IR 05000412/1987032
| ML20216A958 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/18/1987 |
| From: | Anderson C, Durr J, Hoshy T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20216A938 | List: |
| References | |
| 50-412-87-32, NUDOCS 8706290017 | |
| Download: ML20216A958 (29) | |
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E , r U.S.S NUC' L EARi REGULATORI: COMMISSION
" , REGION I-y; ) Report No.. 87-32 -/ F . '
rcDocket No. ! 50-412; '
, < . License lN CPPR-105- ' Priority -1- ' Category -- .
, ,, l Licensee: Duquesne' Light Company:
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n? :. P. ' 0. Box 4 -
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zShippingport,'P'ennsylvania , 15077
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Facility Name: -Beaver Valley - 2' Inspection-At: :Shippingport,-Pennsylvania >
, II'nspection Conducted: April 6-15 and May 7-8, 198 , Inspectors: '
- i d /2 ff '
o _Thom'as KoslYy, Reactor Engineer date-
$ /7 f7l C. Jr Anderson, Chief Plant-Systems
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' Section, EB, DRS: ,
- 1 Approvedby: - M,$zzz . whM 4 -//r'p acquW P- Durr, Chief, Engineering Branch
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I Inspection Summary: A special inspection to follow up on allegations related: .] to cable wraps that are required'for electrical separation. This inspection 1
' involved witnessing field installation, reviewing;QC inspection records and'
'- formal'. interviews with QC. inspectors.
u : R_esults: One violation'and three unresolved items were identifie . .
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< -EXECUTIVE SUMMARY Rig' ion ~I'D'RS performed aLspecial, inspection to. eval'u ate several allegationsLats Beaver Valley Unit.2crelated to the3cableLwrap programsrequired for. achieving; :; electrical ~ separation. 'This: inspection covered several programmatic aspects of;s cable wrap: activities including craft training,Linsta11ation, drawing review,
- 'QC; training,' inspection procedures, material quality andiengineering-involvement.-
" Theallegationwasmade:byalicenseeemp1'oyeewhohadlintimateknowledgeoff cable wrap activities 'at: the site. . The . inspection:wasf conducted by. two region' based. inspector During' the inspection,' the inspector identified:the alleger an'd obtained addi : ' itionallinformationfregarding the allegations. . The NRCJreview:of sthef cableLwrap .
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program did not' reveal any major programmatic deficiencies. .However,1this inspectionLidentified 1' violation and three unresolved items:that deal /with '
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(various aspects 1of.this program. The. alleged deficiencies included use:o *
, un. qualified wrapping.. material,000 1.nspectionEreport-deficiencies, and1the use; Loffdefectivewarpmateria1c1Afollowup.totheorijinil1 April.6-15,11987; inspection;was conducted;on May-7, 8, 1987,'to~ resolve several:technica14 questions 1and assess.the adequacy ofLthe licensee's corrective action .
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' DETAILS , - . " 1.0;; Persons' Contacted-1.1 Duquesne Light Company.
c J *:T. P. Noonan,: Assistant Plant Manager u * C. E.' Ewing,-Manager QA-
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F " -*~J."A.'-Hultz,! Assistant to Senior Vice1 President, QCRP.'
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C ;* J..A'. Kline, Manager Construction'
-* J. J;.Carey, Senior.Vice President',-Nuclear
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* W. Laughlin, Senior Engineer J - * A.: N. Fasano, Investigator, .QCRP -
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d- ~ * R.E. Martin,- Manager Regulatory Affairs
* S._Fenner, Director' Quality Control P
* * C. S.'Majumdar,:' Assistant Director _ Quality Control
. R. Good, Engineer
,R.LLeipertz, As'istant'QC s Supervisor-u, ', L.' E.; Arch, Supervisor, Change Control :** M.JJ.-0'Neill, Manager, Engineerin _
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M. Hartman',1 Training' Coordinator
~ **:J. F. : Konkus, Senior, Engineer, . Engineering . ** R.t C..'.Wittsehen, Engineer, . Licensing ** L'.
R. Knapp, Engineer; Engineering
** J. P. Godleski,' TCT Enginee .
** G.' R. Wargo,. Assistant Director QC
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** D. L'.-Claridge',LEngineer Compliance
?**- L.1M. Rabenau, Lead' Engineer, -Compliance-n
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1.2 ? Stone-and Webster Engineering Corporation
* H.;F. Foley; Project. Manager-l - *
LR. C..Wittschen, Licensing' Enginee * G.cM. Byrnes,; Assistant Project. Manager
. * G. P. Eckert, Principal. Electrical, Engineer .
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P-. Bieni, Assistant Superintendent 1 J..Miloser, Lead QC inspector l
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R. Houlahan, Senior,QC Inspector .j
** P. J. Bieniek, Assistant Superintendent Engineer -
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.**'H. W. Durkin, Superintendent of Engineering I D. L. Post, Engineer,' Mechanical Engineering )
.- K. A. Petty, Engineer. Electrical ) D 1.3 Sargent Electric Company I i R. Donate 111, Assistant Superintendent R. Deirlin, Training Coordinator
..- R. Miehie, Training Coordinator
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W. Strope, Assistant Project Manager
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< U.S.' Nuclear' Regulatory Commission- ' '
i " -*'J! Beall,- Senior; Resident Inspector, Unit 2
'* W. M. Troskoski, Senior Resident Inspector; Unit 1 -** L J. Prividy, Resident Inspector Unit ^2: . ' ' Note: '* Denotes.thos'e present at April' 15, 1987, Exit Meetin . ** Denotes those'present only at May 5, 1987, Exit Meeting.
g, , , 2.0 Introduction-
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- 2.1'. Background s
! The_ Nuclear Regulatory Commission: received an anonymous _allegationLon:
. March 25, 1987, regarding construction. activities at' Beaver Valley Power StationiUnit 2l(BV-2). The alle'gation dealt with severa aspects of:.the. cable. wrap; program. Two region. based inspectors were .i f sent-to the site to follow up on the allegation'.
