ML20126L170

Separation of Electrical Equipment Plant Wide Field Audit Procedure. Related Documentation Encl

ML20126L170
Person / Time
Site:	LaSalle
Issue date:	07/01/1980
From:	Carlton R, Sadlowski R SARGENT & LUNDY, INC.
To:
Shared Package
ML20126L169	List: ML20126L166 ML20126L170
References
PROC-800701, NUDOCS 8106010417
Download: ML20126L170 (36)

Text

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La Salle County Station Units 1 & 2

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Separation of Electrical Equipment

. Plant Wide Field Audit Procedure E

l Project No. 4266-02 P

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4 Commonwealth' Edison Company J

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Prepared by:

1 il Sargent16 Lundy Engineers j Chicago ,

t R. F. Carlton R. E. Sadlowski July 1, 1980 1

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, 'La Salle County Station ,

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. Units 1 & 2 i Separation o'f Electrical Equipment j Plant Wide-Field. Audit-Procedure-

, . Issue Summary i

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' Issue Rev. No. Date Purpose of Issue l 1

0 7-1 Comments- ,

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La Salle County Station Units,1 & 2 Separation of Electrical Equipment

< , Plant Wide Field Audit Procedure Table of Contents i Sectilon - Description Page 1 ' Scope 4, 2 General 1

, 4 3' Audit Criteria 5 t u.. ,

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Systems Selected for Audit 6

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5 Audit Procedure . 6 6.

Separation, Identification and Fire Barrier -'

Requirements 6 7 Audit Progress 7 f

.8 . Audit Results 7g

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- Table 1 Systems Selectd for , Audit 8 Table 2 Index - Separation Audit Forms and Cable Tab Page Numbers 9 Table 2A Miscellaneous Items (See Section 2. 4. 3) Index -

Separation Audit Forms and Cable Tab Page Numbers 10 Table 3. Separation and Identification Requirements 11 Cable Tray and Conduit Segregation Codes 12 Table 4 Table 3 Cable Segregation Codes 13 0

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La Salle County Station

! Units 1 & 2 -

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Separation'of Electrical Equipment i

Plant Wide Field Audit ,

Procedure

.l. Scope 1.1. Perform a detailed field audit to verify that the instalied e lectric equipment and systems conform to the separation criteria ' described _ in the La Salle Final Safety Analysis Report 1 (FG AR) , subsecticas 3.3.1.3 and 8.3.1.4 as projected in Electrical Work Specification J-2559'. The audit shall include.a sample of not less ' than 10% of the ins talled ,

Safety-Related equipment. and cables.

2.- General ,

2. l' The audit shall be conducted by a Separation Task Force Audit Team -(Task Force) consis ting of an engineer Task Ieader with supporting engineering and technical personnel e designated.by Sargent & Lundy and the owner, who are familiar with separation criteria, standards and guides as ,

they apply to the La Salle County Station electrical equip-ment and. systems. No member of the Task Force shall have

, participated' in the design and ins tallation of any equip-

, ment dnd systems subject to this audit.

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The existing onsite Commonwealth Edison Construction Offices shall be used by the Task Force for an audit control center. (Telephone 2.3 The Owner shall designate a participating staf f (Ceco) Task Force member as Safety Coordinator to perform liaison func-

- tions between Ocerations/ Construction forces and the Task

-l Jerce. The' Safety Coordinator shall arrange for tags or

' clearances, when required,ifor access to energized circuits,.

!.f elactrical equipment, panels, enciesures, switchgear and mo?.or control centers. In addition, Jua shall arrange for scaffelding, ladders or other items required to visually <in-spect cable trays or enclosures which are not readily acces-sible.

2.4 The audit shall include samples of (but not limited to) the

't following' general categories:

q L: a. Separation of redundant Class 1E equipment.

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b. Separation of redundant Class lE cables .

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2. General (Cont'd) 2.4 icont'd)-

c. Separation of associated, circuits.

d. Identification (marking) of redundant Class 1E equip-ment and. cables. ,i .

e. Identification (marking) of associated circuits to a level indicative of the Class 1E with which they are associated.

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f. Separation of redundant wiring, indicators and con-trols at panels and control boards.

2.4.1 The audit will include 1a review of conduit and conduit sup-ports, cable tray and cable tray supports, cable in conduit and trays, cable at control ~ boards, and control board wiring for portions of those systems listed in Table 1. g 2 . 4 .' 2 . The specific equipment and systems to be audited are shown on Separation Audit Forms and Cable Tabs which are listed '

in Table 2.

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2.4.3 Separation violations discovered during the audit of equip-ment and systems which do not appear in Table 2 shall be

+ i documented on additional Separation Audit Forms. Miscel-s laneous items will be listed in Table 2A and will form an s,

integral part of this audit.

3. Agdit Criteria 3.1 The safety evaluation report for La Salle County Station con-struction permit was issued on September 10, 1973. Since Regulatory Guide (RG) 1.75 (Rev. 1) " Physical Independence of Electrical Systems" applies to plants whose safety eval-uation report was issued af ter February 1, 1974, compliance with RG 1.75 shall be in accordance with LSCS FSAR Appendix '

3, Amendment 43, Page B.194.

