IR 05000445/1987007

Insp Repts 50-445/87-07 & 50-446/87-06 on 870301-0430.Major Areas Inspected:Previous Insp Findings & Electrical Penetration Assemblies.Two Potential Violations Identified Being Considered for Escalated Enforcement Action

ML20216G466
Person / Time
Site:	Comanche Peak
Issue date:	06/25/1987
From:	Kelley D, Wagner P, Warnick R NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20216G410	List: IR 05000445/1987007 ML20216G403 ML20216G466
References
50-445-87-07, 50-445-87-7, 50-446-87-06, 50-446-87-6, NUDOCS 8707010098
Preceding documents:	ML20238D846 (10 September 1987)
Download: ML20216G466 (14)

Text

{{#Wiki_filter:. . U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report: 50-445/87-07 Permits: CPPR-126

,,... 50-446/87-06  CPPR-127 Dockets: 50-445   Category: A2 50-446 Construction Permit Expiration Dates:

j Unit 1: August 1, 1988- 1 Unit 2: August 1, 1987 l Applicant: W Blectric skyway Tower 400 North Olive Street

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I Lock Box 81 , Dallas, Texas 7b201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 & 2 Inspection At: Glen Rose, Texas Inspection Conducted: March l'through April 30, 1987

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Inspectors , D. L. Kelley, ISenio2' Resident Reactor M.5 87

    'Dat'e Inspector, OperaQ bns   ;
 (paragraphs 1, 2, 4 and 5)
 @.6.LM A P. C. Wagner, Reak: tor Inspector  6/Es/67 Date (paragraphs 1, 2, 3, 4 and 5)

IWviewed by: [ [//I Wull kM/7 R. F. Warn:.ck,-Assistant Directo Dat6 for Inspection' Programs, Comanche Peak' Project Division 9;

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Inspection Summary Inspection Conducted: March 1 through April 30, 1987 (Report No /87-07; 50-446/87-06) Areas Inspected: Routine, unannounced inspection of (1) applicant action on previous inspection findings; (2) electrical penetration assemblies; and (3) plant tour Results: Within the 3 areas inspected, 2 potential violations were identified - failure to make timely notification to the NRC of a deficiency reportable under 50.55(e) (paragraph 2.m) and failure to establish adequate measures to require.the documentation of all nonconforming conditions (Unit 1 only)(paragraph 2.n). These apparent violations are being considered for escalated enforcement actio i a i

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DETAILS l Persons Contacted j

*R. P. Baker, Regulatory Compliance, Manager, TU Electric (TUE) l
*J. L. Barker, Engineering Assurance Manager, TUE
*R. E. Camp, Unit 1 Project Manager, TUE
*R. D. Delano, Licensing Engineer, TUE   ]
*D. E. Deviney, Manager Operations QA, TUE  j
*T. L. Heatherly, Regulatory Compliance Engineer, TUE  j
*J. J. Kelley, Director of Construction, TUE  1
*J. E. Krechting, Director of Engineering, TUE  I
*J. W. Muffett, Executive Assistant, TUE
*L. D. Nace, Vice President, Engineering and Construction, TUE
*S. F. Sawa, U2 Assistant Project Manager, TUE  j
*C. E. Scott, Startup Manager, TUE   l
*J. C. Smith, Plant Operations Staff, TUE  l
*P. B. Stevens, Manager, Electrical Engineering, TUE
*T. G. Tyler, Director of Projects, TUE  .
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*J. E. Wren, QC Services Supervisor, TUE The NRC inspectors also interviewed other applicant employees during this inspection perio Exits were held with the applicant on March 31, 1987 and May 5, 198 * Denotes personnel present at the March 31, 1987, exit intervie . Applicant Action on Previous Inspection Findings (92701 & 92702) (Closed) Unresolved Items (445/8502-U-07; 445/8502-U-09):

