IR 05000445/1986014

Insp Repts 50-445/86-14 & 50-446/86-11 on 860601-30. Violations Noted:Failure to Identify,Tag,Segregate & Rept Nonconforming Components & Failure to Establish Procedures to Control Drilling of Holes Through Cable Trays

ML20215N772
Person / Time
Site:	Comanche Peak
Issue date:	10/31/1986
From:	Barnes I, Phillips H, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215N761	List: IR 05000445/1986014 ML20215N760 ML20215N765
References
50-445-86-14, 50-446-86-11, NUDOCS 8611070254
Download: ML20215N772 (16)

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APPENDIX B CONSTRUCTION INSPECTION REPORT U.S. NUCLEAR-REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-445/86-14 Permits: CPPR-126 50-446/86-11 .CPPR-127 Dockets: 50-445 Category: . A2 50-446 Applicant: Texas Utilities Electric Company Construction. Permit Skyway Tower Expiration Date:

400 North Olive Street Unit 1: August 1, 1988 Lock Box 81 Unit 2: August 1, 1987 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2 Inspection At: Glen Rose, Texas Inspection Conducted: June 1-30, 1986 Inspectors: -

)> /d /A/ /f4 H. S. Phillips, Senior ~ Resident Reactor Date Inspector, Construction, Region IV CPSES Group (paragraphs 1,2,3,4,5,6,7,8,9, 10a, 10b and 11)

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%W P. C. Wagner, Reactog Inspector, Region IV

/ YLOf0(o Date CPSES Group (paragraphs 10c, 10d, and 10e)

Consultants: Parameter - J. Gibson (paragraphs 10c,10d, and 10e)

EG&G - A. Maughan (paragraphs 10c (4), 10e (4), and 10f)

l Reviewed By: .

, WMI _ /o f R. L. Spessard( Deputy Director, Division of Date '

Inspection Programs, Office of Inspection

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and Enforcenent

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8611070254 861031 PDR ADOCK 05000445 G PDR

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Approved By: duo I. Barnes, Chief, Region IV CP5ES Group

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-Date Inspection Sununary Inspection Conducted June 1-30,~1986'(Report 50-'445/86-14)

-Areas Inspected: Routine, unannounced inspections of Unit I which included site. receipt inspection and storage, procedure for drilling cable trays, 'and welder qualification testin , Results: . Within the three' areas inspected, two violations (failure to identify,-

tag, segregate, and report nonconforming components', paragraph 4.b;'and failure-to establish procedures to control the drilling of holes through cable trays

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filled with; cable, paragraph 10.d.(3)) were -identifie Inspection' Conducted June 1-30, 1986 (Report 50-446/86-11)-

Areas! Inspected: Routine, announced and unannounced inspections of Unit'2 which included a~ review of plant status,. general plant inspections, site receipt inspection and storage, mechanical components, reactor coolant pressure boundary welding, welder qualification testing, construction verification testing, preservice-inspection, and electrical inspections.-

V iRsuits:=.Withinthe-nir$.areasinspected,threeviolations,onewithmultiple examples:'-(A.; failure.to identify tag, segregate and report nonconforming

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' components, paragraph 4.b.;> BC failure to properly' identify conduit / junction boxes, paragraph 10.c.(1) and (2); failure to tighten. flexible conduit connectors, paragra'ph 10.c.(3); failure to provide instructions for'and to

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i protect' cable ends during installation, paragraph 10.e.-(1); failure to color

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' code' cable per, procedures, paragraph 10.e.(2); and C. failure to establish procedures to-control-the drilling of holes through cable trays filled with cable.. paragraph 10.d.(3)) were identifie ,~ . : >

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DETAILS Persons Contacted Applicant Personnel

• J. Beck, Vice President, Texas Utilities Generating Co. (TUCCo)