3.2 Independence of redundant Class 1E systems and equipment shall be installed to ensure availability during any design- .

basis event as described in FSAR subsection 8. 3.1.4 l

" Physical Independence of Redundant Systems ," 8.3.1.4.2.2

" Cable Routing Criteria" and 8. 3.1. 3 " Physical Identification of Safety-Rele ad Equipment." These criteria are transmitted  :

to the field by the La Salle Electrical Installation Work l Specification J-2559, Amendment 2, dated December 13, 1978. ,

1 3.3 Cable fire protection shall comply with FSAR subsections I 8.3.3.2, 8.3.3.3, 8. 3.1. 4. 2 and FS AR Appendix H , Fire :czards Analysis.

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3. Audit Criteria (Cont'd) 3.4 The criteria referred to in paragraphs 3.2 and 3.3 (above) shall be the basis for performing this audit.

4. Systems Selected for Audit 4.1 The audit shall be performed on sample portions of systems

• and related electric equipment as shown in Tab 1? 2. The approximate total number of Class lE cables ins talled for

, each system and those to be audited are also included.

4.2 The cables selected represent a variety of physical loca-tions; i.e., the AP system represents portions of various s switchgear and motor control centers, DG represents cables related to each diesel generator, etc.

5. Audit Procedure 5.1 The Task Force shall review those cables, raceways and equipment listed in Table 2, to verify that the Installer nas properly implemented the design referred to in para-graphs 3.2 and 3.3.

i 5.2 The Task- Force auditor shall visually verify that cable routing, raceway separation, control panels and boards, terminations, barriers, isolation devices and equipment

- identification do not present deficiencies that, under 4 single failure conditions, could result in the simulta-s neous loss of redundant safety-related equipment with pos-sible subsequent less of safety function. Any violation of the separation criteria shall be considered as a defi-ciency.

5.3 Field audit forms listed in Table 2, shall be used with l the respective Cable Tab, for recording data.

5.4 Those criteria listed in paragraphs 3.2 and 3.3 are assigned identification numbers for use in this audit as shcwn in Table 3. The Task Force shall become familiar with contents 'and numbering system assigned to various separation criteria described.

6. Separation, Identification and Fire Barrier Requirements 6.1 Separation, identification and fire barrier requirements referred to in Table 3 shall be used by the Task Force to

record deficient or acceptance items for those cables in-cluded on the Audit Forms.

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6. Separation,' Identification and Fire Barrier Reauirements (Cont'd) 1 6.2 Missile, high onergy pipe and' Fire Hazard Areas shall be  !

considered _those shown on Sargent.& Lundy Electrical In-stallation Drawings. The Task Force.shall be alert to observe additional areas that may bef hazardous to redun-dant electrical systems and equipment and shall document them in accordance with paragraph 2.4.3 of this procedura.

I C.' 3 Segregation codes shall meet the requirements of Tables 4 and 5.

7. Audit Progress' ,

7.1 A Task Force member shall periodically meet with a Repre-sentative designated by the owner, to discuss audit progress and to evaluate. audit findings.

7.2 'The Owner'shall designate a time and location for such meetings.

j 8. Audit Results

,; 3.1 The audit results shall be prepared by the Task Force in

., a report format which is acceptable to the ownar, for -

!: transmittal to the IIRC.

r 5 8.2 The- results shall contain a discussion of the corrective

~ action taken for those i tems found deficient during. the J

' audit.

8.3 In the event a large number of deficient items are dis-ccvered during this audit, the report to the NRC shall' 4 contain the Owner's proposal for any additional audit.

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Rev. 0 Dated 7 s Table 1 Systejps Selected for Audit

'i AP - Auxiliary Power RP -

Reactor Protection DC -

Battery and DC Dis- SC -

Standby Liquid Control tribution VC -

Control Room - Aux.

DG -

Diesel Generator Elect. Rm. HVAC DO -

Diesel Fuel Oil VD -

Diesel Generator Room Vent '

HG - Primary Containment Instrument Nitrogen VE - Auxiliary Elect. Equip.

Rm. Ventilation ,

HP -

HPCS VG -

Standby Gas Treatment LC -

MSTV Leakage Control System Vent LD -

Leak Detection VX -

Switchgear Heat Re-moval LP .

LPCS '

VY -

Core Standby Cooling NB. . Auto Depressur- System Equip. Cooling

'. ization (CSCS)

NR - Neutron Monitoring PC -

Primary Containment j  ;

and Reactor Vessel Isolation -

i RH - 2H7  ;

RI -

Peactor Core Iso- i 12 tion C0 cling e

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AVED 7-1-80 W Table 2

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}ggerettom Audit Forms and Cable T4h Pane Nebete Cable fan Audit fore tota'. No. of Total No of ** ** " * "

II * * " ~ Safety Raiated Cables Associated Cas tes Pg. No. Pg. No.

Le be AudLted to be Audited, M01 ML of 5 At09 AP2 of 5 66 43 : 8 8 M17 AP3 of $

AF AP31 Af4 of 3 AP32 AFS o f 5 Occi DC1 of 2

. DC 31  ! ' 36 4 4 OC04 L02 of 2 OG01 DG1 of 4 4

Oc02 Oct of 4 00 112 27 12 .

