IR 05000461/1987004

Insp Rept 50-461/87-04 on 870112-0224.Violations Noted: Failure to Accomplish Switchgear Installation in Accordance W/Design Drawing Requirements

ML20207T352
Person / Time
Site:	Clinton
Issue date:	03/18/1987
From:	Falevits Z, Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207T334	List: IR 05000461/1987004 ML20207T333 ML20207T343
References
50-461-87-04, 50-461-87-4, NUDOCS 8703230470
Download: ML20207T352 (18)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/87004(DRS)

. Docket No. 50-461 License No. NPF-55 Licensee:

Illinois Power Company 500-South 27th Street Decatur, IL 62525 Facility Name:

Clinton Nuclear Power Station, Unit 1 Inspection At:

Clinton Site, Clinton,-Illinois Inspectio.1 Conducted:

Jan ary 12 through February 24, 1987-I.

Inspectors:

Z. Falevits 3//f/?7

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Date R. h. W Approved By:

R. N. Gardner, Chief 3//Bf8i Plant Systems Section Date Inspection Summary Inspection on January 12 through February 24, 1987 (Report No. 50-461/8/004(DRS))

Areas Inspected:

Routine, unannounced safety inspection conducted to eview licensee action on previous inspection findings; licensee action on 10 CFR 50.55(e) report; review of safety-related panel installations; licensee reinspection program for safety-related panels; review of equipment excluded from licensee reinspections; 4.16KV ESF switchgear; diesel generator design logic; and personnel training no violations were identified in Of the eight areas inspected,ied during the review of 4.16KV ESF Results:

One violation was identif seven areas.

- switchgear installations (Paragraph 7 - failure to accomplish activities in

.accordance with the requirements of design drawings).

(62705,92701,92702,

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'99020,41400)

I 8703230470 870318

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DR ADOCK 0500

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DETAILS 1.

Persons Contacted Illinois Power Company

+J.-S. Perry, Manager, Nuclear Program Coordination

1. • +F. A. Spangenberg, III, Manager, Licensing and Safety

1. +R. E. Campbell, Manager, QA

• +J. Greene, Manager, NSED W. Conne11', Manager, Nuclear Planning and Support K. A. Baker, Supervisor, I&E Interfaces

1. +J. A. Miller, Assistant Manager, NSED

+D. R. Falkenheim, Supervisor, NSED

+K. A. Baker, Supervisor, I&E Interface

• J. Emmert, Supervisor, NSED Electrical J. Palchak, Supervisor, Plant Support P. Thompson, Supervising Electrical Engineer, NSED

1. • +J. Brownell, Licensing Specialist

+G. L. Edgar, Attorney

+S. A. Sabel, Attorney

+T. A. Butera, Lead Electrical Engineer, QA

• J. D. Weaver, Director, Licensing Stone & Webster

1. +P. Raysircar, Project Manager Sargent & Lundy Engineers

+W. G. Schwartz, Assistant Manager, Electrical Department

+M. S. Zar, Senior Electrical Project Engineer

+J.'S. Steele, Site Electrical Project Engineer US NRC

+C. J. Paperiello, Acting Deputy Regional Administrator

+J. J. Harrison, Chief, Engineering Branch, DRS

+C. E. Norelius, Director, Division of Reactor Projects

+R. F. Warnick, Chief, Reactor Projects Branch 1

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R. C. Knop, Chief, Reactor Projects Section IB

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+R. N. Gardner, Chief, Plant Systems Section, DRS l

• T. P. Gwynn, Senior Resident Inspector

1. +M. McCormick-Barger, Project Inspector

+B. Berson, Regional Counsel

• Denotes those participating in the telephone pre-exit meeting on

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L January 22, 1987.

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1. Denotes those attending the exit meeting on February 24, 1987.

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office in Glen Ellyn on February 11,;1987.

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'" t,h 1 Additional'planttechnicalandadministrativepersonnsherecontacted'

by the inspector during the course of the inspection.1

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2.

Action.on Previous' Inspection Findings'

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(0 pen)UnresolvedItem(461/86071-02(DRS)):

This its' concerns

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licensee-inspection activities and corrective action to-address l; -

problems' involving improper installation of heat shrinkable tubing manufactured by Raychem.

During the~ previous inspection the

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inspectorf noted that the inspection checklist ~ used by the ~QC.

inspector contained a general' acceptance criteria of a specific-

/0 attribute.' It did not contain inspection r,equirements for:

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minimun bend radius

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non qualified or braided. jacketing materials in splide area-

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heat shrinkable materials used

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During this inspection the inspector visually examined five randomly selected ~ cables containing.Raychem splices. All five cables had

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been.previously.__ inspected by the licensee during the splice'

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reinspection program. Two of the five cables (1FC030 and 1FC04D)

had been reworked with new tubing; the other three cables (1SC76A, 1RS79A'and 1RI81D) were found acceptable by the' licensee.

The-reworked, contained a wire marker u,on-cable 1FC04D, which had been inspectorJobserved that the splice nderneath the inspected heat =

shrink tubing.