• T. Brandt, Quality Engineering (QE) Supervisor, TUGCo

• R. Camp, Project General Manager, Unit 1, TUGCo

• 0. Lowe, Manager, Mechanical Engineering, TUGCo

• D. .McAfee,. Quality Assurance (QA) Manager, TUGCo

• J. Merritt, Director of Construction, TUGCo

• L. Nace, Vice President, Engineering & Construction, TUGCo

• T. Tyler, CPRT Program Director, TUGCo Contractor Personnel G. Purdy, Site QA Manager, Brown & Root (B&R)

R. Vurpillat, Houston QA Manager, B&R W. Wright, Welding Engineer, B&R The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the June exi . Plant Status,-Unit 2 The NRC. inspector discussed the status of work with TUGC0 and contractor (electrical and mechanical) management personnel. Project status reports were also reviewed. Construction is presently at an important milestone -

construction plans to turn over select portions of the reactor coolant system. Construction has turned over approximately 54 percent of the subsystems to TUGCo Startup and overall construction is about 82 percent complet . General Plant Inspections, Unit 2 Safety-Related Buildings / Areas .

At various times during the inspection period, the NRC inspector conducted general inspections of the Unit 2 reactor, safeguards, electrical / control, auxiliary and diesel generator buildings. Almost all of the rooms in these buildings were inspected to observe current work activities or major safety-related equipment which was stored in place. The storage inside these buildings and the area for steel supports, located just outside Unit 2, were also inspecte T 1

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One backshift inspection was performed during this inspection per'io During this inspection the NRC inspector observed work activities in the reactor.and safeguards building No violations or deviations were identifie . Site Receipt Inspection and Storage, Units 1 and 2 Receipt Inspection The NRC inspector selected several parts or components in warehouse "B" to determine if receipt inspections were performe ReceivinginspectionReports(RIRs) 19426, 24421, 19326 , 19876, 26640, and 27565 for ASCO solenoid valves, NAMC0 limit switches,

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instrument tubing and resistance temperature devices (RTDs)

documented inspections of these items when received in accordance with B&R Inspection Procedure QI-QAP-7.2-8.1-1 Warehouse Storage The NRC inspector observed the overall storage conditions in warehouses A, B, C, and the electrical warehouse. In all cases, access to these areas was controlled and the warehouses were clean and orderly. Parts and components were stored in accordance with the required levels (A, B, C, and D) of protection. The following items were selected for closer inspections; i.e., condition, identification, and receiving inspection performed:

Storage Warehouse Item Identification RIR Level Condition A Magnaflu CP F1664-S 19324 C S Spotcheck 12684 C S A Magnaflux P0 30342 Spotcheck 13372 C S penetrant A 1 1/4 inch 10664 21598 C S Hilti nuts and washers B Detector P/N 02810760-02 -

C S assembly B Gamma P/N 126932-7 - C S check source L

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B Reactor S/N 9115E641-G-04 -

C S coolant pump shaft seal assembly B Valve P/N 0907 - A S diaphram B ' Grinding P/N2F -

A S-compound B Sample of Model No A ASCO 1E_ NP8320A-182E; solenoid 186E; 184E; 174E; valves and JV2063816RF received B Sample of Model No A S 2N ASCO NP-8320 A182-v; valves a184-v; and received NP-8316-54-V B 3/8 inch ASME SA 213, 26640 A S stainless heat No.307695 instrument tubing B Main steam Loop 3 MS B/P ISO -

A S handswitches Valve 2HS-02335B B RTD S/N 525 23565 A S B 8 thermo- P0 CP 0012,. -

A U couples C Reactor CPF232712 -

C S pressure vessel studs 1-6, 13-18, 31-36, 37-42, and 49-54 All of the above storage conditions were satisfactory (S-satisfactory and U-unsatisfactory) except for the eight thermocouples. Two of the eight thermocouples were unsatisfactorily stored because they had been returned from the field in a damaged condition. These damaged parts were not identified, tagged, and segregated from the conforming parts. No nonconformance report (NCR) had been issued; however, NCR E86201710 was subsequently issue F~

