ML20028F993

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Final & Interim Deficiency Repts Re Conditions 22,29,37,43, 49,59,53-54,60,64,82 & 102 Concerning Electrical Separation. Next Rept Re Conditions 37,49,54,60,64 & 82 Will Be Provided by 830418
ML20028F993
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 01/28/1983
From: Matlock R
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
10CFR-050.55E, 10CFR-50.55E, G2-83-80, GO2-83-80, NUDOCS 8302070283
Download: ML20028F993 (17)


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Docket No. 50-397

50. SS (c) Report Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 Docket No. 50-397 January 28, 1983 G02-83-80 Mr. R. H. Engelken Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

Subject:

NUCLEAR PROJECT NO. 2 10CFR50.55(e) REPORTABLE CONDITIONS #22, #29, #37, #43, #49,

  1. 50, #53, #54, #60, #64, #82 AND #102; DEFICIENCIES IN ELECTRICAL SEPARATION

References:

a. Letter #GI2-82-101, D.M. Sternberg to R.G. Matlock, dated August 17, 1982, same subject.
b. Letter #G02-82-803, R.G. Matlock to R.H. Engelken, dated September 23, 1982, same subject.

Reference b informed you that WNP-2 had reopened the above subject 10CFR 50.55(e)'s as requested in reference a. Attachments I, II, IV, VI, VII and XII provide the Project's final reports on 10CFR50.55(e)'s #22, 29, 43, 50, 53, and 102. Attachments III, V, VIII, IX, X and XI provide the Project's interim reports on 10CFR50.55(e)'s #37, 49, 54, 60, 64, and 82.

We will continue to provide your office with quarterly updates on items

  1. 37, 49, 54, 60, 64, and 82 until all deficiencies are resolved. The next report will be submitted on or before April 18, 1983.

If you have any questions regarding the above subjects, please contact R. T. Johnson, WNP-2 Project QA Manager, (509) 377-2501, extension 2712.

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R. . Matlock Program Director, WNP-2 LCF/kd Attechments: (12) As stated

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cc: W.S. Chin, BPA - Site A. Forrest, Burns and Roe - HAPO N.D. Lewis, NRC .

J. Plunkett, NUS Corp. 2] 'y IE IC E94 T _

A. Toth, NRC Resident Inspector - Site Document Control Desk, NRC ,.,

L WNP-2 Site Files /917B 0?djk,p' 8302070283 830128 DR ADOCK 05000

i-Attachment I~ l WASHINGTON PUBLIC POWER SUPPLY SYSTEM DOCKET NO. 50-397 LICENSE N0. CPPR-93 1

NON-SAFETY RELATED CABLE ROUTING DESIGN ERRORS 10CFR50.55(e) CONDITION #22 FINAL REPORT Description of Deficiency, Cable routing design errors were identified by the Electrical Contractor, Fischbach/ Lord on CM-RFI-525, dated January 19, 1978. The design error was the routing of a number of non-safety division 'B' Supervisory System Signal Cables in the non-safety division 'A' signal trays. The cables involved were BMISC-1, 2, 4, 5, 6, 8, 10, 11, 12, 13, and 211.

Safety Implication The identified cables are non-safety related and do not directly bridge the safety divisions; therefore, there is no impact on Class IE safety systems. This item is not reportable.

Corrective Action The cable routing was revised (Work Change Notice #218-FCZ-042). In order to prevent future recurrence, the computer program which generates drawings i E550 and E551 (cable schedules) was modified to detect division imcompati-bility in cable routing designs.

Status of Corrective Action 218-FCZ-042 (CM-RFI-525) - Corrective Action Completed 1

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ATTACMENT 11 WAS}lINGTON PUBLIC POWER SUPPLY SYSTEli DOCKET NO. 50-397 LICENSE NO. CPPR-93 CLASS lE CIRCUITS IN SEISMIC CATEGORY II AREAS 10CFR50.55(e) CONDITION #29 FINAL REPORT Description of Deficiency Certain Class lE trays, by design, enter a Seismic Category 11 portion of the Radwaste Building from the Reactor Building. (Refer to 10CFR50.55(e)

  1. 50 as a specific instance of this generic item).