These unresolved items concerned the illegibility of the completed Diesel Generator Tests 1CP-PT-29-03-RT1 and l 1CP-PT-29-04-RT1. A follow-up inspection on these unresolved items was conducted during the reporting period l of NRC Inspection Report 445/8630. The NRC inspector found I that the retest of the' diesel generators was contingent upon the NRC removing the partial load restriction and allowing full load operatio It appeared that if the restriction was not lifted, there would not be retesting of diesel i generators; therefore, the unresolved item was left ope l The applicant has now committed to retest the diesel generators whether or not the load restriction is lifte This item is considered close l (Closed) Unresolved Item (445/8604-U-05; 446/8603-U-05): Adequacy of sacrificial sleeves on electrical penetration assembly (EPA) modules. Questions raised by the NRC l inspector in the report containing the above unresolved item ! led to the development of Corrective Action Report (CAR)-055 l by the applicant. CAR-055 listed.12 examples of l

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deficiencies with the Bunker Ramo EPAs and recommended the replacement of these EPAs with a different design provided by Conax. The sacrificial sleeve was listed as item 5 in the examples of deficiencies; the Conax EPAs do not contain these sleeves. The NRC inspector is following the replacement of the EPAs as an ongoing inspection activity (see paragraph 3 of this report).

c. (closed) Unresolved Item (445/8604-U-11; 446/8603-U-ll)- 1 Adequacy of the vendor installed splices. The adequacy of i

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the splices and the heat shrinkable insulation (HSI) installed on the Bunker Ramo EPAs was questioned by the NRC inspector. This question was also determined to be a deficiency with the installed EPAs in CAR-055 (see above).

The replacement Conax EPAs eliminate the splices in question; therefore, this question is also moo d. (Closed) Open Item (446/8606-0-08): Cable tray not bolted to supports prior to cable installatio The NRC inspector , had identified an instance in which a cable tray was not l bolted into position prior to installing cable in the tra Additional inspector review determined that there were no procedural requirements to preclude cable installation in unbolted cable tray In addition, in Inspection Report > 50-446/86-06, the inspector stated that the unbolted support was an isolated occurrence. The NRC inspector has inspected approximately 25 cable trays subsequent to the above report and has not identified additional instances of incomplete installations with installed cable. Since these cable trays were in the process of being reworked, the inspector has determined that the above was an isolated occurrence caused by rework activitie (Closed) Open Item (446/8606-O-09): Inverse slope of instrumentation tubing. The NRC inspector identified a situation in which the instrumentation tubing from the Safety Injection Accumulator to its pressure transmitter had an inverse slope, apparently caused by work activities in the are The NRC inspector has physically verified that the problem identified with the tubing to 2PT-965 has been correcte In addition, the inspector agrees with the earlier finding that the above was an isolated occurrence based on the observations from numerous plant tour (Closed) Violation (446/8611-V-07): Flexible conduit connector not tigh The inspector identified loose connectors on conduit C22005459 and C23010114 and additional safety-related conduits. The applicant wrote NCR E86-201807 to correct the identified problems and performed an inspection of these installations. The NRC inspector physically checked the example conduits and found the connectors to be tight. In addition, the NRC inspector physically checked 12 connectors on previously completed installations and 12 connectors on recently installed or in

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i progress installations in the Unit 2 Safeguards Building and 12 connectors on the stainless steel flexible conduits inside the Unit 2 Reactor Buildin l The inspector identified one connector in the Unit 2 Safeguards Building which was not tight. The connector was , the rigid to flexible conduit, C04011944, connection at l Junction Box JB-2RE6290-A. The inspector observed that work was still in progress on this installatio All other l connectors were tigh l The NRC inspector also reviewed NCR E86-201807 and found it to have been appropriately dispositioned on July 30, 198 g. (Closed) Unresolved Item (446/8611-U-08): Lack of separation distance between redundant trains of flexible conduit. The condition of Train A flexible conduit touching Train B flexible conduit at the three valves identified in the above item existed because of ongoing installation wor The Construction Deficiency Reports (CDRs) written for the touching conduits at the three valves were voided based on subsequent inspections. The NRC inspector reviewed the inspection reports (irs) and verified by inspection that the required separation was provided when the work was completed. The NRC inspector determined that the separation problem occurred during installation and was corrected as part of the normal installation activit h. (Closed) Open Item (446/8611-0-09): Incorrect documentation for actual work activity. The NRC inspector had written this open item to determine if the failure to produce appropriate documentation for a work activity was an a isolated occurrence or was indicative of insufficient i trainin The NRC inspector has not encountered any other instances in which the craft or QC personnel questioned did not produce the appropriate documentation for the work activity being conducted. Therefore, the NRC inspector has