A second reworked splice on cable IRS 79A contained 1a deep surface indentation due to a tie wrap which was p'la.ced on-the-outer jacket surface of the heat shrink tubing.- Tte licinsee's engineer stated that these splices were found to ba acc~eptable since '

the 1"' overlap requirement was not violated. The inspector informed'

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the licensee that the results of this limited inspection reflected

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poor workmanship and minimal.QC involvement'in documenting such.

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anomalies.- The inspector attempted to expand tnis inspection and-4*

examine power cable splices;' however, due to difficulties in

'.s completing the appropriate documentation required to inspect these

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components, this could not be accomplished during this> inspection.

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Licensee corrective action addressing this-issue will be further-examined in a future inspection.

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(Closed)UnresolvedItem(461/86072-03(DRS)):

This item concerned discrepancies identified between the controlled schematic diagrams (E02-1AP99 sheets-13 and 38) and the actual field installation for

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Diesel Generator 1A output breaker relay 227X-DG1KA.

Condition

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Report (CR) 1-86-11-144 documents the identified discrepancies and A'

provides corrective action.

The resident inspector's review of recordspertainingtothisissueindicatedthatFJeldEngineering Change Notice (FECN) 8189 directed wiring changes to relay

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227X-DG1KA.

These changes had been completed in March 1985 and

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y drawings. The resident inspector further noted that " Document e

I -Supersede / Void Request" dated August 7, 1986, identified the licensee's failure to reference FECN 8189 during subsequent FECN i

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,3 ncorporat ons.

During this inspection the inspector reviewed the y

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(b wiring and contact configuration of relays 227X-DG1KA&B and the e

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\\ applicable' change-documents.

Based on this review, it appears that Y

an inadequate review of design change. documents was performed prior to the release of FECN's 9184 and 10957 which superseded FECN 8189.

Sargent5LundyletterSLEI-20261,datedDecember 12, 1986, indicated

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that all

"C" (closed) items which include superseded, incorporated, and voided documents have been reviewed.

Results of this review have been submitted to the licensee for dispositioning.

The current

system of! posting design change documents within the document status s

system awi on design drawings has been reviewed during previous u.

s inspections.

A violation related to posting of design documents t

is documented in Inspection Report No. 461/86073.

This item is considered closed.

c.,(Closed)UnresolvedItem(461/86073-02(DRS)):

The inspector

expressed a concern that should a thermal overload condition t occur at 95% valve closure during an ESF actuation the valves

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A togotol,circuitwilldeer.ergizepossiblynotallowingthevalves seal.in

the 100% fully closed position.

Subsequently, 7P discussed s

e this issue with NRR contending that based on the low pro?ibility

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redurdancy, and the inertia of the valve operator, this 'ssue should

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not b.n'of concern.

NRR accepted IP's aosition and found the existing

valve circuits' acceptable.

Based on NRR's acceptance of IP's j, position, this item is considered closed.

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3.

' Licensee Action on 10 CFR 50.55(e) Report ('Open)10CFR50.55(e) Item (461/86008-EE):

Improper installation of Raychem Heat Shrink splices in Class 1E circuits.

The licensee performed a re' view to identify installations which utilized Raychem heat chrink in safety-related circuits.

Licensee inspection determi;vd tMt of the 252 cables containing Raychem heat shrink tubing, v

46 had to'be, reworked / repaired due to deficiencies in the Raychem heat shrink tybing.' The deficiencies identified consisted-of improper

- adhesion \\and/or heating, incorrect size, and improper seal length.

( 'Licente C'dndition Attachment 1 to NPF 55, Item 2.C, requires that the licchsee providt a program for resolvin adequac of Raychem s)lices t(kpriortoexceeding51ercentpower(46186008-EE

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Based on tie

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teview conduct'et by t1e inspector, the licensee's program appears to be acceptable; however, aspects relating to its implementation, such as

,I training and workmanship appear to lack consistency.

Additional inspections in this area will be conducted in the future.

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During the-previous'inspectiodInspdcticE~ Report No. l461/86073(DRS))'

% @r the inspector : identified conditions potentially adverse to quality.in-

~J the area of~ design.changejeontrol and field implementation.of design =t

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changes; In addition, problems ^in )osting of design-change. documents'

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were noted.

At the conclusion of tie inspection the licensee 1 indicated 3 that the identified deficiencies were located in HVAC panels which were-

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af excluded from the licensee's -reinspection program conducted in 1985. i o

i This reinspection program was instituted ~by the licensee to address.

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. wiring ahd sorkmanship deficiencies identified:in safet

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> supplied doctr.ical panels (10 CFR 50.55(e) Deficiency h'-related vendor.

o. 55-85-06)..