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This failure to tag, segregate, and report. nonconforming parts or components is an apparent violation of Criterion XV of Appendix B to 10 CFR Part 50(445/8614-V-01;446/8611-V-01). Laydown-Storage Areas The NRC inspector inspected all laydown areas where piping, electrical conduit, cable, cable trays and structural and reinforcing steel were stored. These materials were neatly stored outside on cribbing in well drained areas which allowed air circulation and avoided trapping water. Storage practices met the Level "D" storage

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requirements of ANSI N45. . Mechanical Components, Unit 2 The NRC inspector observed the general storage conditions of mechanical equipment inside all safety-related buildings and in warehouses as described in the paragraph 4b above; however, the following components were observed more closel The NRC inspector observed that the large lateral structural steel restraints for steam generator Nos. 2 and 3 have been hoisted nea'r the location where they will be installed. These restraints were hoisted ~by-placing carbon steel slings around trunnions located on the upper part of the steam generator. The slings had caused galling, however, it appeared that this would not adversely affect these trunnions because of their large size as compared with the weight of the restraints. This condition was discussed with TUGCo Quality and Westinghouse engineering personnel who evaluated the condition. Based on their evaluation of the concern, the NRC inspector determined that this condition.was not likely to be harmfu No violations or deviations were identifie . Reactor Coolant Pressure Boundary Welding, Unit 2 Repair of Weldments The NRC inspector reviewed repair of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Division 1, Class 1 weldments. The.following documents the identification of defects and subsequent repair in accordance with quality assurance and Construction Procedures CP-CPM-6.9 which were previously reviewed by the NRC for Code complianc . .

System Field Nondestructive Repair Welder Wald -Examination .ow., .,m ol Report N Sheet-Reactor FW-1 18657 632252 AY2 RC-2-520-01 FW-31 19076 632283 AMS-Residual Heat FW-1 24694 660244- AFC Removal (RA), <

RH-2-RB-004 Safety FW-5 28571, and 51462 BAG Injection,- 29262 SI-2-RB-026 Review of Nonconformance The NRC inspector reviewed NCRs M03010R4, M-5291, M-5931, M-21800 and M-27209 which were issued on the systems identified above to determine if defects were promptly identified and corrected. The background information and cause of.each nonconformance was discussed with B&R personne No violations or deviations were identifie . Welder Qualification Testing, Units 1 and 2

~ The NRC inspector reviewed the performance qualification work sheet dated June 27, 1986, for welder symbol ACY which documented acceptable results for standard test C6 Weld Process Specification (WPS) 11032R13 and test A5, WPS 10046R17. This qualified the welder for shielded metal arc welding of piping (ASME Section III, Division 1 ANSI B31.1 and AWS D1.1-74). The quality of the weld specimens was also examined, documented, and accepted in radiographic reports 7784 and 778 On June 30, 1986, the NRC inspector witnessed the testing of four specimens of welding completed by a welder (Symbol CKS). B&R quality control also witnessed this test and signed off on the performance qualification worksheet. All specimens met-the acceptance criteria of ASME Section IX QW-163 as no defects were found in the weld or heat affected zone which. exceeded 1/8 inc No violations or deviations were identifie . Construction Verification Testing, Unit 2 The NRC inspector observed the activities for controlling cleaning and flushing of piping systems in auxiliary building rooms 204 and 18 Component cooling water, and chemical volume and control system flushing

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were in progress. Similar activities were observed'in room 66 of the safeguards building where safety injection, Train A, is to be flushe Startup personnel were monitoring the in-process flushing operatio No violations or deviations were identifie . Preservice Inspection, Unit 2

'The NRC inspector reviewed and discussed the status of preservice inspection with the Westinghouse (W) site manager. Preparation for this work activity has begun in the realitor building where the weld surfaces are currently being examined. Approximately 230 NCRs on surface finish have been generated to dat While reviewing reactor coolant pipe' welding activites in paragraph 6 above, the NRC inspector found that B&R NCR M-3010 R4 dated June 11, 1982,

. documented the failure of Procedure QI-QAP-10.2-7, Revision 1, to include requirements for inspection _to the requirements of Specification 2323-MS-100, paragraph 4.27.7. The resolution dated June 1982 was that TUGC0 was to subsequently inspect these welds to Procedure QI-QP-20.0- .The NRC inspector discussed the.preservice program'with TUGCo, B&R, and W management / personnel to find the rationale for closing the NCR when it did not actually correct the final surface preparation or configuration to conform to the specification referenced in NCR M-3020N4. The rationale was that this was and is a TUGCo inspection responsibility which will-be accomplished at a future dat No violations or deviations we'e identifie . Electrical Inspections, Unit 2

' Storage and Protection of Cable and Hardware '

(1) The NRC inspector observed the storage of cable in the cable

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reel yard and found the following stored to level D requirements and controlled as required.