determined that the initial finding was an isolated ) occurrence caused by the similarity of the task to be performe j a (Closed) Violation (446/8611-V-12): Missing color coding on electrical cables and junction boxes (JBs). The applicant wrote nonconformance reports (NCRs) E86-201808 and E86-201824 to correct the identified problem In addition, the applicant committed to retrain the responsible craft j personnel on the color coding requirements. The NRC j inspector reviewed copies of the above NCRs and QC ' inspection reports (irs) 20099246 and 20099247 which documented completion of the required color coding; he then j verified completion of JB color coding by physical 1 inspection. The NRC inspector also reviewed selected craft l training records and the Quality Surveillance records for- I J

6 ' the involved QC inspectors which verified the completion of the actions committed to by the applican ' j. (Closed) Unresolved Item (446/8611-U-13): Electrical cable separation distances in Reactor protective System Cabinet The cabinets which were identified to have separation problems have been verified by the NRC inspector to have been provided by Westinghouse Electric Company. The engineering analysis referred to in the unresolved item was , the generic analysis provided by Westinghouse and approved j by the NRC. The NRC inspector, therefore, determined that I this separation question had been addressed as a licensing issu I k. (Closed) Open Item (446/8611-0-14): Removal of electrical conductor insulation. The acceptability of the removal of a layer of conductor insulation was questioned by the NRC J inspector in the above item. Applicant personnel have ! provided the inspector a copy of Table E to the Low Voltage j control and Switchyard Cable Specification, 2323-ES-13B.1, ! Revision 1. This table indicated that the cables in 1 question were single conductors covered by an insulation l thickness of 30 mils and an individual jacket thickness of 15 mils. This cable jacket was the " insulation" removal of concern. Since the jacket provided protection of the cable during installation and is not required for insulation considerations, its removal was acceptabl l J 1. (Closed) Open Item (446/8611-0-15): Wrong crimper used on lighting system termination. The NRC inspector has witnessed approximately six additional lighting system :

(mostly nonsafety-related) terminations involving crimping a compression connector onto the solid conductors. In all j
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instances witnessed, the proper crimping tool was use Therefore, the NRC inspector has determined that the above observation was an isolated occurrence involving nonsafety-related lighting cables. In addition, by memorandum QA/QC-RT-2042, dated May 15, 1986, ERC .

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recommended that a 100% inspection be performed of the class 1E AC Lighting System Wiring; the NRC inspection of this { ISAp VII.c population will be documented in a separate j repor j l

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m. (Closed) Unresolved Item (445/8703-U-01; 446/8703-U-01): 6.9kv Switchgear Reportability. During Inspection 445/87-03; 446/87-03, the NRC inspector identified , unresolved item 445/8703-U-01 and 446/8703-U-01. In the J Brown-Boveri letter of September 5, 1987 to Texas Utilities ) Generating Company, the switchgear vendor states, " ...that in many cases the metal switchgear floors are unsupported by l

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the concrete floors, which is a critical shortcoming of the installation." Brown-Boveri noted that due to the breaker j weight of approximately a half ton, the floor of the j switchgear has taken a downward set. They note that the l

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condition "...is serious, not only from a seismic view, but from an electrical standpoint." They further. note that because of the floor distortion, there may be inadequate electrical contact from the breaker to bus and " Seismically, the unsupported. floors will act like a trampoline causing the breaker to rock and bounce around in the compartment, perhaps destroying the switchgear,..." In a second letter, dated January 14, 1987, Brown-Boveri recommended "... correcting the original defect, in this case, correct the floor which caused the problem in the first place."

