system and ceeponent function. Based en this it was deterrined that changes te the centrel circuit schematic and flow diagrams would have the greatest potential impact on a preoperational test.

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Page 21 of 23 l-RESL*LTS rep 0P.T ISAP III.d (Cont'd)

           $.0 IMPLEMENTATION OT ACTION PLAN AND DISCL'SSION OF RESL*LTS (Cont'd)

The preoperational test population was therefore identified from the list of referenced drawings I prepared during the review of preoperational test procedures conducted prior to May 15, 198t and not ccepletely reperforred after that date. The final preoperational test population contained the flow and control circuit schematic diagrams identified free this list. 5.3.8 Preoperational Test Population Screening Process t The folleving screening criteria were used to identify design changes belonging to the preeperational test population:

                                         -      The cl.atge is to a design docu:ent.
                                         -      The change is issued thr: ugh DCC.
                                         -      The decu:ent is referenced by a test precedure or is used during the perfer:ance of a specific test.            )

l

                                         -      The test procedures which reference er utili:e the affected docu:ents were perfer:ed durirg the peried of interest    l anel were not completely reperfor:ed folleving the period of interest.
                                         -      The document change occurred prie; to performance of the test.
                                         -      The change would require a test or retest.

5.3.9 Preoperaticnal Test Sampling Results j l A sample consisting of sixty approved design changes j requiring a test by Startup was evaluated. The evaluation showed that each of these sixty saeples cet the fellewing acceptance criteria: A preoperational test procedure incerperated the design change, er var documented as beint eenitored by Startup as an open itet.

  .                                                                                                                                            Revisien:                             1 Page 22 ef ;3 RESULTS REPOPT ISAP III.d (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCL'SSION OF RESULTS (Cont'd)

An open item means the design change was documented as being logged in a Startup organization tracking syste , i.e., a tracking systen such as the Master Data Etse, or Startup Work Authorization log. Since no discrepancies were identified during the evaluatien, the sample size was not expanded. 5.4 Evaluation of Results The CPET implemented the tasks in the action plans and ceasured the results against the acceptance criteria. 5.4.1 STE Access to Current Design Docu=ents The CPET evaluation verified that TUGC0 has established measures to previde reasonable assurance that STEs and other res;ensible test persennel are provided with current controlled design docu=ents and changes. The sa:pling and evaluatien pregra: ccnfir:ed that, during the period of concern, the STEs did use current design docu:ents in the cenduct of both preoperational and prerequisite testing activities. 5.4.2 Potential For DCC Problees to Adversely Affect the Testing Progra: The CPRT evaluation provided ninety-five percent confidence that at least ninety-five percent of the desiFn changes which could have affected the prerequisite and preoperational testing due to decutent control center problems did not adversely affect these progra:s. 5.5 Reet Cause and Generic I: lications The potential generic implications of docueent contr:1 problems were that Startup testing activities may have been adversely affected such that safety-related plant syste=s and components may not be properly tested. This evaluatir.n deter =ined that the Startup organization was using ef fective methods for the use of design documents and was not adversely affected by the document control proble=s. Consequently, rect cause and generic implication evaluations were not f.e c e s s a r y . N. _. ._ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

1

                                                 -                                                                  Revision:          1 Page 23 cf 23 RESULTS'RESC8T ISAP III.d                                                                 '

(Cont'd) 6.0 CONCLUSICSS The CPRT concluded that the Startup and DCC organizations have established sufficient seasures to assure that STIs and other responsible personnel are provided access to controlled desigt documents. The results of this evaluation provide reasonable assuraece that the document control problems which existed prior to 1984 did not adversely affect the testing progra=. 7.0 CN00ING ACTIVITIES There are no engeing &ctivities related to this issue. f 6.0 ACTICS TO PRECLUDE OCCURRESCE IS THE FUT'.*RE

                                        !ased upen the C7ET review, there is no further action requtred te-preclude future occurrence.
                                                                                                                                                   'i 1
                                                                                                                                                    )

.i COMANCHE PEAK RESPONSE TEAM ACTION PLAN-ISAP V.a

Title:

Inspection for Certain Types of Skewed Welds in NF : ipres Revision No. 0 1 2 Revised to Reflec': Reflects Coments Description Original Issue NRC Coments on Plan Prepared and '- , f i Recommended by: Review Team Leader ,1.

                                                                                   /
                                                                                   /
                                                                                                                   -      I    It -

Daee 3I flf $f &fbb fSI n t l l1Yit. s i n or Re v Team k d, L / M. V, / D,ee %Ir/rr U i /2skr % /es i I 1

1 Revision: 2 1 Page 1 of 9 l

       .                                                                                                                 I i

ISAP V.a l Inspection for Certain Types of Skewed Welds in NF Supports l

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC J The TRT investigated inspection procedures of Brown & Root (B&R) ( for velds in pipe supports designed to ASME III Code, Subsection i NF. The TRT found that no fillet veld inspection criteria existed for certain types of skewed welds. By definition, skewed welds are those welds joining (1) two non-perpendicular or non-colinear structural members, or (2) two members with curved surfaces or I curved cross sections, such as a pipe stanchien (a section of pipe used as a structural member) welded to anot!1er pipe stanchion or to a curved pipe pad. Notice that for type 2 (those defined in item j (2) above), the effect of curvature at the veld connection induces l skewed considerations, even though the two joining members are physically perpendicular. The Brown & Root veld inspection procedures CP-QAP-12.1 and QI-QAP-11.1-28 for NF supports have addressed type (1) skewed welds; however, the TRT found that QI-QAP-11.1-28 did not include weld inspection criteria for type 2 skewed welds. Although the TRT was told by Brown & Root personnel that procedure QI-QAP-11.1-26 for piping weld inspection was used, since such veld connections were similar in configuration to a pressure boundary stanchion attachment veld, no evidence documenting the use of this inspection procedure was provided to the TRT. According to records reviewed by the TRT, these welds were actually categorized as "all other velds" rather than " skewed welds" on the required QC checklist. Instead of using fillet veld scuges for measuring the s12.e of nonskewed welds, welders were supposed to use a straight edge ~and a steel scale for measurement , of a type 2 skewed weld, as described in QI-QAP-11.1-28. In ; addition, due to the variable profile along its curved weld connection, the veld size should have been measured at several different locations. The lack of inspection criteria and lack of verification of proper inspection procedures being conducted for , type 2 skewed welds are a violation of ASME Code for NT supports I committed to by TUEC in FSAR Section 5.2.1 and a violation of Criterion XVII in Appendix B of 10CFR50. The TRT reviewed weld inspection procedures, weld data cards, and visually inspected several type 2 skewed welds in randomly sampled ' NT supports where pipe stanchions were used. Although the small sample of welds inspected by the TRT are acceptable, due to f deficiencies in Inspection Records and the apparent lack of j inspection criteria, the TRT is not certain whether other type 2 ] skewed welds were inspected properly. This is a generic issue j involving many NF supports in various safety related syste=s. The lack of documented inspections and criteria for type 2 skewed welds i in NF supports represents a safety concern regarding the possible existence of under-si:ed welds in supports which are required to 4 resist various design leads. i k - _ _ - _ _ - _ - - _ - _ _ - _ _ - _ _ 1

Rsvision: 2 1 Page 2 of 9 )

 .'                                                                                                                                                  f ISAP V.a                                                                '

(Cont'd) 1 2.0 .. ACTION IDENTIFIED BY NRC ' Accordingly, TUIC shall Revise Brown & Root weld inspection-procedures CP-QAP-12.1 and QI-QAP-11.1-28 to properly address type 2 skewed welds of stanchion to stanchion and stanchion to pipe pad. Provide evidence to verify that previous inspections of these types of skewed welds were performed to the appropriate procedures.

3.0 BACKGROUND

3.1 Information Regarding the Historv of Fillet Weld Inspections The methods for QC inspection of type 2 skewed fillet velds and the written procedures describing the methods and means of documenting the inspections'have changed during the construction of the CPSES project. The significance of such changes and their history will be evaluated as part of this action plan. The significance of changes in the inspection methods and the forms for documenting the Inspection Results will be evaluated. A summary of those aspects most pertinent to the formulation of this action plan follows. On September 3, 1982 Revision 12 of inspection procedure QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports" was issued. This established inspection methodology which addressed type 2 skewed fillet welds. Inspections performed prior to thet date were generally not performed using such methods. However, by that stage of construction, most of the welds for NF supports had already been inspected. ; On March 18, 1983, Revision 5 of inspection procedure CP-QAP-12.1, "ASME Section III Installation Verification and { N-5 Certification", was issued. A program was initiated to ' reinspect all NF welds using a checklist created in the revision. The documentation for those reinspection was the checklist, because the Weld Data Cards, which had documented , individual welds, was the record of initial inspection. As a result, the documentation for the reinspection is not specific { to individual welds, instead it covers all the welds for the support. The CP-QAP-12.1 checklist had two entries for the welds; one for skewed welds, another for all other welds. On the CPSES project, type 2 skewed welds are termed " stanchion welds"; therefore, supports with stanchien welds and no other J

Rovision: 2 Page 3 of 9 ISAP 7.a (Cont'd)

3.0 BACKGROUND

(Cont'd) skewed welds had no entry or "N/A" under the checklist item for skewed welds. Although the project intended that the reinspection program would ensure proper inspection of all the type 2 skewed fillet welds, the records in themselves cannot provide conclusive evidence of this. The source of the difficulty is the stated ambiguity of terminology for skewed welds in combination with the documentation method. Given the methods of inspection for type 2 skewed fillet welds prior to September 3, 1982 and the circumstances of the reinspection documentation, it does not appear that a review of documentation in itself can be used to verify the adequacy of methods used for velds initially inspected prior to l September 3, 1982. Initial inspections perfor ed af ter September 3,1982 were controlled by the procedures which included updated inspection methods. Additionally, documentation of inspections underwent significant upgrade. As before.'the documentation of skewed fillet velds which were also pressure boundary welds is veld specific using Weld Data Cards. After December 15, 1982, veld mapping was instituted for non-pressure boundary fillet welds l yielding weld specific documentation. These post-September 1982 records may therefore serve as sufficient information to document which methods were used, even with the ambiguity of terminology for skewed welds. In addition to the procedures 1 discussed above, inspection procedure QI-0AP-11.1-26 "ASME Pipe Fabrication and Installation Inspections" was used directly or by reference to define inspection methods for Type (2) skewed fillet welds, and it will be included in the procedural assessment task. 3.2 Inspection of Full or partial penetration Welds The inspection attribute which is the technical focus of this issue is the geometric and d1=ensional characteristics of the fillet veld in locations where si=ple fillet gauge =easure=ent is not possible. In general, a similar inspection attribute does not exist for full or partial penetration welds. However, if such welds call for reinforcement, the inspection of the di=ensional aspects of the reinforcement is similar to a fillet weld inspection. Such reinforcement is not ce==only used for skewed welds but where they are used, the actien plan will include them. I

R; vision: 2 l Page 4 of 9 ISAP V.a (Cont'd) 4.0 CPRT ACTION PI.AN l l The objective of this action plan is to assure that the as-bu11e size of Type 2 skewed welds on NT pipe supports meets the design requirements. A review of inspection procedures and documentation methods indicates a need for a program which will assess the documentation methods and verify on a random sampling basis, that velds meet the design requirements. Some of the post-September 1982 records do provide sufficient documentation attest to the quality of individual type 2 okewed welds. However, due to the time phased implementation of the procedure revisions described.in Section 3.1, sample reinspection of the entire population of type 2 skewed welds is considered to be more effective than a document review combined with sample reinspection of the part of the population that has ambiguous inspection records. The attached logie diagram depicts the process as described in Section 4.1. 4.1 Scope and Methodology 4.1.1 The chronoiogy of inspection methods documented in procedures will be developed to correlate the period of time and specific procedure revisions for inspection of type 2 skewed welds. This will include a description of methods and inspection documents required. The chronology will be used to identify all revisions of procedures for which inspections were perfor=ed that have not been superceded by subsequent inspection. 4.1.2 Inspection procedures QI-QAP-11.1-26, QI-QAP-11.1-28 and CP-QAP-12.1 will be reviewed to determine if the method of inspection that was included for type 2 skewed weld inspections was adequate to address the unique aspects of skewed weld dimensional configurations. The essessment of adequacy will be a third-party activity. Based on the review, the procedures will be revised to incorporate any modifications necessary to assure the inspection methods address any unique aspects of the skewed weld configuration. Additionally, clarifying direction and appropriate cross reference will be , provided, as required, to ensure a clear understanding of the require =ent to treat all type 2 welds as skewed welds. The physical significance of any procedural changes will be evaluated by a third-party.

r .. . _ _ - _ - - - _ _ _ - _ . _ _ - . Rcvision: 2 Peg 2 5 of 9 , L . ISAP V.a (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 To assess the adequacy of inspection procedure implementation and to verify that design requirements were met, a random sample of type 2 skewed welds (excluding pressure boundary welds, which are not at issue) from Unit 1. Unit 2 and common will be selected for review of inspection documentation and reinspection to current inspection procedures. A sampling evaluation is appropriate since the objective is to determine if the procedural ambiguities related to the measurement of type 2 skewed welds actually resulted in the production of undersized welds. The sample plan will be designed tu accordance with Appendix D and will either provide reasonable assurance that type 2 skewed welds meet design requirements or will detect deficiencies to be investigated and dispositioned. The minimum sample size according to Appendix D is 60, with a detection number of zero (i.e., the critical region is one or more deficiencies found in the sample). In this case a deficiency is defined as a weld which exceeds the ASHI Code allowable stress levels. If one or more wells are found not to meet design requirements (i.e. undersized relative to that noted on design documents), an analysis vill be made to determine the ability of the veld to carry its design loads in accordance with ASME code requirements. If it is determined that the veld exceeds code allowable ! stress levels, a decisi'on will be made to either expand , the sample or go to 100 percent reinspection of type 2 skewed fillet welds. If it is determined that all undersized welds meet code allevable stress levels, an l evaluation of the need for additional inspection will be performed based en the observed trends in the weld inspection data. 4 1.4 Physical reinspection of the random sample will be conducted by third-party inspectors from Evaluation Research Corporation (ERC). The inspection criteria used will be based on the revised procedures resulting from the procedure review discussed in 4 1.2. 4.1.5 The results of the procedure review, phyrical measurements and evaluation of results will be used to assess root cause and generic implications. Any physical modifications and procedural changes required will be identified and corrective action initiated. QA/QC progra=natic aspects which may be implicated by

R; vision: 2

                                                                                                                                  ? age    6 of 9.  ;

ISAP V.a (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) s I the results of the root cause and generic implication ) determination will be addressed under the Quality of j Construction. QA/QC Adecuacy Program. 4.1.6 All critical aspects of the review program will be overseen and verified by third-party. The attached logic diagram identifies the specific activities which are included in the third-party overview and verifiestion. 4.2 Participants Roles and Responsibilities i The organizations and personnel that will participate in this < effort are listed below with their respective scopes of work. 4.2.1 Comanche Peak Project Engineering 4.2.1.1 Scope I Chronology

                                                 -               Procedure review i
                                                -                Procedure revision
                                                 -               Assist in programmatic evaluation 4.2.1.2           Personnel Mr. C. Meehlman                      Project Mechanical Engineer 4.2.2    Third-Party Overview 4.2.2.1          Scope Assiss procedural adequacy 5

Verify sample selection Review reinspection instructions Reinspection of velds (ERC) Verify inspection evaluations t Overviev evaluation of safety significance l l

Rovision: 2 Page 7 of.9 ISAP V.a * (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

                                         -       Evaluate cause, significance and applicability
                                         -       Preparation of Results Report 4.2.2.2    Personnel Mr. H. A. Levin                  TERA Corporation - CPRT Mechanical Review Team Lander Dr. .L R. Honekamp TERA Corporation - CPRT TRT Issues Manager Mr. C. Spinks                    Evaluation Research Corporation Dr. F. A. Webster                Jack Benjamin &

Associates (JBA), - CPRT Statistics Advisor Mr. R. L. Shipp TERA Corporation, Senior Materials and Welding Engineer 4.3 Personnel Qualification Requirement Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and trained to the applicable inspection procedures. Third-party participants in the implementation of this Action Plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. Other participants will be qualified to the require! bents of the CPSES Ouality Assurance Progra= or to the specific requirements t of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section I!I.K. " Assurance of CPRT Program Quality", of the CFRT Program Plan.

I Rrvision:

                                                                                                                ;                      2 Paga               8 of 9 ISAP V.a (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.4       Standards / Acceptance Criteria The criteria for evaluating the acceptability of any weld determined to be less than specified are as defined in the ASMI Boiler and Pressure Vessel Code Section III. The criteria for accepting the sample of reinspected welds are described in section 4.1.3 of this ISAP.

4.5 Decision Criteria The results and cot.clusions of the physical re-inspection of randomly selected type 2 skewed welds will provide the basis for any modifications required to meet the design requirements. Any necessary modifications to meet design requirements will be initiated. An assessment of the generic implications will be included as part of the Results Report, addressing the potential applicability to other areas of the plant.

I

Revision: 2 Pags 9 of 9 ISAP V.A i (Cont'd) ATTACHMENT INSPECTION FOR CERTAIN TYPES OF SKEWED WELDS IN NT SUPPORTS 11 7l i ! .: re8 :-

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f . ._ ' .,. . i' i COMANCHE PEAK RESPONSE TEAM RESULTS REPORT' ISAP: V.a

Title:

Inspection for Certain Types of Skewed Welds in NT Supports REVISION 1 au> r L LLA

                                                                                                 /*l3 'lSb Issus Coordinator                               Date '                                              '
                                                        / t c        -            0~/

Keviedi Team La'a(eYV Date nIn/n ' Y ^ ^ !- /gl2, L /PL.

15hn W. Beck, Chairman CPRT-SRI Date

b T

                                                                         ' Ra' vision:     1
   ;                                                                       Page     1 of 57 e ;

i RESULTS REPORT ISAP V.a

nspection for Certain Types'of Skewed Welds in NT Supports

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The NRC Staff's position on this issue along with their evaluation is presented in Supplements 10 and 13 to the Safety Evaluation ; Report (SSER 10 and.SSER 13) for the CPSES (References 9.1.and 9.2). 'he following excerpts from pages N-327 and N-328 of SSER-10 describe this technical issue:

                      "The TRT investigated inspection procedures'of-Brown & Root (B&R) for welds in pipe supports designed to ASME III Code, subsection NF. The TRT found that no fillet veld inspection-criteria existed for certain types of skewed welds. By definition, skewed welds are those welds joining (1) two non-perpendicular or non-colinear structural members, or (2) two members with curved surfaces or curved cross sections, such as a pipe stanchien (a section of pipe used as a structural member) welded to another pipe stanchien or to a             'l curved pipe pad. Notice that for type-2, the_effect of                    !

curvature at the veld connection induces skewed considerations, even though the two joining members are physically perpendicular. The B&R weld inspection procedures CP-QAP-12.1 and QI-QAP-11.1-28 for NF supports have addressed type (1) skewed welds; however, the TRT found that. QI-QAP-11.1-28 did not include veld inspection criteria for , type-2 skewed welds. Although the TRT was cold by Brown & Root _ personnel that procedure QI-QAP-11.1-26 for piping weld inspection wa.s used, since such weld connections were similar in configuration to a pressure boundary stanchion attachment veld, no evidence documenting the use of this inspection procedure was provided to the TRT.. According to records reviewed by the TRT, these welds were actually categorized as "all other welds" rather than " skewed welds" on the required QC checklist. Instead of using fillet weld gauges for measuring the size of nonskewed welds, velders were supposed to use a straight edge and a steel scale for measurement of a type-2 skewed weld, as described in QI-QAP-11.1-28. In addition, due to the variable profile along its curved weld connection, the weld size should have been measured at several different locations. The lack of inspection criteria and lack of verification of proper inspection procedures being conducted for type-2 skewed welds are a violation of ASME Code for NT supports committed to by TUEC in FSAR Section 5.2.1 and a violation of Criterion XVII in Appendix B of 10CFR50. l a

c. Revision: ; Page 2 of 57 i RESULTS REPORT ISAP V.a (Cont'd)

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (Cont'd) The TRT reviewed vuld 1nspection procedures, weld data cards, and visually inspected several type (2) skewed welds in randomly sampled NT supports where pipe stanchiens were used. Although the small sample of welds inspected by the TRT are acceptable, due to deficiencies in inspection records and the apparent lack of inspection criteria, the TRT is not certain whether other type (2) skewed welds were inspected properly. This is a generic issue involving many NF supports in various safety-related systems. The lack of documented inspections and criteria for type (2) skewed welds in NF supports represents a saf ety concern regarding the possible exis tence of under-sized welds in supports which are req'II, red to resist various design loads." 2.0 ACTION IDENTIFIED BY NRC The IIRC (Reference 9.1) identified that the following action should be taken on this issue:

                                                                                                "Accordingly, TUEC shall (1) Revise Brown & Root veld inspection procedures CP-QAP-21.1 (sic]* and QI-QAP-11.1-28 to properly address type (2) skewed welds of stanchien to stanchien l

1 and stanchion to pipe pad; and (2) provide evidence to verify that previous inspections of these types of skewed welds were performed to the appropriate procedures." ' 3.0 BACKCROUND ESER-10 focuses the issue on the inspection methodology and determination of weld size for type-2 skewed welds only. The procedures used for the measurement of type-2 skewed welds, the measurement techniques and methods for documenting the results of these measurements have changed during the construction of the CPSES. The history of these changes and their significance are discussed in Section 5.1 of this report. A summary of those i aspects most pertinent to the formulation of this action plan is provided below vichin this section. NRC letter incorrectly cited CP-QAP-12.1 as CP-QAP-21.1. i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ . . _ _ I

Revision: ! Page 3of57 4 RESULTS REPORT ISAP V.a

                                                     ;                                         (Cont'd) 3.0 BACKGROWD (Cont'd) 3.1          Inspection of , Type-2 Skewed Fillet Welds On September 3, 1982, Revision 12 of inspection procedure QI-QAP-11.1-28. " Fabrication and ' Installation Inspection of Safety Class Component Supports" was issued. This established inspection methodology which addressed measurement of type-2 skewed fillet welds. Inspection procedures in place prior to this time did not include specific instructions for measurements of these velds.

On March 18, 1983, Revision 5 of inspection procedure CP-QAP-12.1, "ASME Section III Installation Verification and I N-5 Certification", was issued. A program was initiated to reinspect all accessible NT welds using a checklist created in the revision. The documentation for the reinspection was not specific to individual velds, instead it covered all the welds for the support. The CP-QAP-12.1 checklist had two entries for the welds; one for skewed welds, another for all other welds. On the CPSES project, type-2 skewed welds were termed

                                                                     " stanchion velds"; therefore, supports with stanchien welds and no other skewed welds had no entry or "N/A" under the checklist item for skewed welds. Although the project intended that the reinspection program would ensure proper measurement of all the type-2 skewed fillet velds, the records in themselves cannot provide conclusive evidence of this. The source of the ambiguity was in the terminology. used in inspection procedures and documentation for skewed welds.

Given the methods of measurement for type-2 skewed fillet welds prior to September 3, 1982 and the nature of the N5 reinspection documentation, review of the documentation by itself could not be used to verify the size of the velds initially inspected prior to September 3, 1982. Initial inspections performed after September 3, 1982 v.sre controlled by the procedures which included updated inspection methods. Additionally, documentation of inspections underwent significant upgrade. The documentation of skewed fillet velds which are also pressure boundary velds is weld specific using Weld Data Cards. On December 15, 1982, weld mapping was instituted for non-pressure boundary fillet velds thereby providing veld specific documentation. s

1

   .                                                                                                             Revision:    1 Page   ' of 37 4

RESULTS REPORT - ISAP V.a (Cont'd)

3.0 BACKGROUND

(Cont'd)

                                                          'In addition to the procedures discussed above, inspection procedure QI-QAP-11.1-26. "ASME Pipe Fabrication and Installation Inspections" was used directly or by reference to define inspection methods for type-2 skewed f111st velds, and is reviewed in Section 5.2 herein.

3.2 Inspection of Full or Partial Penetration Reinforcement The inspection attribute which is the technical focus of this ISAP is the geometric and dimensional characteristics of the fillet veld in locations where simple fillet gauge measurement is not possible. In general, a similar inspection attribute does not exist for full or partial penetration welds. However, if full or partial penetration welds call for reinforcement, the inspection of the dimensional aspects of i the reinforcement is similar to a fillet veld inspection. I Such reinforcement is not commonly used for skewed welds but where they are used, the action plan has included them. 4.0 CPRT ACTION PLAN The objective of this action plan was to provide reasonable assurance that the as-built type-2 skewed welds on NF pipe supports meet the dimensions specified by the design requirements. A review of inspection procedures and documentation methods indicated a need for a program to assess the documentation methods and verify on a random sampling basis, that type-2 skewed welds meet the design requirements. Some of the post-September 1982 records do provide sufficient documentation to attest to the adequacy of the dimensions of individual type-2 skewed welds. However, due to the time phased implementation of the procedure revisions described in Section 3.1, sample reinspection of the entire population of type-2 skewed welds was considered to be more effective than a document review combined with sample reinspection of the part of the population that has ambiguous inspection records. J I s

e

    '                                                                                 Revision:      1      !

