IR 05000445/1987023
| ML20236S463 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/16/1987 |
| From: | Barnes I, Wagner P NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20236S457 | List: |
| References | |
| 50-445-87-23, 50-446-87-17, NUDOCS 8711250187 | |
| Download: ML20236S463 (17) | |
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S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report:
50-445/87-23 Permits: CPPR-126 50-446/87-17 CPPR-127 Dockets: 50-445 Category: A2 50-446 I
Construction Permit Expiration Dates:
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Unit 1: August 1, 1988 Unit 2: Extension request submitted.
Applicant:
TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES),
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Units 1 & 2 Inspection At:
Comanche Peak Site, Glen Rose, Texas Inspection Conducted:
October 7 through November 3, 1987 Inspector:
.W O44~
11fl6l67 P.
C. Wagneri, Reactor Inspector Date Consultant:
EG&G - A. Maughan (paragraph 2.c)
' i // 6 /e7 Reviewed by:
w I. Barnes, Senior Project Inspector Date hok O
500 g5 G
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a-Inspection Summary:
Inspection Conducted: October 7 through November 3, 1987 (Report 50-445/87-23; 50-446/87-17)
A_reas' Inspected:'Nonroutine, unannounced inspection of applicant
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actions and follow-up on items of' noncompliance / deviations, revi-
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L4 sions to' electrical specifications, general. plant areas (tours) and
'the~ Corrective Action Program.
U Results:
Within the four' areas. inspected, no violations or. deviations ware.' identified.
A meeting will be required to
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clarify inspector questions as.a' result of the review of the electrical erection specification-(paragraph 3) and-follow-up will be made of conductor terminations (paragraph 2.b) and pulling aid
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(removal (paragraph 4.0).
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DETAILS
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1.
Persons Contacted
- R.
W. Ackley, Project Manager, Stone & Webster Engineering
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Corporation (SWEC)
"R. P. Baker, Engineering Assurance (EA) Regulatory Compliance Manager, TU Electric
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- J.
L. Barker, Manager, EA, TU Electric
- R.
D. Best, Nuclear Operations Inspection Report Item
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Coordinator, TU Electric
- R.
C. Byrd, Quality Engineering (QE) Supervisor, TU Electric
- R.
D. Delano, Licensing Engineer, TU Electric
- D.
E. Deviney, Manager, Operations QA, TU Electric
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- T.
L. Heatherly, EA Regulatory Compliance Engineer,
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TU Electric
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- J. J. Kelley, Manager, Plant Operations, TU Electric
- A.
W.
Leach, Engineering Supervisor, Stone & Webster Engineering Corporation (SWEC)
- O.
W.
Lowe, Director of Engineering, TU Electric j
- D.
M. McAfee, Manager, QA, TU Electric l
- L.
D. Nace, Vice President, Engineering & Construction, TU Electric
- D.
E. Noss, QA Issue Interface Coordinator, TU Electric
- D. M. Reynerson, Director of Construction, TU Electric
- M.
J. Riggs, Plant Evaluation Manager, Operations, TU Electric
- A.
B.
Scott, Vice President, Nuclear Operations, TU Electric
- C.
E. Scott, Manager, Startup, TU Electric
- J.
C.
Smith, Plant Operations Staff, TU Electric
- M.
R.
Steelman, CPRT, TU Electric
- P.
B.
Stevens, Manager, Electrical Engineering, TU Electric
- J.
F. Streeter, Director, QA, TU Electric
- T.
G. Tyler, Director, Projects, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the November 3, 1987, exit interview.
2.
Follow-up on Items of Noncompliance / Deviation (92702)
a.
(Closed) Violation (445/8604-V-03; 446/8603-V-03):
Failure to perform required rework.
The lack of suffi-cient heat shrinkable insulation (HSI) over the vendor installed pigtail extension splices on the originally installed electrical penetration assemblies (EPAs) was the NRC inspector observation which led to the identifi-cation of a number of violations involving the EPAs.
These violations were included in the escalated l
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l enforcement Notice of Violation, EA No. 86-09, which was
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transmitted to TU Electric by NRC letter dated May 2,
1986.