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DG04 oct) T4 of 4 18 18 3 3 0604 c41 of 1 D$ ' i mcol ,1Ct of 2 6 3 M 55 9 W;04 HCf of 2 HPOL MPL of 3 12 17 7 U21 MP2 of 3 at 162 nt3 of 3 HP21 LCol LC1 of 3 23 17 4 LCOS LC2 of 3 LC 173 LC3 of 3 LC15 LOO 2 '0L of 3

14) 8 13 Loci L32 of 3 Le 71 LD) of 3

l. LC10 1

34 6 4 LP01 LFL of 1

! LF 43

' N801 NSL of i N802 N92 of 7 N812 h83 of 1 i

219 28 21 N813 N84 of 7  ;

L N3 294 N85 of f I M818

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• N335 M86 of 7 l wtf3 497 of 7 MA03 NRL of 6

• . NR14 NR2 of 6 NUS NR3 of 6 l 408 221 40 20 NR4 of 6 l N1 NRJ8 l NRS of 6 l NR42 *

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- NR44 - u 6 of 6__

FC06 PC1 of 2 gg gg 3 PC13 PC2 of 2 PC 97

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AJt02 RM2 of 8 RH04 RM3 of 3 M14 M4 of 8 gg g4 RM 403 238 U L1 Shes of 8 M40 886 of 8 M 50 M1 of 8 RM11 RH8 of 9

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69 20 7 R102 R12 of 3 t.t 118 af21 at3 of 3 UQ 3 RFL of 7 R104 172 of 7 ff04 173 o f 7 30 4 Af12 3.P4 of 7 1F 502 42 172; Rf5 of 7 1732 Af6 of 7 Rf 42 Rf7 of 7

- $ sco) SC1 of 1 8C - 45 VCO2 VC1 of 3 13 2 vC10 VC2 of 3 TC 151 12 VC3 of 3 VC15 vo01 VD1 of 2 70 47 14 10 .3 VD03 VD2,of 2 vt01 VV,1 af 2 vg 30 21 7 2 vf11 vt2 of 2 3 3 VC03 %C1 of 1 VG $2 21 U03 '41 of 2 v1 24 15 4 2 vios vt2 of 2 VVQ'1 VYL of 2 29 6 3 vy07 vyt of 2 TT ' 51 o as 13

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• Walt,J /*;*0J 7eble 3 Separation and identtitestion Asquireennes

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Critetta Group 1 Physical Separation Condtrion Phvetest Separattoe Critetta

, la Caels tray wichts the same divtston 1. 1 foot vertical esperatton 2.1 tach horisontal separatton La Cabto tray or conduit of dif f erent divisions in Pro- 1. 3 f eet hortaontal t ros stes ratt to adjaccat tacted Zones (Iow probablitty of betat suoject to trar side rail damage f ros aiselles and/or conflagratton). 1. $ feet vertical f roe bottoe of upper to top of lower stay

3. Where hortaontal or vertical distance cannot be met, barriers of L inch transite and 6 inch air space shall be provided is Caele eray or condutt of dif f erent 4tvtstons in dasard 1. 20 feet separation or a o inca retoferced com-lones (high probaott tty of belns subject to dasate crate watt f ree aiestles and/or conflatrattoo)

Misette Areas Fire (Con flacr4t ton Areaa)

Turbine 81d3 (Main floor) 011 Storage Room Rasetor feed Pump Turbines turbine 011 f an'as ,

taatter 81dg. Operating Instde far6tne Shte1d Floor VaLLs f anesth rain Floor Diesel fue1011 Storage Ceaeracer Wydro1= Q , tee L4 Cpen cante trays et dLiterent stetsions in "eneral L. ) feet hortsontal fire att space Flaat Zones 2. 3 feet vertical fire att space

3. Fire resistant barrier with dioensions suf fistant t's natntato minteus f ree att spectag of 1 and 2

, 4. Where horisonts! and vertical diassaces cannot

' b e ee r . Ilgttationg af Celterta Ib shst t be met le Latte t rays of condults et ot!! stent divisions that 1. 12 inch vertical separJtton and trJF 9ust Se crees each other (in Protected Zones)

• covered for $ f eet each side of intersection of centerlince of t rayy

• Ctste LC Contro t 34ardi aed *anels of dif f erent dtyt= 1. Castes entgelag panet must have 3 foot separaa if stone th Protect ed Zones (Cont est 2cce ar.4 Aua. Equip. tion between divisions *

'#**I 2. Where 3 foot separJtton Cannot be Det, caile of one divisjon should be (nstalled in condelt to a point where 3 foot tcp3_ryt ton 19 artsined Class LE Control Soards ar.J Panels of dif f erent divt. L. sat acte gnan one 4 tvts ton in panel 13 stons in Gener.tk Plant Zones 2. I taen air space between panet, un Contatn ent F.tec t rical Penet tstions serving Claes L k. See critertJ 1a Circu t t e * * $ au Jtetttan) 11 h355/ PCts, er$ Systess Routed in accordaace vtch (Sed subsection 9.3.1.6.2.2 I taen hort iont a t and vert tral seperat ten 11 Candan ts w t entn t=e aaee atvtston Crtta .ta droup 2 Identification Equip ++ct id en t. t f l e a t i on C ri t e rt e 2a Gaa'.e t r iv so s in +> t t in accordance with Tshle 4