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The HVAC-and the General Electric Power Generation Control Complex

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(PGCC)'pendls were exc1uded from the licensee's inspection pro TAM

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because.they had been ;previously inspected-on a, sample basis. gram

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'During this? inspection,ich had been inspected during the licensee'sthe in

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local control panels wh reinspection program to determine whether similar deficiencies existed.

d-The following attributes were examined using the applicable design

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documents and dr'awings:

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quantity, of conductors landed per termination poi, t

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color codes of field cables t

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-cab \\el number and internal wire identification - '

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fuse size (where'possible)

Wrimp'ing of. lugs,_ h6s(wires, wire size ahd type

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,4 jumpers and ground c&nections

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. splices

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-incorporation and postirig of design change documents

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workmanship

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~Duringtheibspections,-theinspectoridentifiedthefollowing_

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deficiencies:,

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High Pressure Core Spray Protective' Relay Panel 1H22-P028 (Internal

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. External wiring diagram E03-lHZZ-P028, Revision G)

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4:, 6 4(1) Differential relays E22-K30A, K30B and K30C were' missing device

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and relay numbers.

In addition, the relays were identified ~on N#

the drawing as being located in the front section of the panel,

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while in the field they were mounted in the rear.

The device and relay numbers were still identified on the front portion of eV the panel.

Finally, the' drawing revision block did not specify y,

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d #Nf the appropriate GE document used to incorporate the addition of

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~these relays'onto the drawings.

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.(2)l Internal wiring of the following~ devices'-did not conform to the-

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specified conductor size identified on the drawing:

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Field Drawing

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. Conductor Size

. Conductor Size a): AG-1 to AH-1 to'AM-1-

1. 14

1. 16

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b _AM-2 to-AV-3~to AN-2

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1. 16

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.AF-3 to AZ-9

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.#14 L(d - BF-8 to AZ-7

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1. 14-(e)'AF-7LtoAZ-17.

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-(f)':BF-10 to-AZ-15

1. 10

1. 14 Root'cause for the discrepancies was noted as' drafting errors,_

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and failure to incorporate Field Deviation Disposition Requests (FDDRs) onto the drawings:(ref. FDDR LH1-1300-1, 2675-1 and FDI-SKCY).

(3) Identification labels-BZ and BC were missing from relay K16. and device TSI.

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(4) Protective fuse-(F1) cover plate and label were observed to be

'. laying on the-floo'r.

(5) Twisted pair Cable No. 1HP24C which terminated to TB-AA contained pair numbers which did not conform to the numbers specified on

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the drawing.

Also, this cable was supported by a series of f, ~._ o'

cable ties connected to each other and used to allow for 6"

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separation;.This arrangement was found to be acceptable by GE.

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.(6) The spare green and white conductors of cable 1HP020E were observed to be untaped and in contact with-energized terminal

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(7) The main panel door had to be-detac.hed from the panel in order to allow the inspection of the panel's components.

Louver 1W12YC was situated behind the panel's ' door not allowing the door to open more than 15".

(8) Panel internal lighting was out.

(9) A review of the posting of design change documents applicable to Drawing E03-1H22-P028 in the Design Status System (DSS) program and a review of the drawing itself indicated that

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(a) FDDR-LH1-897-1 was not shown in the DSS.

_(b) FDDR-LH1-897-3 had been incorporated in the field in November 1985; however, it was still posted against the drawing and shown on the DSS.

No approval authorization date or line status was given in the DSS.

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' h (c).ECN-7380-0'had been incorporated in the field; however,'

. it was still: posted in the DSS and against the; drawing.

The: DSS did not indicate the status of control room'

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drawing markup as required.

(d)-FDDR-LH1-3880-0 was: observed to'be incorporated in the

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field;.however, it was still posted in the DSS and against

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the drawing.

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' At-the conclusion of the. inspection of Panel 1H22-P028,.the.

inspector requested that the licensee ~ conduct a~ review of the-control room drawings-and of postings in the DSS to determine.

if'a. generic. problem existed in the areas of posting design.

documents and updating of control. room drawings which are used-

by theLoperators and which must reflect the latest as-built information.

The licensee indicated that a program to address-

- the inspector-concerns was being developed.'

The inspector reviewed the following change documents,

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travelers and test result data sheets associated with panel

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1H22-P028:

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FDDR:LH1-2342-1

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LH1-3880-0

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- LH1-3489-5

LH1-3027-2

LH1-897-3

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LH1-3027-2

LH1-3555-1

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FDI-SKCY-0

ECN-7380 Traveler No. HP007-2, Differential Voltage Relay PVD21

test GTP-403 for: relays E228-K30A, B and C.

During this inspection the licensee took prompt corrective action to address a number of the identified discrepancies and' issued

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MaintenanceWorkRequest(MWR)-C28797,C28668'andDocument

. Transmittal' Form (DTF)-JK1356.

The licensee indicated that

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appropriate corrective action would be taken to-resolve the inspector's' concerns and findings.

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Division III Diesel Generator Control Panel (1E22-S0018) (Internal wiring Diagram E03-lEZZ-5001B, Sheet 4, Revision D, and Sheet 6, Revision E)

The function of this panel is to ensure the automatic startup and shutdown of-the diesel generator.

(1) Relay K54-1, Terminal No. 6, contained one terminated conductor; however, Sheet 5 of the drawing indicated

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two conductors at Point 6.