Page 5 of 57 l f . . i RESyLTS REPORT - ISAP V.a (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1 Scope and Methodology . 4.1.1 The chronology of measurement techniques and documentation methods used for the inspection of type-2 skewed welds was prepared (Reference 9.3). This chronology was used in the evaluation of the results of the sample reinspection, and to identify the procedures used for type-2 skewed weld inspections that have not been superseded by subsequent inspections. i 1 4.1.2 Inspection procedures QI-QAP-11.1-26, QI-QAP-11.1-28 { and CP-QAP-12.1 were reviewed to determine if the ' method of inspection that was included for type-2 skewed weld inspections was adequate to address the I unique aspects of skesed weld dimensional configurations. Procedure QI-QAP-11.1-28 was revised (Revision 30) to directly include the measurement trahniques for type-2 skewed welds and to eliminate the need for referencing other procedures for this measurement; the other procedures did net require revision. ) 4.1.3 To assess the adequacy of inspection procedure implementation and to verify that design size requirements were met, a random sample of type-2 skewed welds was selected. This random sample excluded the pressure beundary velds, which are not at issue. These samples were selected from Unit 1. Unit 2 and common for reinspection and review of inspection documentation. The samples were reinspected to inspection procedures which include specific measurement criteria for type-2 skewed welds. A sampling evaluation was appropriate since the objective was to determine if the procedural inadequacy related to the measurement of type-2 skewed welds actually resulted in the existence of undersized welds. The sample plan was designed in accordance with Appendix D of the CPRT Program Plan, using a sample size of 60, vich a detection number of zero (i.e., the critical region was one or more deficiency found in the sample). In this case a deficiency was defined as a veld in which the ASMI Code allowable stress levels l were exceeded. 1 i 1 s

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l ' ISAP V.a (Cont'd) 1 l 4.0 CPRT ACTION PLAN (Cont'd) The action plan also included provisions for sample expansion in accordanc's with Appendix D if a deficiency had been found, the evaluation of trends of-deviations, and the assessment of root cause and generic implications as required by Appendix E of the 1 CPRT Program Plan. 4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are listed below with their respective scopes of work. 4.2.1 Comanche Peak Project Engineering 4.2.1.1 Scope Prepared inspection chronology Reviewed procedures Revised procedures Assisted in evaluation of inspection results 4.2.1.2 Personnel Mr. C. Moehlman Project Mechanical Engineer 4.2.2 Third-Party Overview 4.2.2.1 Scope Assessed procedural adequacy Verified sample selection Reviewed reinspection instructions

Reinspected welds (QA/QC Review l Team) i l l l I i

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4.0 CPRT ACTION PLAN (Cont'd) 1 Evaluated weld reinspection results Evaluated safety significance of deviations 1 Evaluated trends in the results of the measurements and documents reviewed Prepared Results Report 4.2.2.2 Personnel Mr. H. A. Levin TERA - CPRT Mechanical Review Team Leader Dr. J. R. Honekamp TERA - CPRT TRT Technical Manager Mr. J. C. Miller TERA - CPRT TRT Issues Manager Mr. C. Spinks QA/QC Review Team (ERC) - Inspection Supervisor Dr. F. A. Webster Jack Benjamin & Associates (JBA), - CPRT Statistics Advisor Mr. R. L. Shipp TERA - Senior Materials and Welding Engineer Mr. R. Sanan TERA - Senior Structural Engineer. Issue Coordinator l 3 L__---------------------

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i RESULTS REPORT I ISAP V.a (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Pe.rsonnel Qualification Requirement Third-party participants in the implementation of this Action ;

Plan met the personnel qualification and objectivity : requirements of the CPRT Program Plan and its implementing procedures. Third-party inspectors were certified to the requirements of the third-party employer's Quality Assurance Program, and trained to ERC procedure QI-006 (Reference 9.8). l Other participants were qualified to the requirements of the CPSES Quality Assuranca Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel were governed by the applicable principles of Section III.K " Assurance of CPRT Program Quality", of the CPRT Program Plan. 4.4 Procedures ERC developed procedure QI-006 for the reinspection of skewed welds. This procedure was used by the QA/QC Review Team in this ISAP. j 4.5 Standards / Acceptance Criteria i The criteria for evaluating the acceptability of any weld determined to be less chan specified size are the same as ( those defined in the ASME Boiler and Pressure Vessel Code d Section III. I i 4.6 Decision Criteria The results and conclusions of the physical reinspection of randemly selected type-2 skewed welds provided the basis for any modifications required to meet the design requirements. No modifications were found necessary to meet design requirements. 5.0 IMPLDENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The implementation of this action plan involved: the development of a chronology of the procedures, inspection techniques and documentation methods used for the measurement of structural type-2 skewed welds; the review of scribe line and profile inspection l techniques; and, a reinspection of type-2 skewed welds. The I results of these investigations are su=marized in the following l l l I

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Revisien: 1 1 Page 9 of $7 l 1 RESULTS REPORT i ISAP V.a (Cont'd) l 5.0 INTLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) sections of this report. Additional sections are included to discuss safety significance, trend analysis, out of scope findings, and address the direct concern of the KRC related to the root cause and generic implications of this issue. 5.1 Chronology of the Inspection of Type-2 Skewed Welds A chronology of the procedures, inspection techniques and documentation methods used for the measurement of the type-2 skewed welds was prepared by the Project (Reference 9.3) and reviewed by the third-party. The results of this review are described in this section. Figure 1 shows the geometry of a typical type-2 skewed weld that results when two curved support members are joined using a fillet weld. As indicated in Figure 1, the size of the { fillet veld leg on one side of the weld can be measured with a ' fillet weld gauge or a straight edge ruler since the reference point for this measurement is a flat surface. However, this technique is difficult to use when measuring the size of the other leg since the reference point is a curved surface. For this measurement, two techniques were provided in CPSES procedures. The first, referred to as the scribe line j technique, utilizes a reference mark placed on the support - member prior'to welding as shown in Figure 1. The second, referred to as the profile technique, utilizes a contour gauge ! as shown in Figure 2. Only the profile technique can be used for reinspection of complaced welds if the scribe lines were i not placed prior to velding. In addition, where scribe lines i were used for the original inspection they are generally not visible during reinspection if the support has been painted. The inspection techniques used and the methods of documenting the inspections of type-2 skewed welds changed with time anc involved the following procedures: QI-O AP- 11.1- 2 6 : which addressed the fabrication, installation and inspection of ASMI pipe and attachments welded to the pipe. QI-Q AP- 11.1- 2 8 : which addressed the fabrication, 3 installation and inspection of ASME pipe supports l except for attachments velded to the pipe. 1 1 1 1 i } I ! I I i - _

Revisien: 1 Pcge 10 of 57 RESULTS REPORT . ISAP V.a (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) CP-0 AP- 12.1 : which addressed the final verification of I l ASME pipe supports prior to certification (preparation of the ASKE N-5 form). Table 1 provides a chronology of ete key events related to the measurement of type-2 skewed welds. As indicated in Table 1, specific criteria for the measurement of skewed fillet velds were provided for the first time in September 1982 by Revisions 12 and 13 of QI-QAP-11.1-28. The scribe line technique was the only inspection method included in the procedure at that time. Three months later (December 15, 1982) the type-2 skewed weld inspection methodology was moved from the pipe support l procedure (QI-QAP-11.1-28, Revision 16) to the piping procedure (QI-QAP-11.1-26, Revision 9) on the basis that most of the type-2 skewed welds were attachment welds to the pipe and thus fell within the scope of the piping procedure. The pipe support procedure referred to the piping procedure for all welds which attached support members to the pipe but said nothing about the type-2 okewed welds that were not pipe attachment (pressure boundary) welds. This question was addressed by a Brown & Root instruction to inspectors QCWI-1 (Reference 9.4) which stated that skewed fillet welds attaching pipe stanchions to pipe saddles (i.e. welds that were not attachments to the pipe itself) were to be inspected in accordance with the skewed weld inspection instructions in QI-QAP-11.1-26 for piping attachment velds. While this I instruction provided clear direction for the inspection of the j type-2 skewed welds of concern to the TRT, this instruction was not reincorporated in the pipe support procedure uncti about two years later (January 25, 1985). The third-party reviewed training records associated with QCWI-1 and discussed its use with QC personnel who worked in the ASME inspection grou? at the time it was issued (Reference 9.5). Training records indicate that 21 inspectors were indoctrinated with respect to QCWI-1 the day after it was issued. However, based on discussions with QC personnel it appears that no further training specific to QCWI-1 was performed on the basis that QCWI-1 was not a procedure and that the information contained in QCWI-1 was intended to ce included in the training associated with the piping and support procedures themselves. Since QCWI-1 was only one sentence in length, such training is considered adequate. I l 1 l I i i s

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                                                                                                                                                                                                'I RESULTS REPORT ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND UtSCUSSION CP RESULTS (Cont'd)

In early 1983 a reinspection of all iccessible structural velds on ASME supports was initiated to implement a commitment to NRC Region IV for a reinspection of type-1 skewed welds and to resolve a concern related to excessiveigrinding of velds. This reinspection was conducted as p,nre of a broader inspection and document review related to ASME N-5 certification. N-5 is the data report signed and furnished by the NA stamp certificate holder for the fabrication and installation of the pipin6 As a result, veld reinspection were conducted and documented under procedure CP-QAP-12.1 which referenced the pipe support procedure (QI-QAP-11.1-28) for the inspection of skewed welds. The method of documentation of this reinspectica was a check list which contained two entries (skewed welds and all other velds) to l ' include all the welds on the support. At that time the term

                           " skewed weld" was used by the Project to describe what is referred to by the TRT as a type-1 skewed weld and the term
                           " stanchion veld" was used to describe the type-2 skewed weld.

In this 1983 reinspection the " skewed weld" checklist entry was intended to document the reinspection of type-1 skewed welds in comp 11anca with the commitment to NRC Region IV. In August 1983, the piping procedure (QI-QAf-11.1-26) was revised (Revision 13) to add the profile tachnique for , measurement of type-2 skewed welds. From this point on the piping procedure included both the scribe !1ne and profile techniques for measurement of type-2 skewed welds. In January 1985, the scribe line measurement technique was re-incorporated in the pipe support procedure (QI-QAP-11.1-28, Revision 29). Three months later tte profile technique was added to this procedure under Revision 30. The method of documenting the results of type-2 skewed weld l measurements depended on the measurement technique used and the procedure under which the inspection / reinspection was perf o rmed. For example, since December 1982 the pipe support procedure (QI-QAP-11.1-28, Revision 16) provided documentation of weld size measurements on an individual veld basta. However, the reinspection performed in 1983 under CP-QAP-12.1 utilized a checklist with two entries (skewed svelds and all other velds) to cover all the structural velds on a support. a

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N RESULTS REPORT a ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSICN OF RESULTS (Cont'd) Six<different methods of documenting the results of type-2 skewed weld inspections were permitted by procedure at various times. Thesemethods[were: s -

                            ,                                                                                                                             1.         HIR                       .

Hanger Inspection Report

1. CSC ' c.. Component Support Checklist M 3, MUDC Multiple Weld Data Card

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                            ,,                                                                                                                        4.             WICL                     -

Weld Inspection Checklist {

5. CSF6SWIR -

Component Support Fillet and Skaved Weld Inspection Raport

6. COT -

Construction Operation Trnveler All but one of these methods were etecuarered in the records for the 60 supports selected for reinspection under this action plan. However, the most common r9 cord was the CSC check!ist used for the reinspection performed under CP-QAF- l 2.1. 5.2 Proceiure Review As discussed in Sect 14 n 3.1, two te.chniques for the

                                                                                                                   =easurement of type ," skewed veldr were provided in the Brown
                                                                                                                    & Root procat.ures. tam third-party has reviewed both techniques e,nd concluded that they ara adequate to address the uniqus dimen6(onal aspects ofi the type-2 skewed veld configdzkrion. However, for e two yasr pcried (December 15,
                      ,                 ,                                                                            1982 to 1'anuary 25, 1985) the pipe support inspection s

proceduee (QI-QAP-11.1-28) did not include either tecsnique except by reference to the piping inspetsion procedure

( QI-Q AP-i l .1-26 ) . This discrepancy, which is. che origisal concern identified by the TRT, was documented on VIR-F-1061 and submitted to the QA/QC Progras: Adequacy re71evttra= for classification under that progt.sa. The Project's intent that the Laspection technigse.s for skewed welds in the piping procedure be used for inspection"of skered-velds on pipe supports was clearly indicated by the Broei & Root serso (QCVI-1) 1ssued in Febsuary,1983 (Reference 9.4) . However, training records specific to this instruction were not maintained. In addition, verk sheets or other ;ccords documenting the inspection of type-2 skevedtvelds tving the

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Revision: 1 p 'Page 13 of 57 RESL*LTS REPORT I L ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i ' l techniques referenced in the piping inspection procedure were not required to be maintained for the reiuspections performed under QI-QAT-12.1. Thus, for these reinspection, the inspection records do not indicate the inspection technique used.- A review of the history of the applicable procedures indicated that at the start of the reinspection under CP-QAP-12.1 (Revistan 5 issued March 18, 1983) the piping inspection procedare (QI-QAP-11.1-26 Revision 10) contained only the scribe line inspection technique which is not applicable for reintpections. The profile technique was added in Revision 13

                '                 of C:I-QAP-11.1-26 (issued August 4, 1983). This revision of QI-QAP-11.1-26 corresponds in time to Revision 8 of QI-QAP-12.1. The results of the document review performed under this action plan (Section 5.3) indicate that most of the reinspection were performed to revisions later than Revision 8 and when the profile technique'was available. A summary of the revision number and effective dates for procedure CP-QAP-12.1 and corresponding revisions of procedures QI-QAP-11.1-28 and QI-QAP-11.1-26 is provided as Table 2.

! In response to the concern r'aised by the TRT, the Project l ' revised the pipe support inspection procedure (QI-QAP-11.1-28) to include both techniques for inspectien of type-2 skewed welds thus eliminating the need to refer to the piping procedure for this inspection. In addition, the Project identified and corrected an error in the scribe line measurement technique in both QI-QAP-11.1-26 and QI-QAP-11.1-28. This error involved the omission of a factor that is necessary to correct the measured leg size (dimension C in Figure 1) for the skewed angle in order to determine the ; skewed weld leg size (dimension S** in Figure 1). This error did not affect the reinspection performed under this action

 'n                             plan or the conclusions drawn from these data since these 3                             measurements were made using the profile technique.

fy The Project also concluded that revision of QI-QAP-12.1 to incorporate skewed weld inspection criteria was not required, since the veld reinspection under this procedure were complete. Future inspections or reinspection of skewed welds i would be performed under QI-QAP-11.1-28. The third-party has J ' reviewed the actions taken by the Project to revise the inspection procedures related to type-2 skewed welds tnd concurs that the changes made are adequate. n

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9 Revision: ! Page 14 of 5' RESULTS REPORT ISAP V.a (Cont'd) ! 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) The third-party also evaluated the potential impact of the error in the scribe line technique and the Project's corrective action as defined in TDDR No. PS-86-1973. The impact of the error on the weld stress level is directly proportional to the reduction in the effective throat size of the weld. The ef f ective throat size (ETS) is the minimum distance from the root of the weld to its face and it is calculated from the veld size (dimensions S* and S** in Figure 1). The reduction in ETS due to the error depends on the relative diameters of the two support members being velded and the angle at which these members intersect. If the diameter of the smaller member is less than or equal to 1/3 the no correction to the ETS diameterofthelargermembe{definestheweldsize is required because the Code as equal to dimension "C" in Figure 1. Where the diameter ratio is greater than 1/3, the maximum reduction in ETS at a single point along the weld due to the error is 17%. While this could result in regions of some welds that do not meet the ASME veld size inspection criteria, the reduction in ETS for the weld as a whole is much less. The results of the third-party evaluation (Reference 9.18) indicate that for 90* or "T" joints the reduction in ETS for the veld as a whole ranges from 0 to 6% depending on the l relative diameters of the members. For oblique or "Y" joints I the reduction in ETS for the veld as a whole ranges from 0 to 12% depending on the diameter ratio and the angle at which the two members intersect. Thus, while the error may have led to some veld regions which are undersize and require evaluation on a case-by-case basis, the increase in veld stress levels is expected to be rmall (0 cc 12% depending on the joint design). The supports affected by the error are those with type-2 skewed welds that were measured by the scribe line technique i and were excluded from the population sampled for reinspection l under this actien plan. Tne type-2 skewed welds excluded from I the population sampled were those which attach to the pressure boundary and those that were accepted by QC s.fter the sample was drawn in September 1985. Supports included in the 1 Code in this case refers to AWS D1.1. It is recognized that the controlling code for pipe support is ASME. However, the ASME code does not address skewed fillet veld joiats for pipe supports. As a result the standard industry practice is to utilize the definitions in AWS D1.1 for skewed fillet veld joint details. The supports however are designed, constructed and inspected in accordance with the ASSI code requirements, i

Revisien: 1 Page 15 of 57 RESULTS REPORT ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OP RESULTS (Cont'd population sampled for reinspection are not of concern since undersize weld regions caused by this error would be detected by the profile measurement technique used for the reinspection. The third-party has reviewed the recommended corrective action for TDDR No. PS-86-1973 and provided comments to the Project (Reference 9.18). The Project is developing a corrective action plan which will be overviewed by the third-party in accordance with Appendix H of the CPRT Program Plan. 5.3 Reinspection and Records Review of the Sample of Tvpe-2 Skewed Welds 5.3.1 Population Determination and Sample Selection The population of supports with type-2 skewed welds was established as desc'ribed in Reference 9.6. The basis was a list of all large bore pipe supports obtained from the Hanger Information Tracking System (HITS). All the drawings listed on the HITS printeut were reviewed to identify the supports that contained one or more type-2 skewed welds. The accuracy of the HITS data base was verified by the third-party (Reference 9.7). A total of three hundred fifty-nine (359) supports containing type-2 skewed welds were identified and a random sample of supports was selected in accordance with Appendix D of the CPRT Progra Plan. The initial sample selection process was perfor=ed without any screening. As a result nine (9) supports f abricated by Nuclear Power Services, Inc. (NPSI) and one (1) support fabricated by ITT-Grinnell (ITT) were inadvertently included in the sample for reinspection (NPSI and ITT are pipe support fabrication firms). Since these supportz were fabricated and inspected under the NPSI/ITT QA programs using NPSI/ITT procedures and persennel they were removed from the sample and additional supports were drawn at random from the population of 359 total supports until 60 supports fabricated by Brown & Root were obtained. The total number of supports fabricated by NPSI and ITT that contain type-2 skewed welds is 32, or about 91 of the total population of 359. I l

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ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) The screening criteria used in establishing the final sample were:

1) Exclude supports not fabricated by Brown &

Root.

2) Exclude supports where the type-2 skewed weld was not complete (not yet fabricated).

3) Exclude supports where the type-2 skewed weld had not been final inspected / accepted by Brown & Root QC at the time the sample of sixty (60) supports was selected for reinspection under this action plan.

4) " Exclude supports where there were no structural type-2 skewed welds.

5) Exclude supports where more than 50% of the length of the type-2 skewed welds were inaccessible for measurement using the profile technique.

As described in Section 1.0, the TRT cencern related to the procedures used by Brown & Root QC for the i inspection of type-2 skewed welds. Thus, the first I three screening criteria were intended to focus the sample on supports inspected by Brown & Root QC. The fourth criterion deleted those welds which have a skewed configuration but, because of their angle being greater than 135' (see Figure 2), are not considered in the support design analysis as a structural veld and thus are not required to be measured. The last criterion was for the determination of accessibility. An accessibility criterion was necessary to avoid biasing the sample with a number of supports in which only a reall portion of the weld was measured. Inaccessible welds were those where permanent plant equipment blocked the use of the contour gage at the skewed weld, The need to remove insulation or erect scaffolding was not considered a basis for a weld being inaccessible. The skewed welds in approximately 23% of the supports selected at randec were deter =ined to be inact ?ssible. w_____________ -

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ISAP V.a ' (Cont'd) 5.0 IMP 1.DiENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.2 Results of Reinspection ' The sample of sixty (60) Brown & Root supports contained one hundred-two (102) type-2 skewed welds with a total length of 2475. inches. Each type-2 skeved weld in the sample was reinspected by the QA/QC Review Team, a third-party organization, using ERC procedure QI-006 (Reference 9.8). This procedure utilized the profile technique as described in Figure 2. The acceptance criteria applied for the veld size measurement were as specified lLn ASME Section III subsection ND-4427 (W82). This section of the ASNI code allows welds to be undersized by up to 1/16-inch for 2-inches or 10% of the length of the weld,

                                      .             whichever is less.

Twelve (12) of the sixty (60) supports were found to contain undersize weld regions that were in excess of the ASMI criteria. The total length of the undersize regions was 79-1/2 inches or 3.2% of the total veld length. Table 3 lists the supports found by the third-party inspectors to have undersized welds and the resultant NCRs issued by Brown & Root QC to document these non-conforming conditions. As discussed in Section 5.3.4, evaluation of these undersize welds by i both the Project and the third-party concluded that in all cases the undersize welds were well within ASME allowable stress levels. The results of these inspection have been submitted to the QA/QC Review Team for trending of construction deviations in their Quality of Construction program (Reference 9.17). 5.3.3 Results of Records Reviews The records of the original inspections for the sample of 60 Brown & Root supports were reviewed to determine which procedures were used to inspect the type-2 skewed welds and if there were relationships which correlated with the undersize welds observed in the reinspection performed under this action plan. The results of this review are listed in Table 4 and summarized in this section.

R0 Vision: 1 Page 18 of 57 RESULTS REPORT ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) All the supports in the sample have inspection records corresponding to procedures QI-QAP-11.1-28 or CP-QAP-12.1. The most common record (67%) was the ! Quality Control Component Support Checklis t from CP-QAP-12.1. This is the checklist that contains two entries, skewed welds and other velds, to document the inspection of all welds on the support. This record does not indicate which measurement technique was used to inspect the type-2 skewed welds. Fourteen (14) supports had a record documenting a QC inspection at fit up of the type-2 skewed weld. Since a fit up inspection was not required for these welds prior to (January 25,198?) unless the scribe line

      "                   technique was used to measure the size of the skewed veld, it is considered probable that these skewed weld were inspected using the scribe line technique.                                                        j A review of the relationship between the undersize welds found in the reinspection under this action plan and the Brown & Root inspectors who performed the original inspections indicated no correlation. The twelve supports with undersize welds were inspected by thirteen Brown & Root inspectors with several supports being inspected by more than one inspector. Eleven of these inspectors each had inspected only one of the supports found to contain undersize welds. The remaining two inspectors each had inspected two of the supports fouti to contain undersize welds.

A correlation is apparent if the sample is examined on the basis of those supports for which the records indicate that the scribe line technique was probably used. This group of 14 supports contained no undersize velds compared to a 4.1% occurrence for the retaining 46 supports in the sample or the 3.2% average race for the sample as a whole. A correlation can also be seen if the sample is examined on the basis of whether the supports were f inspected before or after the profile measurement l technique was added to the piping inspection procedure (QI-QAP-11.1-26, Revision 13) on August 4, 1983. Table 4 indicates that of the 60 supports in the sample, 14 were inspected before August 4, 1983. 43 supports were inspected after August 4, 1983 and 3 were inspected l n l l

Revision: 1 Page 19 of 57 RESULTS REPORT ISAP V.a (Con t d) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) both before and after August 4 1983. Ignoring the 3 supports that were inspected both before and after August 4, 1983, the percentage of undersize velds for the supports inspected before August 4, 1983 was 3.3" compared to 1.4% for those inspected after August 4, 1983 when the profile technique was available. .If the 14 supports that were probably inspected by the scribe line technique are eliminated from this comparison, the trend persists, although not as strong (i.e., the percentage of undersize velds for supports inspected before August 4, 1983 becomes 3.3% compared to 2.1% for those inspected after August 4, 1983). These correlations between the probable use of the scribe line technique or the introduction of the profile technique and a reduction in the rate of undersize velds support the TUGC0 contention that Brown

                       & Root QC inspectors were aware of the inspection methodelegy in the piping inspection procedure (QI-QAP-11.1-26) and the intent that this methodology should be used for measu:ement of type-2 skewed welds that were not attachment velds to the pipe.