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Reel N No.& Size Type Color Distribution of Code Control Card i'

Conductors Checked *

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W216-5 2C-2 power green X

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W145-7 12C-12 control orange -

l W845-6 12C-12 control green X w/ stripe

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.w- ,eer,,- - - - , + - .n e ~ - - - , ~ . - - - - , - - . -

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W616-1 2C-2 power yellow -

W815-9 #2 triplex power green -

W108-18D IC-250MCM power orange -

!1265-135 1 STP instrument green X Shielded

1. 16 W165-3 1 STP instrument orange -

Shielded

1. 16 L15H-1 1C-12 lighting green X L15G-1 1C-12 lighting orange -

• X denotes card revie In laydown yard Nos. 3 and 4, a B&R construction worker was observed drawing 25 cable tray hanger clamps for use in the safeguards building at various locations. The worker had observed proper access and withdrawal procedures in that he had the required written authorizatio All of the cable tray hardware in this area was observed to be neatly stored to level "D" requirement (2) The NRC inspector observed that protective covers for level transmitter instruments 2LT-539 and 2LT-537 (located in the Unit 2 reactor building) were removed on June 19, 1986. The tubing associated with these instruments had their mounting supports clamps removed so that the tubing was loose and grinding was in progress overhead to prepare the area for painting. The failure to protect the instruments and tubing from possible damage and contamination is an apparent violation of Criterion V of Appendix B to 10 CFR Part 50(446/8611-V-02).

(3) The NRC inspector observed welding being performed directly over cable tray sections T24RREA16 and T24BREC11 on June 19, 1986, and noted that the cables in these trays were not protected against possible damage from the welding. The failure to protect the cables is violation of Criterion V of Appendix B to 10 CFR Part 50(446/8611-V-03). Cable Tray Hanger Installation The NRC inspector observed the weld (hanger package P22QEBA37) which welder (Sym)ol CEN) had just completed. Drawing CTH0210216, Revision 3, was red lined to show that weld joint No. I was

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undersized. Discussions with the craftsman revealed'that these welds had previously been completed, inspected to the old Gibbs &

Hill (G&H) design, and were accepted by quality control. As a result of recent design engineering activities regarding installed cable tray raceways, EBASCO'sl inspection and analysis revealed that some welds were undersized because the welds did not meet the original design size and/or the original design size must be increased because of new design criteri The NRC inspector determined that, in this case, no NCRs were generated because the new design drawing was being used to identify-deficient welds whose size must be increased. Subsequently, traveler packages identify welds that must be repaired or made larger to meet new design criteria. This questionable practice was discussed with TUGCo QA management and.EBASCO engineering. Although this practice appears to be controlled by engineering procedures, it appears to be in conflict with the TUGCo QA Manual and implementing procedures which require nonconforming welds to be identified. This item is unresolved pending the receipt of and review of additional information(445/8614-U-02;446/8611-U-04).

c. Conduit Raceway Inspections (1) In the Unit 2 safeguards building pipe tunnel at elevation 801 feet, the NRC inspector observed a ceiling mounted junction box, JB2S-5789, color coded with orange.and white tape. This would indicate a junction box containing only Class 1E Train A