The above violation was identified as Item I.B.5 l
in EA No. 86-09.
The NRC inspector had observed that instructions for reworking the splice insulation had not been accomplished which resulted in the above violation.
In response,
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TU Electric letter dated. August 4, 1986, stated that the failure to perform the required rework was the result of an oversight.
In order to correct this problem, the applicant stated that a program was being implemented to verify the qualifications of facility equipment and that the controls on equipment inspection and release for shipment had been revised.
In addition, the number of noncompliance findings presented by the NRC led to the applicant's decision to replace these EPA 3.
The NRC inspector's observations related to the replace-mont of the EPAs are contained in NRC Inspection Reports i
50-445/86-32, 50-446/86-26; 50-445/87-03, 50-446/87-03; and 50-445/87-07, 50-446/87-06.
The inspection reports discussed some of the differences between the original and replacement EPAs, one of which is the exclusion of the vendor installed splice.
Since the replacement EPAs do not have the splice in question, the failure to perform the rework is moot.
However, the implication that additional components may not have received required rework remains.
This question will be addressed in the NRC evaluation of the equipment qualification program (see paragraph 6, below) and in the NRC evaluation of the corrective actions related to violations 445/8604-V-04; 446/8603-V-04 and 445/8604-V-07; 446/8603-V-07.
b.
(Closed) Violation (446/8604-V-02):
Electrical cables spilling over cable tray side rails.
The applicant's first response to this item acknowledged that procedural controls did not exist to implement certain workmanship attributes contained in the electrical erection specifi-cation (ES-100) but denied that the condition cited by the NRC was a violation.
By letter dated January 22, 1987, in response to the NRC letter dated December 30, 1986, the applicant acceded that the condition was a violation and agreed to: (1) rework the cables in accor-dance with nonconformance report (NCR) E85-101983; (2) replace various cable tray sections, and (3) revise i
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the craft and QC procedures.
In addition, construction deficiency report (CDR)87-801 was issued to identify the
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need for reinspection of existing cable tray installa-i tions for cable overfill conditions.
The completion date for the required cable repulling was revised to
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4 September 1, 1987, by TU Electric letters dated May 8 and
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June 30, 1987.
The NRC inspector reviewed the NCRs, procedures, and specification referenced in the applicant's May 8, 1987, response to the portion of the violation dealing with the lack cf procedural control.
The three NCRs were i
dispositioned as follows:
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NCR E86-10459 was transferred to new NCR CE87-190 on
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January 16, 1987, and it was dispositioned."This is not a nonconforming condition, refer to DCA 25475,"
on February 13, 1987.
NCR E86-202317 was transferred to new NCR CE87-2268
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on February 23,-1987, and it was dispositioned "Not subject of nonconformance per DCA 25475," on i
April 27, 1987.
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NCR E86-250405 was transferred to CDR 87-3942 on
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September 18, 1986, and it was dispositioned " Void -
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DCA 25475 permits interlacing of cables," on l
March 13, 1987.
The NRC inspector verified that DCA 25475, Revision 0, dated September 24, 1986, revised the ES-100 requirements to " minimize" interlacing and to lay cables in trays to a
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uniform depth "to the maximum extent practical."
(These requirements were incorporated into paragraph 3.2.4.6 and Appendix E, paragraph 1.6.1 of Revision 3 to ES-100; see paragraph 3, below.)
While the inspector disagreed with the wisdom of this abatement of workmanship requirements for the installation of electrical cable, he was not aware of any regulatory requirement violation because of i
those changes.
The inspector also verified that the
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rework NCR (E85-101983) had been transferred to new NCR CE87-7841.
The NRC inspector began observing the repulling activi-ties for the cables which had been pulled back in accor-dance with NCR CE87-7841.
(The required cable tray sections had been replaced in accordance with DCA 24289.)
The first seven cables were repulled on August 12, 1987.
Of these, only one (EO246116) was pulled from the area of the reworked cable trays on the 832' elevation of the Unit 2 safeguards building to its destination in the Unit 2 cable spreading room located on the 806' elevation
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of the auxiliary building.