5.3.4 Safety Significance i Each of the NCRs listed in Table 3 was evaluated by the Project pipe support engineering organization to determine the effect of the undersize condition. The Project calculations were also reviewed by the third-party (Reference 9.9) to determine if the observed deviations were safety-significant in accordancs with the CPRT Program criteria. The results a i of both the Project and the third-party reviews concluded that all the undersize velds were well withda 1 the ASMI allevable stress levels and thus the deviations were not safety-significant. The NCRs were dispositioned appropriately, use-as-is. In the course of this review the third-party issued two (2) Discrepancy / Issue Resolution Reports (DIRs: D-0130, D-0133) to docu=ent discrepancies in the j Project calculations related to the evaluation of the ; NCR conditions. These DIRs were classified as l observations since the conclusion reached by the Project based on these calculations were correct, the , errors were not progra==atic in nature and the errors, l if undetected, would have had no effect. i 1

4 Revision: I Pege 20 of 57 l RESULTS REPORT ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.5 Trend Analysis While none of the undersize velds was found to be safety-significant, the occurrence of undersize welds on twelve (12) supports in a sample of sixty (60) supports required evaluation in accordance with { Appendix E of the CPRT Program Plan to determine if these constituted an adverse trend. A trend is defined by the Program Plan as adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetected deficiency in the affected area, population or stratum. Figure 3 shows the distribution of the veld size , measurements for the one hundred-two (102) type-2 l skewed welds in the sample of sixty (60) Brown & Root ) supports that were reinspected. In accordance with the ' inspection procedure, each weld was measured at 2 to 3 inch intervals along its length. The data in Figure 3 were obtained by averaging the individual measurements for each leg of each veld, dividing by the design size of the fillet weld leg and selecting the leg that was the smallest fraction of the design size for that weld. As can be seen from Figure 3 the average size of the one hundred-two (107; cype-2 skewed welds in the sacple was 30% larger than required by the design. Figure 3 also shows that about 10% of the welds were smaller than required by the design by amounts up to 25%. Since it was already known that none of these undersize velds exceeded the ASHI allevable stress i limits there was reason to believe that the design weld j sizes contained significant margin. Therefore a statistical evaluatien (Reference 9.10) of the margin in the as-measured veld sizes was performed to assess the probability of type-2 skewed welds in the population exceeding the ASME allevable stress levels. Using the average measured size for each veld, the maximum stress was recalculated for each of the one hundred-two (102) welds in the sample (References 9.11 and 9.15). The resulting stress levels were compared to each of the applicable ASME stress limits. Figure 4 shova the distribution of the limiting type-2 skewed ' I _ _ . _ _ - _ _ _ _ _ _ _ _ _ _ - - _ _ s

Revision: 1 Page 21 of 57 RESULTS REPORT l ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) weld for each support in the sample as a percent of the controlling ASHI limit for that weld. The most limiting weld stress in the sample of sixty.(60) supports was at 82.7% of the ASME allowable stress. The average limiting veld stress in the sample was 37.8% of the ASNI allowable stress. To assess the likelihood of a type-2 skewed weld exceeding the ASNI allowable stress levels, the fraction of the population above the ASHI limits was calculated (Reference 9.10) at the 50% confidence level and at the 95% confidence level using a one-sided tolerance limit approach. For this calculation a normal distribution was assumed. This assumption was tested and accepted at the 5% level of significance using the Chi-square and Wilks-W tests. The results of these analyses indicate that the best estimate (50% confidence) of the fraction of the population above the ASME limits is 0.001. The 95% confidence estimate of the fraction above the ASME limits is 0.006. These statistical inferences are derived from the measurements and analyses of the 60 Brown & Root supports in the sample and hence represent the population from which they were drawn. Since screening criteria were used in selecting the sample, it is necessary to consider the engineering significance of these criteria to determine the extent to which these inferences apply to the part of the population that was excluded from the sampling. The first four criteria excluded supports that were fabricated by NPSI, supports that were either not complace or not inspected and accepted, and supports for which the type-2 skewed welds were not required to be measured (see Section 5.3.1). The NPSI supports were fabricated and inspected under a different program and hence have been analyzed as a separate group, not as part of this population (see Section 5.4). The supports that were not ce=plete or were not final inspected and accepted at the time of the reinspection under this action plan are subject to inspection under the revised procedures which include specific instructions for type-2 skewed welds. Thus, these supports say not be representative of the work performed under the earlier procedures and s

Revision: 1 i Page 22 of $7 1 . RESULTS REPORT - ISAP V.a (Cont'd) 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) { l have not been included in this population. Supports l vich skewed welds that were not required to be measured were not included since they have no significance from either a structural or inspection view point. These four criteria resulted in the exclusion of 43.2% of the supports drawn at random from the total population of 359. As discussed in Section 5.3.1 the accessibility criterion was applied to avoid biasing the results by including a number of supports in which less than half I of the skewed weld length was available for measurement at this time. However, good access for inspection was available during the original inspection of these supports at the time the skewed welds were made. Thus it is reasonable to extend the results of statistical evaluation of the supports reinspected under this action plan to include the inaccessible portion of the population. On this basis, the population size to be considered (accessible plus inaccessible) is estimated to be 204 supports. Using this population size the best estimate is that there are no supports that exceed the ASME limits. The 95% confidence estimate is that the number of supports exceeding the ASHI allevable stress limits is one or less. While this analysis clearly indicates that it is unlikely that any of the Brown & Root supports with type-2 skewed velds exceeding the ASHI stress limits, an additional analysis (Reference 9.10) was perfor=ed to assess the likelihood of a type-2 skewed weld exceeding the allevable stress level by a significant amount (i.e., yield). For this evaluation the ASMI Level B stress values for the limiting type-2 skeved weld in each support were compared to the yield stress. At the 95% confidence level the fraction of the population above yield was negligibly small (10-0). Based on these evaluations it was concluded that the observed undersize type-2 skewed welds do not constitute an adverse trend. I l 1

n

  .                                                                                                       l Revision:

Page 23 of $7 RESULTS REPORT ISAP V.a (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.4 Out of Scope Findings As discussed in Section 5.3.1 prefabricated NPSI and IIT supports were inadvertently included in the sample for reinspection. A total of nine (9) NPSI supports containing ; thirteen (13) type-2 skewed welds were reinspected. One of ] l these NPSI supports (see Table 3) was found to contain an j undersize veld. This non-conforming condition was evaluated I by both the Project pipe support engineering group and the f third-party and found to be well within ASME allowable strass 1evels. Thus, the deviation was not safety-significant and no { corrective action was required. j l To evaluate the significance of this out of scope finding, a margin analysis, similar to that prepared for the B:cwn & Root supports was performed (Reference 9.10). Figure 5 shows the distribution of the average veld , size for the smaller of the two (2) fillet veld legs. As can be seen from Figure 5, the mean of the distribution is'134% of the design size and, on the basis of the average weld size, none of the welds were less chan the design size. The one weld that did not meet the weld size inspection criteria was undersize by 1/16 inch for a length of 3-1/2 inches. Figure 6 shows the distribution of the limiting type-2 skewed weld in the NPSI supports reinspected as a percent of the j controlling ASME limit for these velds. These results were obtained in the same manner as described in Section 5.3.2 for the Brown & Root supports (Reference 9.13). The most limiting type-2 skewed weld was at 70.3% of the controlling ASMI allowable stress. The average of the type-2 skewed welds in the NPSI supports reinspected was 26.5% of the controlling ASMI allevable stress. { To assess the likelihood of a type-2 skewed weld on a NPSI support exceeding ASHI allowable stress levels a statistical { evaluation (Reference 9.10) of the results shown in Figure 6 I was performed. Because of the small size of the population of NPSI supports with type-2 skewed welds a different approach was used for this evaluation than was used for the evaluation ; of the Brown & Root supports. The evaluation of the NPSI supports involved the determination of that fraction of the total type-2 skewed welds in the complete NPSI support population that may exceed the most limiting stress condition (i.e., greater than 70.3%) found for the type-2 skewed welds on the nine (9) NPSI supports that were reinspected. Based on i

l . i

Revisien: 1 Page 24 of 57 RESULTS REPORT ISAP V.a (Cont'd)

{ i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) j ( this evaluation it is expected at the 50% confidence level that 92% of the type-2 skewed welds in NPSI supports will be at or below 70.3% of the controlling ASHI limit. At the 95: confidence level, 76% of the NPSI type-2 skewed welds will be at or below 70.3% of the controlling ASMI limit. Since only one (1) of the thirteen (13) NPSI type-2 skewed welds reinspected was undersize, that weld was still well within the ASME allowable stress limits, and the NPSI type-2 skewad welds have considerable margin for minor veld size deviations, no further investigation of this out-of-scope 1 finding was considered necessary. 5.5 Evaluation of Hypothesized Reot Cause and Generic Implications The investigations performed under this action plan did not identify any deficiencies or adverse trends thus an evaluation of root cause and generic implications is not required by the CPRT Program Plan. However, the TRT (References 9.1 and 9.2) considered the root cause and generic implications aspects of I this issue to be important since the question of adequate measurement techniques for skewed welds had been addressed by a previous (1982) Project corrective action. The IRT investigation concluded (Reference 9.1) that the 1982 corrective action appropriately addressed m4asurement of all skewed veldt on non-ASNE supports and type-1 skewed welds on ASME supports. However, the TRT did not find evidence in the inspection procedures or records that type-2 skewed welds on ASHI supports had been correctly measured thus suggesting potential generic implications related to the effective completion of other Project corrective actions at that time. The investigations performed under this action plan indicate that the 1982 corrective action did include measurement of the type-2 skewed welds on ASMI supports using appropriate techniques. This conclusion is based on: Brown & Root memo QCWI-1 which clearly indicates that type-2 skewed welds on ASHI supports were intended to be measured using the techniques provided in the piping inspection precedure (QI-QAP-11.1-26). The results of the inspections and records reviews !' which indicate that 231 of the supports in the sample were probably inspected using the scribe line measurement technique contained in procedure QI-QAP-ll.1-26. l i

l. -

i

I l

       '                                                                                                                      Revision:                                           !   l Pege 25 of 57 l

RESULTS REPORT I

ISAP V.a (Cont'd) i I 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i The results of the inspections and records reviews which indicate that adding'the profile measurement , i technique to procedure QI-QAP-11.1-26 reduced the rate of occurrence of undersize welds in the sample of supports reinspected. Thus, while the procedures and inspection records for the 1982 corrective action do not provide objective evidence that type-2 skewed welds on ASME supports were measured using the techniques in procedure QI-QAP-11.1-26, the results of this action plan support the position that these techniques were used. Investigation of the possibility that other Project corrective actions may not have been complete is included in ISAP VII.a.2, "Nonconformance and Corrective Actions System." The existence of a group of welds that did not meet the veld size inspection criteria indicates that the 1982 corrective action was not fully effective. However, as discussed in Section 5.3.5 the average size of the type-2 skeved. welds was larger than required by design and the extent of the veld undersize regions was small and not significant when compared to the large margins provided in the design of these welds. Thus further investigation of the population of type-2 skewed welds is not necessary. The results of this ISAP investigation have been submitted for Collective Evaluation to address the impact of all instances where CPRT investigations have found that Project correceive actions were not fully effective (Reference 9.14). In addition. DIR-E-1061 has been submitted to the QA/QC Review Team for evaluation and classification under the QA/QC Program Adequacy program.

6.0 CONCLUSION

S The investigations performed under this action plan confirmed that the procedures of record (CP-QAP-12.1 and QI-QAP-11.1-28) for the inspection of Brown & Root pipe supports did not contain inspecticn criteria for type-2 skewed welds. However, acceptance criteria for type-2 skewed welds were contained in the piping inspection procedure (QI-QAP-11.1-26). This procedure also provided two measurement techniques for type-2 skewed welds during the period when most type-2 skewed welds were inspected. i 1 l l 1

 .                                                                                                                                                             Revisien:        !

Page 26 of 37 RESULTS REPORT ISAP V.a (Cont'd)

6.0 CONCLUSION

S (Cont'd) Project correspondence indicates that it was intended that the inspection criteria and techniques in the piping procedure be used for inspection of type-2 skewed welds on pipe supports. In addition, trends observed in the results of the reinspection performed under this action plan support the position that the inspection criteria and techniques in the piping inspection procedure were used f or the inspection of type-2 skewed welds cnt pipe supports. The pipe support inspection procedure (QI-QAP-11.1-28) has been revised (Revision 30) to contain acceptance criteria and cachniques for the measurement of type-2 skewed. velds thus eliminating the need to refer to the piping inspection procedure for this inspection. The reinspection performed under this action plan provided raasonable assurance that the type-2 skewed welds on Brown & Root pipe supports are within the ASME allowable stress levels. Although twelve (12) supports were found to contain undersize velds., none of these velds exceeded ASME stress limits. An evaluation of margin based on the measured weld size indicates that it is not likely that any of the type-2 skewed welds in the plant exceed ASME limits. A type-2 skewed weld on a vendor (NPSI) fabricated pipe support was found to be underJize. This undersize veld was also within the ASME stress limit. An evaluation of the margin in type-2 skewed welds fabricated by NPSI indicated that chase supports have considerable margin for minor veld size deviations hence no further inves cagation was necessary. 7.0 ONGOING ACTIVITIES ; The third-party will overview the corrective action for TDDR No. PS-86-1973 in accordance with the requirements of Appendix H of the CPRT Program Plan. 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Brown & Root procedure QI-QAP-11.1-28 has been revised (Revision

30) to include acceptance criteria and measurement techniques for the inspection of type-2 skewed welds. Therefore, it is no longer necessary to refer to the piping inspection procedure (QI-QAP-11.1-26) for this information. This should preclude future occurrence of this problem.

s

Revision: 1 Page 27 of 57 RISULTS REPORT ISAP V.a (Cont'd)

9.0 REFERENCES

9.1 NUREG-0797, Supplement No. 10, " Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station Units 1 and 2", Concern / Allegation Number AQW-73, April 1985. 9.2 NUREG-0797, Supplement No. 13. " Safety Evaluation Report Related to the Operations of Comanche Peak Steam Electric Station, Units 1 and 2", Appendix B, page 2, May 1986. 9.3 TUCCO Memo #CPP-18,148 from C. K. Meehlman to Doug Witt, "TRT { Issue V.a and V.e Skewed Weld Inspection, Main Steam Line Installation", April 8, 1985. 9.4 Brown & Root Memo #QCWI-1 from W. T. Sims, " Skewed Welds on Stanchions (NF)", February 21, 1983. 9.5 TERA memo from J. Honekamp and R. Sanan to V.a File. " Summary of Meeting with J. T. Blixt, Brown & Root Quality Engineering Supervisor", CPRT #477, June 5, 1986. 9.6 TUGC0 Memo #56078 from C. Meehlman revising CPPA #46,663. June 10, 1986. 9.7 ERC Memo #QA/QC-RT-200 " Population Items List: Large Bore Pipe Supports, Rigid", July 3, 1985. 9.8 ERC Procedure QI-006. 9.9 TERA Memo from R. Sanan to V.a File documenting the review by Rich Rotblatt of NCRs, June 19, 1986. 9.10 CPRT Calculation #JBA243-010 " Margins on the Maximus Stressed Skewed Welds", Revision 1 September 3, 1986. 9.11 TUCCO Memo #CPPA-48,771 from J. J. Ryan to Claude Meehlman,

                                           " Skewed Wald Study", February 3, 1986.

9.12 TERA Memo from R. Sanan to V.a File, July 2, 1986. 9.13 TUCCO Memo #CPPA 49,046 from J. Ryan to Claude Moelhman "CPSES Skewed Weld Study", February 5,1986. 9.14 TERA Memo from J. Miller to J. Hansel regarding Collective Evaluation, September 5, 1986. I 1 s

 -                                                                                                              Revision:    1 Page 28 of 57 RESUI.TS REPORT                                                                       -

ISAP V.a (Cont'd)- 9.0 REPERENCES 9.15 Memo from R. Sanan to V.a File September 11, 1986 documenting the review of References 9.11 and 9.13. 9.16 QAP/DAP Document Interface Transmittal Form # S-1055, September 18, 1986. 9.17 TERA Memo from J. R. Honekamp to J. Hansel, Trending Information on Undersize Type-2 Skewed Welds, September 17, 1986. 9.18 TERA Memo #ISAP L-003 from J. Honekamp to M. Chamberlain

                   " Comments on the Proposed Corrective Action Plan for the Error in the Scribe I.ine Measurement Technique", October 9,1986.

i 4 l l i 4

t . Revisi:n: , Pege 29 of 37 l . RESULTS REPORT I ) ISAP V.a f ! (Cont'd) Figure 1 Measurement of Typical Type-2 Skewed Weld Using the Scribe Line Technique l l l l 1 I 1

l

Revisien: 1 l Page 30 cf 37

I l RESULTS REPORT ISAP V.a (Cont'd) Figure 2 1 Measurement of Typical Type-2 Skewed 'a' eld Using the Profile Technique i l 1 i l

Revisien: 1 Page 31 or, 27 RESULTS REPORT ISAP V.a (Cont'd) , Figure 3 ' Distribution of the Measured Size of Type-2 Skewed Walds in Sample Reinspection of Brown & Root Supports l l l 4

Revisten: ; Page 32 of 3: RESULTS REPORT ISAP V.a (Cont'd) Figure 4 Distribution of Margin to Controlling ASME Limit For Type-2 Skewed Walds in Brown & Root Supports 1 4 1 l l i i l ji

                                                                                         .1 1

i l t __.__.______o

t Revicion: i Page 33 of 57 RESULTS REPORT ISAP V.a , (Cont'd) ' Figure 5 Distribution of the Measured Size of Type-2 Skewed t.' elds In the Sample of NPSI Supports Reinspected 1

l l;

i I 1 1

Revisten: 1 Page 3e of $7 RESULTS REPORT , ISAP V.a (Cont'd) Figure 6 Distribution of Margin to Controlling ASKE !.imit for Type-2 Skewed Welds in the Sample of NPSI Supports l I i l l l _ _ _ _ _ _ . - _ - _ - _ - _ - . _ - - _ _ - - _ - - - - - - - - - - - - - - - - - - - - ~'-- - - ~ -~ ~ ~ ~ ^ ' ~ ~ ~ ~ ~ ~

I' . Revision: 1 Page 33 of 37 l RESULTS REPORT ISAP V.a (Cont'd) Table 1 , Key Events Related to the Measurement of Type-2 Skewed Welds August 1982 NRC Region IV questions the measurement methodology and acceptance criteria for inspection of type-1 skewed welds. Brown & Root QC questions the methodology and acceptance criteria for the esasurement of type-2 skewed welds (stanchien velds) because of their similarity to type-1 skewed welds. September 1982 i Inspection methodology and acceptance criteria for measurement of both > type-1 and type-2 skewed welds are added to the pipe support procedure l (QI-QAP-il.1-28. Revision 12 and Revision 13). At this time (9/1932) ! the only measurement technique specific ce type-2 skewed welds included in the procedure was the scribe line method. December 15, 1982 The measurement methodology and acceptance criteria for type-2 skewed welds were moved from the pipe support procedure (QI-QAP-il.1-28, Revision 16) to the piping procedure (QI-QAP-11.1-26 Revision 9). February 21, 1983 Brown & Root instruction QCWI-l was issued to inform inspectors to use the inspection methodology and acceptance criteria in the piping procedure (QI-QAP-ll.1-26) when measuring type-2 skewed welds on pipe j supports which are not attachment velds to Lne piping. 1 February / March 1983 Revisions 4 and 5 of procedure CP-QAP-12.1 were issued to initiate reinspection of all accessible structural vsids on ASME supports. These reinspection were documented in accordance with the checklist in CP-QAP-12.1 which contained two entries (skewed welds and all other l velds) to cover measurement of all the structural velds on the support. August 4, 1983 The profile technique for measuring the size of type-2 skewed welds was added to the piping procedure (QI-QAP-il.1-26, Revision 13). Inspection records indicate that most (72%) of the supports with type-2 skewed welds were inspected after this date. s _____ _ _m

 ~
   .                                                                     Revision:                                ;

Page 36 of 57 RESULTS REPORT ISAP V.a (Cont'd) Table 1 (Cont'd) January 25, 1985 The scribe line technique for measurement of type-2 skewed welds was re-incorporated in the support procedure (QI-QAP-11.1-28, Revision 29). April 25. 1985 The profile technique for measurement of type-2 skewed velds was added ! to the support procedure (QI-QAP-11.1-28, Revision 30). From this point on both piping and support inspection procedures contained both the scribe line and profile techniques for measurement of type-2 skewed welds. l 1 1 l l l ! 1 n !

c

       .                                                                       Revision:             ;

Page 37 of 57 RESULTS REPORT ISAP V.a-(Cont'd) 1 Table 2 j Sunnnary of Procedures CP-QAP-12.1, QI-QAP-11.1-28, and QI-QAP-11.1-26 q l i CP-QAP-12.1 Rev. No. and Corresponding Revision Effective Dates Corresponding Revision of QI-QAP-11.1-28 of QI-QAP-11.1-26 Did Not Exist Rev. 0 (09/08/80) Rev. 0 (01/03/80) Rev. 1 (09/11/80) Rev. 1 ' (02/06/80) Rev. 2 (09/15/80) Rev. 2 (06/26/80) Rev. 3 (10/03/80) Rev. 3 (07/22/80) Rev. 4 (12/08/80) Rev. 4 (08/28/80) Rev. 5 (01/17/81) Rev. 5 (04/29/81) Rev. 6 (02/18/81) Rev. 6 (01/15/82 thru 02/21/82) Rev. 7 (05/28/81) Rev. 8 (01/15/82 thru 02/21/82) Rev. 0 (02/22/82 Rev. 8 (02/22/82 thru 03/09/82) Rev. 6 (02/22/82 thru 03/09/82) thru 03/09/82) Rev. 1 (03/.10/82 Rev. 8 (03/10/82 One Day) thru 05/10/82) Rev. 6 (03/10/82 thru 03/11/82) Rev. 9 (03/11/82 Rev. 7 (03/12/82-thru (05/10/82) thru 04/14/82) Rev. 8 (04/15/82 thru 05/10/82) ) i s

Revisten: 1 Page 38 of 3; RESULTS REPORT ISAP V.a I (Cont'd) Table 2 (Cont'd) CP-QAP-12.1-Rev. No. and Corresponding Revision Corresponding Revision Effective Dates of QI-QAP-11.1-28 of QI-QAP-11.1-26 ; a Rev. 2 (05/11/82 Rev. 9 (05/11/82 Rev. 8 (05/11/82 i thru 05/19/82) thru 05/19/82) thru 05/19/82) i Rev. 3 (05/20/82 Rev. 9 (05/20/82 Rev. 8 (05/02/82 j chru 02/01/83 thru 06/11/82) thru 12/15/82) Rev. 10 (06/12/82 Rev. 9 (12/16/82 l thru 07/20/82) thru 02/01/83) l I Rev. 11 (07/21/82 l thru 09/02/82) 1 Rev. 12 (09/03/82 thru 09/20/82) Rev. 13 (09/21/82 thru 09/28/82) Rev. 14 (09/29/82 thru 10/28/82) , Rev. 15 (10/29/82 thru 12/14/82) Rev. 16 (12/15/83 thru (02/01/83) Rev. 4 (02/02/83 Rev. 17 (02/02/83 Rev. 10 (02/02/83 thru 03/17/83) thru 03/17/83) thru 03/17/83) Rev. 5 (03/18/83 Rev. 18 (03/18/83 Rev. 11 (03/18/83 thru 04/11/83) thru 04/11/83 thru 04/11/83)

Revisien: ; Page 39 of 57 RESULTS REPORT ISAP V.a (Cont'd) Table 2 (Cont'd) CP-QAP-12.1 Rev. No. and Corresponding Revision Corresponding Revision Effective Dates of QI-Q AP-11.1-28 of QI-QAP-11.1-26 Rev. 6 (04/12/83 Rev. 19 (04/12/83 Rev. 12 (04/12/83 thru 06/28/83) thru 05/15/83) thru 06/28/86) Rev. 20 (05/16/83 thru 06/28/83) Rev. 7 (06/29/83 Rev. 21 (06/29/83 Rev. 12 (06/29/83 thru 08/02/83) thru 08/02/83) thru 08/02/82) Rev. 8 (08/03/83 Rev. 21 (08/03/83 Rev. 12 (08/03/83 thru 08/18/83) One Day Only) One Day Only) Rev. 22 (08/04/83 Rev. 13 (08/04/83 thru 08/18/83) thru 08/18/83) Rev. 9 (08/19/83 Rev. 22 (08/19/83 Rev. 13 (08/19/33 thru 12/27/83) thru 10/23/83) thru 09/12/83) Rev. 23 (10/24/83 Rev. 14 (09/13/83 thru 12/27/83) thru 12/27/83) Rev. 10 (12/28/83 Rev. 23 (12/28/83 Rev. 14 (12/28/83 thru 06/10/84) thru 04/17/E4 thru 04/17/84) Rev. 24 (04/\8/84 Rev. 15 (04/18/84 thru 06/10/64) thru 06/10/84) l l

l . Revisient ! Pago 40 ef 5 7 L/- RESULTS REPQv] , ISAP V.o (Cont'd)' Table 2

                                ,                                                              (Cont'd)                                           .

CP-QAP-12.1 Rev. No. and . Corresponding Revision ' Corresponding Revision Effective Dates ' of QI-QAP-11.1-28 . of QI-QAP-11.;-26 Rev. 11 (06/11/84 Rev. 25 (06/11/84 Rev. 16 (06/11/84 thru 10/14/84) thru 10/14/84) thru 10/14/84) J-Rev. 12 (10/15/84 Rev. 26 (10/15/84 ' Rev. 17 (10/15/84 thru 05/19/85) thru 11/14/84) thru 05/19/85) Rev. 27 (11/15/84 thru 12/05/841' Rev. 28 (12/06/64 thru 01/24/89) Rev. 29 (01/25/85 thru 04/14/85) Rev. 30 (04/15/85 thru 05/19/85) Rev. 13 (05/20/85 Rsv. 30 (05/20/85 Rev. 17 (05/20/85 thru 08/16/85) thru 06/29/85) thru 08/16/85) Rev. 31 (06/30/85 thru 08/16/85) Rev. 14 (08/17/85 Rev. 32 (08/17/85 Rev. 17 (08/17/85 th:ts 11/19/85) thru 08/28/85) thru 11/19/85) Rev. 33 (08/29/85 Rev. 18 (11/20/85 thru 11/19/85) -- (Completion of third-party review) s C_______..______ _ _ _ _ _ . _ - _ - _ - - _ - - - _ - _- - - - - ----~- - - ------------- - - ~

         ;[f .IE i*      '1'-              M                                                                                                                                 Revision:                                    1 1*          /             $[                                                                                                                              Page 41,of 3;
       -i ;                                                         .

f il. '* jk .d';} ', . RESITLTS REPORT 4 ISAP V.a (Cont'd) ) Table 2

     ,                                                                                   (Cont'd)
                           ,: a m .,, _ .                                                                                                                                                                            !

lI l l

                                                'CP-QAP-12.1 Rev. No. and         Corresponding Revision            Corresponding Revision
   .;                   o                      Effective Dates           of QI-QAP-11.1-28                          of QI-QAP-11.1-26

/p .,: Rev. 15 (11/20/85 Rev. 34 (11/20/85

     .         ,                                  thru 02/17/86)          -

l, {

                                                                      - (Completion of third-pa::ty review)

Rev. 16 (02/18/86-thru 04/03/86) Rev. 17 (04/04/86 (Completion of third-party' review) l i n

  ,                  .~ >
         ,                                                                                                                    Revision:    1   I Page 42 of 37 J                                                                                                                                             ?
                                                               ,RESULTS REPORT ISAP V.a (Cont'd)

Table 3 Summary of Supports with Undersize Welds j N; 3 Random # NCR Support Number 1 7 M-17291 CT-2-005-403-522K 2 8 XI-6/85-0183 CC-X-022-001-F43A 3 24 XI-10/85-0186 CT-1-049-415-C92A l 4 43 XI-3/85-0100 MS-1-004-009-C62K 5 92 XI-4/85-0181 MS-1-002-008-C72K 6 129 XI-5/85-0182 BR-X-001-720-A53A 7 132 XI-7/85-0184 CC-1-087-004-A33A 8 151 XI-8/85-0185 CT-1-042-401-C82A 9 184 XI-11/85-0187 CT-1-033-414-C92A 10 186 XI-12/85-0202 CC-1-019-003- A33R 11 221 XI-859 CC-1-065-002-533R 12 204 XI-21/85-0203 CC-1-173-012-553A NPSI Support XI-2 SI-1-181-005-C41R l O

4 9 I' COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP V.c Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings Revision No. 0 1 2 Revised to Reflec : Reflect Commentt Description Original Issue NRC Comments on Plan Prepared and

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Recetmcended by: Revie. re,m te. der l$.ll._ , D.ee ifnd cali$ 1

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w In g ., i r e V IeSD m l- _- , ' - . A O, $- D,ee \leter 6/u ks- 'Jutu l l

4 Revision: 2 i Pcge 1 of 6 l l ISAP V.c l Design Consideration for Piping Systems Between l Seismic Category I and Non-Seismic Category I Buildings