The applicant has remedied the deficient condition by determinating the cabling and removing the switchgea After removal, the concrete floor and the mounting embedments were leveled and the switchgear repositioned and realigned. The cabling has been reterminated and the-switchgear will be teste ,

No additional information was provided by the applicant regarding the delay in reporting. The NRC inspector ; concluded that there was sufficient information available in 1 the letter from Brown-Boveri, dated September 5, 1986, to l have notified the NRC per the provisions of 10 CFR 50.55(e). ) However, the notification was not made until February 13, J 1987. This is considered to be a violation of 10 CFR 1 50.55(e)(2) which requires that notification shall be made l within 24 hours. The unresolved item (445/8703-U-01; I 446/8703-U-01) is closed having been resolved by violation ) 445/8707-V-01; 446/8706-V-0 n. (closed) Unresolved Item (445/8703-U-02; 446/8703-U-02): Nonconformance Reporting Program. The NRC inspector ! concluded the review of the applicants nonconformance j reporting program and procedures began in inspection reports

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445/8703; 446/8703 and identified as unresolved item Inspection criteria utilized were Criterion XV of Appendix B to 10 CFR 50 and the applicants approved Quality Assurance Pla Operations Administrative Control and Quality Assurance Plan (OAC/QAP),-Section 3.9, paragraph 4 states, " Materials, parts and components which are determined to be nonconforming, shall be identified and reporte Nonconformance reports shall be prepared which identify and describe the nonconformance,..." The documents reviewed were:

. Nuclear Engineering and Operations Procedure, NEO 3.05,
" Reporting and Control of Nonconformances."

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. Station Administrative Procedures, STA-405, " Control of Nonconforming Materials", and STA-606, " Work Requests and Work Orders."

. Quality Assurance Instruction, QAI-002, " Review of Quality Related Work Orders."

The findings of the review are listed below:

. NEO 3.05 contains wording that appears in variance with i criterion XV by adding the phrase "...and cannot be corrected within the scope of such requirements or other wise [ sic] requires an Engineering disposition" to the applicability statement. This appears to mean if it can be fixed by some means, it is not nonconforming and does not need to be reported as nonconformin . A note contained in Section 6.0 of NEO 3.05 states,
"Nonconformance Reports shall be prepared on items when a ' repair' or 'use as is' disposition is required."

The meaning here appears to be that the type of disposition is the judging factor for writing Nonconformance Reports (NCR's), not that a nonconforming condition exist . Section 6.4 of NEO 3.05 starts with a sentence that reads, "Upon discovery of a nonconforming condition, it , should be determined if a NCR is required." This again j relates to the above note for determining NCR l requirements by the type of dispositio . Section 6.5 of NEO 3.05 tasks QA/QC to perform an evaluation of NCR's. The evaluation is to " determine if the NCR is valid, complete, and sufficiently ; detailed so the problem can be clearly understood and l located." The steps following this section provide detailed criteria for completeness and sufficiency of i detail, but provide no guidance for determining l validity. Discussion with a representative of the I

; applicant's QA/QC department indicated that if an NCR '

could be written up on a Work Request, the QA/QC evaluator would invalidate the NCR. However, once the NCR has been invalidated and returned to the initiator, there is no explicit procedural instruction' requiring the initiator to write up a Work Reques . Implementing Procedure STA-405, " Control of Nonconforming Materials," states that those identified nonconforming conditions that can be dispositioned by

" rework" or " scrap (i.e. replace)" need not be reported-on nonconformance reports. Again as in NEO 3.05, it appears.that the criteria for writing NCR's is the method of disposition, not the fact that an item is

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i nonconforming. Additionally, the procedure is in variance with section 3.9, paragraph 4 of the OAC/QAP above which requires an NCR to be prepared which identifies and describes the nonconformanc . The applicability statement of STA-405 requires