Two of the cables (E0246028 and E0246331) were pulled into the auxiliary building and coiled because the designated through-the-wall conduit sleeve (TWS) to the cable spreading room was filled with fire seal material; a different TWS had been designated
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for use to limit the congestion in the sleeve that.had
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previously been used.
Two of the cables (E0228481 and E0246328) were not pulled after preparation because the QC inspector observed that deficiency report (DR)
C87-2329 (a copy of which was in each cable package) had not been dispositioned to correct the duplication of the cable tray node numbers appearing on the cable pull eI cards.
The NRC inspector witnessed the pulling of E0246116 and observed that a total of 16 craft electricians pulled the cable by hand with one person stationed at each cable
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tray junction point; there were also two QC inspectors observing the repulling activity.
The repulling activity was performed in accordance with procedures, including the use of an approved lubricant where the cable was
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passed through conduit sleeves.
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The NRC inspector witnessed the repulling of four addi-tional electrical cables on August 13, 1987.
For one of these cables (EO226918), the NRC inspector checked the entire length of the pulled back cable for any signs of jacket or other cable damage and observed nothing unusual or unacceptable.
On August 25, 1987, the NRC inspector observed a new conduit (C-24033568) installed in the cable spreading room.
The new conduit provided an alternate cable route to produce needed cable slack.
Since the conduit sup-ports did not appear to be a final installation to the inspector, and a review of DCA-50528, which authorized the installation, disclosed no information on mounting requirements, the NRC inspector requested an explanation from the applicant.
(The support on one end, a U-bolt clamp, was observed on September 29, 1987, to be com-pletely off the I-beam to which it had been connected.)
The NRC inspector subsequently determined that Revision 3 of ES-100 (see paragraph 3, below) requires the general foreman to verify that the raceway is " adequately sup-ported" prior to pulling cables (paragraph 1.1.2.3 of i
l Appendix E), and that this requirement had been met.
l-The NRC inspector was informed on October 22, 1987, that the supports for this conduit were temporary and would be replaced with permanent supports in accordance with normal processing of the DCA.
As a result of the interdisciplinary review of the DCA, the Ebasco conduit support group will perform a walkdown in accordance with Procedure CPE-EB-FVM-CS-002, Revision 4, to evaluate and provide design information for permanent supports.
After the permanent supports are installed, the conduit will receive a final QC inspection.
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NRC inspectors continued'to witness various aspects of the cable repulling activities on a daily basis through the end of August, at which time these activities were scheduled to be completed.
The additional NRC activities are documented in Inspection Report 50-445/87-15;
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50-446/87-12 (446/8712-U-04).
On September 1, 1987, applicant personnel requested an additional 30 days extension for completing the cable rework for the remaining few (approximately 10) cables; this verbal request was followed by a letter dated September 14, 1987.
The NRC inspector observed the limited rework activities that were conducted near the end of the month of Septem-ber; however,.these activities were insufficient to complete the rework in accordance with the revised
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schedule.
The applicant, therefore, requested another extension (until November 1, 1987) for completing this rework by letter dated October 1, 1987.
On October 9, 1987, the NRC inspector observed that all of the cables had been pulled from the 832' elevation of the Unit 2 safeguards building into the auxiliary build-ing.
The inspector also observed that the cable tray in the auxiliary building near the TWS to the cable spread-ing room contained three cables with acceptable jacket repairs; two utilized tape, the other utilized a heat shrinkable insulation (HSI) sleeve.
The inspector noted that the cables in this tray (T240ADA79) were not sup-ported by cable grips but did have tywraps installed.
every 3 to 5 feet.
(See Violation 445/8604-V-03 and related responses for further information on cable grip installations.)
The NRC inspector witnessed some of the activities to prepare the electrical cables for reconnection as part of the normal plant tour observations; these included: cable jacket removal, continuity and insulation resistance testing, conductor and shield wire visual examinations for damage and the installation of insulating sleeves over the undamaged shield wires.