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BT NRC In April,1984 the Comanche Peak Special Review Team (SRT), formed and coordinated between NRR, IE and Region II and IV, performed a limited review of Comanche Peak. The TRT, in reviewing the SRT findings in the area of piping design considerations, has discovered that piping systems, such as Main Steam, Auxiliary Steam and Feedwater, are routed from the Electrical Control Building (seismic Category I) to the Turbine Building (non-seismic Category I) without any isolation. To be acceptable, each seismic Category I piping system should be isolated from any non-seismic Category I piping system by separation, barrier or constraint. If isolation is not feasible, then the effect on the seismic Category I piping of the failure in the non-seismic Category I piping must be considered (CPSES FSAR 3.7B.3-13.1). For CPSES, FSAR Section 3.7B.2.8 establishes that the Turbine Building is a non-seismic Category I structure and failure is postulated during a safe shutdown earthquake (SSE). The effect of Turbine Building failure on any non-isolated piping routed through the Turbine Building from any seismic Category I building must be censidered. In addition, for non-seismic Category I piping connected to seismic Category I piping, the dynamic effects of the non-seismic Category I piping must be considered in the seismic design of the seismic Category I piping and supports, unless TUEC can show that the dynamic effects of the non-seismic Category I piping are isolated by anchors or restraints. The anchors or restraints used for isolation purposes must be designed to withstand the combined loading imposed by both the seismic Category I and non-seismic Category I piping. 2.0 ACTION IDENTIFIED BT NRC Accordingly, TUEC shall provide analysis and documentation that the piping systems routed from seismic Category I to non-seismic Category I buildings meet the stated FSAR criteria. _ __-____ _____ _ _-_ D

Revision: 2 P:g3 2 of 6 ISAP 7.c (Cont'd)

3.0 BACKGROUND

TUGC0 committed in the FSAR to provide isolation between seismic Category I piping system and non-seismic piping systems by using anchors or reismic restraints. The methods used to implement the FSAR com=1tment differ depending on such parameters as pipe size, location with respect to seismic buildings and location of isolation valves. Some piping systems have active valves installed at or near the boundary between the seismic and non-seismic portions of the piping run. Furthermore, it is common practice to install an anchor or moment restraint direc.tly to the Category I building structures or indirectly through intervening steel structures. Other piping systems are seismically isolated by using an anchor, moment restraint, or a series of supports. The anchors and moment restraints are designed for the combined load imposed by the piping on each side of the device. The seismically qualified portion has a calculated set of loads. The loads from the non-seismic piping are estimated. Where a series of supports is used to isolate the piping, two approaches were employed for determining the loads. First, for larger piping, the practice is generally to locate additional supports in the non-seismic portion of the system and extend the piping model to include that additional section of piping. The additional supports in the extented region (i.e. non-seismic portion) are designed to carry those loads. Secondly, for small bore piping, leads are estimated based on a presumed span in the non-seismic piping which would establish a simply calculated fundamental frequency that maximizes the seismic response. In the specific situation, first identified by the TRT, a portion of auxiliary steam system piping was routed from a seismic Category I building to a non-Category I building. The piping in question was all non-nuclear safety (NNS) piping (i.e. non-Category I piping); however, the piping was classified as high energy piping. The ISAR provides optional criteria for evaluation of postulated pipe ruptures which can be applied to high energy NNS piping which is seismically I analyzed. That option was selected for the noted portion of auxiliary steam piping resulting in a seismic analysis. As initially configured, the support system included an anchor to isolate the seismical f analy:ed portion frem the portion ! which extended into the non-Category I building. At a later l ____________a

R; vision: 2 l Pag 3 3 of 6 ISAP V.c

l. (Cont'd)

3.0 BACKGROUND

(Cont'd) l date, the device was deleted to alleviate thermal expansion stresses in a portion of the piping. The requirement to retain the seismic isolation was not clear because none of the piping was Category I. Although the specific issue raised by the TRT deals with Category I systems, based on the situation discussed above the scopa of the issue is considered to include any piping system with a seismic analysis boundary. This includes a seismic ! class change from Category I to non-Category I, but also includes any system in which the seismic model is terminated within a piping run or branch. l l l 4.0 CPRT ACTION PLAN s The objective of this action plan is to assure that piping systems routed from seismic Category I to non-seismic Category I buildings meet the FSAR criteria. This objective has been assi6ned to the Project Piping and Supports Program with a third party overview by the Design Adequacy Program. 4.1 Sceee and Methodology The scope of this action plan vill therefore be limited to the following activities: 4.1.1 Identification of all Unit 1, 2 and common piping which has a seismic /non-seismic interface. This includes:

                               -     Category I piping entering a non-Category I building Piping with a class change from Category I to non-Category I in the piping run
                               -     Piping runs with attached piping (i.e. small branch runs) which have a class change

c -s R; vision: 2

   ...                                                                                                                                                          Pega         4 of,6 ITEM NUMBER V.c (Cont'd) 4.0 'CPRT ACTION PLAN (Cont'd)
                                   -      NNS piping runs which have a portion which is
                                         . seismicauy analyzed to postulate breaks 4.1.2 A review and discussion of the events related to and the reasons for the auxiliary steam pipe situation on which this issue is based.

4.1.3 Recommendations to the PPSP and/or the DAP based on 4.1.1 and 4.1.2. Specifically, these will address any potential implications which should be considered during the PPSP and DAP implementation. 4.1.4 Preparation of Results Report incorporating 4.1.1, 4.1.2 and 4.1.3. I 4.2 Participants Roles and Reseensibilities The organizations and personnel that will participate in this effort are described below with their respective scopes of work. 4.2.1 Comanche Peak Project Engineering 4.2.1.1 Scope

                                               -    Identify seismic piping systems with non-seismic interfaces for site scope.
                                               -    Review and provide commentary on auxiliary steam pipe situation.
                                               -    Assist in preparation of Results Report including recommendations to the PPSP and/or the DAP.

4.2.1.2 Personnel Mr. C. Moehlman Project Mechanical Engineer Mr. H, Harrison Technical Ser 1ces Supertiser l

Revision: 2 Page 5 of 6

                                           ITEM NUMBER V.c (Cont'd)                                      -

4.0 CPRT ACTION PLAN (Cont'd) 4.2.2 Gibbs & Hill. Inc., New York, New York 4.2.2.1 Scope ) - Assist CPPE in identifying seismic piping systems with non-seismic interfaces (for rpecific scope of piping analysis problems).

                                                -     Assist CPPE in review of auxiliary steam pipe situation.

4.2.2.2 Personnel Mr. H. Mental Applied Mechanics Supervisor 1 4.2.3 Third-Party Overview 4.2.3.1 Scope

                                                -. Evaluate commentary on auxiliary            '

steam pipe situation.

                                                -     Prepare Results Report including              l recommendations to the PPSP and/or the DAP.

i 4.2.3.2 Personnel Mr. H. A. Levin TERA CPRT/ Structural Review Team Leader Dr. J. R. Honekamp TERA TRT Issues Manager Mr. P. Streeter TERA Senior Mechanical Engineer Dr. C. Mortgat TERA Senior Structural Engineer 4.3 Personnel Qualification Requirements I Third-party participants in the implementation of this Action Plan will cast the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. I I

e Lo . ;

                                                                                 ,                                                                                                   Revision:    2 g                                                                                                                                                                                  Page'   6 of 6 ITEM NUMBER V.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

I Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan. 4.4 Standards / Acceptance Criteria Compliance with TSAR Section 3.7B.3.13 will be assessed during PPSP and DAP implementation. Recommendations to the PPSP and/or the DAP associated with compliance will be identified as part of this action plan. l

f, ' (> ' COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: V.c

Title:

Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category 1 Buildings REVISION 1

                                      /                                                      /

( - 4%J ^ solzeles WGE Co' MMr'"' Datd (

Revfew' Team Leader U a . a /0l1Il0 Date '

                                         &                                         . 2]_                            /4l> 2 Y ?N JpnW. Beck, Chairman CPRT-SRI                                                  Date                    .

Lt. ! Revisi::: ;

   -                                                                                                        I l                                                                       Page I ef [:                          1 l.

I REST *I.TS REPORT , ISAP V.c 1' Design Consideration for Piping j Systems Between Seismic Category I ' and Non-Seismic Category I Buildings

1.0 DESCRIPTION

OF ISSUE l i Issue V.c was identified in SSER-10 (Reference 9.1, page N-329) as follows: '

                  "In April 1984 the Comanche Peak Special Review Team (SRT),

formed and coordinated between NRR, IE and Region II and IV, performed a limited review of Comanche Peak. The TRT, in reviewing the SRT findings in.the area of piping design considerations, has discovered that piping systems, such as Main Steam Auxiliary Steam and Feedwater, are routed from the Electrical Control Building (seismic category I) to the Turbine Building (non-seismic category I) without any isolation. To be acceptable, each seismic category I piping system should be isolated from any non-seismic category I piping system by separation, barrier or constraint. If isolation is net feasible, then the effect on the seismic category I piping of the failure in the non-seismic category I piping must be considered (CPSES FSAR 3.7B.3-13.1). For CPSES, FSAR Section 3.7B.2.8 establishes that the Turbine Building is a non-seismic category I structure and failure is postulat.ed during the seismic (SSE) event. The effect of Turbine Building failure on any non-isolated piping routed through the Turbine Building from any seismic category I building must be considered. In addition, for non-seismic category I piping connected to Seismic Category I piping, the dynamic effects of the non-seismic category I piping must be considered in the seismic desf3 n of the seismic category I piping and supports, unless TUEC can show that the dynamic effects of the non-seismic category I piping are isolated by anchors or restraints. The anchors or restraints used for isolation purposes must be des ...ted to withstand the combined loading imposed by both the seismic category I and non-seismic category I piping." l

? i Revision:

Page of 12 RESULTS REPORT ISAP V.c (Cont'd) 2.0 ACTION IDENTIFIED BY NRC The action to be taken regarding issue V.c was identified in SSER-10 (Reference 9.1, page N-329) as follows:

                  "Accordingly, TUEC shall provide analysis and documentation that the piping systems routed from seismic category I to                                                                                       1 non-seismic category I buildings meet the stated FSAR criteria."

3.0 BACKGROUh'D The general concern expressed by the TRT is that piping classified as seismic Category I in accordance with Regulatory Guide 1.29 (Reference 9.2) must be adequately isolated from connected non-seismic piping both at interfaces within seismic Category I buildings and where the piping may have an interaction with a non-seismic building (i.e.. the Turbine Building). In both cases, the stress analyses for the seismic Category I piping must conservatively address dynamic inputs from the non-seismic piping. Structural isolation is provided by restraints that structurally decouple seismic from non-seismic pipe sections. Process isolation is provided by valves located within the seismic Category I portion such that the integrity of the pressure boundary is assured. The typical structural restraint is a pipe anchor with a six degree of freedom restraint (three transnational and three rotational). Alternative types of restraint are acceptable provided that the loads transferred from the non-seismic pipe are properly accounted for in the design of the seismic Category I pipe. In all cases, the restraint (or restraints) must be designed to properly account for the loads from the seismic and non-seismic portions of piping on both sides of the restraint (or restraints). I All seismic Category I piping and most of the connected non-seismic 1 piping are totally within seismic Category I buildings or areas (e.g., yard). However, some of the non-seismic lines connected to ! seismic Category I piping do pass frem seismic Category I buildings { or areas to the non-seirmic Turbine Building. In these cases, the ! structural isolation device (restraint or restraints) for the seirmic Category I piping must be designed to accommodate the potential interaction / failure of the non-seismic building. High and moderate energy piping that need not be classified as seismic Category I in accordance with Regulatory Guide 1.29 are sometimes computer analyzed for seismic response to define specific pipe break / crack locations for evaluation of the effects of pipe 1 i

Revisien: ' Page 3 of : REST *!.TS REPORT l l ISAP V.c (Cont'd) i

3.0 BACKGROUND

(Cont'd) whip, jet impingement and flooding. It is the responsibility of the TUGC0 Damage Study Group (DSG) to evaluate these effects for safety-related equipment. The specific case (auxiliary steam line) identified by the Special Review Team which led to this issue (Reference 9.3) is an example of a high energy non-seismic Category I line that was computer analyzed to determine break locations. In this case, the restraint located where the auxiliary steam line passes from the Electrical and Control Building (seismic Category i I) to the Turbine Building (non-seismic Category I) was changed j during the design process from an anchor to a two way restraint to i accommodate thermal displacements. This change was evaluated by the Project at that time and a determination was made that the pipe break locations were not affected. j The concern raised by the Special Review Team was that the criteria used for the auxiliary steam line piping analyses may not be adequate to prevent a failure in the Turbine Building from causing damage to the pipe in the Electrical and Control Building. While failure of this line in the Electrical and Control Building had : been evaluated, the evaluation considered only two intermediate locations based on computer analysis stress results. It is possible that Turbine Building failure could induce an intermediate pipe break at a location other than those currently identified, thus invalidating the intermediate break location selection process. The basis for this evaluation (i.e., pipe stress levels) must remain valid during a seismic event which includes the postulated structural failure of the Turbine Building (FSAR 3.75.2.8). In addressing this issue, the TRT reaffirmed the Special Review Team concern and expanded the question to include the group of lines which pass from a non-seismic building to a seismic Category I building and connect to a seismic Category I line. In view of the fact that reliance is placed on seismic analysis of certain non-seismic piping to evaluate the effects of pipe breaks / cracks and that similar analytical / design considerations for isolation apply, a decision was made by the CPRT to identify and evaluate all such non-seirmic piping. This action plan together with the Design Adequacy Program (DAP) address seismic isolation for all seismic Category I lines and for those high and moderate energy non-seismic lines which utilize computer seismic analysis fer break / crack postulation. This includes an assessment of the technical adequacy of the design criteria for seismic isolation. Section 4.0 specifically identifies the scope of relevant issues, while aspects of implementation are addressed in Section 5.0.

Revigien: ; Page 4 of 1: RESULTS REPORT ISAP V.c (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The initial Action Plan V.c (Reference 9.4) was designed to address the full scope of the actions required by the TRT. Part way through the implementation of this action plan the Project initiated the Piping Requalification Program under Stone and Webster Engineering Corporation (SWIC) to resolve a number of issues related to the design of ASME piping and supports. Third-party overview of the SWEC requalification program was included under the Design Adequacy Program (DAP) in DSAP IX. The SWEC program includes provisions for reanalyses of all seismic Category 1 lines which, of necessity, include the seismic to non-seismic transition region for those lines which have such a transition. The reanalysis and evaluation of the restraint design for the non-seismic Category I high and moderate energy lines discussed in Section 3.0 will also be addressed within the SWEC program. A decision has been made to address these elements of Issue V.c within DSAP IX. Thus, the scope of this action plan was reduced (Reference 9.5) to the following activities. 4.1.1 Identification of all Unit 1, 2 and common piping lines which have a seismic /non-seismic interface. 4.1.2 A review and discussion of the events related to the auxiliary steam pipe situation on which this issue is based. 4.1.3 Recommendations to the SWEC requalification program and/or the DAP based on 4.1.1 and 4.s.2. Specifically, these recommendations address any potential implications which should be considered during the implementation of the SWEC requalification program and the DAP. 4.1.4 Preparation of this Results Report incorporating 4.1.1 through 4.1.3. 4.2 Participants Roles and Responsibilities The organizations and personnel participating in this effort are described below with their respective scope of work.

4 Revision:

9 Page 3 ef :

RESL'LTS REPORT ISAP V.c (Cont'd) , 4,0 CPRT ACTION PLAN (Cont'd) 4.2.1 Comanche Peak Project Engineering 4.2.1.1 Scope Identified piping systems with i seismic /non-seirmic interfaces for site scope Reviewed and provided commentary on ! auxiliary steam pipe situation 4.2.1.2 Personnel Mr. C. Moehlman - Project Mechanical Engineer Mr. H. Harrisen - Technical Services Supervisor Mr. J. Finneran - Pipe Support Engineering. Manager

4. 2,. 2 Gibbs & Hill, Inc. , New York, New York 4.2.2.1 Scope Assisted CPPE in identifying piping systems with seismic /non-seirmic interfaces (for specific scope of piping analysis probless)

Assisted CPPE in review of auxiliary steam pipe situation. 4.2.2.2 Personnel Mr. H. Mental - Applied Mechanics Supervisor 4.2.3 Third-Party Overview, TERA Corporation 4.2.3.1 Scope Reviewed the list of lines with a seismic /non-seismic interface. Evaluated auxiliary steam pipe situation. _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ _ - - - - - - - < ' - ' - - " ' ^ ' " '

Revisien: '. ! Page 6 of : REST *LTS REPORT - ISAP V.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Prepared this Results Report including recommendations to the SWEC piping requalification program and the DAP. 4.2.3.2 Personnel Mr. H. A. Levin - TERA CPRT/ Mechanical Review Team Leader Dr. J. R. Honekamp - TERA TRT Technical j Manager Mr. J. C. Miller - TERA TRT Issues Manager Mr. P. Streeter - TERA Senior Mechanical Engineer Dr. C. Mortgat - TERA Senior Structural Engineer 4.3 Personnel Qualifiestion Requirements Third-party participants in the implementation of this action i plan meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. l Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel were governed by the i applicable principles of Section III.K, " Assurance of CPRT I Program Quality", of the CPRT Program Plan. 4.4 Procedures Third-party activities have been conducted in accordance with Appendix G of the CPRT Program Plan. The piping requalification program efforts associated with this issue will be performed in accordance with applicable SWEC procedures. Third-party overview of the requalification program activities will be performed in accordance with applicable DAP procedures.

Revision: ' d Fage 7 cf 1: RESULTS REPORT ISAP V.c (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Standards /Acceetance Criteria Compliance with FSAR Sections 3.7B.2.8 and 3.7B.3.13 will be assessed during the implementation of the SWEC piping requalification program and the DAP. Recommendations to the piping requalification program and the DAP associated with compliance are identified as part of this Results Report. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Identification of Lines with a Seismic Transition The piping which has a seismic /non-seismic transition was identified by Gibbs & Hill and TUGC0 in References 9.6 and 9.7 respectively. All these lines will be part of the SWEC piping requalification program and will be overviewed by third-party as part of DAP DSAP IX (Reference 9.8). This will include non-seismic high and moderate energy lines of the type discussed in Section 3.0. t Since the ongoing SWIC program has resulted in modification to some stress analysis problem boundaries (location and/or design) and since all piping which has a seismic /non-seismic transition will be included in that program, no further activity under action item 4.1.1 is necessary. However, as part of their program, SVEC will reverify the identification of lines with seismic transitions and the third-party will I overview this process. 5.2 Review of Auxiliarv Steam Line As discussed in Section 3.0, the auxiliary steam line is a 1 non-seismic high energy line that was computer analyzed to postulate break locations. The Special Review Team and TRT were concerned that the change of support type from an anchor to a two-way restraint represented a failure to provide adequate structural isolation at the interface between the seismic Category I Electrical and Control Building and the non-seismic Turbine Building.

F.evis ien : '. Page 8 of 1: . 1 1 RESULTS REPORT

IS AP V.c ii (Cont'd) { i 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) In lieu of an anchor, it is acceptable to have a two-way restraint design in combination with other restraints, provided j the seismic analysis appropriately deals with the actual 1 support conditions and supports are designed for expected loadings, (i.e., overlap analysis). The postulation of Turbine Building failure represents a special condition with respect to design considerations for supports near the building interfaces. The review of the subject case by the third-party identified two additional questions requiring further evaluation: Did the interface between the piping design organization and the Damage Study Group function as required to assure that any changes in pipe break location resulting from support redesign were communicated to the Damage Study Group for evaluation? Did the analysis of the line adequately address the impact of the postulated structural failure of Turbine Building? With respect to the first question, Gibbs & Hill provided information (Reference 9.9) which indicated that the modified support condition was evaluated at the time of the design change for the effect on pipe break locations and that the pipe break locations did not change. Both the Gibbs & Mill and TUGC0 procedures (References 9.10, 9.11 and 9.12) require that when piping reanalysis is performed, break locations must be re-evaluated and results of the re-evaluation communicated to the Damage Study Group. A review of existing records by the third-party confirmed that the Damage Study Group was notified of the results of the reanalysis (References 9.13 and 9.14). A detailed review of the analyses of the auxiliary steam line has not been performed under this ISAP. Rather, due to problems discussed below, it is reconnended that the associated category of lines be reviewed and/or evaluated as necessary using seirmic interface criteria consistent with those used for other lines with seismic /non-seirmic interfaces in the SWEC piping requalification program (see Section 5.3). The third-party reviewed the original seirmic interface criteria (Reference 9.15) to evaluate provisions for the design of pipe supports separating seismic and non-seirmic

        ,                                                                                                                                                      Rovisien:      '

Fage 9 cf I: RESULTS REPORT ISAP V.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESCLTS (Cont'd) systems. Two issues related to the justification or basis for these criteria vare raised by the third-party. First, it could not be established that consideration of Turbine Building structural failure per FSAR section 3.7B.2.8 had been consistently accounted for in the design of supports which separate seismic from non-seismic pipes which extend into the Turbine Building. This condition, which is the issue identified by the TRT, has been documented on Discrepancy / Issue Resolution Report (DIR) E-0349, Revision 1 in accordance with DAP-2 and classified as a deviation because it was apparent that a postulated failure of the Turbine Building was not addressed as committ6d in the FSAR. Second DIR D-0098 identified an issue related to the criteria utilized for the design of seismic isolation devices at seismic transitions. Section 1.la of Reference 9.18 allows for the design loads of the device to be based on the loads from the seismically-analyzed side of the device, increased by a constant factor to account for the loads from the side that is not analyzed. The technical justification for this criterion was not provided or evident. The third-party considers that this justification should have been established. Accordingly, this DIR is classified as an observation based upon the lack of justification; however the engineering significance of the criteria is indeter=inate until such a time that piping is reanalyzed as part of the requalification program and the adequacy assessed. The third-party will review the justification to be established as l part of the piping requalification program and based on this i information and the reanalyses make a determination of the adequacy of the original criteria. The DIR will be reclassified as appropriate and corsidered within trending evaluations performed by DAP. 5.3 Recommendations 5.3.1 The Eb'EC piping requalification program should include sufficient justification / documentation to de=enstrate compliance with the FSAR commitments related to piping with seismic /non-seismic interfaces. Of particular interest are those piping interfaces between seirmic and non-seismic buildings (refer to FSAR paragraph 3.7B.2.8 regarding design considerations for Turbine Building f ailure) . 1

Revision: 1 Page 'O of 1: RESULTS REPORT ISAP V.c (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3.2 Other non-seismic Category I'high and moderate energy piping and. restraints should be reviewed and/or re-evaluated as necessary as part of the SWEC requalification program. 5.3.3 The DAP should address the technical adequacy of the work performed under Sections 5.3.1 and 5.3.2 including criteria and implementation. This Results Report will-be forwarded to DAP for their action in this regard. 5.4 Safety Significance Evaluation Two DIRs were issued as a result of the reviews performed under this ISAP. DIR E-0349 was classified as a deviation ,. which requires a safety significance evaluation. DIR D-0098 was classified as an observation. Both DIRs require further evaluation and potential re-classification prior to closure. Since closure of these DIRs. the associated safety significance evaluation (s) and any root cause/ generic implication determinations are dependent on the results obtained through the efforts recommended in Sections 5.3.1 and' 5.3.2, these DIRs are' identified for follow-up action under the DAP as described in Section 7.0 below.

6.0 CONCLUSION

S The issue identified by the TRT is partially substantiated in that existing documentation for the design of some of the piping between seismic Category I structures and non-seismic structures is not sufficient to assure that the effect of Turbine Building structural failure has been adequately addressed. It is also concluded that the interface between the piping / support dasign activity and the 1 damage study activity was adequately defined by procedures and l functioned properly in the subject case. 7.0 ONGOING ACTIVITIES

The implementation of the SWEC piping requalification program and third-party overview within the DAP are in progress. This activity includes the review / reevaluation of the non-seismic Category I high i and moderate energy piping and restraints as described in Section 5.3.2. I E.______________._________ __ _ _ _ _ _ _ _ _ _ - - - - -

i m., Revisien: ' Page 11 of 1; RESULTS REPORT ISAP V.c (Cont'd) 7.0 ONGOING ACTIVITIES (Cont'd) The DAP is also responsible for closure of the two DIRs issued under this ISAP, for any safety significance evaluation and for root cause/ generic implication assessments as required by the CPRT Program Plan. 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE TUTURE The Design Adequacy Program vill identify any action required to preclude occurrence in the future upon completion of their overview of the actions recommended in Sections 5.3.1 and 5.3.2.

9.0 REFERENCES

9.1 Safety Evaluation Report related to the operation of the Comanche Peak Steam Electric Station, Units 1 and 2 NUREG-0797, Supplement No. 10 April 1985. ("SSER-10") l 9.2 NRC Regulatory Guide 1.29. " Seismic Design Classification", Revision 2, February 1976. 9.3 Comanche Peak Special Review Team Report attached to NRC letter, Eisenhut to Spence, July 13, 1984 9.4 ISAP V.c, " Design Considerations for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings, Revision 0, March 1, 1985. (Pile # V.c.1) 9.5 ISAP V.c " Design Considerations for Piping Systems Between Seismic Category I and Non-Seismic Category I Buildings, Revision 2 January 24, 1986. 9,6 R. Dutu interoffice memo to R. E. Ballard/S. M. Msrano (Gibbs & Hill), "TUGC0 - Preliminary Report on Design Considerations for Piping Systems Between Category I and Non-Category I Buildings (Item V.c), "May 2, 1985, transmitting: 9.6.1 Gibbr & Hill Report on Design Considerations for Piping Systems Between Seiscic Category I and Non-Category I Buildings (Item V.c), April 1985, PRELIMINARY. 9.6.2 Anchor Load Evaluation Between Seismic and Non-Seismic Piping ("new loads" for anchor supporting structure evaluation). m___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l

4 j', Revisien: ' Page 12 of 1: 1 9 l

  .'                                                                                                                    l RESULTS REPORT                                  j ISAP.V.c                                      '

(Cont'd) i

9.0 REFERENCES

(Cont'd) l 1 9.7 - S. . V. Lakdavala -(Tt'GCO) of fice memorandum to C. Mortgat l (TERA), May 6, 1985 transmitting reviews of 2 1/2" to 4" ; moderate energy lines and 2" and under moderate energy lines. 1 i 9.8 Piping and Supports Discipline Specific Action Plan DSAP IX, Revision 1. 9.9 R. E. Ballard, Jr. (Gibbs & Hill) letter to J. B. George (TUCCO), " Change of an Anchor to a Two-Way Restraint in the Auxiliary Steam Piping Systems. TRT Issue No. V.c, "Au gu s t 1, 1985.