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'The preliminary. inspection was complete'd on'Aprilf 16, 1987. This-
. report documents the inspection findings resulting from the preliminary inspection;aa. follow up inspection conducted on May 7
'and 8,-1987, and a review of licensee documentation provided after thet inspection .2 Allegations
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The allegations made by the anonymous'BV-2 employee regarding the
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BV-2 cable wrap program are provided below:
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L: Defects in Plant Hardware or Programs
. Inspection procedure is revised.too-often with obvious mistakes'
in '.them. -Apparently author:of Inspection-Procedure-(IP) does-not:.know what-is going,on. IP references-drawings-for wrapp-' , ings. Drawings are constantly being changed too. Currently not2 _ using IP--they inspect to drawing '
, _QC use to'do inprocess inspection of wrapping. Now because i there is not enough QC inspectors they only inspect after the 1 job is don Electricians could do anything to cable whi_le QC
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is not presen ' The alleger indicated several instances of deficient QC
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inspection report i Not enough QC coverage. On March 25, 1987, there was 1 QC for
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13 wrap crews'and 1 QC fcr 9 wrap crew l
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. Backshift QC inspectors are less competent. If reject tags were researched they would find that wraps were done backshift and 1 the~QC~ inspector missed the defect initiall ' ' Wrap material..is'in question. Apparently, electricians get hold i j
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.of-some other type.of material that welders use~for. wrapping and covering and used itifo'r. cable wrap. QC inspectors were told to '
peel back. tape to check wrapping material.without a procedure or se any written instruction .
. Recent question on what to do.if wrap doesn't have adequate overlap ( QC inspectors were told to just patch over it -- later-it was discovered that it:is the' wrong. thing.to.do but now there ~
are.many wraps lwhich were already patched and no one is going' back to fix them. 'Also no written procedure for how to fi wraps in manholes with Unit-1 cables. The Unit I cables arei also-being wrapped but QC management won't let QC. inspector ~ hold the job until. Unit 1 gives (written) approval to work on the-equipment- per' procedur II. Tray Covers'
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. - j t When wrappers approach a tray cover they remove it without
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* procedure lor approval'or.really knowing what they're doin .j When" covers are removed no accountability to ensure that it is put back and done correctl III. General Electricians are not trained in wrapping or coverin Electricians are so use to doing sloppy jobs that everyone thinks.it is correct now, ' Craft SQC are being pressured too much to just get it done, no l matter what the qualit . IV. Quality' Control Inspector / Management
. QC inspectors are raising concerns to their management but are told that.it is not their concern and to ignore i " QC inspectors have gone to Quality Concerns to report problems but have been intimidated by their management when management finds out that someone went to QC When QC inspectors have questions the answers are inadequat {
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..' ' ;0C inspectors are:sent to perform tasks-without'a; procedure: ;Such as checking material in wraps (See. item I.g).-
y QC inspectors are afraid to talkto NRC or- tell- problem ' ' During,the course!of the; inspection,_the. inspector-identifiedithe alleger, and was able to -get clarifications: to the, allegation The allegation clarifications were factored into the: inspector d review of_the allegation ' 2.3 : Scope- o 1The:various aspects oflthe cable wrap program were reviewed consider-- L 'ing.the above-allegations. The inspection reviewed the; adequacy of-.
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'the cable wrap-drawings and instructions for insta11ation; training 1 for' craft'and.QC personnel; QC~ inspection' procedures and hold points; l and'the.timelineti, adequacy and' documentation of the licensee's ( : resolutions 'to field problem u a . . ; - 2.4 Cable Wrap Program i h ~ Cable wraps.are used in.many'. areas of the_ plant to maintai independenc'eiof the safety related electrical circuits. The licensee : committed initheir FSAR to meet the requirements,of Regulatory Guide '1.75 Rev.12 Physical _ Independence:of Electrical Systems. This .
regulatory guide endorses Institute of Electrical and Electronic = , Engineers (IEEE) Standard 384', dated 1974. .This. standard' delineate acceptable methods for achieving separation through.the use of -)
. covered trays and conduits. -Whenever the spatial distances suggested j L ' by this standard cannot be maintained, alternate methods are to be -i use J ~ l The use ofLS11 temp is.an alternate method that allows reduced spatial 3 . distances. Siltemp is a thermal insulating material which is used to )
" contain the heat' generated from'a faulted cable in. order to-prevent 1 the . faulted cable: from degrading.the' cables' of other. channels. The:
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i use_of Siltemp wrap allows the following reduced spatial distance !
. Separation between:
Wrapped cable to cable - 1" minimu Wrapped cable to conduit - 0" minimu q Wrapped' cable to cable tray - 1" minimu Wrapped cable to wrapped cable - 0" minimu Wrapped cable to covered cable tray - 0" minimu The licensee tested the Siltemp wrap in a specific configuration to 1 confirm that the desired level of thermal insulation was achieve The configuration of the wrap is important to assure that the required cable insulation is provide , l
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L , i The wrap process.is done in two stages. First a Siltemp WT-65 tape i
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adhesive glass tape, #69 by 3M Company is wrapped over the Siltemp tape with a minimum one half lapped layer. ..S11 temp blanket 188 CH i
=can be used instead of the WT-65 tape. The wrapping' details for j
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various configurations'are included in three full size drawings SEC0 1.2.3.4.-A40, A50 and A52. Quality Control (QC) inspections are performed at suitable _ hold points to assure compliance with the above l drawing j l 3.0 Allegation Review This section includes a review and discussion of each of the allegation Each of the allegations is repeated. This is followed by the inspector! review'and conclusions'regarding the specific allegatio .1 . Allegation (Ia) 1 Allegation Inspection. procedure is revised too often with obvious mistakes in - I them. Apparently author of Inspection. Procedure (IP) does not know what is going on. 'IP references. drawings for wrappings. Drawings are constantly being' changed too. Currently.not using IP--they inspect to drawing i Details The inspection procedure 12.1 " Inspection of protective wrap" has undergone 26 revisions since its first issue on March 3, .1986. The r'evision numbers and effective dates are listed in Attachment A. The inspector reviewed each of the 26 revisions to this procedur During the' initial part of the. cable wrap program, a full time QC inprocess inspection was performed. It was later changed to QC inspections at specified hold points. This is discussed under , allegation Ib_, See Section 3.2. The inspection attributes.for the Area Release and Color Separation section were removed from the scope of this procedure and were placed in an independent procedure, since I these activities are different from the cable wrap activities. The inspector did not find any evidence of obvious technical mistakes in any of the 26 revisions to the inspection procedure. The procedure revisions consisted primarily of procedure enhancements to simplify
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and clarify the inspection attributes. The NRC inspector did not find a basis to support the allegation that the author of the _
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inspection procedure did not know what was going o ' In Revision 22 of the inspection procedure, the licensee added cable wrap installation drawing details to the inspection procedure. These ' details were removed in the next revision to the procedure. However, the. licensee retained the drawings for reference. The drawing numbers and the revisions are listed in Attachment C. In the
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i beginning of the program, one. drawing, SECO-1.2.3.4.A40, was used to provide installation cetails for the cable wrap. Later, Drawing A50 and A52 were added to provide supplemental information for different l cable wrap configurations. Examples of cable configurations covered i by these additional cable wrap drawings are cables splitting into ; buridles, cables entering conduit, and cables entering wall sleeve Drawings A40, A50 and A52 were revised regularly to provide addi- ! tional wrap details and to clarify the instructions. The inspector i did not find deficiencies in any of the drawings or procedures that would have resulted in an unacceptable cable wra i The QC inspection of the cable wraps are performed using a form j attached to inspection procedure 12.1. This form has undergone a i number of revisions. However, the form and QC sign off requirements ! remained in the inspection progrem throughout the 26 revisions to the