Safety Implication The structural adequacy of the Seismic Category 11 portion of the Radwaste Building was evaluated and found capable of withstanding Seismic Category I loadings. Ilowever, two Reactor Closed Cooling-(RCC) System lines were found to be routed above the trays. Evaluation of the RCC hangers indicated them to be overloaded in the event of a Seismic Category I occurrence.

It was thus concluded that the RCC lines could conceivably cause failure of the subject Class IE cables. This item is considered reportable under 10CFR50.55(e).

Corrective Action Additional hange'rs were provided for the RCC process lines so that they will sustain Seismic Category I loadings (PED 215-M-5151,11-2675,11-3610, 11-3832). A survey of the Seismic Category 11 areas through which the Class lE trays are routed was conducted by Burns and Roe Task 1590 to assure no other Seismic Category 11 supported components endanger a safety-related system or raceway (Ref. Burns and Roe letters BRUP-F-82-932 and BRWP-F 2490, and Burns IOM F-83-0058).

To preclude future re-occurrence, an item has been added to the electrical engineering assignment sheet to determine whether Class lE cables enter a Seismic Category 11 structure, if so, the design of the cables must be either " fail-safe" or appropriately routed above any Seismic Category 11 supported structures / equipment, etc.

Status of Corrective Action PED 215-M-5151 - Corrective Action Completed PED 215-11-2657 - Corrective Action Completed PED 215-11-3610 - Corrective Action Completed PED-215-li-3832 - Corrective Action Completed l

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'. Attachment III WASHINGTON PUBLIC POWER SUPPLY SYSTEM DOCKET N0. 50-397 LICENSE N0. CPPR-93 CLASS 1E CABLES IN SEISMIC CATEGORY II SUPPORTED RACEWAYS 10CFR50.55(e) CONDITION #37 INTERIM REPORT Description of Deficiency Main steam line radiation monitoring cables, 4PRM-1, 2, SPRM-1, 2, 6PRM-1, 2, and 7PRM-1, 2, which are Class 1E, were routed through the Turbine Generator Building (the Turbine Generator Building is a modified non-Seismic Category I structure analyzed to withstand a safe shutdown earthquake (SSE)) without proper consideration for seismic support for safety-related raceways (NCR-218-04210).

Safety Implication The main steam line radiation monitors initiate protective action for both main steam line isolation and reactor scram, thus mitigating the consequen- )

f ces of a fuel failure. It has been determined that, assuming no line break l

or small steam line break within the Turbine Generator Building, no other means of assuring reactor scram and main steam isolation exists in the event of fuel failure should the radiation signals be lost due to a seismic event by failure of non-Seismic Category I supports. This item is con-sidered reportable under 10CFR50.55(e).

Corrective Action Engineering direction was given under PED 218-E-0077 to upgrade the I installation to Seismic Category I.  ;

Addit _ional Information During upgrade of supports it was found that the conduits were located below Seismic Category II equipment (RFI-218-4138). Engineering direction was given to reroute the conduits (PED 218-E-2216) to preclude failure due to non-Seismic Catescry I equipment.

Status of Corrective Action PED 218-E-0077 - Field Work In Process PED 218-E-2216 - Field Work In Process

Attachment IV WASHIDGTON PUBLIC POWER SUPPLY SYSTEM DOCKET NO. 50-397 LICENSE N0. CPPR-93 ELECTRICAL SEPARATION OF RPS SCRAM GROUP 0UTPUT 10CFR50.55(e) CONDITION #43 FINAL REPORT Description of Deficiency Reactor Protection System (RPS) scram group output cables are incorrectly assigned to non-redundant safety divisions. These cables are routed in ,

individual conduits (grounded) through a common blockout in the Radwaste Building, elevation 525' (Drawing E-767, Zone K-14/15). They are suscep-tible to damage by a single event: a fire, missile, etc.

Safety Implication The Reactor Protection System is designed to be a " fail-safe" system. That is, during normal plant operation, the system is normally energized and a " Scram" de-energizes the system to insert control rods. Therefore, a fire or missile event would result in conductors shorting to ground or open circuiting which would cause the system to fail in a safe manner. To inhi-I bit control rod insertion, a hot short to all the cabling would be required.