9.10 As-Built Verification Instruction, Gibbs & Hill Procedure AB-1, Revision 6. August 1985. { l 9.11 Pipe Rupture Damage Study Instruction,.Gibbs & Hill Instruction ME-1, Revision 5, October 1, 1984 ' 9.12. Program for As-Built Piping Verification. TUGC0 Nuclear Engineering Instruction TNE-DC-24-1, Revision 1, November 1, 1985. 9.13 Revised Postulated Pipe Breaks Location (RPB), Problem AB-1-135A, Gibbs & Rill Interoffice Memo AM-M-4383, February 18, 1983. 9.14 Revised Postulated Pipe Break Location (RPB), Problem AB-1-135E, Gibbs & Hill Interoffice Memo, AM-M-4384, February 18, 1983. 9.15 Structural Anchors Separating Safety Related Piping Class 2 and 3, ASME Section III, Seismic Category I from Non-Safety Piping - Load Calculation Guideline Gibbs & Hill Procedure AB-11 Revision 0, February 1982. 1 e

I COMANCHE PEAK RESPONSE TEAM ACTION PLAN-ISAP V.e .

Installation of Main Steam Pipes I Revision No. 0 1 2 Revised to Reflec<; Reflect Coment ' Description Original Issue NRC Coments on Plan Prepared and Recommended by: ,/ ) Review Team Leader > .f _ s% Date b (, ft( I f2 fff l l i l l Approved by: Senior Review Team b" d / _1 1 OE zJ. b 1 D w J. b / Dae. 1lcler "s/zc /ir

                                                                          .         'i/u/n           !

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l Revision: 2 , Page 1 of 8 l ISAP V.e Installation of Main Steam Pipes I

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC l The TRT investigated an allegation that a Unit 1 main steam line l had been installed incorrectly and had been forced into proper - alignment after flushing operations by use of the main polar crane and come-alongs. It was also claimed that pipe supports had been modified to maintain the line in its forced position and vibrations following detachment of the flushing line could have damaged the main' steam line. Based on its investigation, the TRT determined that the alleged incident pertained to restoration of the Unit 1, Loop 1 main steam line to its initial, correct installation position. (The line had shifted during flushing operations due to the weight of the added water and because the temporary supports sagged.) The TRT also determined that the modifications to permanent pipe supports were necessary to provide proper support to the main steam line in its restored position '(initial designs for and construction.of the supports had been based on the shifted position of the line), and, although the alleged vibrations could not be confirmed, their associated stresses might not have damaged the main steam line. (The highest stresses would have occurred in the weaker, temporary fir: 0ing line.) The TRT review of the TUEC analysis, perfor=ed 1 year after the incident, concluded that the analysis was incomplete. An evaluation for the full sequence of events leading up to the incident had not been performed. The TRT review of Gibbs & Hill Specification No. 2323-MS-100 indicated that there were inadequate requirements and construction practices for the support of the main steam line during flushing, and for temporary supports for piping and equipment in general. In particular, evaluations to assure the adequacy of temporary supports during flushing and installation were not required. The deficiencies in the analysis, specifications, and construction practice identified above constitute a violation of Criterion V of Appendix B to 10CFR50. 2.0 ACTION IDENTIFIED BY NRC Accordingly TUIC shall: Modify Gibbs & Hill Specification No. 2323-MS-100, and institute procedures for support of the main steam line during flushing and for temporary' supports for piping and equipment, in general, to assure that the quality of piping and equipment are not affected. Perform an assessment of stresses in the portions of the Unit 1, Loop 1, main steam and feedwater lines that were affected in the sequence of events involved during their initial installation, flushing and final installation. Conditions requiring stress analysis are:

- z-                                                                                                                j 1

L .

Rovision: 2 l Page 2 of 8 l i ISAP V.e 1 (Cont'd) 1 b l 2.0 ACTION IDENTIFIED BY NRC (Cont'd) j , Flushing condition when the lines were full of water l and temporary supports had sagged or settled. , ( Disconnecting condition when vibrations of the , temporary line could have occurred. Lifting condition when forces were applied by the polar crane and come-alongs. 4 l These assessments shall be based on appropriate piping j configurations involved. Perform a non-destructive examination of locations in the Unit

1. Loop 1 main steam and feedwater piping where stresses greater than relevant stress allowables were exceeded during the conditions of concern identified above. I 1

Review the existing baseline UT examinations for.those portions of the Unit 1. Loop 1, main steam and feedwater involved in all the conditions of concern identified above, for unacceptable indications. Review records of hydrostatic ttseing of the main steam and feedwater line to verify the qtultty of piping involved in the incident. Provide similar assessments for circumstances involved in a lifting incident identified during the TRT inspection for the Unit 1. Loop 4, main steam line. Provide assessments of effects on quality of safety related piping and equipment which were involved in similar incidents of sagging, settlements and failures, if any, of temporary supports. , Submit the results of analysis, examinations and reviews in a documented report for NRC review.

3.0 BACKGROUND

The preliminary review of the main steam line installation issue shows that the NRC description of the situation is generally correct. The allegation itself appears to be misleading based upon current knowledge.

i Revision: 2 ) l ,. Page 3 of 8 ISAP V.e (Cont'd)

3.0 BACKGROUND

(Cont'd) In the normal course of completing the installation of the line, it was found that the main steam line as installed on its temporary supports was out of position approximately 3-1/4" vertically and 3" horizontally with respect to the Steam Generator nozzle to which it was to be welded. Engineering was informed and, subsequently, calculations were reviewed to determine the weight of the line that was out of position. The line was lifted into position in a controlled manner, using a load measuring dynamometer in series with the main hook on the polar crane. The dynamometer was clearly visible and was observed by the field support engineer and other personnel during the lift. The maximum load was approximately 15 tons. This was consistent with previously calculated estimates of the weight of the line being lifted. The one lift plus the horizontal displacement with a ceme-along resulted in satisfactory alignment. No further , adjustments by bending, heating, or cutting were necessary to obtain a fit. A related issue identified by the TRT concerns the welding of temporary supports without a weld procedure specification or by an unqualified welder. The TRT reviewed the requirements for temporary supports, and made walkthrough inspections in both Unit I and Unit 2. The TRT established that temporary supports are employed during construction to maintain the required positions and alignments of components during installation until designed supports are permanently installed. Such supports are essentially made up on the site by construction personnel from available materials which are assembled in a manner to provide the necessary support function. Based on its investigation, the TRT determined that, except for attachment velds to components or permanent plant structures, no written requirements existed addressing weld fabrication of temporary supports. The TRT included the following required action statement in NUREG-0797 Supplement No. 10. TUIC shall modify Gibbs & Hill Specification 2323-MS-100 requirements and provide procedures i for the fabrication and installation of temporary supports to l assure that the quality of piping and equipment so supported is not adversely affected. This action is related to that i required for Mechanical and Piping Category II, allegation I AP-13, item 1 (installation of main steam pipes -- See ) paragraph 2.0 above). I 4

            ,.           s l       ,.

lavision: ' 2 4 Page 4 of 8 ISAP.V.e (Cont'd) [ i . 1, * ' i l i i N. l L

                                                                                                                                                                                                           .        1        1 i

4.0 CPB"' ACTION PLAN 4.1 Scope The objectives of the plan are: Perform an engineering investigation of the main steam line and supports including the connection of the flushing line near the SG to determine the detrimental physical effects, if any, of the adjustment of the line to achieve final ficup. Identify the extent of construction'ptactices at the site related to the specific mair. 5:aam installation and to the more general area of tenorary supports and determine the nature and extent of detrimental physical effects in other important piping systems. If detrimental effects are found in either the main steam line or other syetems, the'ueed for remedial action will be determined. If necessary, a suitable program to remedy the damage will be formulated and implemented. 1

7 , s Revision: 2 Page 5 of 8 ISAP V.e (Cont'd)

'\

h 4.0 CPRT ACTION PLAN (Cont'd) s 4.2 Methodology - The specific engineering. investigation of the steam line adjustment will be performed 43 follows: 1

                                             -   Review procedures for pipe erection and placement of temporary and permanent pipe supports.

Interview personnel involved with the steam line adjustment.

                                             -   Evaluate engineering significance of procedures and practices.
                                             -   Perform an analytical evaluation of stresses and support load changes during steam ifne movement for Unit i. Loop 1, including full parametric variations of possible inputs.
                                             -   Establish engineering significance of stresses and support loads from previous step.
                                             -   Review the existing UT examinations and hydrostatic tests for the affected piping on Unit 1. Loop 1.
                                             -   Determine the need for reinspection of portions of the line that may have been highly stressed and identify location for reinspection. If appropriate, recommend and implement reinspection program.

A generic study of possible damage in other piping, including the Unit 1 Loop 4 main steam line, will be performed as follows: Review procedures and specifications for pipe erection and placement of temporary and permanent pipe supports.

                                             -   Review NCRs and Piping Deviation Request Forms (PDRFs) with cirecmstances similar t:0 the steam line.
                                             -   Interview pipe installation personnel to determine other piping that had location adjustments made during ficup.

1 Review all other sources of residual stresses to piping systems such as bending in place, etc. 1

Revision: 2 Page 6 of 8 ISAP V.e (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Evaluate the engineering significance of residual stress due to ficup adjustments. Perform comparative evaluations relative to other sources.of residual stress. Consider guidance from codes and standards, ASME, ANSI, SRP, etc. If required after the above evaluations, specific additional samples of piping fitup will be chosen and specific engineering evaluations performed as with the steam line. Where required, modify Gibbs & Hill Specification and/or reinted procedures, to insure that piping in general-(and the main steam piping in particular) and associated equipment are not adversely affected during flushing activities and/or by use of tenporary supports. The attached logie diagram identifies tasks and the inter-relationship of tasks for resolution of this action plan. 4.3 Participants Roles and Responsibilities 4.3.1 Comanche Peak Project Engineering 4.3.1.1 Scope Modification (as required) of procedures and specifications for control of pipe erection, temporary support, hydro / flushing. Provide documentation for process and procedure review. Assist in preparation of Results l Report. - 4.3.1.2 Personnel l Mr. C. Moehlman Project Mechanical l Engineer i Mr. H. Harrison Technical Services Supervisor

Revision: 2 Page 7 of 8 ISAP V.e (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2 Third-Party Activities 4.3.2.1 Scope 1 All activities identified in section 4.2 except those identified in 4.3.1.1 will be performed by third-party.

                                                                                                          -       TERA Corporation verification of work performed by RLCA.

4.3.2.2 Personnel Mr. H. A. Levin TERA Corporation - CPRT Mechanical Review Team

                                                                                                            .                 Leader Dr. J. R. Honekamp TERA Corporation - TRT Issues Manager Mr. P. Streeter        TERA Corporation - Senior Mechanical Engineer Dr. R. L. Cicud*       Principal RLCA Mr. C. I. Browne*      Project Manager RLCA 4.4  Personnel Qualification Requirements Third-party participants in the implementation of this action plan meet the personnel qualification requirements of the CFRT                                 '

Program Plan (see note relative to Dr. R. L. Cloud and Mr. C. I. Browne). Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel vill be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

Dr. Cloud and Mr. Browne have recently assumed responsibilities assisting the project in the area of piping design. Accordingly, these individuals are no longer associated with the third-party team. Their prior work will be verifie,d in detail by TERA Corporation.

4 R vision: 2 Page 8 of 8 ISAP V.e (Cont'd) ATTACHMENT INSTAL 1.ATION OF MAIN STEAM PIPES r 11 i i:l.l!

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COMANCHE PEAK RESPONSE TEAM RESEI.TS REPORT ISAP: V.e

Title:

Installation of Main Steam Pipes REVISION 1 { ./ flk Tssue Crbraf'nator 10 -l% " 8 6 Date f vidv Team Lead C

                                                      ~       10-f("$l Date r                                                                                I
                  & 41 $ 1_

Jory W. Beck, Chairman C?RT-SRT

                                                             /0/hr/Pt.

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f . - [T Revision: '. Page I ef 67

1 RESULTS REPORT 1 ISAP V.e l Installation of Mein Steam Pipes

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC k Issue V.e was identified in SSER-10 (Reference 9.1, page N-330) as follows:

                                                                        "The TRT investigated an allegation that a Unit 1 main steam line had been installed incorrectly and had been forced into proper alignment after flushing operations by use of the main polar crane and come-alongs. It was also claimed that pipe supports had been modified to maintain the line in its forced position and vibrations following detachment of the flushing line could have damaged the main steam line. Based on its investigation, the TRT determined that the alleged incident pertained to restoration of the Unit 1, loop 1 main steam line to its initial, correct installation position.                                      (The line had shifted during flushing operations due to the weight of the added water and because the te=porary supports sagged.) The TRT also deter =ined that the modifications to per=anent pipe supports were necessary to provide proper support to the =ain stea= line in its restored position (initial designs for and construction of the supports had been based on the shif ted position of the line) and, although the alleged vibrations could not be confir:ed, their associated stresses might not have da= aged the main staa= line.                                  (The highest stresses wculd have occurred in the weaker, te=porary flushing line.) The TRT review of a TUEC analysis, perfor=ed 1 year af ter the incident, concluded that the analysis was incomplete. An evaluation for the full sequence of events leading up to the incident had not been performed. The TRT review of the Gibbs
                                                                       & Hill Specification No. 23:3-MS-100 indicated that there were inadequate recuire:ents and construe:1on practices for the support of the main steam line during flushing, and for teeperary supports for piping and equip =ent in general. In rarticular, evaluations to assure the adequacy of temperary supports during flushing and installation were not required.

The deficiencies in the analyses, specifications and construction practice identified above constitute a violatien of Criterion V of Appendix B to 10CFR50." 1 6 _________._______J

f Revisien: . Pate : of 6: RESf*LTS REPORT ISAP V.e (Cont'd)

1.0 DESCRIPTION

OF ISSUE IDENTIyIED BY NRC (Cont'd) A related issue identified by the TRT in SSER 10 (see Reference 9.1 pages N-37 to N-39) concerns the velding of temporary supports without a veld procedure specification or by an unqualified welder. The IRT reviewed the requirements for temporary supports, and made walkthrough inspections in both Unit I and Unit 2. The TRT established that temporary supports are employed during construction to maintain the required positions and alignments of components during installation until designed supports are permanently installed. Such supports are essentially made up on the site by construction personnel from available materials which are assembled in a manner to provide the necessary support function. Based on its investigation, the TRT determined that, except for attachment velds to components or permanent plant structures, no written require =ents existed addressing veld fabrication of temporary supports. 2.0 ACTION 7DENTIFIED BY NRC 2.1 Installation of Main Steae Piees The action to be taken regarding the first portion of issue V.e was identified in SSER 'O (Reference 9.1, pages N-331 and S-332) as follows:

                                          "(1) Modify Gibbs & Hill Specification No. 2323-MS-100, and institute procedures for support of the main steam line during flushing and for temporary supports for piping and equipment in general to assure that the quality of piping and equipment are not affected.

(2) Perform an assessment of stresses in the tortiens of the Unit 1, loop 1, main steam and feedvater lines that were affected in the sequence of events involved during their initial installation, flushing and final installation. Cenditions requiring stress analysis are:

a. Flushing condition when the lines were full of water and temporary supports had sagged or settled.

b. Disconnecting condition when vibrations of the temporary line could have occurred,

c. 'if ting condition when f orces vere applied by the polar crane and ccee-alongs.

l l

Revisien: ': Page 2 of 67 RESULTS REPORT ISAP V.e 1 (Cont'd) 2.0 ACTION IDENTIFIED BY NRC (Cont'd) j These assessments shall be based on appropriate piping ; configurations involved. (3) Perform a non-destructive examination of locatiens in the Unit 1, loop 1, main steam and feedvater piping involved where stresses greater than relevant stress allowables were exceeded during the conditions of concern in a. through c. above. (4) Review the existing baseline UT examinations for those portions of the Unit 1,' loop 1, main steam and feedwater c.,

a. through involved in all the conditions of concern in above, for unacceptable indications.

(5) Review records of hydrostatic testing of the main steam I and feedwater line to verify the quality of piping involved in the incident. (6) Provide similar assessments for circumstances involved in a lifting incident identified during the TRT inspection for the Unit 1, loop 4, main steam line. I (7) Provide assessments of effects on quality of safety-related piping and equipment which were involved in similar incidents of sagging, settlements and failures, if any, of temporary supports. (8) Submit the results of analyses, examinations and i reviews in a documented report for NRC review." ' I

.: *'elding

                      .         of Temeerarv Suceerts The action to be taken regarding the related issue was identified in SSER-10 (Reference 9.1, page N-42) as fo11cvs:
                                "TUIC shall cedify C&H Specification 2323-MS-100 requirements and provide procedures for the fabrication and installation of temporary supports to assure that the quality of piping and equipment so supported is not adversely affected. This action is related to that required for Mechanical & Piping Category 11, allegation AJ-13, item 1."

I J l i 1

I c R ev is ie n.1 : Page 1 ef 67 PdSUI.TS REPORT ISAP V.e (Cont'd) ) i I

3.0 BACKGROUND

f The CPRT review of the =ain stes: line insta11atf.en issue i indicates that the NRC description of the situation was generally correct. However, the investigation perfer:ed as part of this Action Plan has identified differences which are discussed in Section 5 of this report. These differences primarily involve the sequence of the activities. During the process of erecting the =ain stea= line, prior to the installation of the last seg=ent which connects to the stea: generator and prior to flushing, it was found that the location of the elbow at the 899'-9" elevation was out of position approximately 3-1/4" vertically and 3" horizontally. At this point in the erection process, the portion of the subject steam line inside contain=ent was installed on te=porary supports and the end adjacent to the stea: generator was connected te a te=porary flushing line. Engineering was informed and determined the weight of the line that was out of position based on the gravity loads for the per=anent supports which had been designed but were not yet installed. The ce:porary flushing line was then cut, and the

                                                                                    =ain stea: line lifted into position in a centro 11ed =anner using a lead =easuring dyna =ometer in series with the hook of the contain=ent polar crane. The max 1=um recorded load was approx 1=ately 15 tons. The one lift plus the horizontal displacement with a come-along resulted in satisfactory

! align =ent. No further adjustments by bending, heating, or cutting were necessary to obtain a fit. With respect to the velding of te=porary supports, the A=erican Society of Mechanical Engineers (ASMI) Boiler and Pressure Vessel (B&PV) Code, 1974 Edition (including Addenda ' through Su==er 1974) and the A=erican Welding Society (AWS) D!.1-75 Structural Welding Code do not address the subject of ce:porary supports except for temporary velds attaching to, and their re= oval fre=, Code installations. As noted by the TRT, this aspect (i.e., velding of te=porary attachments to permanent components) was addressed by CPSES procedures. The TRT also found (Reference 9.1) that the i practices e= ployed in the fabrication of te=porary supports together with the te=porary support recuire=ents contained in I 1 l

4 Revisien: ' Page 3 of 6' eESULTS REPORT ISAP V.e. (Cont'd)

3.0 BACKGROUND

(Cont'd) the piping fabrication and installation procedure (Reference 9.2) were adequate. However, since the practices used were described as unwrit;en principles, the TRT concluded that they should be controlled by written procedures to preclude conditions which could be hazardous to personnel or damaging to permanent installations. 4.0 CPRT ACTION PLAN 4.1 Scope The objectives of the plan were: Perform an engineering investigation of the main stea: lines and supports including the connection of the flushing line near the SC to determine the decr1= ental physical ef f ects, if any, of the adjustment of the line to achieve final ficup. Identify the extent of construction practices at the site related to the specific main steam installation and to the more general area of temporary supports; and , determine the nature and extent cf detr1= ental physical ! effects other i=portant piping systems may have experienced as a result of inadequate ce:porary supporting practices. If detrimental effects were found in either the main stea: line or other systems, the need for remedial action was to be ' d e t e rmined. If necessary, a suitable program te remedy the da: age was to be for=ulated and i=plemented.

                                                                                                           ..: Methodelery The specific engineering investigation of the steam line adjust =ent was perfor:ed as follows:

Reviewed procedures for pipe erection and placement of te=porary and permanent pipe supports. Interviewed personnel involved with the steam line adjustment. Evaluated engineering significance of procedures ani j practices. 1 k

Revision: Page 6 of 6' RESULTS REPORT - ISAP V.e (Cont'd) 4.0 CPRT ACTION PLAN (Cent'd) Perfor=ed an analytical evaluation of stresses and support lead' changes during steam line movement for

                             . Unit 1. Loop 1, including full parametric variations of' possible inputs.

Established engineering significance of stresses and support 1 cads from previous step. Reviewed the existing UT examinations and hydrostatic tests for the affected piping on Unit 1, Loop 1. Determine the need for reinspection of portions of the lines that may have been highly stressed and identify location of reinspection. If appropriate, recec=end and implement reinspection program. (The third-party deter =ined that there was no necessity for reinspection; however, the Project performed sete reinspection as a prudent course of action (see Section 5.1.4).] A generic study of possible damage in other piping, including the > Unic 1, Loop 4 main stea: line, was perfor=ed as follows: Reviewed procedures and specifications for pipe erection and placement of temporary and per=anent pipe supports. Reviewed NCRs and Piping Deviation Request Fo r=s (PDRFs) describing circumstances similar to the sceam line. Interviewed pipe installation personnel to deter ine other piping that had location adjustments made durine ficup. Reviewed all other sources of residual stresses to piping systems such as bending in place (springing), etc.. Evaluated the engineering significance of residual' 1 stress due to fitup adjustments. Performed ce=parative evaluations relative to other sources of residual stress. Considered guidance from codes and standards. ASMI, ANSI, SRP, etc.. l I E

    '                                                                                                                                                                                 Revisient

Pace i cf F' 4

RESL*LTS REPORT ISAP V.e (Cont'd)' 4.0 CPRT ACTION PLAN (Cont'd) Based on the above evaluations, specific additional samples of piping ficup were chosen and specific engineering evaluations performed as with the steam line. Where required. Gibbs & Hill Specification and/or related procedures were modified, to insure that piping in general (and the main steam piping in particular) and associated equipment are not adversely affected during flushing activities and/or by use of temporary supports. 4.3 Participants Roles and Responsibilities 4.3.1 Comanche Peak Project Engineering 4.3.1.1 Scope Modification (as required) of procedures and specifications for control of pipe erection, te=porary support, hydro / flushing. Previde documentation for process and procedure review. Identify NCRs which have circumstances si=1lar to the main stea= line. Assist in preparation of Results Report. 4.3.1.2 Personnel Mr. C. Moehl=an Project Mechanical Engineer Mr. H. Harrison Technical Services Supe rvisor

r___ _ _ Revision: . Page S cf f 7 REST *LTS REPORT ISAP V.e (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Dr. R. L. Cloud

Principal, RLCA Mr. C. I. Browne* Project Manager, RLCA 4.3.2 Third-Party Activities 4.3.2.1 Scope i' All activities identified in Section 4.2 except those identified in ;

4.3.1.1 will be performed by l third-party. TERA Corporation verification of work perfor=ed by RLCA. 4.2.2.2. Persennel Mr. H. A. Levin TERA Corporation - CPPT Mechanical Review Team l Leader I j t Dr. J. R. Honeka:p TERA Corporation - TRT Technical Manager Mr. J. C. Miller TERA Corporation - TRT Issues Manager Mr. P. Streeter TERA Corporation - Senior Mechanical Engineer 4.- Persennel Qualification Requirements Third-party participants in the implementation of this action plan =eet the personnel qualification require =ents of the CPET Progra: Plan (see note relative to Dr. R. L. Cloud and Mr. C. I. Browne). RLCA (R. L. Cloud Associates, Inc.) assu=ed responsibilities assisting the Project in the area of piping design in =1d-1985. Accordingly, these individuals are no longer conducting third-rartv activities. Their prior verk has been reviewed in detail bv TERA , Cor;cration. ' s I

   ,                                                                            Eevision:                                         .