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inspection procedure. The NRC inspector determined that the quality ; requirements of'the wrap, the overlap of the Siltemp tape, the use of i glass tape and the glass tape overlap were adequately addressed in j each of the revisions to the procedure and in each of the revisions to the installation drawings. The installation drawings contain all of the necessary inspection attributes and an extensive number of l specific details to provide adequate control for special cable wrap j configurations. The inspector did not find any evidence to support ; the allegation that at some point when cable wraps were being { installed there was not an inspection procedure or that the inspec- l tion procedure was not use The NRC inspector determined that if the QC inspector satisfies the attributes in the inspection report f using the installation drawings, the. quality of the wrap should be i assured. The QC inspector is required to use the drawings to verify the method of wrapping for specific configurations. The inspector reviewed selected inspection reports to confirm that all of the
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i inspections attributes were satisfied. A list of these reports is provided in Attachment The inspector observed cable wraps in a number of plant area No deficiencies were identifie ! l
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Conclusion l The statement that the drawings and the inspection procedures were frequently revised is tru However, no deficiencies were identified i in any of the procedures or drawings that would have resulted in un- ' acceptable cable wraps. Increased reliance on drawings for '. inspection of sne wraps does not negatively influence the inspection attribute The QC inspectors were required to use the drawings to verify special cable wrap configurations. A combination of the inspection procedure and the drawings retained all the necessary quality requirements to assure the correct installation of the cable 1 wrap. As discussed above some elements of the allegations were supported. However, the quality of the cable wrap was not compromise : L
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3.2 Allegation (Ib) Allegation QC use to do inprocess inspection of wrapping. Now because.there is not enough QC inspectors they only. inspect after the job is don Electricians could do anything to cable while QC is not presen : Details The licensee provided complete QC inprocess inspection of cable wrapping from the beginning of the program until October 2, 198 ! The licensee determining that-full QC coverage of cable wrap activi-ties was not necessary to assure the quality of the cable wra Therefore, starting with revision 16.of the inspection procedure, the licensee changed from inprocess full QC coverage of wrap activities to hold points. This allowed a single'QC inspector to cover the- i activities of several cable wrapping crew ' The inspection attributes included.in the inspection procedure are overlap of the Siltemp tape material, tightness of the wrap, adequate l length of the wrap for separation, use of the correct material and i installation in accordance with the drawing details. The lic'ensee ! determined that these attributes could be inspected without continuous QC coverage. The inspector did not identify any problem associated with the licensee action to use hold point Recently, the licensee documente'd four cases of cable wraps performed without observing the first hold point of inspecting the cable for ! damag The inspector reviewed the disposition of these document No deficiencies were identifie j The allegation that the electrician could do anything to the cables was not supported. The alleger did not provide any examples of degraded cable wrap or degraded cables which went undetected by the licensee. The NRC inspector reviewed the qualifications of nine cable i wrap crews. Each crew contained three or more qualified journeymen electricians. The average experience of the electricians was more
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than 5 years of Nuclear Construction. The knowledge and experience gained in 5 years of Nuclear Construction activities is adequate for an electrician to recognize the importance of following procedure Conclusion It is true that full QC witnessing of cable wrap activities is not i performe The licensee program to inspect cable wraps at hold j points is an acceptable approach for assuring cable wrap qualit j The NRC did not find any bases to support the allegation that there j were not enough QC inspectors to cover cable wrap activities. In , addition, the NRC inspector found no bases to support the allegation ' i I
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that cables would be damaged or cable wrap improperly installed'as~a [ result.of a lack of knowledge by the electricians' performing the: ; cable wrap ! 3.31 Allegation (Ic) Allegation'
' ,The alleger. indicated'several instances'of. deficient inspection :l; . report !
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Detail The NRC. inspector determined.that.the issue of the potehtially deficient' inspection reports involved ten-inspection reports that had
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been 'previously-referred to the licensee's Quality Concerns-Resolution.(QCR) program by.an anonymous allegation for resolutio The NRC inspector-reviewed the QCR resolution file'for this issue, i The licensee's resolution of this issue indicated that the: QC-inspections ~ associated with the subject inspection reports wer .! , : acceptable. Accordingly,.the subject-cable wraps were not reinspecte : ' by the license Subsequently the NRC. requested the licensee to reexamine the cable-wrap.. installations associated with the potentially-deficient
inspection' reports. The licensee responded to the<NRC request by performing a visual examination of the. installed wrap at each of the locations. The licensee did not identify-any deficiencies'in the
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subject cable wrap installations. Based on these reviews,.the '
. licensee concluded that the quality'of the subject cable wrap installations was substantiated. The NRC inspectors had no further i questions regarding the quality of the subject cable wrap-activitie ' .During the inspection, the issue of deficient cable wrap installations associated with.the potentially deficient. inspection reports was ' identified as an unresolved item 50-412/87-31-01, See Section Conclusion i
The NRC inspector determined that the cable wrap installations that i were associated with ten potentially deficient QC inspection reports g were acceptable. This was a result of the licensee reexamination of the' subject cable wraps. No deficiencies were' identifie l 3.4 . Allegation (Id) Allegation Not enough QC coverage. On March 25, 1987, there was 1 QC for 13 wrap crews and 1 QC for 9 wrap crew t i
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fd Detail's - p " ! The NRC inspector attempted to review QC coverage of cable. wrap-activities by, cable. wrap crews for. March 25,>1987'. -However, the
. ; licensee had.no records that would' allow the'NRC inspector to deter- 'l mine the number of cable wrap crews covered by a-QC inspector lduring 'a given-' shift. Discussions with'QC inspectors'. indicated an-average of 6,to'8 crews per QC inspecto . '
f!< The NRC inspectors discussed the issue of work load with 16 QC cable 1 [; wrap inspectors. The QC. inspectors confirmed that a high work load
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'the inspection. procedures. The, licensee program.to inspect cablec . "
wrap; installation at hold points had been in effect since October 2'- , l1986, (See Section 3.2). The inspector determined.that the-licensee's-practice of utilizing ~ hold' points might. slow down.the installation of cable wraps, since work could not proceed until the hold.' point wa ~o bserved._ However, the quality of the wrap activities should not be-affecte . The NRC : inspector witnessed : cable wrap activities performed on three - shifts _on'the 6th and 9th of April'1987. The NRC inspector confirmed ~ that-the' hold points were observed. The inspector reviewed cable'
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wrap installations at various areas.in the, plant. No deficiencies j were observe i i
. Concl u s'i on i i
The NRC inspector found no basis to support the allegation that there was inadequate QC coverage by cable wrap crews.. The licensee's approach to inspect cable wraps at hold points is ade'quate to assure ' the quality of the wrap. The practice of one QC inspector covering the activities of a number of cable wrap crews could affect the time-to install the wraps. -However, it should not affect the quality of . the installation, j
3.5 Allegation (Ie) 1 i
Allegation l
'l Backshift QC inspectors are less competent. If reject tags were j researched they would find that wraps were done backshift and the QC "
l inspector missed the defect. initiall Details The alleger concluded that the backshift QC inspectors are less competent because of the higher number of rejects in the backshift The NRC inspector reviewed the record of rejects and concluded that this observation of the high number of rejects during the backshift is correct. The NRC inspector checked the licensee records for'the
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, wrap installations performed during the month of March 1987. The NRC inspector determined that the backshift had performed 50 percent more cable wraps than the day shift. Thus, the rejects were proportion- ; ally higher. However, the percentage of rejects was not higher than i the overall 6 percent reject rat The inspector determined that the licensee has a program to verify
' cable wraps before completion of the construction activity. .This i verification program is to be performed under inspection procedure i 12.3 " Area Release Electrical Inspection". This program will provide additional assurance of the quality of the cable wrap !