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nonconforming conditions discovered during receiving inspections to be identified as nonconformances. In addition, the definition of nonconformance defines deficient documentation as a nonconforming conditio Contrary to this, STA-405 also allows items which are nonconforming during receipt inspection to be placed in a "QC Hold" area without preparing an NC The conclusion reached by the NRC inspector is that the nonconformance program and procedures are inadequate to i implement criterion XV of Appendix B to 10 CFR 50; and the ! applicants OAC/QAP Section 3.9, paragraph 4. This program inadequacy is considered a violation of Criterion XV of Appendix B to 10 CFR 50 (445/8707-V-02). Electrical Penetration Assembly (EPA) Replacement (51053) The NRC inspector continued the inspection of the replacement of Bunker Ramo EPA modules with Conax module In addition to verifying that the appropriate procedures were being implemented for storage, transportation, installation and connection activities on an ongoing basis, the NRC inspector performed the i following in-depth inspections of selected EPAs: ' EPA 1E-59, Module E, Low Voltage Power on March 17, 1987, the NRC inspector accompanied craft personnel to the outboard side of EPA lE-59, in the Unit 1 lower electrical equipment room, to witness the connection of the Module E pigtails to the field cables. The 12 Module E pigtails were #2 AWG solid conductors with Kapton insulation. Each of the conductors was covered with a HSI sleeve; this sleeve was damaged on four of the conductor The construction deficiency report (CDR) written for this condition was being dispositioned based on the Conax recommendation that the damaged areas be covered with additional sleeves of HSI. Since the connection would have to be disconnected (if work continued) to install the additional HSI sleeve, it was decided to await repair of the damaged insulation jacket before proceeding with the connections of Module The NRC inspector's review of the document package for Module E disclosed that Seal Area Evaluation Form (SAEF) 00230 indicated rejectable scratches on the inboard seal area which required rework. The SAEF further indicated that the seal area was acceptable following the rework on March 10, 198 Also included in the document package, in addition to inspection reports (irs) for transporting the module, was IR l-0108875 for the installation of the module into the E port of lE-59 and IR !

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i I I 1-0103967 for performing the electrical tests on the pigtail The NRC inspector noted that all 12 pigtails were indicated to be infinity (higher resistance to ground than was measurable) on the , insulation resistance test data sheet dated March 14, 1987, i (satisfactory results).

The craft personnel returned the HSI connection kits for Module E to the warehouse and were assigned to other activitie l As of the end of this report period, the connection of these modules to the field cables had not been mad , EPA lE-51, Module C, Nuclear Instrumentation System on April 7, 1987, the NRC inspector accompanied the craft and QC personnel as they transported this module, in its cardboard container, from the warehouse area to the laydown area in the J Unit 1 Electrical Equipment Roo The module, which contained 5 triaxial conductors, was removed from its container and the seal areas were inspected. The unacceptability of a scratch on , the seal area was documented on SAEF 00566. A review of the j documentation package showed that the EPA port seal areas were found acceptable on April 7, 198 The NRC inspector also observed that Module C was a replacement for a Conax Module which had been removed in accordance with NCR E86-104574, Revision j The disposition of this NCR on November 25, 1986, indicated that ! previously installed Conax modules C, D, E and F of epa 1E-51 and ' Module D of EPA 1E-65 were to be replaced because of the lack of earlier cable support and because of NCR E86-10526 A review of this other NCR indicated that the November 17, 1986 disposition

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l directed replacement of Modules C and D of 1E-51 because the end l sealant had been damaged by contact with a solven l The NRC inspector witnessed the removal of the scratch on the seal area to an acceptable finish under the direction of a project engineer. The scratch was removed by_pclishing the seal area with a Cratex wheel. Measurements of the flange width before and after the polishing remained essentially unchanged at 0.806 inch. The project engineer then completed the SAEF to indicate an acceptable finish had been attaine EPA 1E-65, Module D, Nuclear Instrumentation on April 8, 1987, the NRC inspector inspected the seal areas of this module which contained 5 triaxial conductors. The inspector then witnessed the installation of the outer Q seal and the three support bushing A review of the documentation package showed that SAEF 00576 had been appropriately completed as had the required irs. This module was also replacing a Conax module; see 1E-51C, above. The NRC inspector accompanied the craft and QC personnel as the module was transported, by hand, from the laydown area to the inside of the Unit 1 Reactor Buildin He observed that great care was taken in maneuvering the module through and around the various restrictions to position it for