Page 9 ef 6' RESULTS REPORT ISAP V.e (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Other participants were qualified to the require =ents of the CPSES Quality Assurance Program or to the specific q requirements of the CPRT Program Plan. Activities performed { by other than third-party personnel vere governed by the j applicable principles of Section III.K " Assurance of CPRT Program Quality", of the CPRT Program Plan. 4.5 Acceptance and Decisien Criteria 4.5.1 Pipe Stress Analyses All pipe stresses calculated as part of the i=plementation of this ISAP should be less than nor=al condition allowables per the definitions in NC-3652.1 and NC-3611.3(a) of the ASME Code (Reference 9.3). The only loads on per=anent pipe attachment points which are of potential concern are the loads on the contain=ent penetration assemblies. However, since the design load for these assemblies is the collapse load of the attached pipe, the acceptance criterien at these attach =ent points is still te maintain the above stress I levels in the piping, l 4.5.2 Procedure / Documentation Review Specific criteria are identified within the text of the l i=ple=entation section of this results report (Sectien 5.0) or within the major supporting docu=ent of this ' report (Reference 9.4). 4 5.0 !M? LAMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 1 An index of the actions required by this action plan and their j lecation in Section 5.0 is shown in Table 1. 5.1 Evaluatien of Main Steam Lines J l 5.1.1 Sequence of Events The pri=ary purpose for the review of the sequence cf j events was to provide the basis for selecting an ; appropriate range of paracecers for evaluation in the pipe stress analyses. The sequence of events as summari:ed in Table 2 and described in more deca 11 in Reference 9.4 was based en a ee binatten of inter.tews

s Fevigice: Page 10 of A7 RESL'LTS FEPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) (some details related to the lifting of the =ain steam lines are based on individuals' recollection three to f our years later, of events that occurred in January, 1982) and record reviews. From these sources, sufficient documentation was available to define or cross-check the paraceters important.co the pipe stress evaluations. These parameters are: Configuration of the permanent and temporary piping (project drawings--References 9.5, 9.6, 9.7, 9.8, and 9.9). Force applied during the lift (issue record for dynamometer *--Reference 9.10) Vertical distance that the line was moved (survey records before and arter the life--Reference 9.13) ( Rigging for the lift (References 9.14 and 9.15). 1 Other infor=ation important to the sequence of events that can be substantiated by project records includes: Date of the lift: January 16, 1982 (issue record for dyna =ometer--Reference 9.!O) Approval by Pipe Support Engineering to fill the main steam and feedvater lines fer flushing and hydrostatic testing: February 2 7,1982 (Proj ect Me=o--Ref erence 9.16) . Flushing of main steam and feedvater lines: Last week of March and first week of April 1982 (Integrated Flushing Plan and Flushing Log--Re ference 9.17) . Cyna=o=eter calibration records before (August 12, 1981) and after (Feb ruary 11, 1982) the lifts indicate a dyna =o=eter accuracy of , appr xt=ately -/-500 lbs (Ref erences 9.11 and 9.12) . j cam . . o r. m .o .u - ___m

y

        .'                                                                                       l l    br:

Revisten:

Page *1 of 6' RESULTS REPORT ISAP V.e (Cont'd) l i

               .5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)            ,

Hydrostatic test of main steam and feedvater 1 lines: July 9, 1982 (Test records--Reference 9.18). 1 The TRT in its evaluation (Reference 9.1) did not present a detailed sequence of events. However, the statement on page N-330 of Reference 9.1 that "The line. had shifted during flushing' operations due to the ! weight of the added water and because temporary supports had sagged." is not consistent with the results of this review. As indicated in Table 2, the off-location condition existed and was corrected prior to flushing and thus was not caused by the weight of l l water added during the flushing operation. The pipe stress analyses described in Section 5.1.2 cover the full sequence of events in four phases: pre-lift when the pipe was off-location. cutting of the flushing line when vibratiens may have occurred, lifting ef the line, and the flushing operation. Thus, while the sequence is different frem that reported by the TRT, the full scope of the concerns identified by the TRT has been included in the evaluation. The only other difference noted between the secuence of events implied by the TRT in SSER-10 and the results of this review relates to whether both loops 1 and a were lifted on the same day as indicated on the issue record f or the dynamometer. The TRT noted that it was unlikely that both events occurred on the same day whereas the R. L. Cloud Associates, Inc. (RLCA) reviev , (Reference 9.4) concluded that it was probable. This ' difference is not i=portant in establishing the sequence of events for the purpose of perforting the stress analyses, since the survey records provide independent confir=ation that the lines were =oved l i

Revisten: .I Page 12 e f 6 7 I PESULTS REPORT - ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESL*LTS (Cont'd) prier to flushing. However, it was also noted that one individual involved (Reference 9.1, page N-106) indicated that the force applied during the lift was greater than stated on the dynamometer issue record. l Therefore, a range of life forces, exceeding the value j of the lift force stated by this individual (Reference 9.1, page N-106) was used in the pipe stress analysis. The investigation into the sequence of events indicated that the most likely event causing the off-location condition was settling of temporary supports. However, there is a possibility that some portion of the off-location condition was a result of the normal :2" tolerance band allowed for free-ends of spools during pipe erection (see Reference 9.2 for construction procedure and Reference 9.19 for QC procedure *). As such, it was appropriate to consider this in the stress analysis by looking at stresses caused by the lift alone (without gravity acting) to insure that all l possible installed positions were bounded. It was also

deter =ined that the stea: lines were not connected to < the steam generator and that lif ting occurred prior to flushing of the steam lines. Related to this discussien of the sequence of events, it was noted by the TRT that initial designs for and construction of the main steam line supports had been based on the shifted position of the piping (prior to the lift) (as noted in Table 2, attachment of permanent supports to the main steam line did not occur until well after the lift). However, support adjustments are ce==on practice during pipe support insta11atien and out-of-tolerance adjust =ents are also co==only incorporated in support design drawings. Therefore, it is considered by the third-party that any such design modifications were not significant relative to the j evaluations and conclusions of this report.

                                      "ote. chat there is no require =ent within these procedures to cocument the precise locatien of the free-end. Thus, it cannot be deter =ined within the :2" how much the f ree-end eight have been off the design location (however, during final fic-up, free-end location must be within established welding tolerances),

s

4 Fevisien: . Page 13 of $7 RESI'LTS rep 0RT' ISAP V.e

(Cont'd) 5.0- IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)-

5.1.2 Main Steam Line Pipe. Stress Evaluation Separate evaluations were performed (Reference 9.4) for loops 1 and 4 main steam lines. To the extent they were involved in the sequence of events. the loops 1 and 4 feedvater lines were included in these evaluations. In-addition, a vide. range of parameters was investigated in a series of computer analyses. Figure I shows the configuration of loop 1 of the Main Steam line from the i containment penetration to the point where the temporary flushing.line was cut. The configuration of loop 4 is shown in Figure 2. The various phases evaluated and the principal results obtained are summarized in Table 3 and discussed briefly in the following sections. All of these analyses were performed by RLCA using the ANSYS computer program and checked by the third-party (Reference 9.20). ANSYS is a general-purpose finite-element program videly used and accepted in the industry. Program verification is addressed by the RLCA quality assurance program (see discussion in Reference 9.21).

                                                                 .ttesses discussed in the following. sections were calculated and compared to allowables in accordance with Section III of the ASME Boiler and' Pressure Vessel Code (Reference 9.3) (also see footnote to Table 3).                                                                           I The allovables used were those applicable to normal operating conditions.                             The allowables were selected to provide a reasonable basis of comparison for the various loading conditions associated with the sequence cf events described in 5.1.1.

5.1.2.1 Loop i Pre-Lift Phase The purpose of the pre-lif e analyses was to assess the effects of the noted off-location position of the main steam line. Although it was most likely that the off-location position was caused by settling of temporary ) l supports, consideration was given to the ' possibility that some or all of the difference between the noted position and the design location was the result of the pipe insta11atian process. It should be noted that the containment penetration was the only s

_ _ , _ __ , m_ _ .- 4

              )
  ,-                                                                                                                               l Revisien:

Page 14 of 6-RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) pe rmanent attachment to the main steam line at this time. Since the. penetration is designed to withstand loads. capable of collapsing the attached pipe, the stress icvels in the pipe, not the reactions at the containment penetration, represent the limiting condition for these evaluations. The analysis model (Model 1. Reference 9.4) includes the piping as shown in Figure I with variations in the assumed effectiveness of the following temporary supports that vere in use during this phase: A steel horse support at node 3 which was composed of an I-beam crosspiece supported by pipe legs bolted to the floor. A steel cable wrapped around the pipe at node 9 and attached to an overhead concrete beam. A nylon choker vrapped around the pipe at node 17 and attached to a chainfall supported from an overhead steel beam. A lateral and gravity-only support at the shield vall (node 24). A vertical red hanger attached by a ' pipe clamp at node 28 en the temperary flushing line. Bilateral supports at nede 30 on the 1 temporary flushing lina. Three cases were investigated to provide a basis for bounding the potential effects of i settling of the temporary supports (Table 3). The weight of water was not included in these dead weight analyses since the system was net filled until after the line was reposittened (see Section 3.1.1). I l~ t _. - _ _ _ _ _ _ _______-..---________.--_______________a

Revision: ' Page 15 of 67 RESULTS rep 0RT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)- l The following support assumptions were intended to bound the actual support conditions conservatively. Cases l'and 2 represent decreasing' levels of support between the evo end supports (codes 3 and 24). In case 1, the steel cable at node 9 was assumed to be ineffective. Case 2 assumed that both of the intermediate supports (nodes 9 and 17) were ineffective. The third case (case 5 in Table J) assumed that both intermediate supports were ineffective and that the suppert at the shield vall (nede 21) settled about 1-1/4 inches. This amount of settlement at node 24 was selected to achieve the observed 3-1/4 inch displacement at the midpoint of the-elbow between nodes 18 and 22. As can be seen from Table 3, the maximum stress levels for all three cases are well vichin the allevable limits (Reference 9.3). While the precise support configuration prior to the lift is not known,'the three cases evaluated are censidered to bound the actual conditions since: Cases 2 and 5 assumed no intermediate support, and l - Case 5 assumed that the 3-1/4" i vertical off location indicated in the survey records was due entirely to settlement of supports rather l than erection tolerances. It is possible that the line was erected near the low end of the colerance band (c2 inches). If this were the case, the portion 3 of the observed displacement due solely to f support settle =ent would be decreased such i that the corresponding pipe stresses due to support settlement would be less than chose shown in Table 3 for any of the pre-lift J phases (stresses associated with lifting fr:m this " low end" position are discussed in j Section 5.1.2.3). )

 .                .                                                                             1 i
 .                                                                                Revisien:

Page 16 ef f-R[SULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) The possibility that the line was erected near the high end of the tolerance band va= also considered. In this case, ;b+ utsunt of sag due to gravity Isais bould be the same as in the essec elready evaluated. For case 2 (no intermediate support), the calculated sag at the midpoint of the elbov was about 2 inches. Thus, if the line sagged from a position at the high end of the tolerance band (+2 inches), it would have ended up near the design location unless it is also assumed that the support at the shield vall settled on the order of 3 inches. A three-inch settlement of the pipe at the shield vall is not considered plausible because: A vertical support was provided at the shield vall to prevent =otion in the downward direction. None of the personnel interviewed indicated the need to modify the support at the shield wall. Lifting the. pipe off the suppert at the shield vall to restore it to the design location would have recuired a force of 38,000 pounds rather than the 31,250 pounds indicated on the dynamo =ecer. Based on the analyses and considerations discussed above, it was concluded that

                                             =ax1=u    pipe stresses prior to the lift were well within allowable 11=its.

5.1.2.2 Loop 1 Disconnect Phase { The disconnect phase refers to the cutting of the te=porary flushing line at node 24 prior I to the lift. The analysis model (Model 2 l Reference 9.4) includes the sa:e piping I ( l

e

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Fage 17 of f~ RE.crLTS rep 0RT - ISAP V.e (Con;'d) 5.0 1. IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) configuration as was used in the pre-life evaluation. The ANSYS program was used to determine the stiffness characteristics of the piping configuration above the cut for two of the same cases (1 and 2) evalucted in the pre-lift phase. 4 Before the temporary piping was cut, the 18-inch diameter riser was in a vertical orientation as it connected'the main steam and feedwater lines. When the pipe was cut, the upper portion of the vertical riser moved to a new equilibrium position. The scored energy in the vertical riser that was released when the pipe was disconnected may have caused some low f requency, vibratory. motien of the upper portion of the riser. Hevever, as indicated in Table 3, the maximum stress levels in the permanent pipe were consistent vi:h the pre-lift analysis and well within the ASME allowable stress limits. The stiffness at the cur end of the flushing line in the horizontal plane was in the rance of 200-240 pound / inch. The static displacements at the cut end of the flushing line, which indicate the new equilibrium position, were calculated to be in the range of 6-3/4 to 13-1/2 inches for-the cases evaluated. Basec on these analyses, it was concluded that the section of piping above the cut was quite flexible and that the internal pipe forces released when the pipe was cut may j well have been sufficient to initiate a Icw ' frequency vibratory motion. While these vibratory displace =ents may have been startling to an observer (e.g. , esci11ations en the order of 6 inches or = ore), the stress levels in the permanent pipe were well within allevable limits. t

          .. .                                                                                                            1
   >,                                                                                                     Revigien:

Pace 18 e f 6 ' RESULTS REPORT ISAP V.e I (Cont'd) } 5.0 I. IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 4 5.1.2.3 Loop 1 Lifting Phase

-)

The model used for the analysis of'the ] lifting phase included.the piping shown in j" Figure 1 vich the variations in parameters as indicated in Table 3. ! In case 3, the chains mentioned in Reference 9.1 and shown in Figure 1 were included. For comparison, these chains were deleted.in case 4 Both cases 3 and 4 were based on the 31,250 pound lifting force recorded on the dynamometer issue record.. As can be seen-from Table 3, the maximum. pipe stress levels for both of these cases were less than in the pre-lift phase and well within the allovable limits. In addition, the chains'at nodes 17 and 18 had almost no effect on the maximum pipe stress levels. The calculated vertical displacements at the reference location (midpoint of the elbev between nodes 18 and 22) for both cases 3 and 4 were consistent with the working survey information and the lift force recorded on the dynamometer issue record. Yhat is, a lift force of 31,250 pounds was adequate to raise the main steam line at the reference location 3-1/4 inches above where it =ay have settled on its temporary supports. In addition, the calculated lateral displacements for these two cases (3 inches !~ north of the pre-lift positien) agree well vich the working survey information. An evaluation of the effect of changing the i ' lift force was performed using the case a configuration (no chains). The lift ferce was changed from zero to 50,000 pounds in 5,000 pound increments. The results of this evaluation are shown in Figure 3 which indicates the location and maanitude of the highest stress point as a function of the lift force. i

RGvigien: '

Page 19 of 6-t L i REST *LTS REPORT . ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) The starting point for this evaluation, zero lift force, is the same as case 2 in the pre-lift evaluation and results in the same maximum pipe stress (9.4 ksi) . As the lift force increases, the max 1=um pipe stress decreases because the pipe is being

                                                                  -raised from a sagged condition to a more neutral condition. The reference lift, condition (31,250 pounds) is only slightly beyond the lowest stressed condition. To reach stress levels equal to the pre-life condition requires a lift force of about 41,000 pounds. This is beyond the point where the line would have been lifted off of the support at the shield vall and corresponds to a displacement of about 4-1/2 inches (see Figure 4) rather than the 3-1/4 inches indicated by the survey records. .

However, even at a 50,000 pound lift force, which corresponds to about a 9 inch displacement (see Figure 4), the maximum pipe stress levels are less than the ASME allevable limits for normal operation. As was discussed earlier, it was considered possible that some portion of the off-location position was caused by installation (as opposed to all of it being caused by support sag). Since it was net documented just how much might have been caused by installation, an analysis was perfor=ed (Case 6 Table 3) which bounds the effects of this possibility. For this case, { the model was the same as described above but the pipe was assumed to be weightless (the reason for this assumption was to consider only the effects of the life; the inclusion of gravity would offset these effects - 'see further discussion below). A force was applied at node 17 sufficient to raise the

                                                                  =1dpoint of the elbov between nodes 18 and 22 the observed 3-1/4 inches (note that this is equivalent to. assuming that the pipe was s

Revisice' Fage 20 of 6- f RESULTS REPORT ISAP V.e i 1 (Cont'd) f l 5.0 IMPLEMENTAT_3N OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) ( installed 3-1/4 inches low with a subsequent lift of 3-1/4 inches). The maximum stress resulting from this case was approx 1=ately 7.3 ksi at node 3. Super 1= posing gravity-induced stresses would reduce this value since gravity forces and the lift force are in opposite directions. Based on these analyses, it was concluded that the maximum pipe stress levels were well within the allevable limits. Additionally, the stress levels during the lif ting phase l were generally less than during the pre-lift phase. 3.1.2.4 Loop 1 Flushing Phase Figure 5 represents the piping and suppert configuration for the loop 1 main steam and feedvater systems at the time of the flushing operation. This flushing configuration reflects the Brown & Root piping and hanger location isometric drawings, temporary piping spool sketches, and discussions with field personnel. The model includes the weight of water in addition to the weight of the piping. The analytical model consists of a portion of the =ain steam line up to node 22. The 19 inch te=porary flushing pipe extends free the 32 x 18 inch reducer threugh the shield vall to a long vertical riser (about 70 feet) and connects to the 13 inch feedvater line at node 41. The 18 inch feedvater line extends frem node 61 back to the containment penetration M!-5 (nede 68). A 6 inch auxiliary feedvater (ATW) line extends from contain=ent penetration KV-18 to node 72. A 6 inch temporary spool piece connects the ATV line at node 72 to the 18 inch te=porary riser at node 33.

                      'r
                  ?                                                                                   Revision:                                 .

Page ?! ef 67 4 RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) To complete the model, a 6 inch line connects l node 67, on the feedvater line, to node 88 on the AFW line. The temporary piping is used to connect the various parts of the main steam and feedvater systems, bypassing the steam generator, and to avoid flushing any debris, etc., into the steam generator Thr. temporary supports in the model were at locations and in the directions indicated by the arrows in Figure 5. These support locations reflect those provided in the-hanger location isometrics and, for analysis purposes, are representative of the actual temporary support locations. The flushing configuration, as represented by the analytical model described here, existed after the main steam line lift. As noted in Table 2, a correction was also made to the feedvater line prior to the lift by =icering an elbov upstream of the cut. Therefore, both the main steam and feedvater lines were on design location and were resupported with appropriate temporary supports during the flushing operation. The maxi =um pipe stress f or the flushing phase was 2.9 ksi at node 33 in the te=porary piping. The maximum stress in the permanent

                                                 =ain steam piping was 1.0 ksi; the maximu=

j stress in the permanent auxiliary feedvater j piping was 1.3 ksi; and the maximum stress in j the permanent feedvater piping was 1.2 ksi. These stress values indicate that stresses ] in the actual piping were well belev AEME allevable limits during the flushing operation (e.g., the 1.0 ksi in the main steam line represents approximately 6: ef the ASME allevable limit). Because of the low stress value for the feedvater piping and I i

 .           e 4

r ' Revision: Page,22 ef 67 RESULTS REPCRT ISAP V.e (Cont'd) 5.0 D:PLEMENTATION OF ACTION PLAN AND DISCUSSION OT RESULTS (Cont'd) because the feedwater piping was not involved in the life, it was concluded that the analysis for flushing provided assurance of the adequacy of the feedwater piping for the events surrounding the main stea line lift. 5.1.2.5 Loop 4 Evaluation

                          ,                           The evaluation of the loop 4 pre-lift phase was similar to that performed for loop 1.

Infor=ation for the loop 4 evaluation was

based on documentation s1=ilar to -- or in se=e cases the same as -- that identified in Section 5.1.1 for loop 1 (References 9.10 through 9.12, 9.14 through 9.18, and 9.22 through 9.27). Case 1 assumed that there were no effective supports between the shield wall and the contain=ent penetration (see Figure 2). Case 3 assumed no inter =ediate supports plus a settle =ent at the shield wall support i sufficient to result in a 1-1/2 inch dowr.vard ! displace =ent at the =idpoint of the elbew ' between nodes 20 and 23. The 1-1/2 inch displace =ent was based on the working survey ; information prior to and after the lift. The R

                                                      =axi=u= pipe stress levels for both cases, as                                                  1 shown in Table 3, were well within the allowable li=1ts.

Both the lift feree recerded on the dyna =e=eter issue record for loep 4 (17,750 pounds) and the upward displace =ent (1-1/2 inches) were less chan for the loep 1 lift. The evaluation of the loop 4 lifting phase was. based on the sa=e approach as used for the loep 1 evaluation. The =aximu= pipe stress levels shown in Table 3 are again veil within allevable limits.

4 Revision: ; Pege 23 ef 6' RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (C nt'd)

                                                                                                     '          No analyses of the disconnecting.and flushing phases for loop 4 vere performed. However, 7

the: stresses in loop 1 during these conditions were found to'be bounded by the pre-lift.and lift phases and clearly. net detrimental. Therefora, it was concluded that the loop 4 stresses during these phases. vould also be bounded by the pre-lift and

                                                                                                             ' lift phase stresses, which are not detrimental.

5.1.2.6 Summary of Pipe Stress Evaluations Tipe stress analyses were conducted for the loop 1 main steam line using models based on-the best available information and on more conservative configurations (i.e., assuming certain supports were not present). The following phases vare analyzed: Pre-lift phase, Disconnect phase (temporary flushing pipe disconnected), Lifting phcse, and Flushing phase. In all cases, maximum stress levels were determined to be well within the allevable ASME limits. l Pipe stress analyses for the loop 4 main i steam line were conducted for the folleving l phases: Pre-lift phase and Lifting phase. Analyses for the disconnect and flushing ; phases of loop 4 were not conducted because possible stress levels were considered to be beunded by the levels reached during the l above phases. These analyses deter =ined that the stress levels in loop 4 were vell vitht: the allevable ASMI limits. ! i

  ;,                 *r 4* '

Utevis ion : ' - Page 24 ef f" W3 RESULTS REPORT ISAP V.e (Cont'd) 5.0 1 IMPLEMENTATION OF ACTION Pl.AN AND DISCUSSION OF RESULTS (Cont'd) 5.1.3 Review of Weld Inspection Records and Hydrostatic Test Results As discussed previously, the main steam lines (both loops) were involved in all the events. described in Table 2. However, the feedwater lines were primarily involved in the flushing process. Because of this and because of the very low stresses calculated for the feedwater piping during flushing, the emphasis for review of weld inspection records and hydrotest records

                                                                                                         ,     was on the main steam piping.
                                                                                                             'The main steam lines contain both shop welds made by ITT Grinnell and field welds made by Brown & Root _

during the installation process. Figures 6 and 7 show

                                                                                                              'ebe location of these welds for loops 1 and 4
                                                                                      ,                        respectively-(welds are at the pipe stress analysis nodes with the exception of node 1; the distinction I

betwen shop welds and field welds is noted .in Tables 4-1,and 4-2 of Reference 9.4). The segments:of piping .. k fren'the elbows (Figure 6 - node 22 and Figure 7 - node

z

                                                           ,              ,                                    23) to.the steam generators were installed after the                                  '

1 mai ' steam lines were repositioned, resuppertec and' 4 3 flushed and hence were not subject to the concerns

                                                                                                       ,       identified by the'!RI. However, for completeness they e                               ,

t n, werd y s included in this review. t I s , '_" 6

                                                                                              .               Tb re are two basic categories of non-destructive

g. examination (NDE) records for the welds shown in !

( Fidres6and7 These are: L Radiographic (RT), magnetic particle (MT). 3

                                                                                                                                ,and dye penetrant (PT) inspection tecords
                                                                                                                                    ~

1 f rom the' examinations performed during the fabrication and installation precess. (The t.

                             '           \

t seld inspection ~ data for the shop welds on g IT: Orinnell pipe spools are maintained in i the CPSES plant records vault and filed by i, t ths spool piece number. The weld inspection data for field welds joining the pipe spools

                         ',                                                                        )                              are also maintained in the CPSES plant e                               records yault and filed by the field weld number, which includes the pioing iscretric l.*                                                            : caber. y Note that the spool piece numbers and the tield weld numbers arc-given in
                       ,           q                                                                                              !abin '-1 and J.-2 of Referene c.4.)

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                          ,                                      b                             ]                   1 t

w

                   -                                                        ,                                                                   s s                                                                      g      &

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                                                                                                                                              '        O.             _       .

4, Revision: : Page 25 of '~ RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) Ultrasonic (UT) and MT inspection records from the pre-service inspections (PSI) performed by Westinghouse on about 25T of these velds. The PSI provide base line data for the in-service inspections required to be performed throughout the plant life (Reference 9.28). The primary purpose of this review was to determine if the pre-service inspections, which were performed af ter the lines were repositioned, contained indications of unacceptable conditions. The records of the inspections performed during fabrication and installation were also reviewed to provide background infor=ation useful for the evaluation of the reinspection performed as part of this review.

                             .The review of the fabrication inspection records indicated that all velds were acceptable prior to the repositioning. The review of the Westinghouse PSI records confir ed that the velds inspected after the repositioning vere also found to be acceptable (Reference 9.28). It is i:portant to note that the velds inspected by Westinghouse in the PSI progra: vere at or near the high stress locations identified in the evaluation of the repositioning event (see Table 3).