The inspector noted that CDR 87-10194EC had been issued for cracked Weidmuller terminal block sections and that NCRs had been written for damaged shield wires and damaged conductor insulation.
Since a number of problems have been identi-fled, the reconnection activities will probably not be completed for some time.
Therefore, the actual reconnec-tion activities will be observed in conjunction with
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future plant tours.
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i Since the electrical cables in question have been rein-stalled in an orderly manner and no longer overflow the cable tray siderails, this item is closed.
c.
(Closed) Deviation (445/8607-D-03):
Lack of QC inspector certification.
The NRC inspector was unable to locate the QC inspector certification during documentation package reviews as part of an ISAP VII.c inspection.
The I
applicant,-by letter dated February 18, 1987, stated that l
the QC inspector's certification for Procedure QI-AP-11.8-1, Revision 1, had been located in the perma-
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nent plant records vault (PPRV); therefore, the cited i
condition was not a deviation.
The NRC agreed with this assessment by letter dated September 11, 1987, and withdrew the deviation.
The NRC inspector verified that the certification file for the QC inspector now contains the document in question, i
3.
Electrical Erection Specification Review (51051)
The electrical erection specification, ES-100, underwent a i
major revision to incorporate the numerous design changes which were in effect and to revise various requirements to reflect present facility philosophy.
The NRC inspector reviewed the revised document (Revision 3, dated June 5, 1987)
to determine the significance of the changes and to verify that certain design changes had been incorporated.
Revision 3 was approved on August 14, 1987, and implemented upon comple-tion of craft and QC training on August 31, 1987.
The NRC inspector had previously compiled a listing of 59 DCAs, which had been issued against Revision 2 of ES-100, for use in evaluating the acceptability of craft and QC inspection procedures.
Review of the Revision Record in the front of Revision 3 disclosed a total of 45 documented changes and a listing of 124 DCAs which had been incorporated.
A comparison of DCA numbers showed that all but eight of the DCAs on the NRC list had been incorporated; the remaining
eight were all listed on the Open Design Change Log affecting i
The reformatted ES-100 is divided into six sections (I through VI) with the majority of the instructional informa-tion contained in 18 appendices (A through T).
The detailed requirements have been removed from the craft and QC proce-dures and included in ES-100 to limit any inconsistencies between the procedures and the specification.
However, Appendix K to ES-100 contains the " Quality Assurance Require-ments" and is essentially a compilation of the requirements which affect safety-related installations that are described throughout the specification and the other appendices.
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The'NRC inspector verified that requirements included in the
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NRC listing of design. changes had been incorporated into
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Revision 3 by noting the following additions:
j DCA 11702 requirements for connecting EPA pigtails to
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field cables were incorporated into Appendix K and l
Appendix P,
" EPA Installation and Removal."
DCA 12562 requirements and the commitments rnade in
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response to NRC violation (445/8614-V-03; 446/8611-V-10),
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which related to. drilling holes in cable trays, were incorporated into. paragraph 3.1.3.13.
DCA 31429 requirements, and commitments made in response
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to 446/8612-V-03, related to junction boxes installed in F
the reactor building, were' incorporated into paragraph 3.1.8.6.
DCA 31492 requirements for the proper torquing of West-
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inghouse Type AR relay terminal screws were incorporated
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into paragraph 1.5.d of Appendix D.
Appendix E incorporated the present requirements for l
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cable pulling activities; however, the adequacy of these requirements may be reconsidered when the applicant
studies (SDAR CP-86-71 and CAR-093) on this subject are completed.
l Appendix F incorporated the present electrical separation
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criteria.
The NRC has not accepted these criteria.
NRC review of Amendments 60 and 62 to the FSAR is pending.
The NRC inspector developed some questions from the review of ES-100 and requested a meeting with involved applicant person-nel to discuss those issues and obtain clarifications.
Due to personnel availability problems, this meeting is scheduled to occur during the next report period and will be discussed in that report.
No violations or deviations were identified.
4.
P,lant Tours The NRC inspector made frequent tours of the Unit 1, Unit 2, and Common areas of the facility to observe work in process, i
housekeeping practices, and other items of interest.