1. Io accordance with Cabte tan i

2b !aale <

2. Cable tag with permanent eaterial to each cable end and where it passes carough a wati or an l enclosure (p accord mee with IJhtee # 4 )

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,M M HMcMMENT G ' ~ '-

.Survelliance Date: Febre.' rt 1', t931 File No. 33.5.1 LASALLE Q. A. -SURVEILL*,NCE 2EPORT t40. 81-79 s l

b 1- Follow Up Audit No. 1-80 63 Contractor / Organization Ooserved: Project Constr tion Category: (30)

Finding #1 (Question.#2):

Contrary to the LaSalle County FSAR 24% of the 3"" Class IE cablen u:

equipment audited were improperly marked.

'Auditee Response:

Project Construction takes exception to the gener:tl wording of thi.:

finding. fhe discussion portion:of the finding rekes no .it t6 mpt i. e indicate any established trends or attach acverit, level to then>-T i r.

resulcs listed in Attachm:nt 2.- In addition, th. auditors did review any of the electrical contractors quality c rocedures to analyze the T.casures established to control the ' ' aes of itoms thur were identified. The following_is a list unich "etegori..m il of the safety-related items contained in Attachment ':

A. Safety Related Com'uit Identificccion Nuc.ber o r 7.on-  % of 398 ' cln duit/ Cab Resict. d t

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1. Not tagged properly or not tagged at terminal boxes of equipment, valves, cable.: ray, etc. 47 11.85 5 1.257,

2. Broken off-or missing tags

3. Tagged with two separate seg. tags 1 0. 2 5 l'

0. 2 7,..

4 Incorrectly marked 1

3. Safecv R21sted Cabic Identification

1. "Brady" tags not lezible '

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2. Incorrc:tly tagged 0. 50l; number transoosition 2 wrong color ' tag 1. 2 5!'

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1. 50 /,

3. Not t agged inside panel or J3 6 1 0 . 2 9

4 Tagged twice

5. Auciter errors l (a) stated cable service did not match nabic tab description (2) (0.53.

(b) stated cable was not tagged above equipment (11) ( 2. 7'E >

?CD's response to each of the above categories is as follovs:

v Category A.1: Discussion with the auditors :odicated tbnr th specific problem in this catoimry was that the segregation tags were not phy *cally ..t the

.y piece of equipment. That is, i nc segrm.itiou ? -

N was at the end of the ritid c duit but not at the equipment end of the flexi' i e conduit ..hico

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1 - l connects the rigid condui t to the equipment.

l f- Project Construction is cuite aware of this practice J and does not consider it a separation " violation" j because the flexible conduit is limited to 18" l minimum and 6' ma:imum. This interpretation was d agreed to by both S:30'and S&L in a meeting on j I

October 21, 1980. i e Category A.2:

This item involves segregation tanc that were broken i off or missing. H. P. Foley (HPF) 'dork Instructions j

301 and 302 requires that these tags are installed i and this is verified by HPF QC on checklists HPFCo-028 {

and 030. There are numerous reasens why these tags J' j

c could have been knocked off after the conduit was l installed. Therefore, the area walkdown pi;ocedure which is being generated by Project Construction and I HPF contains a check for missing negregation t?gs. I Because a missing segregation tag is easily identified, Project Construction caels that tha area walkdo'n procedure is the correct mechanism to repiece any of these missing tags.

lc Cctegory A.3 and A.4:

These items involve one conduit which had two segregation tags and one conduit ihich had the vrong.

3 color tag. There is no evident renson why this was not identified during HPF's QC inst 2ctions. The ars-walkdown procedure indicated above requircr; another

! review of these tats and should be a sufficient cent en1 to correct the low percentage of this type of

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l' misidentifications.

.Catecorv B.1:

This item concerned cable tags which were not legibn.

Because of the low percentage identified as illegible f

during the audit and the fact that a cabin's number can be verified by drawing referente, this itam is not considered significant. Field cables are and will continue to be re-tagged whenever it is identified that they require it. The audit results support that no additional action in this area is s.arranted.

Category B.2.a and B.2.b:

This item involves cables that were incorrectly tagted either by number transposition or urong color tags.

times the correct number is evident, for examnle, Many Unit #1 instead of Unit #2 or "IS" instead of "SI".

HPF WI400, Cable Pulling, requires that cables are marked and this is verified by HPF QC.

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5 M Category B.2.n and B.2.b con't:

- As' in Category E. i, Project Constructi.on feels that the very low percentage of cables Cound incorractly marked indicates that this work lustruction is providing a realistically acceptable control in this.

area.

htegory B.3:

This item involven cables not beinr labeled inside of a aanel or JB. HPF WI500, Cable Tecminations, requires caale to be identified inside of a panel and this is verified by HPFCo. QC. In addition, UIS00 also requires that the cable is identified above a panel which is not a requirement in the LaSaTJ.e ES AR. This midit i.onal marking was added to aid the termi. nation crews and or inspectors. Many of the cables not identified inside  ;

the panel were indeed, identified just above the panet.

This fact and the very low percentqe found not mot +.. i .

indicates that no additional action i.s warranted.