" associated" cables. One conduit entered the junction box, C23903919, and was color coded with orange banding only. Three conduits exited the box. One was marked C23903918, had orange banding only, and ran to junction box JB2S-569, also marked orange; this would indicate a Train A circuit. Another. conduit labeled C24912117 exited JB2S-5789, and was color coded with orange and white tape along its entire length; this' indicated that both Train A and " associated" cables were in the junction box, not only " associated". The third conduit that exited the box was labeled C23905257, and ran to junction box'JB2S-571; this box was marked orange, but the physical label did not

contain the "p" suffix. Also, this conduit was marked with an

, orange and a white stripe where it exited JB2S-5789, but was

! marked with only the orange stripe at intervals along the l remainder of the ru Paragraph 3.6.2 of TUGCo Instruction QI-QP-11.3-23, Revision 13,

dated Se)tember 6,1985, " Class 1E Conduit Raceway Inspections,"

, states tiat a conduit containing Train A cables should be

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identified with only an orange band and the entire conduit run

!' markings should be compatible. Paragraph 3.8.3 of this instruction states that a junction box should contain the i primary color markings along with a white stripe, only if it contains no cables other than " associated." The failure of the

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' applicant to properly color code junction box JB2S5789 and

. conduit C23905257 is an apparent violation of Criterion V of Appendix B to 10 CFR Part 50 (446/8611-V-05).

(2) As identified above, conduit C23905257 entered junction

_ box JB2S-571. Conduit C23905357 exited this box and connected to-flexible conduit C23905357, which in turn was connected to level switch 2LS-5349. The flexible conduit appeared to be properly identified, but the rigid conduit identification did not contain the required five digits in the " unique". identifie A sticker on the conduit indicated that it had been QC accepte TUGCo Instruction QI-QP-11.3-23, Revision 13, dated September 6, 1985, " Class 1E Conduit Raceway Inspections," paragraph 3.6.2, indicated a five digit " unique" identifier. The failure of the applicant to properly identify this conduit, as well as the junction box to which it was attached, is an apparent violation-of Criterion V of Appendix B to 10 CFR Part 50(446/8611-V-06).

(3) The NRC inspector observed that flexible conduit connectors at the rigid conduit connection point were loose (not hand tight)

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for C22905459, 2ESB6/3, and 2ESB5/3 in the electrical equipment

. room, and C23910114 in valve room 90. It was also observed that the lighting conduits (designated ESB) had not had cable

' installed as of the inspection date. Paragraph 3.5.1 of TUGCo Instruction QI-QP-11.3-23, Revision 13. dated September 6, 1985,

" Class 1E Conduit Raceway Inspections," states that the-installation of flexible conduit which terminates'at equipment will not normally be complete or inspected until cable installation is complete. Therefore, the NRC inspector did not identify any violations or deviations with respect to the two lighting conduits during the' inspection perio Thepowerandcontrolconduits(C22905459andC23910114)had cables installed which had been terminated, were energized and

" turned-over" for use. Paragraph 3.2.1.e of TUGCo Instruction QI-QP-11;3-28, Revision 30, dated May 21, 1986,

" Class 1E Cable Terminations," " Verify Adequacy of Flexible / Unique /Servicair Flexible Conduit Installation,"

states, in part, ". . . Verify that the connection is hand tight, as a minimum." The NRC inspector also determined that the condition cited above existed on approximately ten additional Class 1E conduits. The failure of the applicant to tighten the flexible conduit connectors hand tight.is a violation of Criterion V of Appendix B to 10 CFR Part 50(446/8611-V-07).

Train A flexible conduits were observed touching Train B flexible conduits at valves 2FCV-520,~2LV-2165 and 2LV-216 This item is unresolved pending completion of a' records review by the NRC (446/8611-U-08).