The records of the hydrostatic test (hydrotest) of loep 1 were also reviewed (Reference 9.4) to verify the quality of the piping involved in the lifting event. This review included: Piping iso =etric drawings and flev diacrats that were marked to indicate the bouncaries of the piping that was tested. Test data sheets including information such as test pressure, test te=perature, relief valve set points, etc.. Pressure gauge calibration records. i l - Check lists used by QC to verify j i=ple=entation of the applicable procedure. ! 1 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _J

Revisien: Page 26 cf 6~ RESULTS e.EPORT ISAP t'. e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DIFLJSSION OF RESULTS (Cont'd) Records which document that the test was vitnessed by the Authorized Nuclear Inspector (ANI) and others required by the procedure. Based on the review of information contained within the hydrotest package, as well as the procedures that controlled the hydrotest, the package appeared to be cc=plete and in accordance with the appropriate procedures, and the results of the hydrotest were satisfactory. No indications were found that suggested any lack of quality of the main steam and feedvater lines. 5.1.4 Weld Reinspection The results of the pipe stress evaluations (Section 5.1.2) and records reviews (Section 5.1.3) indicated that no damage or detr1= ental effects occurred to the main stea: and feedvater lines as a result of the settling ef the supports and the disconnecting, lifting, and flushing of the lines. Specifically, the stresses at piping velds were well belev allevables. Therefore, re-examinations were not required by the action plan. Hevever, certain welds on the main stea: line for both loops 1 and 4 as listed below were re-examined: MS Line loop 1 Field Welds 14 and 7 (Stress isometric nodes : and 8 - see Figure 6) MS Line leep 4 Field Welds 16 and la (Stress 1semetric nodes : and 8 - see Figure 7) These welds were examined using both RT and UT nethods. The RT examinations were perforced by Brown & Roet to ASME Section III requirements in accordance with the Brown & Root procedures in Reference 9.29. The radiographs were interpreted by Brcwn & Root, the Authorized Nuclear Inservice Inspector (ANII), and CPSES Maintenance Engineering. No rej ectable indications were found. i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - - - - -- ' ~ ' - ' ~~' ' - - - ' ~ ~ ~ ' - - - - - - - ' - ~ ~ ~ ~ ~ ~ - ~ ~ ~ ~ ~ ~ ~ - ~ ~ ~ ~

  #'   a.

f ' Revision: ; }. Page !7 of 67 i PESULTS REPORT l ISAP V..e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l The UT examinations were performed by Maintenance Engineering to ASME Section XI requirements in i accordance with the CPSES instruction in Reference 9.30. This examination was also witnessed by the ANII. No rejectable indications were found. 1 5.1.5 Main Steam Line Installation Process In the specific situatien of the main steam lines being off location, it is noted that no NCR was issued. Thus, it is appropriate to investigate whether circumstances warranted issuance of an NCR. The basic criterion for a nonconformance is a deficiency in characteristic, documentation, or procedure which renders the quality of an item unacceptable or indeter=inate (10CTR50, Appendix B) . Thus, for a process such as installing the main steam lines, an NCR would be required if any of the following types of conditions existed: The hardware is damaged during installatten including duries rework to resolve installation problems. Installation attributes such as dimensions, when submitted for QC inspection, do not conform to design requirements. Installation or inspection procedural require =ents are not followed leading to a condition where the quality of the hardware 1 is unacceptable er indeterminate. The specific conditions related to the main steam line being off location and the subsequent repositioning would not of themselves require an NCR for the following reasons: 1 The piping run was not eceplete or supported on per:anent hangers when the off-locatien condition was encountered. At that stage. the i=portant considerations were to assure that the pipe would be within gradient and fit-up tolerances without springing when the final closure weld was =ade and that attached 1 1

d Revision: . Page 25 of 67 RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont 'd) nozzle loads were not exceeded. Since the free ends of the individual spools were within tolerance when the spool welds were made (as evidenced by QC sign-off on applicable Weld Data Cards - Reference 9.31) and no fit-up problems were encountered with the final closure weld to the steam generator nozzle, there is reasonable indication that the configuration was correct. QC inspections during the installation process which involve pipe locations are required at the time each end of a spool piece is welded in place (Reference 9.19). When the "first" and is welded to a piece of equipment (or in the case of the =ain steam line, the containment penetration asse:bly), its fit-up is checked to assure proper alignment for making the weld. At the sa:e time the first end's weld fit-up is checked, the "second" (or free) end of the spool piece is checked to make sure it is within :2 inches of the pipe's design location. 'a*h e n the "second" end is velded, its fit-up is checked'to assure proper alignment for =aking the weld to the next spool piece or equipment connection (note that this process assures piping being on-location relative to the equipment to which it attaches). In the case of the main steam line, this means that there were no require =ents for additional QC inspections of pipe locations between the times when the third and fourth (final) speel pieces were installed *. The off-location was detected and corrected by engineering in a controlled manner. Adjustment of off-location piping under direction of the Engineering groep is in accerdance with procedure CP-CPM-6.9E. Referring to Figure 6, the first three spool pieces connected frem the contain=ent penetracien to the te:porary flushing connection point (nedes 0 to ::); the fourth speel piece cade the final cernectien to the stea= generator (nodes 22 to C). I i I

e Revision: '. Page 29 ef 6-RESULTS REPORT - ISAI 7.e (Cont'd) l 5.0 !. IMPLEMENTATION OF ACTION PLAN AND DISCU$SION OF RISCLTS (Cont'd) The fact that an NCR was not issued is not considered to be a deviation from QA program commitments for the following reasons: The off-location condition was detected and l corrected by engineering in a controlled manner consistent with applicable procedures. The magnitude of the lift force and displacements were such that an engineer could reasonably conclude that the quality of the pipinF and the containment penetration would not be compromised. The evaluations performed as part of this action plan confir=ed that there were no adverse impacts due to the off-location er repositioning. 5.2 Evaluatien of other Svstems 5.2.1 NCR Review As discussed in Section 5.1.5, no NCR vas written for the off-location condition of the main steam line. No other instances similar to the main steam line could be recalled during interviews on this subject , :;e e discussion ih Section 5.2.2). As a result, it was not readily apparent what other mechanisms could be used to identify potential instances of temporary support settlement or inadequate temporary supporting practices. However, on the bases that springing is a consideration during QC inspections (see Reference 9.19 and related interview comments in Section 5.2.2) and certain limitations existed'en the use of temporary supports (see Reference 9.2), it was concluded that a review of piping-related NCRs would in fact provide the most reasonable means for identifying such instances. Based on the above considerations, a review of Nonconformance Report (NCRs) and attendant Piping Deviation Request For=s (PDRFs) was undertaken to aid in identification of other instances where temporary support problems might have led to uncontrolled i

's

~' Revister: 1 Page 3C :f 6: 4 DESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) springing *. To facilitate review of the mechanical /pi-ing discipline NCRs existing at the time of this review (approximately 15,000 total), the project applied screening criteria (Reference 9.32) to determine the potentially relevant subset of this population. This resulted in a much smaller group of NCRs for which uncontrolled springing might be of concern. This group of NCRs is summarized in Table 4 Identification, verification and review of these NCRs by the Project is documented in References 9.4 and 9.32). Third-party review of the efforts is documented in References 9.33 and 9.34 The third-party concurred with the identification and review of the NCRs described in Reference 9.4. For each of the NCRs in the identified categories of Table 4, the disposition was reviewed to the extent possible. That is, since most NCRs address temporary conditions, it is not always possible to perform after-the-fact' physical inspections to verify disposition. As such, it was necessary to assess whether there had been adeouate consideration of the effects of uncontrolled springing as evidenced by the NCR. In this discussion, the word " controlled" refers to actions whose execution is to be carried out according to written procedures;

             " uncontrolled" refers to actions for which there are or vere no written procedures defining the mede of execution. " Springing" refers to the action of displacing a pipe by use of external force.

There are normally two reasces for performing controlled springing. One reason is to relieve nozzle leads when the pipe is hot. This involves a fairly complex installation activity and is commonly done in the fossil industry for =ain steam and reheat lines. The term " cold spring" most often refers to this type of springing. Another reason is to achieve fit-up and is not so cocmonly done. Achieving fit-up is also the primary reason for uncontrolled springing, s

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Page 3i of 67 RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTA!!CN OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) Reference 9.4 discusses the disposition of each of the groups of NCRs identified in Table 4 in more detail. In general, the NCRs were dispositioned in a =anner consistent with correct resolution of the stated nonconforming condition. There were no indications in any cases that piping was forced (or sprung) into position to accommodate fit-up. Regarding the dispositioning of NCRs when equipment nozzles might be affected, the third-party requested a clarification of the process. The Project responded (see References 9.35 and 9.36) that in these cases, the engineer makes an assessment as to the potential effect of the nonconforming cond1 tion on the equipment. This assessment may not be specifically documented en the NCR. The engineer's signature on the NCR indicates his concurrence with the dispositioning of the NCR. Except for NCR M-2223, the third-party concurs with the I implementation of the process (see References 9.4 and 9.37). NCR M-2223 (Reference 9.38) describes a series of instances identified by the Brown & Root OC depart =ent between /pril 1980, and February 1981, involving pipe attached to equipment (i.e., pumps, heat exchangers, tanks). The nonconfor=ing' condition was stated to be

                            " pipe supported by equipment nozzles, thereby causing indeterminate stresses on equipment." The NCR indicates that most of these instances were resolved by the addition of temporary supports. hevever, it was not evident in any of the instances that a nozzle evaluation was perfor=ed either by visual examination (i.e., walkdown of attached piping) or by calculation.

The apparent lack of docu=entation represents a potentially incocplete dispositioning of the stated noncenfor=ing condition *. This determination required further investigation by the third-party. Closer examination of the NCRs issued before and after M-2223 revealed a number of similar cases wherein nozzle evaluations were conducted (see Table 5). Thus it appears that M-2223 is unique regarding its potentially ince:plete dispositioning. In an attempt to resolve this point and to deter =ine whether there was A OIR (D-le39) was written regarding this discrepancy, s

f Revisien: ; Page 32 of 67 RESULTS REPORT ISAP V.e I (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RISULTS (Cont'd) any damage, it was decided to inir. late an investigation based on available evidence. This investigation - included personnel interviews, documentation reviews and an engineering evaluation. The engineering evaluation included walkdowns of the equipment, noz:les and associated piping identified in M-2223, cnd where ; appropriate, perfor=ance of calculations. ' 5.2.1.1 NCR M-2223 Investigation -- Personnel Int e rviews As a first step in this investigation, various individuals in QC, Construction and Engineering were interviewed (Reference 9.39

                                                                                                -- note that these interviews were in addition to the more general interviews conducted by RLCA and discussed in Section 5.2.2 below). The infor=ation gathered in these interviews indicated that prior to issuance of M-2223, there were some cases wherein temporary supports were remeved ficm piping without QC or Engineering approval.

The supports involved were easily re=ovable types including chainfalls and co=e-alongs which were in demand because of the large amount of pipe installation activities ongoing at the time. However, to prevent unauthorized removal of temporary supports, such easily removable temporary supports were not allowed on piping attached to equipment when the pipe was unattended (see paragraph 3.18.4 of Reference 9.2). 'In order to identify these areas and to assure ongoing long-term co=pliance with the procedure, it was decided that QC would monitor various installation activities to identify locations where improper te=porary supports were beirg used; NCR M-2223 was the result. It was concluded by some of those interviewed that where the NCR indicated that a particular region of pipe was " unsupported" that, in fact, the inspector =eant the pipe was supported by easily removable (i.e., not acceptable) supports. Although these c:nclusiens night be accurate in se=e cases, the nature of the circumstances (i.e., involving temporary supports) =ake i

Pevision: . Page 33 of 6-RESULTS FEPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) substantiation of the conclusions difficult. However, it was possible for the third-party to =ake certain observations based on the NCR

description and walkdowns of the current

                                                            , configurations with per=anent supports. In some cases, the length of pipe indicated on M-2223 as bqing unsupported was such that lack of support would have resulted in obvious unacceptable conditions (e.g., bent pipe, overturned equipment); no such conditions were documented (see discussion in Section 5.2.1.2 below). In these instances the interviewee conclusions mentioned above appear to be supported. However, in most instances indicated in M-2223, obvious unacceptable conditions would not have occurred; but there is a potential that da= age could nonetheless have resulted if supports were lacking. It was also noted that there could have been cases prior to M-2223 which were not docu=ented (e.g.,

chainfalls removed one day and returned the next). Althcugh the interviews and third-party observations discussed above provide so=e measure of confidence in the disposition of NCR M-2223 and the acceptability of the associated equipment nozzles, it was concluded that the investigation needed to include further examination for potential j da= age to the nozzles. Such additional i efforts vould aid in providing a more selid basis for making conclusions about these nezzles and for extending the results cf the investigation to other s1=11ar instancer.. J 5.2.1.2 NCR M-2223 Investigation -- Documentation Review The next step in the investigation involved ! identification and review of the ! docu=entation associated with the installation and testing activities for each of the nozzles identified in the NCR. The project ccnducted an extensive review of this decu=entation which included weld data i

Revisien: . Page 3. of c'

     ,                                               RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLOP.ENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) records, flange travellers, hanger installation records, preservice inspection records, Test Deficiency Reports, hydrocest records and Operations' NCR records. The review is summartzed in References 9.40 and 9.41. Third-party review of the project efferts is documented in Reference 9.42.

From the documentation, it was determined by the project (and concurred with by the third-party) that no damage to the applicable equipment was noted by QC subsequent to M-2223. The validity of this determination is partially substantiated by noting that there were other instances identified in NCRs where nonconfor=ing bent pipe or nozzles were part of vendor-supplied equipment (see References 9.43, 9.44 and 9.45 for exa=ples). In addition to the above, the documents were reviewed for indications of problems which

                                                 =ay have been caused by the stated nonconfor=ing condition of the NCR. Such indications could involve veld repair (depending on the reason for repair), flange rework (again depending on the reason),

unacceptable leakage during hydrotest at or near the nozzle in question, etc. There were some indications of this type but it could not be conclusively established that these were related to sprinFing. On this basis, it was concluded by the project and the third-party that an engineering evaluation was warranted to provide better assurance ef the adequacy of equip =ent and attached piping. 5.2.1.3 NCR M-2223 Investigation -- Engineering Evaluation As a final part of the investigation, an engineering evaluation was perfor=ed by the third-party. The f1rst aspect of t'.41s involved a walkdown of each nezzle and associated piping to look for conditions which might not be of the obviously unacceptable type noted in Section 5.2.1.. l i

                                                 .                                                                                                              1 Sevision:   . .
                                                                                                                                             .Page 35 ef t' RESULTS REPORT-ISAP V.e (Cont'd) 5.0   IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) above. That is, it is possible that cracking might occur at nozzle connections or other
                                                                                                          " weak points" in the pipe-to-nozzle region if loads of sufficient magnitude were imposed rapidly, i.e.,   a high strain rate is present.

However, from a practical standpoint, cracking ves not considered likely to result from loading where a one-time (non-cyclic) gravity load is applied relatively slowly as would occur from the removal of chainfalls or come-alongs. To confirm this conclusion, criteria were established for the walkdowns which were intended to detect anocolies that might be indications of damage. These criteria were not intended to duplicate inspection criteria used during fabrication, installation or operation. Rather, they were intended to address from an engineering standpoint, the specific conditions associated with the NCR. Each nozzle was evaluated on these bases. With two ( exceptions involving cracked paint, there were no indications of overstressing or overloading (see Reference 9.46). The two exceptions were included in the analytical evaluation and were deter =ined to be acceptable, indicating that the observations of cracked paint were not indicative of damage to the nozzle. I During the walkdowns, the third-party also reviewed the configurations of the attached piping and determined that in =ost cases, the configurations would not be decr1= ental to l the associated equipment even assuming that { no supports were present. This cenclusion was based in part on the fact that =any of i che pipe regions cited in the NCR extend through wall penetrations which, if other support was lacking, would have acted as adequate temporary support points. Additionally, the general composition of equipment nozzle design allowables (piping-plus-equipment leads for ce=bined events of gravity, pressure, thermal expansion and earthquake) is typically

Fevisien:

Page 36 of 67 RESl'LTS REPORT ISAP V.e (Cont'd)-

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) higher than would be expected for the potential worst case loads on equipment described in M-2223 (pipe gravity load in excess of expected pipe gravity lead). To confirm this conclusion, the second aspect of the engineering evaluation involved ! performing si=plified stress analyses for { certain of the piping configurations l considered either representative of other I configurations or most likely to result in high pipe stresses and/or high nozzle loads. All of the cases resulted in pipe stresses below applicable limits. In some cases, nozzle loads were calculated to be above allevables, but on the basis of assumed boundary conditions, selected to conservatively represent the support configuration. For example, unless there were indications to the contrary, the pipe was adsumed 'to be unsupported and cantilevered directly off the equipment nozzle. However, even in these cases under these conditions, the amount of excess was not considered sufficient to have caused yielding in the equipment; this aise was considered to be substantiated in that there were no indications during the walkdevns of cracking or local deformations in or near any of these nozzles. The results of these analyses are also documented in Reference 9.46. 5.2.1.4 NCR M-2223 Investigation -- Results Based on the results of the investigation discussed in Sections 5.2.1.1 through 5.2.1.3 above, it is concluded by the third-party that the nonconfor=ing conditions of NCR M-2223 did not lead to any unacceptable conditions on equipment nozzles. Additionally, because of the lack of any indications of defor=ations or da= age to the numerous pieces of equip =ent addressed by [

j. Revigi:n: *

                                                                                             .Page 37 of 6' RESULTS REPORT ISAP \*.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

NCR M-2223, it is concluded that similar temporary supporting practices which might have occurred prior to issuance of M-2223 also would not have led to any other instances of equipment or pipe deformations or damage. 5.2.2 Interviews with Pipe Installation Personnel As a further aid (in addition to the NCR review) in determining whether there may have been other instances involving temporary supports with the potential for uncontrolled pipe springing, various individuals involved in pipe installation at CPSES vere interviewed (some of the interviews also addressed the main steam line lifts discussed in Section 5.1) (these interviews were conducted by RLCA, vich selected third-party ove rview; interview statements, signed by those interviewed, are documented in Reference 9.47). None of those interviewed could recall any other instances where te=porary supports may have been involved with the potential for uncontrolled pipe springing. An additional concern discussed during these interviews involved a question raised in the SSER (page N-100 of Reference 9.1) regarding the general understanding and use of the terms " springing" and " cold springing" at CPSES. The responses related to this concern are restated here: (1) The terms " springing" and " cold springing" are considered to be the same at CPSES. (2) Springing /ccid springing is the application of an external force to maintain align =ent for pipe fit-up. (3) There is no controlled springing / cold springing at CPSES. (4) Uncontrolled springing / cold springing is not allowed except to the extent that fit-up might be achieved by the force of one person pulling / pushing on a pipe (however, even this use of force is subject to QC inspectien).

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                 ,a Revision:    .

Page 38 ei e ! RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) (5) All fit-ups are checked by QC to assure that no external force is being used to maintain alignment except as noted in (4). This includes check of adjacent piping for wood cribbing, come-alongs, etc.. (6) Most fit-ups use a fit-up clamp. The clamp is incapable of transferring significant lateral loads. (7) If off-location, the most typical methods of achieving alignment are mitering and cutting / adding spool pieces (this occurs only with authorization from Engineering). In sum =ary, the above responses indicate some potential fer confusion regarding the specific definitions of the terms " springing" versus " cold springing". However, from a practical standpoint, this is of little , consequence to CPSES construction practices since "ccid springing" as defined in SSER-10 (referred to as

                                                       " controlled springing" by those interviewed), is not done at CPSES even though it is addressed in the Gibbs
                                                       & Hill piping installation specification (see Reference 9.48 and discussion in Section 7.1.1.2 of Reference 9.4).

A specific subject of one of the interviews (vich the , field mechanical engineering supervisor) related to the ' discussion on page N-101 of Reference 9.1 where note , was made of the possible inappropriate use of a portien ! of a Bechtel specification. The interviewee in this i case stated during the Rt.CA interview that if springing I were done at CPSES to achieve fit-up (in excess of that f noted in (4) above) ag if a need was identified to do ) this many times, it would result in a written i procedure. As an example of what such a procedure I might be, he showed (during the RLCA interview) a ? Bechtel procedure from another project with which he had been previously associated. He clarified that this 4 procedure was not authorized for use nor had it ever l been used, to his knowledge, at CPSES. He also knew of ; no other individuals at CPSES who had a copy of the ! procedure (see Reference 9.47, interview notes for l Keller). !

} Revisten: Page 2C cf 67 RESULTS REPORT ISAP V.e (Cont'd)

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.3 Evaluation of Residual Stresses There is the potential for some moderate springing that may occur during the installation process. The pipe stress analyses indicated that pipe stresses resulting from such springing are lov. However, a portion of these stresses will likely become residual stresses and review of the effects of'these stresses is warranted. To assess the significance of residual stresses adequately , it was considered appropriate to review the effects such stresses have on the potential failure =echanisms of piping. This review can then provide further input into assessing the potential for

                                      .detri= ental effects caused by pipe sprinFing during temporary supporting processes.

As discussed in Keference 9.4, piping can potentially 6 fail by one (or more) of the following =eans: (1) Bursting due to overpressure (ductile' failure) (2) Fatigue cracking (3) Stress-corrosion cracking (4) Brittle fracture (non-ductile failure) (5) Plastic collapse or other distortion-related mechanisms, (i.e., progressive distortien) (6) Creep (7) Stress rupture These are discussed further below. 5.2.3.1 Bursting Due to Overpressure , I In an overpressure failure, the stress in the i pipe is increased until it passes the yield l point and goes into the plastic range. As ) the stress continues to increase in the plastic range, defor:ation increases until a point of plastic instability is reached and s

4 Revision: Page I.0 cf 67 REST'LTS REPORT ISAP V.e ) (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) bursting occurs. k* hen the pipe passes into the plastic range, stress redistribution

                                                                             '   occurs and the residual stresses, which are caused by incompatible displacement, all vanish. Therefore residual stress has no effect on bursting strength.

5.2.3.2 Fatigue Cracking Fatigue cracking requires cyclic loading. The dominant cyclic loadings on the main steam line are the ther:a1 and pressure cycles. This line it designed according to the ASME Section III Code (Reference 9.3) which has allevable stresses that are reduced to allow for cyclic loading. Further, the reduced allevable stresses are themselves determined from tests (Reference 9.49) of as-welded piping which have locrted-in yield icvel residual stress. Fre: another point of view, the residual stresses caused bf small defer.ations (about 1 strain, which is greater than could have been imposed by the lift *) cause no significant metallurgical change. ~herefore, the net effect is to change the baseline er datum level about which the cyclic stresses oscillate. Fatigue is then caused by cne oscillatory stresses. Another consideration involves zean stress since residual stress can conservatively be i thought of as mean stress. It is possible f for =ean stress to have an effect on high j cyclic fatigue. The cutoff (in tar:s of { nu=ber of cycles) for where mean stress begins to have an effect on fatigue strength varies with the materials used but the least nu=ber of cycles for steels is about 1000 (Reference 9.50). Since the significant Maximu strain corresponding to the stress values of Table 3 are less than 0.1%. ; l 1

, .o Revision: ' Page 41 of 6 7 RESULTS REPORT , ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) l thermal and pressure cycles of the main steam lines number well below 1000, residual stress ' will have no effect on fatigue strength of the main steam piping. For the specific cases of the main stea: , lines (loops 1 and 4), the growth of weld ! defects or flaws was addressed by a ! re-examination of key welds. The results of the re-examination were that there were no weld defects or flaws (indications) that increased to a reportable size as a result of the erection process, the position adjustment lift, or the flushing and disconnecting operations. 5.2.3.3 Stress Corrosion Cracking Residual stress can contribute to stress corrosion when two other conditions are present: sufficiently high temperature and susceptible caterial/ environment co=bination. In the case of the main steam line, there is a sufficiently high operating temperature, but the other condition is absent. The main steam line material (SA-155 carbon steel) would be susceptible to stress corrosion enly in heavily caustic environments. The main steam line does not operate in a caustic environment. 5.2.3.4 Brittle Tracture i Residual stress can contribute to brittle (non-ductile) fracture, particularly if it is sufficiently widespread or well distributed. Although the temperature at which brittle fracture occurs varies, typical steel brittle f racture transition temperatures (at which the conditions for brittle fracture are present) range frem fifty degrees Farenheit to well below zero degrees Farenheit. Since the operating temperatures of the main steam piping are well above this range, brittle fracture is not a consideration. , 1 I i o

Revister: ' Page -2 of f" RESULTS REFORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.3.5 Plastic Collapse or Related Failures In any failure in which large ductile deformations are present as would occur during plastic collapse, residual stress is not a causative factor as discussed under Section 5.2.3.1. 5.2.3.6 Creep and Stress Rupture For main steam line design in fossil plants, creep leading to stress rupture are fundamental design considerations. However, in light-water-cooled nuclear plants, main steam temperatures are well below the creep rtnge (taximum operating temperatures are in the 600*F range; mini =um creep range temperatures are 700 to 800*F -- see Reference 9.51), and therefore, these factors are absent. Residual stress has little or no effect in any event. 5.2.3.7 Su==ary Residual stresses are not ordinarily detri: ental in P'a'R piping design. S tres se s induced by positten or fit-up adjustments are considered a nor=al part of the erection process. Based on the preceding caterial property considerations associated with the practical engineering applications of nuclear piping desiFn in general and the main steam line in particular, it is concluded that residual pipe stresses associated with the nor=al erection process will have ne adverse ' effects. 5.3 Precedure Evaluatien 5.3.1 Procedure Review A review of engineering, construction, QA/QC, and start-up procedures related to the use of te perary pipe supports was perfor:ed (see Section 7.0 ef Reference 9.1). Third party review of these procedures and Reference 9.4 is decu=ented in Peterence 9.37. As s

s

        .                              4-Pevisien:    .

Page 43 of.67 RESULTS REPORT ISAP V.e (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) a result of this review, some additional procedure revisions were identified as being desirable to strengthen existing practices regarding temporary supporting of pipe. Resulting revisions of procedures are addressed in Section 5.3.2. With regard to the NRC concerns about pipe springing, this was addressed in part during site interviews (see section 5.2.2), Site personnel who were interviewed generally used the terms " springing" and " cold springing" interchangeably to refer to uncontrolled springing. This was of concern to the NRC since these ter=s are used in Gibbs & Hill specification 2323-MS-100 (Reference 9.48) to refer to uncontrolled and controlled springing (respectively), and as such, the abcve understanding by site personnel might lead to inappropriate construction practices if controlled springing were used at CPSES. However, even thcugh 2323-MS-100 per=its cold springing in certain instances, interviewees noted that. there is no controlled springing at C7SES (refer to the footnote in Section 5.2.1 of this report ar.d the discussion in Section 7.1.1.2 of Reference 9.\). Thus, in practice, this application of the phrase (old springing" dees not affect construction practices. Other aspects of NRC concerns involve consistent procedure considerations of pipe springing. The NRC (en page N-100 of Reference 9.1) indicated that (1) cold springing was not addressed in all issues of construction procedure CP-CPM-6.9E (Ref erence 9.2) and QC instruction QI-QAP-II.1-26 (Reference 9.19); and (2) ; springing requirements were adequately addressed on'y ' in revisions beginning with Revision 1 of CP-CPM-6.9E and Revision 10 of QI-QAP-ll.1-26. Based on the preceding discussion on " springing" and " cold springing", these two concerns in practice can be considered the same. Review of CP-CPM-6.9E indicated that the sections which address springing in Revisien I were apparently inadvertently omitted from Revision 0 with Revision 0 only being in effect for about eso months in 1980. Prior to this, springing was addressed in CP-CPM-6.9 issued in October, 1979 (in 1980, CP-CPM-6.9 was "breken up" into several appendices of which CP-CPM-6.9E is ene). A detailed discussion of this is presented in Section 7.1.1.2 of Reference 9.4 h

.. .e Revist:ni ' Poge 44 cf A* i FESULTS REPORT

i ISAP V.e l (Cont'd) f 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) ! Review of QI-QAP-11.1-26 indicated that all revisions addressed springing prior to weld fit-up. Beginning with Revision 10, springing is also addressed for flange fit-up. Although it can be inferred that this might lead to inadequacies prior to Revision 10 related to flange fit-up, it should be noted that QC inspections are intended to verify that construction procedures are being satisfied. Therefore, even though the QC procedure did not specifically address cold spring with respect to flange fit-up, this was addressed in Revision 0 of the construction procedures CP-CPM-6.9 (see Section 7.1.1.2 of Reference 9.4). Adequate QC implementation in this regard is noted by review of the NCRs reviewed in Reference 9.4 Several of these NCRs specifically relate to flange fic-up. The earliest noted is M-2193 (Reference 9,52) which was. issued April 10, 1980, approximately two-and-a-half years prior to issuance of Revision 10 of QI-0AP-11.1-26 (issued February 2,1983). Several other flange fit-up NCRs (included in the tables of Reference 9.4) were issued prior to this date. 5.3.2 Procedure Revision All procedure revisions are documented in Reference 9.53 and su==arized in Table 6. Third-party efforts consisted of verification of stated revisions (in Reference 9.53), and it was concluded that revisions adequately addressed project intentiens (of 5.3.1) and TRT-required actions. Third-party review is documented in Reference 9.54, 5.4 Su==arv of Evaluations Based on interviews and document reviews, a sequence of events was established for the main steam line activities associated with this action plan. This sequence formed the basis for a series of stress analyses of the Unit 1, loops 1 and 4 main steam piping inside containment. These analyses provided an assessment of pipe stresses prior to, during, and after the lift activities, and subsequent flushing. In addition to these analyses, records of UT examinations and hydrotests were reviewed to determine whether any anomalies were apparent which might be associated with the sequence of events. Further investigation included re-exa=ination of =ain steam s _ _ _ _ _ _ _ a

i

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Page 43 of 6 !

l RESCLTS DEPORT

                                                  ! SAP V.e (Cent'd)                                                     J I

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) L pipe welds in regions of highest predicted stresses. The I results of these evaluations indicated that pipe stress levels I throughout the sequence were well within allowable limits and j that there were to indications of damage or detrimental effects. Thus no deviations or deficiencies were identified. The potential for other piping systems sustaining adverse effects during the temporary supporting process was investigated. This investigation primarily involved a review of all piping-related NCRs and interviews with site personnel. In addition, residual pipe stresses which might result from springing were generally reviewed and determined to have no adverse effects. ! The result of the investigation discussed above was the identification of a single NCR for which there were uncertainties regarding its disposition (DIR D-1839 was written to address this concern). Therefore, additional investigation was perfor=ed to evaluate the adequacy of the ; dispositten. This investigation consisted of = ore personnel j interviews, documentation review and an engineering ' evaluation. Procedures associated with the use of temporary supports were reviewed. Several changes were identified which would i strengthen these procedures. These changes as well as those ' identified by the TRT related to the welding of te=porary supports have been incorporated. No deviations fro: progra: commitments were identified. 5.5 Root cause and Generic Irv11 cations 1 1

The investigations performed under this action plan did not identify any deficiencies or adverse trends, thus an evaluation of root cause and generic i=p11 cations is net required by the CPRT Program Plan. The TRT, in its review of the installation of =ain steam pipes, hypothesized that the need to reposition the Loop 1 main stea= line af ter flushing was due to inadequate require =ents and construction practices for the support of tne ; main stem: line during flushing, and for temporary supperts I for piping and equipment in general. The CPRT review I deter =ined that the Project's method of handling the ain steam pipe repositioning and flushing was adequate; however. l

        .                              . a
            ;t Revisien:    ;

Page 46 of 67 RESULTS REPORT ISAP V.e i (Cont'd) i 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the opportunity existed to strengthen associated procedural requirements. Accordingly, the hypothesized root cause was partially substantiated. This has been addressed by DIR E-0347 which is classified as an observation, but transferred to the Quality of Construction (QOC) program for , trending (related external source DIRs E-0807 and E-1057 have also been basis classified of this report).as observations but closed out on the 1

6.0 CONCLUSION

S The sequence of events associated with the main steam line lifts was determined to differ in certain aspects from the sequence implied by the TRT. Existing documentation supplemented by interviews established a sequence described herein and evaluated. Main steam and feedvater piping stress' analyses, incorporating bounding parameters,' provide an adequate basis for concluding that there were no deleterious effects resulting from the sequence of events. Reviews of existing records of UT examinations and hydrotests, along with acceptable results of NDEs conducted for this review, provide additional support for this conclusion. It is noted that settlement of temporary supports, prior to filling with water for flushing, may have contributed to the off-location event; however this did not adversely affect the hardware. Review of existing specifications and procedures involving temporary support of pipes and interviews with site personnel indicated that springing to achieve fit-up was not permitted and that this was well understood. Review of NCRs confirmed that springing to achieve fit-up was not a ce==on practice. For the specific situation identified in Section 5.2.2 related to possible misapplication of a Bechtel procedure. it is concluded, based on the interview (Ref erence 9.47) that no such misapplication occurred. The NCR review did not identify other cases of settlement of temporary supports. However, several cases of possibly inadequate temporary supports of pipe attached to equipment were identified. All of these cases were associated vtth a single NCR that had been dispositioned with a cenclusion that the hardware was acceptable, b* hen the circumstances of issuance of this NCR vere reviewed, it was concluded that additional evaluation was required to address the potential for no::les being leaded in excess of allevables. An

9

                                                                                                       Pavisien:     .