.stegory B.4:

This item involves a cable being mnrked tuice. It ir very similar to Categories B.2 and B.3 in that the H L '"

controls (UI400 and 300) are the scme. Only onn er.m: Le 1 of this does not warrant any additional action, besi Ws one of the markers was correct.

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Category B.5:

As stated in S&L Letter 659 dated :10/31/80 (copy l attached), thirteen safety-related cables should not  !

have been found unacceptable by the audit team. This l was a misinterpretation of the La.Srile identification criteria and these cables do meet the requiremeats of the LaSalle FSAR. (For Item B 3.b. ploase note tha:. the tagging of cables above a panel is a requirement of UF eb WIa00, but baccuse these cables we re 'dcutified in,)

panel, the LaSalle FSAR cable identi'fication criteria was not violated.)

i Corrective Action and Date of Full Comollance:

1 The field is correcting the occific listed in Attachment 2. The stacus o, is is " complete as indicated on the attachec .py. .a > lkdo m mentioned above will be conducted on a schedule which is commensurate with the scheduled area turnover to the LaSalle Operating Department. As sho.tn above.

it is Project Construction's opin4nn that no further action than this is justified.

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W Follow Up Action:

Category: A1 - T. E. Matts letter dated December 23, 1980 to T. E. Qucha (sce attached) concurr with Pro' ject Contruction that the segregation tag at the end of the ri,gid conduit instead of the equipment and of the fic::ible conduit, uas a legitimate and acceptable methcd of tagging the conduit.

Categories A2', A3 & A4 -

Foley Procedure SCP-15 (f.rca Walhdown) is currently beine impicmented at LaSalle. Th- procedure specificaU-requ[res an c::cminction veri"yirc the cable end  !

conduit identification tags c.re correct nud in cloc c.

In the T. E. '.latts letter dated D .ccmber 23, 1980, Project Encincaring agreed wl.tb P oject "onstructinn ,

1 that the walkdoun insnection uill be an eEEoctivo 1 means of identifying and correc ti ig taggi.ng ocfic iencim on an arca basis, rather than tryLng to repnir or l replace cach tag individually. l Category 31 - In reference to the T. E. Watts 1.tter dntod December 23, 1980, Project Engin~. ring agreed uith Projee.t Construction that illegibl.e identification ' cans on cabia is not a major problem. The basis for their decision was that there was a le percentagn idone e n .1

,s in the audit along uith the fact '. hat there is t  !

mechanism wherchy cabic nuse':a - n be r edily vert icd l 4

i Also the arca walkd<r m will be identif yine

- by these the typeso drr.d: g,f discrepancies prior to system turnovm .

Category B2 & B4 -

For appro::imately the past two y ars Foley trork instruction WI-400 has required o.C. verific ation of the cable ta; identifications for all safoty rel: ted cables. It.is quite possibi.e tbo; the s:"n L J pe r"co r +

l of cables that were discovered to be incorrortly tagged, were pulled prior co the present inapoccion l

i requirement and were not part of .he sampic that i  : :re :alected for inspectin;; at that time. Projne:

C- ~'ct Lon indica:cd in choir ~sponse that Mrd ng

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!cncles which ucre a result of tran. position ~ rore werc generally evident as to their corrout enble numbers. They,also indicated tb.h Foley's ,oik instruction provider a realistic cceptabic control in i this area. QA verified that cabins VR090 and VCO2!,

which S&L agreed were cable marking deficiencies, (see attached letter 659 dated 10-31-80) wcr: round to have bcon corrected. Althout l

l only be verified above the panc3.. Cable '/CO21 cwid m

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- 3 1 Category B3 - In the letter dated 2-4-03 (sce attachtd), T. l E. Watts states the. the icw percent'go l of cabics fotmd witbout identificat!.on markLng insido l the pancis does not constitute a pro'dem of concern, since the majorit the panels por H.y o*? cables P. Foley were wtried Work Inst.ruction '.!I just obeve 90".

Category B5 - The T. E. Watts letter 2-4-81 states that there appears to have been a misinterpretation of the identification criteria as pointed out in S&L latter 659 dated October 31, 1980. In fact cables not beLug narked above panuls is a violation of a H. P. Foley procedure anel not the LaSalle FSAR.

Deficiencias from area walkdown #8 were examined, widch was conducted in the Unit I Reactor building at elevati.on 673, between A-J

& 8.9-15 and performed on 11-1-80. A1:o examined wore deficiencien that were discovered in arca walkdown #5 acrformed on 1-31-81 and eanducted -

45.

in the Unit I Reactor building, at alt:.*ction 786 Iw.wcen A-J & 8.9 These deficiencies appeared to have identified mauy taggire d"ficic'icts for both conduit and cabic, which Lindicates th't Procedure 'CF-15 is apparently being properly implemented and providing the necoscary conern1 for identifying these type of deficiencies.

Several discrep .ncies between the cabic segrrgation mid the conduit code which resulted from crrors on the S&L 9I drawings were The affected cables were HIP 2'o, 19 154, gi verified te have been corrected.