A fire or missile would not cause hot shorting since cables of other systems are not routed within these conduits.

Therefore, based on the fail-safe design of the RPS, failure due to lack of separation would not have resulted in an adverse safety impact even if it had gone undetected.

The condition is therefore evaluated to be non-reportable under 10CFR50.55(e).

Additional Information General Electric filed a 10CFR21 on the entire PGCC including RPS Scram group cables. GE issued FDDR-KKl-549 to correct the RPS problems. Burns and Roe issued enginen-ing direction to follow up on this FDDR (PED's 218-I E-3481, 3875, and 429o). As a result, the present routing of these cables is not identical to the routing at the time the potentially reportable j 10CFR50.55(e) was originally filed.

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Attachment V WASHINGTON PUBLIC POWER SUPPLY SYSTEM DOCKET NO. 50-397 LICENSE N0. CPPR-93 OPERATION OF STANDBY GAS TREATMENT SYSTEM DAMPER 10CFR50.55(e) CONDITION #49 INTERIM REPORT Description of Deviation The Standby Gas Treatment System (SGTS) contains redundant trains consisting of two 100% capacity fans per loop for a total of four 100% capacity fans.

To maintain a 1" water gage negative pressure within the Reactor Building in the event of a LOCA, only one fan is required.

As shown on the attached flow diagram there exists electrically operated dampers to control the mode of operation of each train (e.g., isolation,

, recirculation or exhaust). Also depicted on the attached diagram is the 3

source of emergency power for each motor operated damper and fan, it is contended that due to the system design which provi&!s two redundant i divisions of dampers in each fan train, a possible loss of both Standby Gas Treatment System loops from a single event is possible and that separa-tion problems exist in each fan and heater area (i.e., all four dampers within either division, if closed, would render the system inoperable).

Safety Implication 4

Since all compatible division damper control circuits (for all four fan trains) are routed together, the worst case single failure will be a fault which could generate a localized fire and cause both SGTS trains to become inoperative.

Corrective Action The SGTS fan and heater circuits have been reviewed and no electrical separa-tion violations have been identified.

The Architect Engineer, in conjunction with Supply System Project engineers is evaluating the damper control circuits for corrective action. -

Status of Corrective Action Quarterly reports will be filed until resolved, o

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  • Attachment VI WASHINGTON PUBLIC POWER SUPPLY SYSTEM DOCKET NO. 50-397 LICENSE N0. CPPR-93 HPCS/ CST LEVEL SENSING CABl.E ROUTING 10CFR50.55(e) CONDITION #50 FINAL REPORT Description of Deficiency Level sensors on the condensate storage tanks (CST) are used to detect low-level conditions, thereby initiating automatic transfer of High Pressure Core Spray (HPCS) pump suction from the CST to the suppression pool. The cable used to transmit the signal which is Class lE is routed through the Turbine Building.

Safety Implication The Turbine Building is a modified non-Seismic Category I structure designed to withstand a safe shutdown earthquake (SSE). However, during a SSE, a potential loss of the low-level signal could occur due to Seismic Category 11 supported equipment damaging the conduit. If so, suction on the HPCS pumps may not be transferred from the CST to the suppression pool. Further investigation indicated that piping from the CST to the HPCS pump is routed within the Service Building. The Service Building is not designed to withstand an SSE. During an SSE, the piping could fail. A single failure (E.G., loss of a diesel generator), in addition to the above, would reduce the Emergency Core Cooling Systems below the minimum requirements listed in FSAR Sections 6.3.1.1.2.d and 6.3.1.1.2.e. The condition is considered a reportable deficiency under 10CFR21 and 10CFR 50.55(e). Corrective Action A standpipe has been added to the piping from the CST inside the Reactor Building (PED 215-M-A420). A level sensor on the standpipe tran mits a signal for initiation of automatic switchover from the CST to the suppres-sion pool. For detailed discussions, refer to the responses to FSAR ques-tions 031.128, 122.146, and 211.197. Also, see FSAR Figure 6.3-1 and Appen-dix B, Item II.K.3.22. The cables were re-routed to remain within the Reactor Building (PED 218-E-5138). Status of Corrective Action PED 215-M-A420 - Construction Action Complete PED 218-E-5138 - Construction Action Complete