1 Page 47 of 6 7 l RESULTS REPORT 4 ISAP V.e i (Cont'd)

6.0 CONCLUSION

S (Cont'd) investigation was performed involving personnel interviews, documentation review and an engineering evaluation. It was concluded that no damage occurred to the equipment identified in tha NCR nor was likely to have occurred for other equip =ent under similar circumstances. On the basis of this conclusion, the associated DIR D-1839 was reclassified as an observation. Because the DIR involved dispositioning of an NCR, the DIR was transferred to the QOC program for evaluation as part of their collective significance evaluation. Ccreain aspects of the specifications and procedures involving the fabrication and use of temporary supports were revised. This was done to strengthen existing practices and addressed in part the specific TRT concerns of Reference 9.1, pages N-38 and N-39, regarding welding of temporary supports. It is concluded that the procedural requirements related to fabrication and use of te=porary supports are adequate. 7.0 ONCOING ACTIVITIES The project has made a ce=mitment to revise procedure CP-CPM-6.9E to specifically require the use of "hard" te=porary supports in all instances (the procedure currently requires this only for pipes attached to equip =ent). The third-party concurs that such a change will strengthen existing practices. [All TRT required procedure revisions have been made.} 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE No actions are required. 9.0 ! RIPEPENCES 9.'. Safety Evaluation Repert related to the Operation of the Comanche Peak Steam Electric Station, Units 1 and 2 NUREC-0797, Supplement No. 10, April 1985. ("SSER-LO") l l 9.2 " Pipe Fabrication and Installation," Brewn & Root Procedure CP-CPM-6.9E. 9.3 ASMI Boiler and Pressure Vessel Code Section III, 1974 j Edition, Su==er '74 Addenda. I i i

Revisten: ' Page a8 of 67

                                                            'RESULTS REPORT ISAP V.e (Cont'd)'

9.0 REFERENCES

(Cont'd) 9.4 Robert L. Cloud Associates, " Installation of Main Steam ' Pipes. Item Number V.e,"~RLCA/P142/01-85/001, Revision 2. 9.5 " Unit i Main Steam Feedwater Flushing" G&H isometric:sketeh showing main steam loop 1, feedvater, auxiliary feedwater, and temporary piping (undated). (RLCA Reference P142-1-490-029). 9.6 Isometric drawing for MS loop 1 permanent pipe t BRP-MS-1-RB-002, Revision 13, July 10,1984 (RLCA Reference.

                                  'P142-1-433-031) 9.7      Isometric hanger drawing for MS loop 1 permanent pipe BRHL-MS-1-RB-002, Revision 3, July 26, 1983. (RLCA Reference P142-1-433-032) 9.8' Isometric sketch for MS loop 1 temporary flushing. pipe (undated) . (RLCA Reference P142-1-433-039) 9.9     Isometric sketch for MS loops 1 and 3 temporary flushing pipe dwg no. FSM-00165, Revision 1, August 21, 1979.                                                        (RLCA Reference F142-1-433-040) 9.10 Measuring and Testing Ecuipment Issue Record for MTE-357 dated January 16, 1982. (RLCA Reference P142-1-490-017) 9.'11 Dynamometer calibration report for 100,000 lb. dynamometer, ID # M&TE-357, August 12, 1981.

9.12 Dynamometer calibration report for 100,000 lb. dynamometer, ID # M&TE-357, February 10, 1982. 9.!3 Isometric sketches of Main Steam Line loop 1 shewing survey records for December 20, 1981. February 18, 1982, February 23, 1981 ("81" is apparently a typographical error, it should read "Feb rua ry 23, 1982"), April 20,_1982, August 4, 1982. (RLCA Reference P142-1-490-011) 9.14 Package of various interview notes between RLCA and Project personnel (January 23, 1985 to July 25, 1985). (RLCA Reference P142-1-242-006) 9.15 TUSI Me=o Co==ents to Keller re: MS loop 1 lifting secuence February 4, 1983, revised January 25, 1985. (RLCA Reference P142-1-293-016) { s

,~

Fevision: *

. ~

Page 49 of 67 i RESULTS REPORT ISAP V.e (Cont'd) )

.)

i

9.0 REFERENCES

(Cont'd) j t 9.16 " Engineering Release of L* nit 1 Main Steam & Feedwater Systems (3401 & 2802)". TUSI memo from Finneran to Schoen February 27, 1982). Attachment I to RLCA report (Reference 9.4). 9,17 Main Steam Line System Cleanliness Verification Sign-off (free Start-up Flush Plan 1901 Package). (RLCA Reference P142-1-440-130) 9.18 Hydrostatic Test Record for the Main Steam and Feedwater Systems (Secondary Side Hydro) Loop 1, 1-SEC-001; Loop 4, 1-SEC-004, July 8, 1982 (both). (RLCA Reference P142-1-440-133) 9.19 "ASME Piping & Welding Inspections," Brown & Root Instruction I Number QI-QAP-ll.1-26. 9.20 " Documentation for Third Party Review of ISAP V.e, Installation of Main Steam Pipes," memo Johnson to Honekamp, October 7, 1985. 9.21 RLCA letter dated August 12, 1986, from T. Ludington to P. Streeter re: RLCA QA. procedures and ANSYS verification. 9.22 Isemetric sketch for MS loop 4 temporary flushing pipe (undated). (RLCA Reference P142-1-433-030) 9.23 Isometric drawing for MS loop 4 permanent pipe BRP-MS-1-RB-001, Revision 8, October 4, 1983. (RLCA Reference P142-1-433-027) 9.24 Isemetric drawing for FW loop 4 permanent pipe 3RP-FW-1-RS-001, Revision 19, July 3,1984 (RLCA Reference

                                                                                      ?!42-1-433-021) 9.25 Isometric Hanger drawing for FW loop 4 permanent pipe SRHL-FW-1-RS-001, Revision 3, October 10, 1983. (RLCA Reference P142-1-433-022) 9.26 Partial plan of MS loop 4 temporary flushing pipe to auxiliary feedwater pipe (undated).      (RLCA Reference P142-1-433-02S) 9.27 Isemetric sketch of Main ' Steam Line loop 4 showing survey records before and after lift (only date shown is December 9, 1981).     (RLCA Reference P142-1-490-014)
                                                                                                                                    ~

s

9 a . f' Revisio.: Page 50 of 6" RESULTS REPORT ISAP V.e (Cont'd)

9.0 REFERENCES

(Cont'd) 9.28 Pre-service- Inspection Report. Westinghouse Electric Corporation. Report No. PMcM-1093, Revision O. (RLCA i Reference No. P142-1-490-008) ' 9.29 " Radiographic Examination," B&R Instruction OI-QAP-10.2-3, Revision 4 9.30 CPSES Nondestructive Examination Manual Instruction NDE-600, Revision 0, Ultrasonic Examination of Welds - ASME Section XI. 9.31 Weld Data Cards for Field Welds 6, 7, and 14 on Main Steam Line Loop 1. (RLCA Reference P142-1-490-028.) 9.32 Brown & Root Me=orandum from G. R. Purdy to distribution, No. IM #28,081 Dece=ber 21, 1984 (RLCA Reference P142-1-490-013) 9.33 Tenera Memo CPRT-286 frem J. B. Groncki to C. I. Browne " Third i Party Review of the Project Initiated NCR Review Process", 1 March 4, 1986. 9.34 " Supple = ental Information to letter #CPRT-286 dated March 4, 1986," memo, J. B. Groncki to C. I. Browne, March 6, 1986. 9.35 " Piping Nonconfor ances," =eco no. CPPA-51,836, Meehlman to Streeter .May 12,.1986. 9.36 " Piping Noncenfor=ances." memo no. CPPA-52780, Moehl an to Streeter, May 22, 1986. 9.37 TERA Me=orandum from P. Streeter to J. Miller regarding Documentation of third-party review of Reference 9.4, May'29, 1986. 9.3B Brown & Root QA Department NCR M-2223 Revision 4 9.39 "Mainsteam ISAP V.e," =emo no. CPPA-56351, Meehlman to Streeter, July 1, 1986. 9.40 " Evaluation of Equip ent Nozzles Associated with NCR M-2223", TUGC0 ce=o nu=ber CPPA-57003 from C. Meehican to P. Streeter. 9.41 " Evaluation of Equipment Nozzles Associated with NCR 2223", ; TUGC0 =e=o nu=ber NE-0612 frem C. Meehl:an to P. Streeter. '

5 Revist n: . Page 51 ef 5-RESL'LTS REPORT ISAP V.e (Cont'd) 9.0 PEPERENCES (Cont'd) 9.42 " Third Party Review of NCR M-2223 Equipment History as Presented in TUCCO Memos CPPA-57003 and NE-0612", Tenera Memorandum, P. Streeter to J. Miller, dated September 18, 1986. 9.43 Brown & Root QA DepartrJent NCR M-2896. 9.44 Brown & Root QA Department NCR M-42005, 9.45 Brown & Root QA Department NCR M-53745. 9.46 "CPRT Engineering Evaluation of Possible Overstressing of Equipment Nozzles, Nort:le k' elds, and Adjoining Piping during Piping Installation", Revision 0, dated October 2, 1986. 9.47 RLCA letter, C. I. Browne to P. Streeter, dated February 3, 1986. 9.48 " Piping Erection Specification," Gibbs & Hill Specification 2323-MS-100. 9.49 Markl. A. R. C., "Tatigue Tests of Piping Cc ponents " Transactions ASME, volume 74, 1952, 9.50 Langer, B. F., " Design of Pressure Vessels for Low-Cycle Fatigue," Journal of Basic Engineering, Volu:s 84, Septe:ber 1962. 9.51 " Class 1 Components in Elevated Temperature Service" ASMI Boiler and Pressure Vessel Section III Division 1 Cede Case No. N-47-21, dated December 11, 1981. 9.52 3revn & Root CA Depart':ent NCR M-2193. i I I 9.53 " Installation of the Main Steam Line," memo no. CPPA-46,66' Moehlmar j to Honeka:p, October 3,1985. j 1 9.54 Tenera Memorandu=, P. Streeter to J. Miller " Third-Party 1 Review of CPPA-46,662", April 25, 1986. 9.55 DCA 23327, Revisien 1, to Gibbs & Hill Specification ! 23:3-M.5-100, Revision 8. i

7

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                               . r.                                                                                                                                                          REstLTS RE:-dnt ISAP V.e                                                                                                      !

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                                                                               ..                    Figure I                                                                                                                     l if
 ,p                                                                          Main Steam Line Loop 1 'a'ith Cut in Temporary Piping 3

(Applies to Pre-Life, Disconnect and Lifting Phases) 3 SHIELD WALL NORTH 25 k ,,

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                                                                                                                                                                               . ; ,. . 24 CONTAINMENT                      CONNECTION                                                                                                    $

PENETRATION TO TEMPORARY a . FLUSHING Ll 8 22 e6 18 , LIFT POINT a 9 d l n5 37 g (CHA!NS l 3 J , I M . ,14 N,. l -- s t 10 Y l STEEL SAW >l2 HORSE X Z lI

      't MAIN 5 TEAM LibE                                                                                                            l LOOP 1
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s , (PERMAbENT P!PE) n, :

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                                    )                                                                                                                                          TEMPORARY FLUSHINC LibE l

5 SYMBOLS: 1 APPROXI/AATE TEMPORARY WT IN TEMPORARY l SUPPORT PCSITION FLUSHING LibE P!PE STRESS ANALYSIS

NOCE l

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_RESL*LTS REPORT ISAP V.e (Cont'd)

                                                                                                   ,,                      Figure 2 F.ain Steam Line Loop 4 With Cut in Temporary Pipe (Applies to Pre-Lifc and Lifting Phases)

NORTH Y CONtECTION TO TEMPORARY 24 ' FLUSHING SHIELD WALL LINE " ~ 23 l LIFT POINT 20 II 17 90

8. i MAIN STEAM Ll?E !!

LOOP 4 I l (PERMAPENT PIPE) ! 6 TEMPORARY SYvaCL5: i n APPROXIMATE TEMPORARY SLPPORT POSITION I DIPE STRESS ANALYSIS NOCE CUT IN TEMPORARY FLUSHING LINE { 2 2l CCNTA!NMENT PENETRATION m _ _ . _ _ _ _ . . _ _ _ ___ _ _ _ _ _ _ _ _ _ ___.

Revisier: ' Fage 55 ef 6-RESL't TS REPORT ISAP V e (Cont'd)

                                                           ,                        Figure 3

> Maximum Pipe Stress In Main Steam Line Loop 1 Versus Lift Force 18 - NOTE: MAXIMUM STRESS OCCURS AT NODE POINT (5) 16 - INDICATED IN PARENTHESES. (5 & 6) 14 - 3 12 - 5 (3) W G 10 - y (5 & 6) I (3)

                                          }2  8-(5 & 6)

R 1 6- (3) (5 & 6) (3) 3_ (12 & 14) l 1 (I (12&14)l 2- l 31,250 LB LIFT FCRCE I 0

                                                 ,       ,        ,       ,      ,       ,        ,                      ,        ,                  ,            i O                10             20            30                               40                           50 L1FT FCRCE (kips)

NOTE: MAXIMUM PIFE STRESS CALCLLATED IN ACCCRCANCE WITH EQUATION 3 CF NC-3632.1, SL35ECTICN NC, SECTICN 111, ASME SCtLER AND PRESSURE VESSEL CCCE

i Revisien: ; Poce 56 of 67 REST.'LTS REPORT ISAP V.e (Cont'd)

                            ,                     Figure 4 Vertical Position of Main Steam Line (Midpoint of Elbow Between Nodes 18 and 22)

Versus Lift Force Loop 1

                +0.0 -
                +6.0 -

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                +4.0 -

l 2 - P!PE LIFT OFF THE SUPPORT j AT THE SHIELD WALL g +2.0 - c G

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Face 37 ef 6-REST.*LTS RE? ORT ISAP 1*. e (Cont'd)

                                                                             ..                                    Figure 5 Main Steam Line Loop 1 'a'ich Temporary Piping Connected To Feedwater and Auxiliary Feedvater Piping (Applies To Flushing Phase)

NORTH SHIELD WALL

                                                                                                                                                         -h CONFECTION TO                22 TE MPOR ARY                                     TE MPORARY                                  /

FLUSHINC FLU $H1NC# ' LIFE 18 Life 9 17 o 3 MAIN STE AM Ll?E LOOP l I (PERMAfENT PIPE) - 1 CONTAINMENT PENETRATION g - 4 a Y

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5 5YMBOLS: h APPROXIMATE TEMPCRARY SUTORT PC51 TION o!PE STRESS ANALYSIS

                                                             ?     NOCE
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           .                                                                                                    Revisien:                    .'

Page 58 ef.57 RESULTS REPORT I ISAP V.e (Cont'd) i

                                                       ,                 Figure 6 k' eld Inspection Locations For Main Steam Line Loop 1 A

SHIELD WALL NORTH C'f

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22 5 E A v, 6o CENE:. A' 9c I8

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16 2** 3 o l4* 4 7 Y I I '13 X MAIN LIM LOCP1 STEAM / z PIPE STPESS CONTAINMENT PEMTRATION ANALYSIS NOCE (TYPICAL)

WELD LOCATIONS SELECTED FCR REINFECTION

                              .lNCLUCED IN PRE-SERVICE INSFECTION I

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Revisten:

7 Page 59 ef F RESULTS REPORT ISAP V.e -

(Cont'd) Tigure 7 Weld Inspection Locations For Main Steam Line Loop 4 A B 0* SHIELD WALL NCRTH ' 23 STEAM j CEM RATOR 20 fl g7 fi , o l5

                                     .ia'
                                                                                          .,14 12 MAIN STE AM /

LIM LOCP6 6+ PF. STPZ55 ANALYSIS NCCE (TYPICAL) Y $ 3 CONTAINMENT PENE.TRATION 2..

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                                                       .INCLUCED IN P815ERVICE INSPECilCN 1"f /"1 C C T                                                 i
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Revision:
Page 60 of 67 RESULTS REPORT I i

ISAP V.e (Cont'd) Table 1 Location in Section 5 of Action Item Resolutien

                                                        . Action Item                                   Subsection Location Main Steam and Feedwater Lines

1. Review procedures 5.3.1

2. Interview personnel 5.1.1

3. Evaluate procedures and practices 5.3.1 4 Analyses.of Unit 1, loop 1 Main Steam and Feedwater Lines 5.1

5. Establish significance of stresses and.1 cads 5.1.2

6. Review NDE results of Unit 1, loop 1 5.1.3

7. Reinspect line 5.1.4-Generic Study

8. Review procedures 5.3.1

9. Review NCRs and PDRFs 5.2.1

10. Interview pipe installatten personnel 5.2.2

11. Review sources of residual stresses 5.2.3

12. Evaluate significance of residual stresses 5.2.3'

13. Perform evaluation of specific piping ryr.tems 5.2.1 14 Modify specification and/or procedures 5.3.2 Other

15. Modify requirements and provide procedures for temporary supports, especially velding (from SSER10) 5.3.1, 5.3.2

e Revision: ! Page 61 of 67 RESULTS REPORT ISAP V.e (Cont'd) Table 2 Sequence of Events for Main Steam Line Lif t Note: Unless otherwise indicated by direct reference to loop 1 or loop 4, each sequence item applies to both loops.

1. Main steam (MS) line installed on temporary supports from containment penetration up to but not including final spool piece to steam generator MS connection.

2. Feedwater (FW) line installed on temporary supports from containment penetration up to but not including final spool piece to steam generator FW connection.

3. Temporary flushing line installed on temporary supports connecting free ends of permanent MS and FW pipes.

4 MS line noted to be off-location.

5. FW line (loop 1) noted to be off location; pipe mitered upstream to ensure that " free" end (at that time connected to lower part of flushing line) would be on-location for eventual connection with final spool piece.

6. Flushing line rigged prict to cut to insure adequate suppert of upper portion of flushing line during and immediately folleving cut.

7. y1ushing line cut on riser above connection to FW pipe, possible vib ra tions .

8. MS line and portion of flushing line (above cut) rigged for lift; loop 1 line lifted with polar crane.

C. Easily removable temporary supports (chainfall, nylon choker) adjusted and/or placed in position and attachment to polar crane released for loop 1.

10. Loop 4 line lifted with polar crane.

j

                                                                                                            \
             !!. Easily removable temporary supports adjusted and/or placed in                           j position and attachment to polar crane released for loop 4

12. More substantial temporary supports placed in position; j l

easily-removable temporary supports removed. I l _-------------_o L - - - - - - - - - - - - -

      . +
 . r. 44 Fevision:

Page 62 of 6 RESULTS REPORT ISAP V.e (Cont'd) Table 2 (Cont'd)

13. Short pipe section added to temporary flushing line to account for lift distance; flushing line reconnected including new, temporary connection to auxiliary feedvater piping (see Figure 5,. node 33 --

applies to loop !). 14 MS and - F*a*-lines filled and flushed.

15. Flushing lines removed.

16. Final sections of MS and FW lines installed and welded to the stea= generators.

17. Hydrostatic test of MS and FW lines.

18. Installation of per=anent supports for MS lines completed. No p e r=anen t supports were attached to the piping prior to this tit 1 I

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                                                                                                                                                                               .Revisien:

Page 64 of 67 RESUI.TS REPORT ISAP V.e (Cont'd) Table 4 NCR Review Sum =ary NCR Category Description Springing Specifically i= plied potential for springing during pipe installation. Misalign=ent Pipe installed off design location (springing not identified). Gradient Deviation Pipe installed outside gradient tolerances. Flange Misa11gn=ent Related to flange misalign=ent during installation or flange unbolting. Bent / Bowed Pipe Pipe damaged during erection. Pipe / Sleeve Pipe and/or sleeve installed Misalign=ent off location with respect to each other. Clearance Violation Pipe installed with clearances to other items belov =inimum requirements. Te=porary Supports Pipe inadequately supported by ta=porary supports. Pri=arily involves attachments to equipment.

3

R evis ie r. : ' Page 65 of 67

                    ,              RESL*LTS REPORT ISAP V.e (Cont'd)

Table 5 NCRs f or blich Nozzle Evaluation k'as Evident

M-2166 M-2192 M-2193 M-2210 M-2574 M-2965 M-12949 Descriptions of these NCRs are given in Table 8-2 of Reference 9.4 1

i 1 1 l l

o= ., . .+. Revision: Page 66 of 6~

                                                                                                                                              \
            .                                     RESL*LTS REPORT                                                                             l l

j ISAP V.e (Cont'd)- Table 6 { Procedure Review Resolutions

                                                                          .                                                                   1 Project-Identified or                       TUCCO Reference

TRT-Required Change Resolution 9.55 Piping.co be evaluated Specification 2323-MS-100 for proper support prior modified to clarify need for to water-fill. proper support prior to

                        .                                            flush or hydrotest.

9.2 Document the practice Procedure CP-CPM-6.9E (Rev. 8) related to location of Section 3.18.5 added; temporary supports. discusses temporary support location practices and use of ANSI B31.1 criteria. 9.2 Piping Department Pipe Procedure CP-CPM-6.9E (Rev. 8) Foreman to approve movement Section 3.18.9 added; or modification of temporary required Piping supports. Superintendent approval for removal of temporary supports. 9.2 Limit or prohibit use of Procedures CP-CPM-6.9E (next cables, woed cribbing, and Section 3.18 will be revision) other "less desirable" modified to require "hard temporary support practices. supports" as temporary supports for all piping. 9.2 Location of temporary supports Procedure CP-CPM-6.9E (Rev. S) not to interfere with permanent Section 3.18.5 added; systems. discusses temporary support location practices. 9.2 Qualified welder and weld Procedure CP-CPM-6.9E (Rev. 3) procedures required to attach Section 3.18.6 and 3.18.8 temporary support to permanent added; prohibits velding of structure. temporary support to component being supported and requires AWS Dl.1 compliance for veld and welder when attaching to permanent s t ruc ture . i'here cb.ange indicated. _--___._.__-______-_._.-____.__.__n__ _

e. '

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Revisien: .! Page 67 of 67 PESULTS REPORT ISAP V.e (Cont'd)_ Table 6 (Cont'd) Project-Identified or TUCCO Reference TRT-Recuired Change Resolution 9.2 Te=porary ("T" suffix) welder Procedure CP-CPM 6.9E, (Rev. 8) may be used for veld fabrication Section 3.18.7 added; of temporary supports. controls " temporary" welders ; snd requires an ASW i prequalified welding procedure. 9.2 Weld procedure and filler log Section 3.18.7 added to (Rev. 8) required for te=porary suppert CP-CPM-6.9E addresses and welds, pre-qualified welding 9.56 procedure. Existing revision of CP-CPM-6.93 addresses use of weld filler material log for temporary velds. 9.57 QC inspectien vill fdettify No resolutien required, te:perary supports as Existing revision of ;

                          " discrepancies requiring         QI-QAP-11.1-28 addresses QC                          ;

clearance" prior to final identification of j acceptance. nonconforming supports. ' i 1 1 d L 1

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