1RH406, 1RR152 and 1RR158 and the discrepan:ics ar" described in che attached S&L letter 659, dated 10-21-80 on page 2. Based von Project Engineerings concurrence with Project Construction imd S&1 es: onras td this audit and the fact that the types of deficiend.os idcutificd for the most part will be controlled by the finr1 orca valkdowu, thin finding is considered closed. 4 -

Reported by: [144y / /4 Do"U, f Reviews.d by: $)/ef k nes en . pg .f' Approved by: 12.CN.B,e w- -

Date: 7 7

/y,/m cc: U. J. Shewski/G. F. Marcus L. J. Burke /N. H. Donaldson vt. E. 0.uaka/0.. f . File Contractor B. R. Shelton B. B. Secphenson D

2 w - - - -

g 4-Project Construction response to each category is as follows:

Category C.l._1: Discussion with the auditors indicated that the specific proolem- in this category was that the segregation tags were not physically at the piece o f equipment. Thut-is, the seg-regation tag was at the end of tl.e rigid conduit but not at the equipment end of the flexible conduit which connec ts the rigid conduit to the' equipment.

Project Construction is quite aware of this practice and does not consider it a separation " violation" because Ute flexible conduit is limited to 18" minimu:a and 6' caximum. This interpretation was agreed to by both SNED and 3&L in a meeting en October 21, 1980.

Catego ry C.l.b: This item involves associated segregation tags tnat nave a Jolid white background instead of a :dciped background.

All of -the associated conduit segregation tags purchased for LaSalle have a white background and are stamped vtth a number to indicate the division association. This type of tag hon been accepted by Project Constru: tion, QA and the NRC for many years. However, in a meeting on October 21, 1980 3UED and S&L recommended that a striped tape be added in addition to the white metal tag to further indicate the division association.

The striped tape for each of the three associated divisions has been ordered and will be added to the conduite when it is

, II received. This additional taping will be verified during the aren walkdovns mentioned in Finding #1.

. Category C.2:

This item involves segregation tags that were broken off or missing. H.P. Feley (HPF, h'ork Instructions 301 r.nd 302 requires that these tags are installed and this is verifle l by HPF GC on checklists EFFCo-020 and 030. There are numerous reasons why these tags could have been knocked off after the conduit w:is installec. Therefore, the area walkdown procedure which is being generated by Project Construction and HPF containa a chect'. for missing segregation tags. Eacause a missing segregation tag is easily identified, Proj?ct Construction feels that the araa walkdown pro:ecure is the correct mechanism to replace any of these missing tags.

Category C.3:

These items involve one conduit which had two sedregation tags and- one conduit which had the wrong color tag. Ibare is no evident reason why this was not identified during KPF's CC inspections. The area walkdown procedure indicated above requires another review of these tags and should Pa a suzIicient control to correct the low percentage of this typ' of mic Ldonti-

~~T fications.

1 1

w.-.. = - a- e-,w-- ----,-rew w. .s,---vn-..c--.m- --wegw,,,-, ~-m e.,--ue- .em,e -,ye y . .,~%w,- e ,=we ,-e n r w g+w.-rww. - s -

-.+--,teve g -ww,, wwc "'

M 3 ,

Catego ry C.4: l 7} l This involves an associated (lix) cable TheIVX052 ceditor which wasthe indiented routed  !

in a conduit with Div. 1 cables.

j i This is incorrect; the conduit r.hould have been marked 13 K. l conduit is and should be marked liK. This was confirced in S&L's letter 653 dated 10-31-80, page 2.

Category C.5:

This involves seven junction boxes which were idW Lfied during the coloraudit as notmarker permanent having(a permanent one). HPF has marker (six) started just recenriy or had the wrong tag is to put on junction box covers (normally where the permanent p15ced) because the cable pulling in Unit #1 is nearly comple te.

This is another item on the area walkdown checklieb that will )

be verified during the walkdowns.  !

Catecorv D.1:

Because This item concerned cable tags which were not legible.

of the low cercentage identified as illegible durtng the audit and the fact that a cable's number can be verified oy drawing reference, this item is not considered significant. Field cables are and will continue to be re-tagged whenever it is identified that they require it.

The audit results support that no additional

. . ,3 actica in this area is warranted.

lL' Category D 2a cr.d D.2b: l I l As stated for Category B.2.a, the low percentage of cable tags having number transpositions and the fact that cable numbers can be readily verified by drawing or cable tab relerence, l

indicates that no further control in this area is required.

Item D.2.b involves cable tags which are the wrong :olor.

PCD feels that the primary purpose of the color coded cableOnce tag is to verify cable segregation during cable p nling.

the cable is installed, there is no cafety significince to the cable tcg color coding. It is Project Constructirn's positico that the Audit results inqicate that this color emie marking -

is being controlled within acceptable limits.

Cate co rv D. :a :

This item involves cables not being labeled inside of a panel or J3. HPF WI500, Cable Terminations, requires enele to ha identified inside of a panel and this is verified by HPFCo. CC.

In additier., b'I 5CO 31co requires that the cable ir identified above a panel which is not a requirement in the LaSalle FSAR.

This additional marking was added to aid the termination crews and CC inspectors. Many of the cables not identifiedThis inside fact the panel vore indeed, identified just above the panet.

J and the very low percentage found not marked indientes tha t l

no adcitional action is warranted.