Attachment VII WASillNGTON PUBLIC POWER SUPPLY SYSTEM DOCKET NO. 50-397 LICENSE N0. CPPR-93 li!Gil PRESSURE CORE SPRAY (llPCS) SERVICE WATER SYSTEM l 10CFR50.55(e) CONDITION #53  ; FINAL REPORT l i Description of Deficiency, 4 It was reported that Division 3 IIPCS Service Water Pump Discht qe Pressure Monitoring Instrumentation receives power from a Division 1 source instead of a Division 3 source. Ilowever, upon investigation, it was determined that only SW-PS-40A was incorrectly powered by Division 1. Safety implication The deficiency would not have affected plant safety. This'instrumcnt pro-vided no active safety function, i.e., its only function was to alert (annun-ciate) the plant operator in the event that system pressure was lower than normal. The annunciator is non-Class IE and serves only to indicate a potential problem with the HPCS Service Water System. Upon alarm, the operator would investigate system status at panel lil3-P-601. Panel lil3-P-601 has Class 10 instrumentation indicating flPCS status at follows: e Instrument itPCS-FI-603 - IIPCS pump P1 flow indicator o instrument I!PCS-PI-601 - IIPCS pump P1 discharge pressure e Instrument SW-PI IIPCS pump P2 discharge pressure Based on the operator evaluating itPCS system sttitus at panel lil3-P-601, rather than the annunicator alarm prior to implementing any corrective action, this item is considered to be non-reportable. Corrective Action Project Engineering Directives (PED's) 235-E-0050, 235-E-0071, and 218-E-1653 were issued to correct the deficiency by supplying the power to SW-PS-40A from a Division 3 power source. Status of Corrective Action PED 235-E-0050 - Construction Action Completed PED 235-E-0071 - Construction Action Completed PED 218-E-1653 - Construction Action Completed l l t

Attachment VIII L WASHINGTON-PUBLIC POWER SUPPLY SYSTEM ! DOCKET N0. 50-397 LICENSE N0. CPPR-93 SEPARATION VIOLATIONS WITHIN PGCC 10CFR50.55(e) CONDITION #54 INTERIM REPORT Description of Deficiency The lack of Division 3 ducts within the B0P portions of the PGCC has resulted in safety-related Division 3 High Pressure Core Spray (HPCS) cables (CB-A2-1-21, CB-DA-17, CJB-TCG1-2.2A, CJB-TCG1-2.2, and JB-TCC2-4.2) being routed with Division 1 and Division 2 safety related cables. These Division 3 cables were routed in a separate flexible conduit within Division 1 and 2 duct sections. Safety Implication It was concluded that a fire in Divisions 1 or 2 floor sections could sub-sequently lead to failures in Division 3. Accordingly, the BOP portion of the PGCC routing could have adversely affected the safety of the plant, and the design does not conform to the criteria stated in the Safety Analysis Reports. Therefore, this condition is considered to be reportable under 10CFR21 and 10CFR50.55(e). Corrective Action j A separate miniduct system was designed within the B0P portion of the PGCC for routing of Division 3 cables (PED 218-E-3677). Division 3 cables will now be installed in flexible conduit within the miniducts. However, control room human factors changes have removed four of the specific cables (CB-A2-1-21, CB-DA-17, CJB-TCG1-2.2A, and CJB-TCG1-2.2) from the BOP PGCC ducts (FDDR-KK1-795 and PED 218-E-4974). The remaining cable (JB-TCC2-4.2) will be dispositioned by PED 218-E-A431, which will be issued by January 31, 1983. Status of Corrective Action PED 218-E-3677 - Construction Action Completed FDDR-KK1-795 - Field Work In Progress PED 218-E-4974 - Field Work In Progress PED 218-E-A431 - To Be Issued