During
this period, the following observations were noted:
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a.
' Electrical Cable Protection (51063)
(1)
Protection of Cables in Trays The inspector made frequent observations of work activities in the vicinity of electrical cable trays to ensure that the contained cables were being adequately protected.
The cables were protected from welding and grinding activities by enclosing these activities in tent-like covers made of rein-forced plastic sheeting and/or covering the trays with fire retardant materials.
The inspector also ULserved that wooden, temporary covers were placed over the trays during construction or Post Construc-tion Hardware Validation Program (PCHVP) activities to prevent personnel from stepping on the cables.
The inspector found these provisions to be suffi-cient to provide protection for the electrical cables.
No violations or deviations were identi-fled.
(2)
Electrical Cable End Caps On October 7, 1987, the NRC inspector observed preinsulated, cap-type, compression splice connec-tors installed on the five conductors of spared cables SP118148 and SP118152 inside the Unit 1 Termination Cabinet No. 20 (TC-20).
The NRC inspec-tor assumed that these ten connectors had been installed as end cap seals, and while the inspector had no technical problem with their installation, he questioned applicant personnel about the previous procedural prohibition on the use of these connec-tors in nonlighting system applications.
The craft and QC procedures addressed only cables (not individual conductors) as requiring end protec-tion during in-process storage; however, the proce-dures only allowed the use of the cap type splice connectors on lighting circuits.
On October 14, 1987, the NRC inspector observed additional examples of this type of installation inside the ERF Computer Multiplexer Cabinet No. 2 (CR-24) which is also located in the Unit 1 cable spreading room.
On October 21, 1987, the NRC inspector was informed that, while the applicant engineering personnel also did not have a technical problem with the installa-tion, that the splice connectors would be removed
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and that a DCA would be. issued to clarify the requirements for end protection.
The inspector noted that the requirements for spared cable protec-tion had been clarified, but individual conductor protection was not added in. Revision 3 of ES-100 (see paragraph 3, above).
The NRC inspector, while personally endorsing a greater amount of control
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over spare and/or spared conductors was unaware of any regulatory. requirements which were not being adhered to.
No violations or deviations were
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identified.
(3)
Electric'al Cable Pulling Aid On October 15, 1987, the NRC inspector asked the applicant representative to explain the existence of a " fish tape" in through-the-floor conduit sleeve (TFS).A-027 near cable tray T23ACZ39.
(A fish-tape
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is a flexible metal band that is fed through con-i duits from one point to another in order to pull a i
cable from the later to the starting point.)
This I
cable tray had been discussed in paragraph 8 of Inspection Report 50-445/87-13; 50-446/87-10, because the cables were slumped due to not being supported; the replacement tywraps, which were proposed to be installed at that time had not, as
yet, been installed.
The cable slump problem has, however, been documented on DR C87-3288, Revision 1 (transferred from CDR 87-9093EC).
On October 21, 1987, the NRC inspector was informed that the existence of the fish-tape, which extended approximately 12" out of the TFS, had been document-ed on a NCR; however, as of the end of this report period, the NCR had not been located.
The NRC inspector will follow the resolution of this issue as part of the inspection of corrective actions for Violation 445/8626-V-02.
The TU Elec-
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tric, July 13, 1987, response to this violation
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stated that the action plan to resolve the correc-tive action report (CAR) 87-59 concern of pulling aids remaining in raceways would be developed by December 31, 1987.
No violations or deviations were identified.
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b.
Electrical Conductor Seal Assembly (ECSA) Installation (51053)
On October 21, 1987, the NRC inspector observed the installation of two ECSAs on the safety injection accumu-lator tank No. 2 fill isolation valve (HV-8878B) position indication limit switches.
The' installation of the Conax j
Buffalo Corporation, Part No. Nll222-02, ECSAs, was
performed in accordance with construction operations
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. traveler (COT) ES87-01094-V5700.
The NRC inspector observed that the steps in the COT were in accordance j
with requirements and were being followed, including the
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use of RTV to seal the threads of the housings to those in the limit switches.