I f

w- _

9

.' 4

,g Category D.3b:

This item involved associated cables which were marked with one piece of white tape and one piece of colored tape instead of the normal striped marker. Thi.o was done by HPF Production cn a temporary basis because they ran out of associate J markers. This was written up by HPF QC on a Cor.ective Action Report. This controlled document will be required to be closed Jut prior to Project Construction turning over the particular areas to LaSalle Operating. It is Project Construction's opinion that this hos been and will be the best method to control the remarking and assure its completion.

Cateeorv D.h:

This itas involves a cable being marked twice. It is very similar to Categories 3.2 and 3.3 in that the HPF controls (WI 400 and 500) are the sane. Only one examole of this does not warrant any additional action, besides one of the markers was correct.

Categorv D.5a & D.5b:

As stated in S&L Letter 659 dated 10-31-80 (copy attached),

thirteen safety related cables should not have been found unacceptable by the audit team. This was a misinterpretation of the LaSalle identification criteria and these cables do meet the requirements

([I of the LaSalle FSAR. (For Item 3.5.b pleaie note that the tagging of cables above a panel is a requirement of HPF WI 500, but because these cables were identified inside the panel, the LaSalle FSAR cable identification criteria was not violated.)

Corrective Action and Date of Full Como11ance:

The field is correcting the specific items listed i.n Atta"hment 2.

The status of this is necrly complete as incicated on the attached copy. The area walkdowns mentioned above will be conducted on a schedule Nhich is commensurate with the scheduled ,rea turnover ,

to the LaSalle Operatin; Department. As stated in Finding #1, it is Project Construction's opinion that no furthur action then l

this is justified. ,

l Follow Ua Actior, Cate go ry C .1. c The T. E. '.latts letter dated December 23, 1980 to T. E. Cuska (See attached) concurs with Project Construction that the segregattnr e

e W

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- - , - , . , - v - - . -

nm,- . - v - --

w - m ..

tag at the end of the rigid conduit instead of th" equipment 7). end of the flexible conduit, was a legitimate and neceptable method of tagging the conduit.

Category C .1. b . C . 2. ' C . 3, C .,5 Striped 3rady marker tags have been ordered by Froject Construction to be placed on the conduits containing associated cables. These markers have not been recieved on site thus far.

This item can be closed though,)baced upon the is currently fast that Foley beirc Procedure CCP-15 (Arca Walkdown This procedure requires the verification implemented.at LaSalle. Also missing tecs, of cable and conduit identification tags.

and wrong color tags on conduits ns well as no permanent ma'rkers or the wrong permanent colored markers onAdditionally junction in boxes would be identified in the Area Walkdown.

the T. E. Watts letter dated December 23, 1980, Project Engineering agreed with Project Construction that the walhdown inspection will be an effective means of identifying end correcting tagging deficiencies on an area basis, rather then trying to repair or replace each tag individually.

Catenary C.h

(

S&L letter 659 dated 10-31-80 confirmed that the 1TK tag11K) i on the conduit which contained associated cable 17XO52 (g ne  ;

l was correctly marked.

z) u Caterary D.1 .

As indicated in Finding fl category B.1, Project Engineer!ng agreed with Project Construction that The illegible jd :ntifica tion basis for their tags on cable is not a major problem.

decision was that there was a 1cw percentage identified in the audit along with the fact that there is a mechanism wnereby cable numbers can ba readily verified by the drawings. Also the arca walkdown will be identifying these types of discrepencien

. prior to the system turnover.

Catecor" D.2 nnd D 6 Only a small percentace of associated cables areIt.mrified appears that by Foley G.C. , per Foley work instruction 6I 600.

l with the small percenta;e of these cable tagging deficiencies identified that an acceptable control exists in the area of associated cable. Cables VR090 and VCO21 which S6L agreed were cable markir.g deficiencies (See attached letter 659 dated 10-31-30) were found to have been corrected. But cable VCO21 could only be verified above the panel.

Catecorv D. ?.a N As indicated in Finding #1, Project Engineering (T. E. ',la tts letter catea 2 6-31) cic not feel inside thethat cables panels fouad without constituced a problem of identification marking

. . .. . ..-____..-u - . - . - . . .

6 6

g.

- concern, since the majority of 'the cables were aarhed juct outside the panels per H. P. Fola, ilork Instruction (9/I-590).

Since Foley's work instruction requires identifien tion bo th above and inside the panels, it cppears that reasonable control is established to address these types of deficiencies in the future.

- Catego ry D.3.b Based upon the fact that associated cables were marked with one

, piece of colored tape and one piece of white tape on a temporary basis, and Foley Corrective Action Reports have documented the locctions where this practice nas ur.ed, a system of control is in place.

Category D.5 In reference to S&L letter 659 dated 10-31-80 (See Att'd) nets or the FSAR nor S&L's Cabic Identification Crit 9ria for LaSalle County Station require that a cable be tagged where it enters an enclosure. Consequently, twenty six associated cable idencified during the audit as having this deficiency are to be dropped, based upon Project Engineerings concurrence (letter dated 2 4-81) with S&L and Project Construction that no violation of th< F AP exist.a.

Ci

v As indicated in Finding #1 deficiencies from area 'Jalkdown i 6e were ' examined, which, was conducted in the Unit I Peactor building at elevation 673, bat'</ con A-J and 8.9-15 and perro med on 11 1-80.