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._ . j 12 -r (4) The NRC inspector observed work at various ' stages of completion

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. Installation of one of two conduit hangers for conduit.C2402T . The installation of four, 4-inch conduits (non-class 1E) in the Unit 2 safeguards buildin No violations or' deviations were identified.-

d. Cable Tray Raceway Inspections (1) Power and control cable trays were inspected by the NRC inspector in the Unit 2 safeguards building, specifically with respect to potential problems regarding tray fill. The NRC inspector did not identify any violations or deviations in this are (2) The NRC inspector observed B&R electricians drilling holes in solid bottom cable tray section T2495F004, located adjacent to corridor 94 at elevation 832 feet in the safeguards buildin The NRC inspector noted that the cable tray was being reworked to correct a situation where cables were spilling over the siderails of.the trays and to provide slack at vertical fittings. When asked by the NRC inspector as to the nature of-the work and authorizing documents, the electricians produced DesignChangeAuthorization(DCA)17,035, Revision 1;noother documentation was offered. The NRC inspector reviewed this DCA and observed that it involved plugging unused holes in cable trays with 1/4 inch round head bolts. A subsequent inspection of the completed work activity by the NRC inspector revealed that the work actually done was the drilling of holes to attach field fabricated fittings between the tray sections. This work was necessary due to the tray routing change. The failure of the craft personnel to produce appropriate documentation relative to the actual work activity may be indicative of insufficient training. This item is open penJing results of additional NRC inspection in subsequent. reporting period (446/8611-0-09).

(3) The NRC inspector also observed that holes had been drilled in solid bottom cable trays.to facilitate the use of TY-RAPS to fasten / support the cables. The NRC inspector was informed by applicant personnel that the drilling of the holes had occurred both before and after cables had been installed in the trays.

! The NRC inspector was also informed that the drilling of the t

holes was allowed by procedure, but that no in-process controls

were imposed by the procedures.

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The NRC inspector reviewed G8H Specification 2323-ES-100,

" Electrical Erection," which did allow the drilling of 1/4 inch holes in solid bottom tray to facilitate the use of TY-RAP The NRC inspector also reviewed TUGCo's instructions (QI-QPs)

for cable tray and cable installation inspections. These instructions permited the drilling of holes, but did not address in-process controls. The drilling of holes in cable trays,

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whether for TY-RAPS or fitting attachments, is important to safety, particularly regarding protection of installed cable The failure.of'the applicant to specify in appropriate procedure / instructions activities affecting quality (i.e., the drilling of holes in cable trays and the protection of the cables installed therein), is an apparent violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8614-V-03; 446/8611-V-10).

e. Cable Installation Inspection (1) The NRC inspector observed in panel CP2-ECDPPC-03 in the cable spreading room, that conductors were " trained" and attached to panel channels by TY-RAPS. These conductors were not terminated; some of these conductors were marked as " spare" (SP designation), and some were not. Also, some of the conductors hadprotectiveendcoverings(tapeorcaps),whileothersdid not. The NRC inspector was informed by the applicant's QE representative that this condition existed throughout the plan The NRC inspector reviewed TUGCo Instruction QI-QP-11.3-26, Revision 24, dated October 11, 1985, " Electrical Cable Installation Inspection," paragraph 3.2.1.j, which states,

" Cable ends - Cable ends shall be sealed with heat shrink caps or tape after pulling activities." Paragraph 4.7.1 of B&R Engineering Instruction EEI-7, Revision 5, dated October 8, 1982, " Cable Pulling," states, " Cable ends shall be sealed with heat shrink caps or tape during the period prior to the terminations." TUGCo Instruction QI-QP-11.3-28, Revision 30, dated May 21, 1986, " Class 1E Cable Terminations," did not address conductor end protection for cables which had their outer jackets removed, but had not been terminated. None of the above mentioned instructions addressed the marking of spare cables / conductors using the "SP" designato The failure of the applicant to provide conductor end protection in accordance with QI-QP-11.3-26 and EEI-7, and/or to prov.ide instructions regarding end protection in QI-QP-11.3-28, is an apparent violation of Criterion V of Appendix B to 10 CFR Part50(446/8611-V-11).