In addition, TB11-48 contained

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one terminated-conductor on the internal side of the terminal-block; however, Sheet 4 of the drawing' indicated two conductors at Terminal 48.

The conductor between relay K54-1 Point 6 and terminal block TB11-48 was subsequently determined to have been added-by GE FDDR-LH1-2851, Revision 0, dated March 22, 1985..This change was added to Sheets 4 and 5 of the drawing but was never implemented in the field.

Licensee initiated DTF No. JK1356 requesting GE to resolve this discrepancy.

(2) TB11-65 contained one external and two internal' wires in the field; however, Sheet 4 of the drawing showed only one conductor on each side of the terminal block.

Also, TB11-68 contained one internal conductor; however, the drawing showed none.

In addition, FDDR LH1-3311, Revision 1, was incorrectly posted against Sheet 4 of the drawing, as it should have been posted against Sheet 6.

Finally, FDDR LH1-3311-1~and LH1-3914-0 were shown on DSS but not posted against Sheet 4 of the drawing.

The-inspector subsequently determined that the internal wires from TB11-65 and TB11-68 were added by FDI-SKRL.

Subsequently, FDDR LH1-2851-0 deleted these wires but the work was never implemented in the field.

The inspector was informed that GE would issue FDDR-LH1-4032-0 to complete this work in the field.

In addition, FDDR-LH1-3311, Revision 1, will be revised to-correctly lost the E03-1H22-P028 drawing sheet number.

Finally, t1e posting of FDDRs would be examined by the licensee.

(3) Two untagged internal wires were found snipped and laying in a wireway between TB11 and TB13'of this panel.

Licensee investigation revealed that the ends of both wires had not been terminated or tagged.

On July 20, 1984, IP notified the NRC of a potentially reportable deficiency No. 55-84-16 concerning the internal wiring in the electrical panels attached to the High Pressure Core Spray (HPCS) Division III Diesel Generator.

Ap]arently, the two snipped wires identified by the inspector had aeen identified by the licensee during their investigation of this issue in 1984, but were never removed.

c.

Remote Shutdown Panel 1C61-P001 (W/D E03-1C61-P001 Sheet 6, Revision 1)

(1) The drawing indicated that Terminals 3, 6 and 7 on the isolated signal common bus (SC) contain two conductors each; however, the inspector observed that only one conductor was terminated at Points 3, 6 and 7.

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The' inspector: subsequently determined that FDDR'LH1-2821,

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Revision 4,, revised theidesign application of Meters-C61-R005,-

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r10 and 11 by removing the, negative wires from the signal common

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1 bus. These wires were removed in the field but were not:

removed from the connection' diagram;'therefore, the-schematic-

diagram was not in agreement with the connection diagram.

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-Alsor present. field wiring contained two wires landed-at; signal common Bus SC-1.

Per the connection diagram,.one of-these wires'should be reterminated to' Point SC-3.

S'ubseguent to the above-findings, GE issued FDDR-LH1-4033,.

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' Revision 0, to resolve these discrepancies.

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(2) Sheet.5 of the' drawing indicated that Points 2, 5, 8,;15, 18

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and 21 of Signal Resistor Unit SRU3) contained one conductor each;however,noneofthesepo(intswereobservedtobe terminated in the field.

~ The-inspector-. subsequently determined that Field Engineering Change Notice No.-12932, dated November 4, 1985, revised the Suppression. Pool Temperature indication loop,by removing-Points 2, 5, 8, 15, 18'and 21 from the circuit;-however,-the-drawing'was not: corrected.

Subsequently Sargent & Lundy issued a deviation per PI on February 7 1986,CP-022 incorporate the deviation onto the drawing.

This created the-discrepancies noted between the field installations and the design' drawings. The licensee stated that the drawings would.

be corrected.

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The~ deficiencies identified above'were similar to those previously cited in NRC Inspection Report No. 461/86073 issued on January 12, 1987.

As.a result of the identified deficiencies, a meeting was held on January 30, 1987, in the Region III office between the licensee and l

Region III staff.

The inspectors indicated that the~ licensee appeared to have deficiencies relating;to installed equi) ment versus design drawings and design change documents.

During tie meeting the licensee stated that a program would be implemented to review a sam,)le of wiring

' diagrams against installed safety-related equipment which 1ad not been previously inspected under the overinspection program conducted during the period of 1982-1985.

The-first inspection sample included 28 HVAC panels and 18 Main Control

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Room termination cabinets.

During this inspection the licensee identified numerous deficiencies such as: wiring not installed per drawings; jumpers installed in field not shown on drawings and vice versa; deficient lug crimping; damaged components; shields not connected; ID deficiencies; and documentation deficiencies.

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A second meeting was held on February 11, 1987, in the Region III offices between the licensee and Region III staff.

The licensee proposed an inspection program which would involve the reinspection of all 230 Class IE Electrical Panels and the development of final as-built electrical drawings.

This program, however, would not be subject to any milestone and had an estimated completion date of December 31,-1987.