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11-installation in the EPA por The protective covering was $ removed and the. seals and seal areas were cleaned and given a final check by the QC inspector. The module was installed and q the sealing ring tightened with a calibrated torque wrenc The l QC inspector was present throughout the evolutions involving ' handl,ing,of the EP EPA 1E-23, Modules B, D and E, Control Rod Drive' Power The NRC inspector reviewed the' documentation package for the above modules on April 8, 1987. The inspector observed that the 1 package contained the SAEFs for the ports and modules'as well as !

'the irs for transporting and' installing these modules similar to -{

those which would be expected for safety-related modules. The J NRC inspector identified no problems or questions from this revie ] i EPA 1E-12, Modules B and E,-Low Voltace Power On April 16, 1987, the NRC inspector checked the completed 1 connections for this EPA. Module B contained 7 #2/0 AWG solid ' conductors and Module E contained 12 #2 AWG solid conductors; only these 2 modules were installe The splice connections to the field cables for the conductors to be used from these modules (4 from Module B and 3 from Module E) were determined by the . ' inspector to be acceptable based on. physical observations of the HS The cable and' pigtail support for the Module E conductors was acceptable; the support for Module ~B appeared to exceed the len@th allowed by procedure. Further NRC inspection determined that the condition of the conductor unsupported length. exceeding the 36 inches allowed by QC Inspection Procedure QI-QP-11.3-28, Revision 33 had been documented by the applicant in IR 1-0104028, dated April 8, 198 EPA 2E-39, Module A, Reactor Protective Channel III j On March 26, 1987, the NRC inspector witnessed the connecting of i the EPA pigtail conductors to.the field cable inside-the Unit 2 i Reactor Building. The field cable was identified as ER 228117Z and was a #16 AWG TQ W/SHL; i.e., twisted quadruple. conductors

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l with a shield wire. .The EPA pigtails'were identified as 2E39A-11 through -15 and were 5 twisted #16 AWG solid conductors. The ; connections.were made in accordance with Design Change i Authorization (DCA)'31552 to. Drawing'2323-E2-0511, Sheet 39A, ' Revicion~1. The completed cable splice assembly was then placed in c Wie tray T24RREA2 .

" Ira Mtc inspector performed the'following:-
. Witnessed cable jacket and conductor insulation removalifrom :

the cable'and pigtails. . Verification of proper insulation removal. lengths was. performed by placing the splice barrel

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over' the conductors: to . ensure the conductor was inserted to ' t I .

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the center inspection hole when the insulation was flush with the end of the barre .- Witnessed the installation of the HSI shims on the cable and i pigtail conductors and the. placement of the HSI. kit I

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components prior to the actual conductor splicin . Verified the splice connections were made.as indicated on the drawing, and that the crimping tool was properly calibrate . Witnessed the~ installation of the HSI kit. A detailed discussion'of these kits was included in paragraph 2 of NRC : Inspection Report 50-445/87-03; 50-446/87-0 The NRC inspector observed that the craft'and QC personnel made frequent double checks, in excess-of procedural requirements,.to ensure that the completed connections.were. acceptabl EPA 2E-47, Nuclear Instrumentation on April 13, 1987, the NRC inspector observed the initiation of the required leak rate test for this Unit 2 penetration. This penetration contained three triaxial conductors in Modules B, C, D and E and #16AWG twisted quadruple < conductors in Module The penetration leak rate test commenced at 11:20 am at.50.3 psi The NRC inspector checked the progress of the~ test at 1:20 pm on~ April 14, 1987, and observed that the properly calibrated test gauge registered.49.7 psig. 'The installation and testing QC Procedure QI-QP-11.3-57, Revision 1, dated December'10, 1986, allowed'a pressure drop of 3.3'psig F for'this 10 inch EPA with the 5 modules installed over the required 30 hour-leak test duratio On April 15, 1987, the NRC inspector observed'the completion of the EPA leak testing; the test gauge was replaced with the normal monitoring gauge and the EPA repressurized to 60 psig.. The final test data was entered on IR 2-0103148 to indicate that the EPA final pressure at 8:25 am on. April 15, 1987 was 49;7 psig. The NRC inspector observed that the pressure drop was only 0.6 psig during the 45 hour test period which was very conservativ ,