Conclusion
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It was concluded that the number of cable wrap rejects associated with backshift cable wrap activity was higher tien the number of rejects in-the day shif However, no evidence was found that this 1 was a result of the backshift QC inspectors being less competent than day shift QC inspectors. Rather, the backshift performed 50 percent l more cable wraps and the rejects were correspondingly highe ; 3.6 Allegation (if) Allegation Wrap material is in question. Apparently, electricians get hold of some other type of material that welders use for wispping and , covering and use it for cable wrap. QC inspectors a re told to peel back tape to check wrapping material without a proceCure or any written instruction : Details The other material referred to here is Siltemp 84-CH. T iis material was used in general plant areas to shield cables and otter installa-tions from welding sparks. This material was not qualified for cable ! separation applications. The qualified blanket matvial for cable wrap, Siltemp 188-CH has a similar appearance ;.o 84-C This similarity in appearance resu,: H in th; improper use of this blanket !
-material at several plant location The licensee identified this '
proble They documented 4 such misapplications in Nonconformance and Disposition (N&D) report No. 39178. NRC inspector discussions with licensee QC inspectors indicate that these four cases were from a sample of nine inspected. The use of-this blanket material is very . limited. Preliminary discussions with the licensee indicated that ! this misapplication could potentially affect approximately 10_0 cable ' wraps. The licensee's preliminary disposition of this N&D indicated i that the 84-CH wraps would be reworked with the qualified Siltemp : 188-CH. Later, on April 20, 1987, the licensee indicated they were " considering qualifying the Siltemp 84-CH material . i p I
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'The. absence of a procedure and documentation to inspect the cable wrap for the.' improper 84-CH blanket did'not present a problem since,.
the cable wrap was. restored to the initial condition. utilizing the
'c: ' original installation procedure in the presence of a cable wrap -
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, Conciusion '
l ' The' installation of the unqualified 84-CH Siltemp material'wa identified as an unresolved item.50-412/87-32-02 pendin'g the-
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licensee's ~ corrective action to' qualify the. material or develop a program to. identify..other. locations where.the unqualified wrap.is 'I installed-and replace the wrap'with.a qualified wrap. This issue was q closed, see section 4.2.of this repor ' Th'e lack of a' procedure to check-for the' improper 84-CH cable wrap . , 9 material is not a problem since, the wraps were restored to their
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; initial condition utilizing the. original installation procedure in j
[j the presence'of a cable wrap trained QC inspecto .a
' Allegation (Ig)
l Allegation-f Recent question on what to do. if wrap -doesn't have adequate
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1: . ov.e rl ap . QC_ inspectors were told to just patch over it -- later i it was discovered that it is the wrong thing to do but, now I l there are many wraps which were already patched and- no one is.
? going back to fix the . No written procedure for how to fix wraps in manholes with Unit , I cables. The Unit I cables are also being wrapped but QC- j management won't let.QC inspectors hold the job until Unit 1 gives (written) approval to work on the equipment- per procedur ,
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Details The present procedure for cable wrap installation does not allow patching of the siltemp material for insufficient overlap ~or gaps in the wrap. If previously performed patching remains uncorrected, the only possible effect is an increased wrap thickness. This would result in increased protection for adjacent cable However, the increased thickness of the wrap j material can influence the ampacity and heat buildup of the
- . wrapped-cables. An increased thickness of wrap is found at multiple cable bundles and cable bundle branch out sections.
l !; The NRC inspector determined that the licensee procedure 1 does not impose a limit on the maximum Siltemp tape wrap thickness during cable wrap installatio i
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! .The manholes contain BV Units 1 and 2 cables. The inspector observed.the work done in manhole 6B. The licensee nonconfor-mance and' disposition reports 15890A and 15893A state that Unit 1.and 2' cables will be wrapped for color separation. Any unit 1 .
cable on a shared raceway will be treated as an electrical l separation. problem. All the cables in that tray will be ! wrapped. The inspector concluded that this is an acceptable i approach to assure electrical separation between channels and between units. The Duquesne Light Company BV-1 Nuclear Group
' Memorandum NOINEM: 0137 dated May 20, 1985, approves'the use of : BV-2 cable wraps on BV-1. cables. .The memo requests BV-1 QC to j be notified before wrapping BV-1 cables. The engineering i approval for wrapping BV-1 cables and using the BV-2 cable wrap ! procedure with QC coverage is an acceptable approac !