During the meeting the licensee indicated that 92 safety-related.

electrical panels had not been reinspected in the past in conjunction with any of the licensee's verifications, reinspections, or 10 CFR 50.55(e)

investigations.

The NRC informed the licensee that the 92 panels, not previously reinspected, would have to be reinspected before a full power license would be granted, and recommended that the licensee not attain initial criticality unless a sample of the 92 panels were reinspected.

Subsequently, IP developed a plan to reinspect the remaining 92 panels prior to initial criticality.

5.

Review of Licensee Panel Reinspection Program Duringthisinspectionperiodtheinspectorexaminedthemethodology of the licensee s reinspection program, including the resolution and-disposition of electrical / instrumentation and control deficiencies identified during the walkdown inspections.

Based on the insaector's concerns identified during the initial panel reinspections, t1e licensee developed a comprehensive training program (see Paragraph 9) and developed verification and evaluation procedures and checklists.

In addition, the licensee took action to assure that QA/QC was involved in the reinspection program.

This was accomplished prior to conducting subsequent inspections on the remaining 92 panels.

Region III's overview of the licensee's reinspection program was accomplished by onsite as-built inspections and meetings with the licensee's management and staff.

In addition, the inspector reviewed selected engineering evaluations made by the licensee and architect / engineer of deficiencies identified during the inspections and reviewed Quality Assurance audit findings of the as-built program.

The review indicated that the licensee had not conducted a comprehensive analysis and review on some of the findings.

The inspector discussed the specific details with the licensee and discussed the importance of conducting a thorough analysis of each finding to determine adequate corrective action.

The inspector selected several licensee walkdown packages which had been verified and evaluated for review.

The following observations were made:

a.

Walkdown Item No. 2-1076-31 - This item identified that the white and red conductors of Cable IVC 61J at TB191 and 192, located in Panel OPL72JA, were not installed in conformance with Drawing E03-0PL72JA, Sheet 13.

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Rbiewofthisitemindicated-thattheE03-drawing lisincorrect-

'and 'that the field installation should. function properly. 'The.

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111censee' stated that'-the root ~cause of this deficiency could be

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' attributed to =a change that was made in the' field by unknown -

personnel without-prior authorization to perform the. change and-without documenting the change.

. b.

.Walkdown Item No. 2-1063-07' ; Drawing E03-1P706B: Sheet 1-(loopAMSIV),showedajumperbetweenPoint9ofTM032and Point 20 of TM033..This lum)er was not installed in the.

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field. ' Another jumper not s10wn on.the= drawing was 'found to

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-be installed between Points 4 and'20 of-TM033.

Licensee review of this finding indicated that the miswiring would

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result in lack of in on plant. operations.put to;the GETARS computer.and have no impact

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A more thorough review by the NRC inspector

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indicated that the above~ circuit was used to determine the closure time of the MSIVs during an.ESF actuation.

In addition, the circuit-was used to monitor and record plant transients.

The'same miswiring.

was-also identified during this walkdown on TM019-20 which serves -

-Loop C MSIVs. The inspector informed the licensee that a more comprehensive:indepth design review of the findings was.needed to determine the appropriate category of the fi, eld noted exceptions.

' Subsequently,.the inspector was informed that the above

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deficiency was noted by a test ' engineer during a recent-surveillance.

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.Walkdown ~ Item No. '2-1055-7 -~ This item identified a loose conductor.(B55) in Panel 1PL53JB.

The licensee determined that in a worse case' failure the loose wire would fail to provide power to' Panel Fuses f01, FU2 and FU3 and that several services would be~1ost.

The 1%ensee, however, determined that this would.

not cause the degradation of-a safety function below an acceptable-level.

During the review of this-item,.the inspector noted that

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-FU1:was the only fuse ' depicted.on the schematic diagram; FU2 and FU3 were not shown. The inspector raised ~the concern that-while

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Ful, FU2 and FU3 are physically' connected in parallel in the field, L

the schematic does not show the circuits for FU2 and FU3. This

.might lead to confusion by operators and maintenance personnel.

l The inspector requested that the licensee examine this matter and determine if it applies only to the HVAC schematics or if it is a generic problem.

This issue will be further reviewed during

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NRC review of the licensee's response (461/87004-01(DRS))pending subsequent inspections.

This is considered an open item L

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d.

The inspector examined the following selected walkdcwn items:

E 2-1063-08, 2-1064-04, 2-1065-11, 2-1065-16, 2-1066-01, 2-1070-04, 2-1070-05, 2-1047-06, 2-1050-06, 2-1050-12, 2-1052-16, 2-1054-59, 2-1055-06, 1070-07.

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? Typical; findings were:

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Configuration'shown on: documents other than the' drawings

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' Incorrect wiring,Jrelay settings, missing fuses, etc.

which have. impact on equipment function

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Incomplete grounding or termination of shield wires.

Inaccurate posting.of Design Change Documents

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• L Labeling of, cables, wires or devices was incomplete or

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missing-

.DeviceElocation depicted.on drawing did'not match field

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installationi

Damaged terminal block, missing screws.