     ' Plant Tours (71302)

The NRC inspectors performed frequent tours of Unit 1, Unit 2 and common plant areas during the inspection period. During these tours, particular attention was'given to the general housekeepin activities and the specific cleanliness, protection and storage of electrical equipment. The inspectors also verified that the-proper color coding and separation of electrical cables and components was being maintaine On March 26, 1987, the NRC inspector witnessed the installation of a cable'from the upper Train B electrical

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equipment room in the Unit 2 safeguards building. This installation was of interest because the green jacketed ! cable (indicating safety-related Train B) had been field ' color coded with red bands (indicating Reactor Protective Channel I) and was being installed in a cable tray with a K j designation (indicating a nonsafety-related tray). The craft personnel informed the inspector that, in accordance with Unit 2 Procedure CP-CPM-9.1, Revision 1, dated January 15, 1982, the cable was red color coded and would be tagged to indicate that it was a temporary modification. Since the 4 i inspector was familiar with the Unit 1 procedure (STA-602) which required purple color coding (not a normal cable { designation) for temporary modifications, he discussed this situation with applicant personnel. The inspector related his concern of the possible confusion arising from different requirements between Unit 1 and Unit 2 and that the i confusion of red color coding in Unit 2 could result in an I unauthorized reuse of the cable in a safety-related applicatio Applicant personnel agreed to take the inspector's comments under advisemen ;

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on April 1, 1987, the NRC inspector verified the existence of the required tags on the completed installation which involved two green and one orange jacketed cabl t The tags were placed approximately every five feet in cable tray ! T22KSBS46, and contained cable and usage identification informatio l

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b. ..on April 7, 1987, the NRC inspector observed a number of ! twist-on wire nuts making connections between wires pulled I out of lighting system Junction Boxes JB2SB5, 11, 13 and 41 l located in the Unit 2, Train A, Motor Driven Auxiliary Feedwater Pump Room. The connections appeared to be for a I temporary modification for a flexible cable which was '

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connected to wires from the JB by wire nuts for area lightin Applicant engineering assurance (EA) personnel informed the NRC inspector that, although not allowed by procedural instructions, there was no prohibition to using wire nuts, especially on temporary modifications to equipment which had not been final QC accepted. The NRC inspector questioned the control over wire nuts, i.e., what was the origin of the wire nuts in question, where else are wire nuts used and what assurance exists that the temporary modification in question would be returned to the appropriate configuratio It should be noted that a wire nut was detected by the NRC inspector connecting a lead of the auxiliary oil pump for Unit 2 Safety Chiller Cp2-CHCICE-06. This observation was reported in NRC Inspection Report 50-445/86-22; _ 50-446/86-20, and is included as one of the safety chiller inspection findings in Unresolved Item 445/8622-U-08; 446/8620-U-0 ,

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The NRC inspector was informed by applicant EA personnel that wire nuts are only used by construction maintenance personnel for temporary connection In addition, the q inspector was provided a copy of a new procedure for i lighting system inspections; ECP-11, " Inspection of ) Non-Class lE Lighting Terminations", Revision 1, dated )

-December 3, 1986. Since the JB involved non-class 1E '

lighting circuits, the NRC inspector had no further questions on this subjec ~ i 5. Exit Interview (30703) Exit interviews were conducted on March 31, 1987 and May 5, 1987, with the applicant's representatives identified in paragraph 1 of ] this appendi During these interviews, the NRC inspectors j summarized the scope and findings of the inspection. The applicant acknowledged the finding i l

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