.' Conclusion j
{'"t ) The NRC inspector concluded that patching of the Siltemp j
j wrap can influence the ampacity and heat buildup of the
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l cables. See item 50-412/87-32-03 (Section 4.3). ! BV-1 Engineering approved the use of BV-2 cable wraps and the .i BV-2 cable wrap procedure for wrapping BV-1 cables in manholes ! containing BV-2 cables. The NRC inspector determined that this ' is an acceptable approach-to assure electrical separation I between channels and unit .8 Allegation (iia,b) Allegation .. l Tray covers When wrappers approach a tray cover they remove it without ! procedure or approval or really knowing what they're doin ' When covers are removed no accountability to ensure that it is ; put back and done correctl Details
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Cable wrap crews are. required to remove cable tray covers as needed , to perform cable wraps. The licensee's' Field Construction Procedure 41.1 Sargent Electric Rework Control Program provides specific instructions to document all required rework resulting from construc-tion activitie Tray removal and firestop degradation are examples ; of such activities. These are to be documented in a " Rework notifi- l cation form". This form is tracked to assure completion of the rewor l QC sign off is required to close out the rework documents. Adherence ' to this procedure provides accountability for tray cover remova !
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In order to account for potential deviations from the above proce- 2 dure,-the licensee has a program to perform a final walkdown of the cables using the IP-12.3 Area Release-Electrical Inspection Proce- , dure. This procedure provides for an inspection for electrical i separation, damage, length of cable in free air, placement.of cable j tray covers and non permanent attachments. This program is designed ! to identify any oversight that may occu l Conclusion
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The allegation that examples were noted of tray cover removal not j being properly tracked may be valid. No spcific instances were cited i by the alleger and none were identified by.the NRC inspecto _ However, the allegation that the licensee did not have a procedure l for. tray cover removal and accountability is not vali The licensee ' does have a procedure in place for all rework required and a program to reinspect each area for compliance to separation requirement .9 Allegation (III.a,b) Allegation ) General . i Electricians are not trained in wrapping or covering.
j- Electricians are so use to doing sloppy jobs that every , l one thinks it is correct now.
! Details The Sargent Electric Company management ensures that every cable L wrap crew has at least one cable wrap trained electrician. The inspector was unable to identify any instances to the contrar The electricians receive formal classroom training in the process , of cable wrapping. This training is documented in training records.
l Another cable wrap training method is on-the-job training offered i by.the foreman. On the job training is followed by classroom training in the next available scheduled clas The inspector verified the training records of 46 electricians that performed cable wrap during April 5 and 6, 1987. No deficiencies were ,. identified, l-NRC inspector discussions with the QC inspectors indicated inadequate craft training in second and third shifts. The NRC inspector reviewed the licensee's trend analysis to evaluate , this allegation. The licensee's program on trend analysis dated February 2, 1987, states that "Due to high number of unsats occurring on second and third shift additional training may be required of the personnel who are installing the protective wra Inspection backlogs have arisen due to the high number of a- _. ._ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ -
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4 m l16 E unsats bsing: encountered". WNilethe. licensee'strendanalysis initially indicated a deficiency in.backshift training o personnel installing the wrap. .It later was concluded by the licensee'that the increased unsats during backshift reflect 1the-proportional.ly higher' number of wraps insta11ed'backshift, see
. .Section 3.5b b; The NRC. inspector inspected completed cable wraps and.in process cable wrap activities at-various plant' areas. No deficiencies-were identifie ' '
The NRC inspector found no bases to support the allegation of-slop'py ' jobs. If the electricians work was unacceptably-' sloppy.,- the.QC inspector would. reject the work. 'Furthermore, the licensee's program to. reinspect all areas should. identify'any-deficient. wraps. .The -licensee records indicate a. six percent
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reject of cable wrap y
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Conclusion' The allegation that the-electricians are not trained in wrapping-or covering was not supporte There was nofevidence of slopoy wrap jobs serious enough to q influence the function of the cable wrap, 1
.:3'10' Allegation (IIIc) .
' Allegation Craft SQC'are being pressured t.oo much to just get it done, no matter what the qualit ~
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Details I
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. The-NRC inspectors interviewed 16 QC inspectors, all the inspectors '{
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confirmed'that the work load did not impair the.' quality of the wra .
-Further discussion of'this issue is covered under allegation Id Section l Licensee's-QC inspectors documented 4 cases of cable wraps that were (
performed without the initial hold point. This hold point involves { assuring that the cables are free from damage. The licensee ] disposition of'this inspection deficiency was to rework these wrap i Conclusion j i This allegation is unsupported. The QC inspectors were able to j perform the inspections required by the inspection procedure. This I was evidenced by the amount of rejected work and the 4 documented l cases of missing hold point d
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g" 3.11 A11egation'(IVa)_ Allegation
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Quality Control / Inspector Management-QC inspectors.are' raising concerns.to-their management but'are told; that'it is not:their concern and to ignore i , NRC Understanding of'the^Allegati_o_n ,
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During the inspection the -a11eger provided one example' to. clarif , H .the above. statemen The alleger stated that the QC inspectors.were.-
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told not to' concern.themselves with.the. quality of the Siltemp tape'. ,
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Details y The_Siltemp tape quality concern in question. deals with observed-
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shredding:of Siltemp. tape. The licensee has a' procedure for communication,of potential problems to management and other technical ljl D *.