Improper. lug crimping,- loose conductors

-Improperly set. protective relays

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The review' indicated that some of the root causes of thel-findings could be attributed.to poor workmanship, inadeguate

incorporation of design change documents, drawin damaged components, inaccurate DSS.information, g deficienci and hardware-deviations. 'The licensee determined that none of the identified deficiencies would have resulted-in a reduction of functional capability ~of a system beyond that allowed by-plant design.

In a continuing effort to overview licensee ongoing activities and in order to determine'the adequacy and comprehensiveness of the. licensee's. field inspections,,the inspector selected the-following verified (completed) panels for visual field

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inspection:

H13-P851 - HVAC/B0P Misc. Cont. and XDCR panel Div. II H13-P601 - Reactor Core Cooling Control Panel-H13-P672 - Neutron / Process Radiation Div. panel Div. I H13-P861 - HVAC/B0P Misc. Cont. and XDCR'

1C71-P001B - 120V AC NSPS Bus B H13-P669 - Neutron / Process Radiation Div. I H22-P011 - Standby Liquid Control Local Rack

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1CM01SA - Containment Atmosphere H /0 Monitoring System Panel 2 2 Overall, the licensee performed an adequate verification of the components'that were easily accessible for visual inspections.

Components such as plug-in cables, wiring in ducts, switches,

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indicators, etc., that were not easily accessible were not

inspected.

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During the review the inspector noted that components

1E21-N559A, N660A, N661A, N662A and N663A located in panel H13-P861containedajumperbetweenpointsFRandF2.

These e

jumperswerenotshownontheconnectiondiagramandwerenot

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identified by the verification team. Also, panel H13-P672 i -

contained the same jumper on loop D devices which were not shown

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on the drawing and not identified by the verification team.

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In addition, the inspector.noted the following workmanship

' deficiencies in Containinent Atmosphere Ho/0 Panels ICM01SA and

-1CM01SB:

terminated conductors containe8 exposed or not fully inserted stripped conductors and strands approximately of an inch out of the Weidmuller screw clamp terminal point. The vendor specified stripping lengths of insulation and torquing limits for each terminal type; however, these requirements were not available for review in the licensee's applicable procedures raising the concern that the terminated conductors might have been insufficiently inserted into the terminal point allowing'the conductors to possibly become 1 m se or determinated.

(The licensee had identified a determinated external conductor in the same panel during this ins]ection effort).

The inspector informed the licensee that tie external wiring in Panels ICM01SA and ICM01SB is indicative of poor workmanship,imilar termination blocks.and requested that the licensee ident additional s The licensee stated that the inspectors concern would be addressed.

6.

Inspection of Electrical Equipment Excluded From the Panel Reinspection Program a.

The licensee elected to exclude the following equipment from the Class 1E Panel reinspection program:

motor-operated valves, junctionboxes, penetrations,andlocaldevicessuchasmotors, instruments, etc.

This decision was based on the fact that previous licensee verification efforts have included these components and equipment.

The inspector selected several components that were-excluded from the recent reinspection program for review and field visual inspection as follows:

(1) HPCS Minimum Flow Bypass to Suppression P001 Valve 1E22-F012, as depicted on Drawing E03-1HP00, Sheet 1, Revision J.

(2) LPCSInjectionShutoffValve1E21-F005,asdepictedonDrawing E03-1LP00, Sht t 1, Revision K.

(3) HPCS Pump Discharge Valve 1E22-F004, as depicted on Drawing E03-1HP00, Sheet 1, Revision J.

(4) DG 1B HX Valve 1SX063A, as depicted on Drawing E03-1SX00, Sheet 13, Revision D.

(5) Division 2 Motor Control Center 1B2 (1AP76E); external connections in Compartments 1A, B, C and D, and 11A, B and C.

No deficiencies were noted during the inspection of items (1)

through(5).

(6) DG 1B HX Valve 1SX063B as depicted on Drawing E03-1SX00, Sheet 13, Revision D.

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.The inspector-noted that external power Cable 1SX31A was.

I depicted on the drawing as terminated to. Terminals T1,-

-T2 and T3; however, fie1d' installation contained Raychem heat-shrink' connections rather than being' terminated to T1,

-T2 and T3. The licensee indicated that the drawing will

~ be corrected to reflect the as-built installation.

In addition,.the termination block supports inside the valve-were not secured-in place, and'several-nicks were noted on the red and black conductors of the external cables.

The licensee subsequently located a Maintenance Work Request (MWR);

which had been written to correct these-deficiencies.

'(7) Main Stop Valve Position Switches - 1C71-N006A, B, C and D.

-These. switches input into the Reactor Protection System Scram circuitry as-depicted on Drawings E02-1RP99, Sheet-7, Revision G-and E03-1RP00: Sheet 1, Revision G.