(2) At elevation 832 feet in the safeguards building, the NRC inspector observed a black cable in junction box JB2S-956G. The J

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.junctionboxwasseparationTrainB(green),butthecablewas not color coded at the junction box opening to indicate a Train B or " associated" cable. Similarly, in Room 85D near the safeguards pipe tunnel, the NRC inspector observed a black cable in junction box JB2S-544B; this cable was not color coded at the junction box opening to indicate that it was a blue channel or

" associated" cable. In addition, this cable was not color coded at the first " upstream" condulet opening in conduit run C24808615. The NRC inspector also noted that the gasket of this condulet was damaged and notified the applicant accordingl The NRC inspector reviewed TUGCo Instruction QI-QP-11.3-26, Revision 24, dated October 11,.1985, " Electrical Cable Installation Inspection." Paragraph 3.1.3.c states, in part,

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. . . If field color coding becomes necessary, Class 1E and associated Class 1E cables shall be color banded at intervals not exceeding 5 feet, and shall be visible at all openings . . . ."

The failure of the applicant to field color code cables in accordance with established procedures / instructions is an appa' rent violation of Criterion V of Appendix B to 10 CFR Part50(446/8611-V-12).

(3) The NRC inspector observed what initially appeared to be a cable separation deviation in panel CP2-ECDPPC-03 in the cable spreading room. Less than 2 inches free air separation existed between blue cables EB205330 and EB205322, and orange cable E9246255. Normally, the minimum separation would be 6 inches'without an appropriate barrier installed. Upon further investigation, however, it was' determined that Section 8.3 of the FSAR allows the "as-built" configuration in this panel (aswell'astheotherthreecounterpartpanels)particular . No violation or deviation was identifie (4) The NRC inspector observed work at-various stages of completion at various times during the inspection perio In some cases the work observed turned out to be non Class IE work, however, this was beneficial because these crews install both Class 1E and non Class 1E cable.. The following are the results of these inspections:

. Cables E0226910Z through E02269257 in Unit 2 containment were prepared for performance of continuity checks and verification that the cable ends were sealed after checks were complete . Cable separation criteria in process racks TCX-XIELRK-01 was checked for Protection Channel I and in CS-XIELRK-04 for Protection Channel IV and the results were:

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(1) Train "C" cables touched Channel IV cables instead of

.having the required 6 inches of separation, and similarly, (2) Train "C" cables touched Channel I cables. The NRC inspector discussed-this violation of cable seaaration criteria with applicant personnel who stated t1at the cables in these cabinets are exempted from separation requirements in paragraph 3.2.22.e of TUGCo Instruction Ql-QP-11.3-28, Revision 30, because of an engineering analysis. This subject is an unresolved item pending the receipt an review of this analysis (446/8611-U-13).

. About half the thickness of the conductor insulation had been removed for terminated jumper cables E0220901'and E0220904. These cables consisted of four to five single conductors and are located inside of motor control center (MCC)2EB1-1. The acceptability of this condition is an unresolved item pending completion of a TUGCo evaluationofthiscondition(466/8611-U-14).

. Non-Class 1E cables (for lighting circuits 25C4, 6, 8, 9, 10, 11, 12, 17 and 18 (non-class IE) were pulled in accordance with procedures. Lighting cables were terminated by two electrical crafts. No quality control inspector was present because they are not required to witness non-Class 1E cable pulls. The craft performed the steps as stated in B&R Engineering Instruction EEI-8, Revision 5, except an incorrect crimping tool was used. An AMP model crimper was used instead of the T&B Shure Stake model required by the procedure. The AMP crimper leaves a dot code on the connector and the T&B does not. Further checking of other terminations in this lighting run revealed that all the other connectors had been crimped using an AMP crimper. The use of the wrong crimper was discussed with TUGCo's QE personnel. This lighting run was non-class 1E, but Instruction EEI-8 is used for both class IE and non-class 1E terminations. This item is open pending furtherinspectionofthispractice(446/8611-0-15).

~f. Electrical Component Installation The NRC inspector observed the installation of motor starter for battery room 2-1 exhaust fan in MCC 2EB3-1. This installation was witnessed by site quality control inspector Overall, during electrical inspection on Unit 2, two violations, one with six examples, were identified in paragraphs 10a, 10c, 10d, and

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11. Exit Interview An exit interview was conducted July 9, 1986, with the applicant's representatives-identified in paragraph 1 of this report. During this interview, the NRC inspectors sunnarized the scope and findings of the inspection. The applicant acknowledged the finding _.