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The NRC inspector noted that the installation was re-quired by DCA 58232 and that these ECSAs differed consid-erably from the previously used Conax ECSAs.
The differ-ences were mainly in the seal assembly (now a feedthrough module with a ferrule seal to the adapter body) and the lengths of the pigtails (approximately 12" on the device side and 12' on the field side).
In appearance and design, the ECSAs are similar to miniature Conax EPA feedthrough assemblies.
A review of DCA 58232 disclosed that various solenoid valve coils were to be replaced with screw terminal type coils and ECSAs were required to retain the class lE status of those solenoids located in a harsh environment.
The DCA listed a total of 39 valves which were affected, including 1HV-8878B.
Also included in the documentation package was DCA 57923, Revision 1.
A review of this DCA disclosed that Revi-sion 0 had been written to install ECSAs on selected limit switches to retain their Class lE status and that Revision 1 included the ASCO solenoid valve coil replace-ment and requirements to revise the associated junction box (JB) identification numbers.
The replacement of the solenoid valve coils and the installation of ECSAE with long pigtails eliminates the use of splice connectors at the device-to-ECSA-to-field wiring which had existed.
The same is true for the limit switches which already contained screw type terminals.
(The use of splices from solenoid valve pigtails to pigtail extensions had been the subject of NRC Violation 445/8518-V-01.)
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Further review.of:DCAl57923 verified that the JB had been properly marked as JB1C-292 Gland that the required. wiring
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would be connectedLon the six' position terminal 1 board (TB);within the'JB.
The TB.was the appropriate black colored Weidmuller TB for use within the reactor. build-ing. ;The NRC. inspector found the above-' activities to be acceptable; ;rua violations or deviations were identified.
During1the plant tour on' October 21, 1987, the NRC inspector also. witnessed the replacementlof jack. shafts in two Train C 6.9kv. circuit breakers, including lthe examination of the new and replaced components, and the..
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L installation of the new feedthrough adapter for: EPA 1E-46 Module C.
The'NRC inspector had no questions or problems with~these activities.
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-No violations or deviations were identified.
5.
Corrective Action Program (CAP) (51063)
a.
Post' Construction Hardware Validation Program (PCHVP)
Manual Review j
.The NRC inspector reviewed sections of the PCHVP. manual to. determine if additional information had been incorpo-rated related to the portion of the electrical, CAP involving the percent fill of conduit sleeves.
The i
results of the inspection of walkdown data collection for i
conduit sleeves was documented in NRC Inspection Report 50-445/87-16; 50-446/87-13.
The PCEVP manual provided the following list of proce-dures which are applicable to the electrical CAP:
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Procedure Title
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ECE 3.04-01:
Post Construction Hardware
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Rev. O, EDGN 1 Validation Program
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Implementation Plan - SWEC-CAP.
CPE-FVM-EE-023:
Acquire Data for Cable Percent-Rev. 2 Fill Calculations and Identi-i fication of Thru-Floor and Thru-
Wall Embedded Conduit Sleeves.
CPE-FVM-EE-064:
Acquired Data for Heat Rev. O Shrinkable Sleeve Installation j
CPE-FVM-CS-068:
Commodity Clearances.
Rev. 0
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CPE-SWEC-FVM-EE/
Post Construction Hardware ME/IC/CS-086:
Validation (PCHV) Program Rev. 1 Construction / Quality Control Reverification.
CPE-SWEC-FVM-EE/
Post Construction Hardware
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ME/IC/CS-088:
Validation (PCHV) Program Rev. 1, ICN 1 Engineering / Quality Control Reverification i
CPE-SWEC-FVM-EE/
Post Construction Hardware ME/IC/CS-089:
Validation (PCHV) Program Rev. 1 Engineering Walkdowns.
CPE-SWEC-FVM-EE/
Post Construction Hardware
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ME/IC/CS-090:
Validation (PCHV) Program Rev. 1 Quality Control Reinspection.
NQI-3.09-E-001 Inspection of PCHVP Commodities per Field Verification Method No. FVM-086.
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NQI-3.09-E-002 Inspection of PCHVP Commodities per Field Verification Method No. FVM-088.