The inspector noted that 1C71-N006A, B and C switches were missing identification tags and that the black and white external conductors to switches 1C71-N006B and C were trained inside the limit switch such-that they.were leaning against the electrical' contacts of the switch. These conductors could possibly get lodged between the contacts when the switch is actuated preventing proper operation of the contacts.

The licensee indicated that corrective action would be taken to correct this condition.

Except for indications of poor workmanship conditions as noted above, the equipment reviewed during this period of the inspection appeared to conform to the requirements of the applicable design drawings and applicable regulatory requirements.

7.

Review of 4.16KV ESF Switchgear Installation Whileconductinganinspectionon4.16KV,ESFBus1B1(1AP09E) Breaker Cubicle E, the inspector observed.that Phase C of overcurrent protective relay C0-5 (used in the Drywell chiller 1B (1VP04CB) protective circuitry)

.had an existing field time dial setting of 7.

A review of relay settings

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Drawing E02-1AP04, Sheet 1, Revision B, indicated that Phase C of the above relay had a specified time dial setting of 1.

The inspector reviewed the latest test data available for the Drywell Chiller 1B protective relay C0-5.

Test Procedure No. GTP-59, dated June 12, 1985, specified a time dial setting of 1.

Page 3 of 3 of test DataSheetGTP-59 stated (undercomments)thattheactualtimedial

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setting to achieve specified time was left at 1.05 at the conclusion of the test.

The data sheet contained signatures of the " performed by" and the

" verified by" test personnel.

Investigation by the licensee could not determine when the time dial was set to 7 or who was responsible for its incorrect setting.

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The settings of the protective relays are performed in the field to CPS-

' Procedure No. 8502.04.. The acceptanc? criteria (section 9.2) requires:

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~the relay to match the test point by.iS%.

Further inspection of time dial rela cubiclesof4.16KV.switchgears.-1B1(ysettingsonallsafetg-)related 1AP09E),and1Al~(1AP07

,= revealed

.that Phase A of the overcurrent protective relay located-in Cubicle D of Bus 181 Lserving RHR pump 1B, had an existing field time dial setting of 2.2 while the relay. setting drawing specified a time dial setting of 11.5.

The inspector informed the licensee that all safety-related protective relays requiring specified setpoints such as overcurrent and undervoltage relays would have to be inspected to determine:whether they had been set-to the required setpoints.

Subsequently, the licensee conducted a field inspection of 120. Class 1E-protective relays with time dial settings.

The following three protective relays were identified as:having' time dial' settings out of

~ tolerance (greater or less than "1" time dial as determined by.

-engineeringjudgment):

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a.

Phase A'overcurrent relay on 4!16KV Bus 1C1 breaker whichifeeds the 480V Unit Sub 10:had existing time dial of 6.2.

Design setting was specified as 4.0.

b.

Phase'C overcurrent relay on 4.16KV Bus 1C1 breaker which fceds 480V Unit Sub 1C had existing time dial of 6.-2.

Design setting was.specified as 4.0.

c.

IAV overcurrent relay on division 3 Diesel Generator had existing time dial of 2.0.

Design Setting was specified as 5.0.

The licensee conducted a review of Sargent & Lundy relay coordination-dated October 20, 1986, and 19AN-4 calculations 19AN-8, 19AN-14, 19AN-17,ined that the overcurrent relays dated July 8, 1985.

The review determ on the 4KV breakers upstream would coordinate with the relays found set out of tolerance. The licensee will review calibration test data to determine if the relays are in their calibrated "as-left" condition.

The relays found out of tolerance will be reworked and recalibrated.

The inspector informed the licensee that failure to accomplish activities i

affecting quality in accordance with prescribed instructions, procedures, is an example of a violation of 10 CFR, Part 50, Appendix B, ordrawings,(461/87004-02(DRS)).

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Criterion V L,

8.

Diesel Generator Design Logic Review a.

The inspector reviewed the diesel generator control logic, specifically the signals which are permitted to trip diesel

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generators 1, 2 and 3 during a LOCA event.

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.FSAR Section 8.3-18, Position C.7, Amendment 38, May'1986,

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states that all division 1, 2 and 3 diesel generator trips.

except generator differential and engine overspeed are bypassed on a LOCA.

FSAR Section 8.3-10 Amendment 36, January 1986, states that-

all division 1 and.2 diesel generator protective trips except generator differential and engine overspeed are bypassed on a LOCA.

Clinton Safety Evaluation Report NUREG-0853, dated

February 1982, Pages 8-10, states that "BTP ICSB17(PSB)

requires that diesel generator protective trips be bypassed when the diesel generator is required for a design-basis event..All protective trips are allowed during periodic testing. The allowed exception to the above requirement for bypassing are diesel engine overspeed and generator differential current.

Any other trip. retained must utilize

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coincident logic in order to avoid spurious trips..In case of a design-basis accident, the applicant is bypassing all the protective trip"s except engine overspeed and generator differential.

Regulatory Guide 1.9, December 1979, Section 7, states

that "... engine overspeed and generator differential t. rips may be implemented by a single channel trip.