. ' departments. This is done- through a> " Request for Information" .(RFI). . '
The.NRC inspector. determined that the RFI 3340-QC regarding tap d shredding provided-sufficient' guidance ~to establish the acceptability' i of the Siltemp tape. In addition,1the NRC inspector reviewed all of~ Ll the RFIs related to cable wrapping activities. '. In- each case, the l licensee's response was prompt and technically adequat The NRC inspector discussions with the QC inspectors: indicated that-l' some QC inspectors had-identified several concerns that were not: addressed in writing. While the QC. inspectors concerns may have been raised orally. There was'no indication that the: QC inspector docu-
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! n mented their questions in RFI Conclusion The licensee has an RFI program to address technical concerns. It-was determined that, for the examples reviewed, the program provides a prompt and technically adequate method of resolving. technical issues. However, the QC inspectors 'did not always make appropriate use of the RFI progra The NRC inspector identified a potential problem with.the tape installation. It is possible that shredded tape can influence the ! quality of the cable wrap. This is discussed further in the ' unresolved item on cable wrap program controls 50-412/87-32-04 Section i i
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3.12 AllegationL(IVb); ll
' -Allegation +. ;QC? inspectors have gone to Quality, Concerns.to report problems (but ..ha've'been intimidated by their management when management?Vinds out ,
y 1that.someone'wentEto QCP. _
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The Quality. Concerns: Resolution. Program (QCP/QCRP) is a licensee y program.to address employee 1 concerns. .During the NRC inspector's; j interviews with 16.QC inspectors,'a number of: the QC: inspectors 'a interviewed' indicated that they would be reluctant to bring technisa concerns to QC Some'.statsd.that.QCP should only'be contacted i avery significant' safety concerns are identified. . Several-QC inspec-
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- tors: indicated- that they. were. not satisfied 'with QCP disposition of
.'some issues ~. However, no specific deficiencies were.. identified by ' '
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, the.QC insp'ectorssrsgarding;QCP handling of issue '
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Conclusion Thefallegationf of' management . intimidation' for approaching .QCP was not ., supporte '
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3.13 Allegation'(ivc)
-l Allegation: i : When-QC. inspectors have questions the answers are inadequat , '
- ' Details-The. licensee's method for formal' communication of technical concerns =j is through a Request For-Information. The NRC inspector' reviewed all- 1
'of the RFIs related'to the cable wrap program %1d'.found them to be j . technically adequate and timely. 'A < list of th e : cable wrap RFIs : reviewed is included in Attachment C. (Reference Section 3.11, ! . paragraph IVa)
t Conclusion
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The allegation that the licensee provided' inadequate answers for.-
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technical . questions was not substantiate j
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13.14 Allegation (IVd) Allegation QC inspectors are sent to perform tasks without a procedure: Such as checking material in wrap Deta il s Ths a11eger provided one example of QC work'that was performed with-rbt a procedure. As discussed in Section 3.6, the NRC inspector determined that for this situation, there was no problem. The lack of a procedure to check for icproper cable wrap was justified since ; the wraps.were restored to their initial condition in the' presence of ! a cable wrap trained QC inspecto Conclusion The absence of- a procedure to inspect for a defective cable wrap does not pose a problem, as the wraps were restored to their initial condition in the presence of a cable wrap. trained QC inspecto .15 Allegation (IVe)' Allegation QC inspectors are afraid to. talk to NRC or tell problem . Details
.During the courso.of this inspection, the NRC inspectors conducted fermal and Informal interviews with 16 QC inspectors and nine cable
. wrap crews. These individuals espressed an interest in discussing l Jetails of the cable wrap activitie The QC inspectors were candid j in' responding to NRC questions lun cable wrap quality. All but one of the people interviewed stated that there vere no significant concerns in the cable wrap program. The allegation that QC inspectors are 4 afraid to talk to NRC was not supported. One concern that was dis-cussed by several QC inspectors related to the potential misappli-cation of' unqualified 84-CH Siltemp blanket. This issue was j discussed in Section'3.6. Several licensee person 1ei believed that i this item was not being tracked to assure resolution. Another con::ern that was discossed by one individual was wrapping the BV-1 cable using BV-2 procedures. This issue is discussed in Section ThesNRC inspector observed that the cabla wrap concerns identified by licrasee personnel were being addressed' by the licensee. I
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', The. statement that QC inspectors are afraid to talk to NRC or tell problems'was~not' supported. The QC inspectors' talked freely to the NRC inspectors'on technical issues. However, these' issues were lalready addressed by the licensee's program.
vn ' 4.0' Findings-The findings' listed below were identified by the-NRC inspectors to'the' licensee during the April 15,.1987 exit meeting. . The ' subsequent follow up
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r and review ?f. licensee supplied information has resulted in the resolution of severi sf the issue '
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4.1l .(Closed): Unresolved Item 50k412/87-32-01 Deficient Inspection Report f
(Ref: Allegation Ic Section 3.3)
Potential deficiencies existed in selected QC cable wrap inspection reports. These deficiencies led the NRC to question the: quality of
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the specified cable wraps. The licensee' performed a visual examina-tion of the~ installed wrap at each of the locations. The licensee did not ide..tify any deficiencies in the: subject cable wrap instal.1ation This item is close .2: (Closed)' Unresolved Item 50-412/87-32-02 Use of Unqualified Siltemp Material-(Ref: Allegation If Section 3.6).
LThe licensee used unqualified S11 temp'84-CH material instead of-188 .CH .for cable' wraps' required for meeting electrical ~ separatio Nonconformance and Disposition report No'~ 39178. dated March 31, 1987,
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documents four cases of unqualified Siltemp us Preliminary NRC discussions with the licensee indicated that this-misapplication.could potentially affect approximately 100 cable wrap During the inspection, the NRC inspector ~ requested that the licensee ll disassemble a portion of_one instal' led cable wrap that utilized a i Siltemp blanket wrap. It was determined that the blanket was the qualified 188-CH materia ; In response to NRC' questions raised during the period of April 6-15, 1987, the licensee performed a comparison of the thermal ; characteristics of the two cable' wrap materials under calculation i-US(B)-217 dated May 4, 1987. .The licensee generated a computerized
. thermal model of the heat transfer from a faulted cable with quali- '
i E fied-188-CH wrap. The thermal model utilized the computer program i TAP-A-(Thermal Analysis Program A), developed by Westinghouse. The i tap-A program has been in industrial use for about five years. The l computerized thermal computer model was benchmarked using test data l
.from cable wrap tests performed at Wyle Lab's in 1984. The Wyle ,o v - %
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tests' included the 188-CH Siltemp blanket material. The verified: thermal model was run using the thermal characteristics (thermal
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conductivity and thickness) of the unqualified 84-CH Siltemp blanke . Calculation results indicate'a maximum temperature for an. adjacent
~ . unwrapped conductor.of 203 degrees Fahrenheit.- This temperature is W 26 degrees Fahrenheit higher than that calculated for the previously: , , .quali fied .188-CH material . However, this is substantially below,the licensee's acceptance criterion of 340 F. This analysis demonstrate that'Siltemp material 84-CH has an adequate thermal insulatio \, , capability: for use.as a- cable wrap materia The licensee ~ revised engineering calculation E-107 to determine th effect of.Siltemp wrap on cable ampacity. The purpose of thi calculation is Lto establish that the ampacity derating resulting from 7 -the use of the 84-CH'materialLis within acceptable limits.