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NQI-3.09-E-003 Inspection of PCHVP Commodities l
per Field Verification Method FVM-090.
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The[NRC' inspector' reviewed these procedures, except as
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indicated below, and observed that most were' general
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directives which lacked. specificity; however,
CPE-FVM-EE-023 was sufficiently. detailed to provide J
adequate guidance for data collection.
The inspector
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.noted thatLthe implementing procedures (NQI-3.09-E-001,
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'tional information included on.how the data collected
from the conduit: sleeve walkdowns was to be used.
A detailedLreview of.CPE-FVM-EE-064 will be conducted prior to NRC inspection of that portion of the electrical' CAP.
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b.
Electrical CAP.
(1)
Conduit Sleeve Percent Fill Calculations a
The NRC inspector had intended to verify the accura-i cy of the percent fill calculations for TWS'and
.through-the-floor conduit sleeves 1(TFSs).using the data previously collected.from walkdowns and compar-
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ing calculations'with those-generated by the Cable
'and Raceway-Data System (CARDS).
However, recent reports' submitted to the NRC raise' questions on the accuracy of the CARDS data.
These letters are:
TXX-6779 dated September 28, 1987.- Submitted
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SDAR CP-87-79 interim report on possible inconsistencies on percent fill calculations.
TXX-6836 dated October 9, 1987.
Submitted'SDAR
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CP-87-98 interim-report on possible wrong cable diameters being used in calculations.
TXX-6843 dated October 9, 1987.
Submitted SDAR
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CP-87-99 interim report'on cable which exceeded the maximum allowable outside diameter.
The NRC inspector was informed by SWEC personnel involved in this CAP that because of these identi-fled problems, a recommendation had been made to revise the CARDS data base to reflect the maximum cable outside diameters and recalculate the percent fill of the conduit sleeves.
Therefore, NRC verifi-cation of the accuracy of the calculations will be deferred until the CAP efforts have been completed.
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Embedded Conduit Sleeve Identification The third portion of the conduit sleeve CAP program involves providing unique sleeve identification.
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I The applicant originally committed to sleeve identi-fication in response to NRC Violation 445/8513-V-01.
The design of the new identification markings was provided by DCA 21464.
The applicant, by letter dated September 23, 1987, revised the completion date for final design validation of conduit sleeve identification to March 1, 1988.
The NRC inspector has not, to date, observed any new identification markings installed for these sleeves.
No violations or deviations were identified.
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6.
Equipment Qualification (EO) Status Review (25576)
Between October 6 and October 8, 1987, P. Wagner, M. Malloy, j
and G. Hubbard held discussions with TU Electric and Impell l
personnel on_the methodology and status of the EQ efforts with emphasis on 10 CFR Part 50.49 equipment qualification.
In addition to determining the status and schedule of this effort, so that a timely follow-up NRC audit can be conducted, the NRC personnel' reviewed some selected documentation to gain an understanding of the approach being implemented.
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The NRC personnel expressed their concern over the number and significance of the findings made by the TU Electric Technical
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Audit Program on the EQ effort.
While these findings indicated a well working technical audit program, the fact that a number of significant findings were documented indicat-ed possible weaknesses in the methodology being implemented in i
the EQ program.
The NRC review identified concerns similar to the TUE audit findings.
The onsite inspectors will continue to monitor the EQ effort and the Technical Audit Program effort in order to determine an appropriate schedule for an NRC follow-up audit.
7.
Exit Interview (30703)
An exit interview was conducted November 3, 1987, with the applicants representatives identified in paragraph 1 of this report.
During this interview, the NRC inspector summarized the scope and findings of the inspection.
The applicant acknowledged the findings.
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The inspector also' indicated that no explanation had, as yet, been provided relative to the capacitors he had discovered in the emergency diesel' generator control panel-(see unresolved issue 445/8718-U-11), and that as a result of his review of drawings and DCAs he had questions relative to the accuracy of the working copies of drawings.
These matters had been previously discussed with appropriate applicant personnel and will be followed as part of the above unresolved item.
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