Attachment IX WASHINGTON PUBLIC POWER SUPPLY SYSTEM i DOCKET NO. 50-397 LICENSE NO. CPPR-93 INCORRECT IDENTIFICATION OF SAFETY-RELATED CABLES 10CFR50.55(e) CONDITION #60 INTERIM REPORT Description of Deficiency Seventy-nine (79) Class lE analog instrumentation cables used for safety-related functions and post-accident monitoring, are mislabeled as Non-Class lE. This mislabeling caused Class lE cables to be routed without required Class lE documentation for route, pull, etc. In addition, these cables may not be routed in Class lE raceways along their entire length. Safety Implication The evaluation of the deficiency (BRWP-79-412) revealed that the cables were routed in Class lE raceways only. Therefore, the problem constitutes the lack of proper cable designation and installation documentation. Since the cabling was routed and bulk pulled with Class lE cables in Class lE raceways only, there exists no safety hazard and the deviation was con-sidered to be not reportable under 10CFR50.55(e). Corrective Action NCR 2808-5657 was written and has been closed by IR-218-13462. Prior to revised engineering direction, 6 of 79 cables were installed. Two of the 6 cables were spared. Four were bulk-pulled with Class lE cables so Class lE documentation exists for them (218-E-1963) and were re-identified as Class lE. Also, the remaining 73 cables were re-identified as Class lE and subsequently pulled as Class lE. The following PED's re-identified the cables: 218-E-1650, 218-E-1685, 218-E-1720, 218-E-2278, 218-E-2362. Additional Information Cables AIR 21-9010 and Air 22-9010 were not re-tagged oy PED 218-E-1650. The conductors for SW-PT-32A and B were spared in these cables and new cables were added for the pressure transmitters. PED 218-E-2362 was issued to re-tag cables AIR 21-9010 and AIR 22-9010 per further engineering changes not related to NCR 2808-5657. Status of Corrective Action PED 218-E-1650 - Field Work in Progress PED 218-E-1685 - Construction Action Completed PED 218-E-1720 - Construction Action Completed PED 218-E-1963 - Construction Action Completed PED 218-E-2278 - Construction Action Completed PED 218-E-2362 - Field Work In Progress j l

Attachment X i l WASHINGTON PUBLIC POWER SUPPLY SYSTEM ! DOCKET N0. 50-397 LICENSE NO. CPPR-93 PLANT ELECTRICAL SEPARATION 10CFR50.55(e) CONDITION #64 INTERIM REPORT Description of Deficiency As of August 1979, the Main Control Room had been reviewed and approxi-mately 150 instances were discovered involving violations in the application of WNP-2 Electrical Separation Criteria to safety related cables and panel wiring. In general, the deficiencies involved incorrect labeling, routing, or termination of cabling within PGCC or Control Room panels. Safety implication The deficiencies found could have resulted, under single failure conditions, Il in the simultaneous loss of redundant safety-related equipment with possible subsequent loss of safety function. The condition was therefore concluded to be a reportable deficiency under 10CFR50.55(e). Corrective Action In 1979, a task force reviewed the Main Control Room and plant areas for other violations of WNP-2 Separation Criteria in all safety-related applica-tions. The UNP-2 Electrical Separation Criteria were refined and clarified and were used by a Separation Task Force to judge plant separation as designed and as installed. These same criteria were submitted in FSAR Amendment 23, Section 8.3. Instances of deficiencies identifieu as criteria viola-tions are being evaluated and corrected vio Project Engineering Directives (PED's). An additional task force was established in September, 1982 to review the overall separation criteria and construction installation to that criteria. A formal report from this task force will be available in February, 1983. Status of Corrective Action 1979 Task Force Separation Study PED's 218-E-2111 - Field Work In Progress 218-E-1725 - Construction Action Completed 218-E-2155 - Field Work In Progress 218-E-0051 - Field Work In Progress 218-E-2362 - Field Work In Progress 218-E-2209 - Construction Action Completed 218-E-0044 - Field Work In Progress 218-E-2090 - Field Work In Progress 218-E-2198 - Construction Action Completed 235-E-0062 - Field Work In Progress