All other diesel generator )rotective trips should be handled in one of two ways:

Eitler (1) a trip should be implemented with two or more independent measurements for each trip parameter with coincident logic provisions for trip actuation, or (2) a trip may be bypassed under accident conditions...."

'IEEE 387-1977 (committed to by Clinton) does not address

this issue specifically; however, IEEE 387-1984 Section 5.5.4, states the same requirements as Regulatory Guide 1,9, December 1979.

During the review of diesel generator 1A Control Schematic the inspector determined Diagram E02-1DG99, Sheet 10, Revision K,try allows for the following that for on a LOCA Condition, the circui three auto trips:

)

engine overspeed (K3 relay (87 relay)

(1)

overcurrent differential (2)

(3) engineovercrank(K4 relay)

The same circuitry was used for diesel generator 18.

HPCS Diesel Generator 3 trip control logic did not contain the overcrank trip on LOCA conditions.

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The licensee stated that the overcrank trip circuit was added to prevent the air system from exhausting prior to the required five engine starts. -The inspector informed the licensee that requirements.

dictate that any LOCA condition trip circuit installed in addition to the overspeed and differential protection trips would require a coincident logic to avoid spurious trips.

. Subsequently, Region III' staff contacted Mr. John Knox and-Mr. Byron Siegel of NRR to discuss this issue.

NRR staff classified the overcrank trip signal as a trip signal,-not a protective trip signal and therefore not requiring the coincident logic circuitry.

NRR will inform the licensee.to revise the FSAR to include the overcrank circuitry.

b.

FSAR Section 8.3-11, Amendment 36,. states.that " periodic testing of the HPCS-Diesel Generator is performed from'the Control Room.by manual initiation or simulation of-a LOCA.

This testing does not.

impair the capability of starting the HPCS pump within the required time.

The test controls are overridden by the LOCA event."

The same FSAR section included the following statements'which appears to'be contrary to the statement above.

"The local en control switch also provides a maintenance and test position.gine

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The test position is used only for test after maintenance prior to transferring to automatic operation. The LOCA signal will not start the engine when the engine control switch is in test position."

The inspector raised the concern that since this switch is not a keylock switch, tion, thereby, preventing the HPCS diesel from anyone could walk up to the local panel and place it in test posi automatically starting on LOCA condition.

Review of this item revealed that the test position of this switch is not to be used under any operating or testing conditions.

The licensee informed the inspector that if in the future there is a need to use the test position on this switch, special procedural l'

provisions will be implemented to control this activity.

Present design provides an alarm in the Control Room "HPCS NOT RDY FOR AUTO START BKR IN LOWER POS". Whenever this switch is placed in

test position, however, this alarm window is being shared with

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numerous other plant in ut parameters such as " breakers lowered,"

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" loss of control power,p' "DGIC lockout relay energized " " Auto setupindicationrelaydeenergized,"and"generatorvoltage regulator switch other than auto position".

The inspector noted that operations status alarm Procedure CPS No. 5062.32, stated however, the requirements for gossiblecausesforthisalarm; ions"tobetakenwhenthisalarm Auto Actions" or " Operator Act comes on were noted as "NONE".

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The inspector 1 interviewed a plant operator.and' questioned'him'as to:

the actions he'is required to take when the above alarm appears on-.

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st e board. The operator. stated that an Auxiliary operator will.be -

h dispatched to determine'which one of the possible causes listed.in CPS 5062.32 initiated the alarm.

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9.

! Training of Personnel:on Proper-Use of Electrical Design Drawings-In~ February 1987, the-licensee developed and implemented a training.

-program designed to familiarize plant technical and operational. personnel with electrical design drawings and change documents. 'The purpose of

'this; training is to achieve an adequate understanding of the intendedi use of these drawings and documents when conducting maintenance and

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operational activities.. This training should result in'a reduced number-of personnel errors.

In regards to the recent electrical panel reinspection program, the licensee established training and qualification requirements for the individuals designated to perform the electrical verifications'and subsequent evaluations.

The training included a formal course of instructions presented by the CPS Nuclear Training Department on the use of electrical. design documents, verification techniques and the requirements'of walkdown verification Procedure No. X.13, dated and evaluation Procedure No. X.14, dated February 10,c1987, The' requirements included a written examination 1987.

~ February 7,ing grade of'75% and a practical examination with:a passing with a pass grade of.70%.

The inspector reviewed the training and qualification records ofEthe verification and evaluation group and found the program to be adequate.

During this inspection period.the inspector noted that licensee's management has put a concerted effort into training its personnel on the proper use and knowledge of electrical design drawings and documents.

10. Open Items Open items are matters which have been discussed with the licensee, which will be' reviewed further by the inspector, and which involves some action on the part of the NRC or licensee or both. Open items disclosed during this inspection are discussed in Paragraph Sc.

11.

Exit Interview The Region III inspector met with licensee representatives (denoted under Paragraph 1) at the conclusion of the inspection on February 24, 1987.

The inspector summatized the purpose and findings of the inspection. The licensee acknowledged this information.

The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.

The licensee did not identify any such documents / processes as proprietary.

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