, The : licensee ussd this analysis to justify- the acceptability of the-
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existing installations using the S11 temp 84-CH material. - As of April 0" 1987, the licensee had made thm material' unavailable for cable wrap
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installations. They l'abeled it as an expendable material. A
- refresher training. program was instituted during the inspection to-inform ~ the craft' personnel that this material wasnot to be used for -
cable wraps. At the conclusion of the inspection' about 90% of
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the electricians performing' cable wraps had completed this refresher Cours .,
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~This item'is close '4 ..3 -Violation 50-412/87-32-03 Cable Wrap Technical Issues
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Several. technical' issues were raised during-the course of this inspection. These 1.ssues included: the effect of. cable wrap quality-on the wrap. insulation properties; and the effect of. cable wrap thickness on the ampacity of the~ wrapped cable. These issues'are discussed belo . I
~A review of the cable. wrap inspection procedure and discussions with .{ QC inspectors material quality.indicated there This issue waswas noas raised formal control a result of cable wrap of noted (deficienciesinthecablewrapquality. including: fraying, browning and. tape thickness variation ,
The licensee receipt inspection included inspecting for damage or deterioration. However, the cable wrap inspection procedure did not have any material quality attributes. On April 4, 1987, the Licensee i revised the cable wrap inspection procedure 12.1 to include material quality attributes. While tape quality was not an inspection attri-
, bute, the NRC inspector concluded from interviews with 16 QC ',
inspectors that defective tape was routinely discarded by QC inspector I _(
L .. I The licensee stated and the NRC inspector agreed that the strength of the Siltemp material'is not critical to the required performance of' the cable wrap. The Siltemp material is kept intact by a glass tape wrap which forms the outer layer of the cable wrap. Moreover, the Wyle lab tests performed in 1984 Report no. 17666-02 indicate a substantial margin in the insulating capacity of the cable wrap which is adequate to accommodate minor discrepancies in material . qualit I
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The issue of the adequacy of the material quality is close ! The NRC' inspector noted that the drawing controlling the insta11 tion i of the Siltemp blanket material specified a maximum limit of 200s thickness. However, the Siltemp tape wrapping procedure imposed no limit on the maximum allowable thickness of tape wrap on cables (Ref: Allegation (Ig) Section 3.7). This concern applies to localized wrapping of multiple bundles and extended length cable
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'J wraps using S11 temp tape WT-6 ]
In response to questions raised by the NRC inspectors regarding the affect of-cable wrap thickness on the ampacity of the wrapped cable, J the licensee provided the inspectors with the results of cable ! ampacity calculations. The licensee's analysis W.0. 12241 predicted the conductor temperature for several cable wrap configurations. Cal-culations were performed for cables with 3 and 4 layers of Siltemp j thickness for a minimum of 18 inches in wrap length. these calcula- ; tions pertained to localized cable wrapping of multiple cable _
: bundle The Beaver Valley Power Cable Specification 2BVS-828 and 2BVS-30S specified that the maximum conductor temperature for normal ;
operations not exceed 90 The results of these calculations ! Jemonstrated that the maximum conductor temperature for the most restrictive application.is below 90 C. This calculation only applied to short sections with increased cable wrap thicknes The inspector observed that based on the BV-2 practice of cable wrapping, concentric layers of tape material can occur for an extended length of cable wrap. The installation drawing SECO 1.2.3.4-A40 Rev. 11 requires a minimum of one half lapped Siltemp tape application. No maximum lap is specified for the tape application. In order to achieve a minimum of one half lap electricians could have gone to 1 3/4 lap. This would result in 3 j layers of tape on the cable. Data furnished by the licensee for 2 l layers of siltemp material indicate a maximum conductor temperature { of 87.8 C for number 6 power cable for a 60 inches length of wra ! The inspector estimated the maximum conductor temperature for an l extended three layer tape configuration, using data provided by the 1 licensee. This estimate indicated that the maximum conductor j temperature could exceed 90 C. Three layers of tape can potentially l degrade the long term (ie 40 years lifetime) performance of the cable i insulation by the conductor exceeding 90 C, the specified conductor
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temperature for'the BV-2"#6 power cables 11n specifications 2BVS-828-and 2BVs-309. The licensee did-not provide.in either the installa-- ] ition drawing or the inspection criteria measures to. assure that;the
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<c 90*C maximum conductor temperature'for'#6; power cables not be J
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-exceeded for normal-operation. -This' constitutes a violation of 10 -
r CFR 50 Appendix B Criterion .III, which requires that measures shall
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be established lto assure that design-basisLfor components are' J
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_ correctly translated into procedures'.and instruction ],
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- 4. 4 (Closed) Unresolved Item'50-412/87-32-04 Cable' Wrap Program- !
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Several questions were raised during the course of this inspection
- regarding the adequacy-of the licensee. cable wrap installation ..
program. Specific' programmatic issues includer The adequacy of the training of craft installing the wrap; the technical l adequacy and timeliness of the licensees program to resolve cable wrap technical issues; and the. adequacy of_the licensee program to control the !
' quality of the cable' wrap material. Resolution of each'of these programmatic issues _is discussed belo Discussions with QC_ inspectors and a review of the licensee trend- -analysis.for cable wrap installations indicate that there.was-a substantial amount'of rejected cable wrap work. This information was revi.ewed to determine if it was a result of inadequate craft trainin ,
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i , The licensee provided documents' that' demonstrated that the increased a
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amount of rejected work'was due to the increased number of cable'_ j Lwraps performed during March, 1987. The large amount. of rejected a work 1 reflected the increased amount'of cable wrap activity performed 1 during:this' period. The. reject rate during this period did not
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exceed the overall reject. rate of 6 percent for all cable _ wrap
. installations.
.- Allegations ivc and' discussions-with QC' inspectors. indicated that cable wrap; technical concerns ~ raised by QC personnel might not have received a' timely and technically adequate resolution, j-The NRC inspector reviewed all the cable wrap RFI The inspector-concluded from this review that all of the technical concerns raised through the formal RFI program were answered adequately and in a , timely manne l
A question was raised regarding the adequacy of the licensee program !
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to control the quality of the cable wrap material. This issue was raised as a result of discussions with QC inspectors and craft which indicated that a substantial amount of S11 temp tape had been rejected-due'to fraying of.the tape. Licensee document SQC Receipt inspection report 5626, dated June 10, 1986, indicates such a rejectio The , NRC inspector noted that two out of five, 4 inch rolls of tape i observed and one out of five 2 inch rolls of tape observed in the l warehouse were discolored at intervals along the tape with some signs ! of brownin ! i
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s The licensee collected all the historical records for rejected l Siltemp tape material. The total reject rate was 4.5 percent from a " total of 24,072 tape reels. The licensee's qualification test data
.for the cable wrap in Wyle Report 17666-02 indicated a substantial !