Attachment X Page E cf 3 218-E-2213 - Field Work in Progress 218-E-2222 - Field Work In Progress 218-E-2237 - Field Work In Progress 218-E-2252 - Field Work In Progress 1 218-E-2129 - Construction Action Completed 218-E-0153 - Construction Action Completed 218-E-2257 - Field Work in Progress 218-E-2248 - Field Work In Progress 218-E-2278 - Construction Action Completed 218-E-2309 - Field Work In Progress 218-E-2439 - Field Work In Progress 218-E-2413 - Field Work Not Started 218-E-2385 - Construction Action Completed 235-E-0055 - Construction Action Completed 218-E-1816 - Construction Action Completed 218-E-2199 - Construction Action Completed 218-E-2395 - Field Work Not Started 218-E-1953 - Construction Action Completed 218-E-1951 - Construction Action Completed 218-E-2020 - Field Work In Progress 218-E-2011 - Construction Action Completed 218-E-2031 - Construction Action Completed 218-E-2038 - Field Work Not Started 218-E-2036 - Field Work Not Started 218-E-1983 - Field Work Not Started 218-E-2040 - Construction Action Completed 218-E-1715 - Construction Action Completed 218-E-1954 - Construction Action Completed , i 218-E-1961 - Construction Action Completed 218-E-2110 - Construction Action Ccmpleted 218-E-2343 - Voided by PE0 218-E-3154 218-E-2669 - Construction Action Completed 218-E-2390 - Field Work Not Started 218-E-1648 - Field Work in Progress 218-E-1650 - Field Work Not Started 218-E-1685 - Construction Action Completed 218-E-1720 - Construction Action Completed 218-E-1649 - Construction Action Completed 218-E-1716 - Field Work In Progress 218-E-1768 - Construction Action Completed 218-E-1795 - Construction Action Complet ed 218-E-1759 - Field Work In Progress 235-E-0057 - Construction Action Completed 235-E-0500 - Construction Action Complet.ed 218-E-1653 - Construction Action Completed 218-E-1904 - Field Work Not Started 218-E-1778 - Field Work in Progress 218-E-1714 - Field Work in Progress 218-E-1713 - Field Work in Progress 235-E-0063 - Construction Action Completed 218-E-1690 - Construction Action Completed

  • Attachment X Page 3 cf 3 218-E-2967 - Field Work in Progress 218-E-3085 - Field Work In Progress 218-E-4829 - Construction Action Completed 218-E-4869 - Construction Action Completed 218-E-3053 - Construction Action Completed 218-E-3479 - Construction Action Completed 218-E-3153 - Field Work in Progress 218-E-2858 - Field Work In Progress 218-E-3532 - Field Work Not Started 218-E-3530 - Field Work Not Started 218-E-3046 - Construction Action Completed 218-E-3750 - Construction Action Completed Task 3670 Separation PED's (Compliance to Section 8.3 FSAR Ammendment 23) 218-E-4247 - Field Work Not Started 218-E-4490 - Construction Action Completed 218-E-4587 - Construction Action Completed 218-E-4599 - Field Work in Progress 218-E-4633 - Construction Action Completed 218-E-4656 - Construction Action Completed 218-E-4702 - Field Work In Progress 218-E-4780 - Construction Action Completed 218-E-4789 - Field Work Not Started 218-E-4824 - Field Work In Progress I' 218-E-4836 - Field Work Not Started 218-E-4837 - Field Work Not Started 1 218-E-4840 - Field Work Not Started 218-E-4841 - Field Work Not Started 218-E-4855 - Field Work Not Started 218-E-4888 - Field Work Not Started 218-E-4902 - Field Work Not Started 218-E-4951 - Field Work Not Started 218-E-A083 - Field Work Not Started 218-E-A141 - Field Work Not Started 218-E-A222 - Field Work Not Started 218-E-A405 - Field Work Not Started 218-E-A527 - Field Work Not Started 218-E-A274 - Field Work Not Started 218-E-A304 - Field Work Not Started 218-E-A670 - Field Work Not Started 218-E-A725 - Field Work Not Started
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Attachment XI WASHINGTON PUBLIC POWER SUPPLY SYSTEM l DOCKET NO. 50-397 l LICENSE NO. CPPR-93 LACK 0F INSTALLATION DOCUMENTATION FOR CLAS.i 1E CABLES IN THE MAIN CONTROL ROOM RACEWAY 5 10CFR50.55(e) CONDITION #82 INTERIM REPORT Description of Deficiency The documentation verifying the installation of safety related cables in the Power Generation Control Complex (PGCC) floor ducts (main control room under floor raceways) was incomplete rendering the PGCC cable routing sum-maries invalid. It was determined, relative to the installing contractor's work, that: 1) there were no definitive inspection criteria; 2) changes to the QA records were not traceable in some cases; and 3) routing sheets used to install the cables did not match the QA record documentation for approximately 14% of the cables. Safety Implication j Valid documentation is required to provide an accurate assessment of compliance to the electrical separation criteria which assures that the redundant safety systems are not made functionally inoperative by a single event. Related investigations (10CFR50-55(e) #64) have shown that safety-class cables were in fact routed improperly such that faults in one safety division could have adversely affected other divisional cables. The condition was therefore evaluated to be a reportable deficiency under 10CFR50.55(e). Corrective Action A Quality Assurance surveillance review was conducted. This review generated corrective action requests CAR-1437 and CAR-1439 which identified a signficant lack of PGCC (uality Class 1 cable installation documentation. Based on these findings, an action plan was developed to generate taiform Quality Class 1 PGCC documentation which would alleviate documentation deficiencies in the area of Class 1E cable terminations and routine in the PGCC ducts. To avoid a recurrence of this problem, a control room Jtop Work Order Number 7 was issued on May 23, 1980, until such time that FQA could enforce approved PGCC installation procedures (PED 218-E-2967). This step was essential to avoid any documentation problems for future PGCC installation, specifically for FDI, FDDR, PED and Startup Work Requests. Fischbach/ Lord instituted work procedure CP/QAP-428 to provide Quality Class 1 instructions for installation and documentation in the Main Control Room. As part of the corrective action plan, PED 218-E-3064 was issued to address the documentation deficiencies in the existing installation. Fischbach/ Lord implemented this directive and forwarded the as-built cable routings via RFI 218-6163 and RFI 218-6251. These RFI's resulted in a number of PED's (reference letter BRWP-F-82-5260) that were issued to correct the routing errors (see 10CFR50.55(e) #64 for a list of PED's). (Continued)

       ,                                                                Attachment XI i  .                                                                     Page 2 During implementation of the PED's listed in BRWP-F-82-5260, discrepancies were found in RFI 218-6163 and 218-6251. The Supply System then initiated another 100% walkdown of cables installed in PGCC in September 1982. The results of this walkdown were issued to Burns and Roe (Ref. WPBR-F-82-237, WPBR-F-82-238) which showed further discrepancies in cable routing in the PGCC. Burns and Roe issued engineering direction (PED 218-E-A405) to correct the routing errors for the BOP PGCC. General Electric issued FDDR-KK1-935, Rev. O and 1 to correct the errors within the NSSS portion of the PGCC.

Status of Corrective Action PED-218-E-A405 - Field Work In Progress FDDR-KK1-935, Rev. 0 - Field Work in Progress FDDR-KK1-935, Rev.1 - Field Work in Progress

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l. lc Attachment XII WASHINGTON PUBLIC POWER SUPPLY SYSTEli DOCKET N0. 50-397 LICENSE N0. CPPR-93 INCORRECT IDENTIFICATION OF ELECTRICAL CONDUITS 10CFR50.55(e) CONDITION #102 FINAL REPORT Description of Deficiency Tagging of conduits throughout the Reactor Building around the periphery j of the Main Control Room and in the Cable Spreading Room has been found to be deficient. -Conduits containing both safety-related and non-safety-related cables were tagged with the "non-safety-related" divisional designa-tion. Safety Implication Inaccurate tag identification of conduit carrying both safety-related and non-safety-related cables could affect the safe shutdown analysis relative to electrical separation and fire protection for dedicated safety systeus and protection of safety system components and cables from missiles and pipe breaks. The condition is considered to be a reportable deficiency under 10CFR50.55(e). Corrective Action Project Engineering Directive PED 218-E-3085 was issued revising conduit identification and contract specification requirements, directing tagging of conduit to be based on the safety division compatibility of the cables routed within the conduit. Status of Corrective Action Fischbach/ Lord has developed a tagging procedure (CP-QAP-412 Typical Identi-fication Marker Installation) to implement the PED. PED 218-E-3085 - Construction Action Complete

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