margin in the insulation capability cf Siltemp 188-CH. With this ! margin, it was determined that some fraying of the Siltemp cable wrap l could be accomodated without affecting the required insulation i characteristics of the cable ~ wrap. Discussions with 16 QC inspectors ! indicated that shredded tape was routinely rejected even though-tape ! quality and shredding was not a QC inspec: tion attribute. The . l inspector had no further questions. A potential problem related to the browning of tapes is being addressed by N&DR 39245. In addition, the QC department revised inspection procedure 12.1 to assure that cable wrap tape material that is used be free from any deterioration, fraying or shreddin These items related to the cable wrap installation program are close i 5.0 Status of previously Identified Issues 5.1 (Closed) Unresolved Item (50-412/86-46-02) Raychem SkV In-Line Splice installation bend radiu The licensee initiated a Nonconformance and Disposition Request (N&D) 38725 to address the subject problem. Accordingly, all three phase { conductors of cable 2SISA0H301 were retrained and cable reterminated
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using Raychem NMCK8-IL kit. A minimum bend radius of 4 times the outer diameter of the pigtails for the in-line splice was maintained, based on ICEA S-19-81, Appendix M recommendation. Also, the motor terminal box was replaced with a larger. size box to permit an acceptable cable bend radius. The corrective actions. included a placing edge dressing material on all sharp edges of the cable box l openings to prevent cable damage from recurrin ( The licensee conducted a review to identify similar problems in other ' motor terminal boxes. The corrective actions for these problems l were implemented through N&D 38873. The licensee revised the field 1 cable installation inspection instruction SPE-350. This procedure l was used for subsequent reinspection on the rework of identified l deficiencies. The NRC inspector inspected two reworked motcr terminal I boxes (2CCP*P21C and 2EGE*0CFLD2) and verified that the licensee's corrective action was adequat This item is close l i
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C > , Q* :5;2H(Closed)'Unre' solved Item (86-41-01') Cable DeratingiDue to Tray Covers
. > ' ~ Theilicensee sized [smallipower cables without the diversity-F L.factorf for~ 1oads'. A further derating' isinot needed if tray fill does ; '
not' exceed 80 percent 'of the_ design limit orr ifl intermittent duty '
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; cables: constitute 20 percentfor more of the* tray fill design limi v . For: 480Vl power cables .Wyle' test No.17666-02 'estab11 shed :a; 22. to; pr ,
'26Lpercent ampacity' margin for BV-2 cables'in accordance:withllPCEA- >
j P 46-426. 'Therefore,.'a two foot section of solid tray cover does.not ' b . necessitate 1further derating of the cables. For power' cables for y c4160V, analysis wastprovided to demonstrate that' the axial' heat
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s b lou transfer?through.the'large conductors is adequate'. to prevent' hot :
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, : spots resulti_ng from solid tray covers up:to two fee " ' '
L BV-2 drawing RE-39BC 'and cable, criteria ' document 2BVM-42 control the -
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'above. design' bases of'two foot solid tray cover' sections and tra :W '
fill. lAny. exceptions to th.is criteria will be analysed on a case by case basi ~
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This item'is close j 5 ' "' 5.3L'(Closed): Unresolved' Item (50-412/86-46-03) Moisture Impingement j-on Kerite Splices: ' w Theilicenseelestabl.ished that condensation of steam in the outer-f' : jacket' .tapei tolthe Kerite 3/c' 5kV cable anderplice samples, during a'. LOCA' test-and direct 1 boron spray, would notadegrade the functional:
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.capabilityJof1the test! specimens. The results of leakage. current '
, tests conducted during the Kerite Splice environmental' qualification testnindicated that the splices .will: perform their sintended function
- under postulated accident condition's iffthey met:BVPS-2 acceptan.ce'
. criteria. JThe subject Kerite splice installations are limited to th component. cooling'wa'ert pump motor' connection This item is closed,
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5.4 (Closed) Unresolve'd' Item (50-412/86-46-04) Preventive Maintenance j The licensee included a routine preventive maintenance task l specifying meggering the circuit breakers'to the motors served by the j Kerite splices, on a periodic basis, as established in the environmental qua11fication package 2BV-309 (931A). A visual . { examination of the splices will'be performed, during thisftask, to j identify any apparent physical damage. The subject Kerite splice i
.. installations .are limited to the ' component. cooling water pump motor
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> I y This item is close ]
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6.0 i: Unresolved' Items.:. B . Unresolved items.'are matters for which additional information is: required P .iniorder to'; ascertain'whether they are acceptable,. violations,'o'r devia-
[ tions. . Unresolved items are discussed in Section .0 Exit Meeting-The; inspector met with . licensee ~ representatives at-the conclusion of th inspection on April 15;'and May 8,.1987. The inspector. summarized the
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purposefand.the scope of the inspection and the findings. 'AtLno time
., dur.ing the'. inspection was written material provided by the inspector to the license m l
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' ATTACHMENT A : , , '
, Inspection procedure 12.1 Inspection of Protective. Wrap q ,
, . - . ;Revisiont Procedure Effective Date 0: '12.1& l 1- 12.1&31 04-25-86- ,
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-2- 12.1&3
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'04-09-86'
C"'< 3 12.1&3: .04-24-86 h 4 12.1& e ;5 L12.1&3 . 05-16-86 6 12.1&3 05-21a86 m 7 12.1&3- '06-02-8 /1&3: '06-18-87-9 12.1&3' 06-19-86 U, > 10 12.1&3L 07-03-86 11 12.1&3 07-30-86-12 12.1&3 08-06-86
' ~ , c 13 12.1&3 08-07-86 '
114 12.1&3 08-13-86 '. ~15' 12.1&3 09-19-861 116- 12.1- 10-02-86 -
~ 17- 1 .10-15-86:
18 - J1 P 1 ! 20' 1 '12-22-86 21: 1 . 1 .11 03-05-87-24' 1 '03-11-87: 25- '1 ~j
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' : . -ATTACHMENT 8 i I
CABLE WRAP INSPECTION REPORTS 510-1824 710-1699-710-1733 j 510-0566' 3-20-87 L: 110-0343 2-23-87 110-0343 3-25-87 110-0343 3-26-87 110-0335 3-19-87 to 3-27-87 110-342 510-1515~ 390-5072 390-5128 390-5335 510-1585 j 510-508
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710-1367 l 510-288-
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3.-/ s ATTACHMENT C
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;0THER DOCUMENT $' REVIEWED' ,-
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Drawing for the' Ins'tallation'of. Protective WrapLfor Color Separation-
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'SEC0 - li2!3;4.A40 Rev. 1 to 11-
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' SECOL- 1.2.3;4.A52LRev. 1 to 3
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03-09-87: SQCL 0285-GY q'
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: 04-16-87. L SQCL'. 0285-HA'
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;Reques' thor'I'nformation[(RFIs).
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.3340-QC:-.
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r 13373-QC L3448-Q " ' 3601-QC'. ,
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3610-QC.- 3857_-QC . t, Construction Deficiency Reports _ g r. , ,
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:SE-7240i SE-7239: '
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