Also examined ware deficiencies that were discover-d in area walkdown 95 performed on 1-31-81 and conducted in the Unit I Reactor building, at elevation 786 between A-J and 8.9-15 These deficiencies appeared to have identified many tageing deficiencies for both conduit and cable, which indicatus that proceduru CCP-15 is appcrently beinc properly implemented and providtng the

,necessary control for identifying these type of doficiencien.

Several discrepencies between the cable segregation and tue I drawir.gs conduit code v.hich resultad frr. er~c . .,lc. "2.Mn4 11bles

.  ;.2 uere were verified to have been corrmt:2d.n m; acre onneles are 1HP219, 1RH4C6, 1RR152, end ' 1RH1; 5 described in the attcched S&L letter 659, dated 10-31-80 on page 2. Based upon Project Sngineerir.gs corcurrence with Prcject i Construction and S&L responses to this audit and the fact that l the types of deficiencies identified for the nos+ part will be controlle l j

by the final crea walkdown, this finding is consid9 red closed, 1

l j

"' cc: 'cl.J. Shewski/G.F. Marcus L.J. durke/a...n. canaldson Reported by--- b c-

, LL -

On te - - -

T.E. Quaka/Q.A. File j Reviewed bybO M d M?

DateP - 7.,

Contractor Approved by I'3 C' 8.~~ Da tnya,.

B.R. Shelton ,

B.B. Stephenson

laSalle Q. A. Surve111,4ce Beoort to. 31-94 m

V- .

Folle., Up

'a .

Audit No._ 1-80 63

'ontracto r/Organitation - Observed : r2roject Engi.neering Cate go ry : ( .'

Findine #3 - Cuestion #4 Contrary to the LaSalle Ccunty Station FSAR.five r~nels were

..dentified -c having wirir.3 separation violat.i.ons ,,t the ceni rola or terminal blocks inside the panels.

The followins internal panel wiring deficiencies were identified dIring.the audit:

1. - Panel 1;-:13-P614 has Cable lRR092 blue-associated and Cable 1RRC89 yellow-associated terminating into Recorder B33-R639 Cables are in contact with each other and ~ terminate at some block.

Also , _n same panel, - Cables RR369, RR184, RRCo'1 yello .,-a s soc iated and Cables 093, 092, ?63 blue-associated termi' tate in .,

Re: order 533-R601.

.p

2. At Panel 1PM1CJ, Main Control Room Di9 ision 1 associ& red ~

cables were terminated- with ' Division 2 associa ted cao.v s at the sace terminal blocks.

J. At Pane _1PMC9J, Main control Room Division 1 occocia rad Cable 1FCO25 is bundled together with Division 2 associated cables and terminated at TB12 with cables.

h. Panel.lH13-P6.1.1, NSSS/RPS Trip System B. Divicion 2 Cablas 1PC076,1PCO32,1PC090, and 1PC091 are bundled and ternitn etos; -

together with RPS Cables B2C at same Terminal Block.

5. Panel 1.-L3-P609 NSSS/RPS Trip System A. Division 2 Cable" lNECh3, 1FC051, 1PC140, and 1RR389 are bundled and terminating together with RPS Cables A2C at same Terminal Block.

t,uditee Resounse S&L's letter 659 dated 10-31-80 states that Items 1, 2 and 3 of this findin,; do not violate the LaSalle Separation Criteria.

The letter ces on to say that for items 6 and 5, the existin;; fipid installation do not directly violato any stated criteria, but f.oes state that the criteria is vague at this transition point

-s in the cabl 's routing. Project Construction doe:. not feel tha t

• ' any rebundlin; is warranted until additional critoria is 'inalir.ed; v bundled namely, to what extent should the rebundling occur and one what is the separution requirements of the bundleu, em y 7--- an. -w g g. m e --m-,y-. g a y -.,,gg 4p. q9- -

g.g+-g9--gwe r e- yer r 9' ----g,

- ~' " ~ I 2 (

.- Corrective Action and the Qtte o f Full Comnliance:

Until additional criteria is rbceived fmn SNED cr S&L, Project Construction maintains that the existing field incta11ations do (

not violate the LaSalle Separatico Critaria.

l l

Follow Un Action Project Engineering is in agreement with S&L's decision that I items _1, 2, and 3 identified in this findin6 do no t violate j the LaSalle Separation Criteria (reference Wntts 1.etter dated 2-4-81). In addition, Project Engineering is in ngreement

)

with S&L and Station Construction that rebundling or reterminating of cable is not justifiable at this time, since items 4 an1 5 are not directly violating any stated criteria. Consequ ntly this finding is considered closed.

1 I

l B

v.

1 Reported by U/>n.i. ]. -E' O :) S DatO/

• Reviewed by dJ/ c8eM Dn tep,3 Approved by ECi A % ___ _Dnteg. ; j cc: W. J. Shewski/G. F. Marcus L. J. Burke /W. H. Donaldson T. E. Quaka/Q.A. File /

Contracter B. R. Shelton B. B. Stephenson 9

1 t- *d- *=- P- - - - - - , .-e- -. +i -

w--+ , y v- r- m --- , , ---w+sy- - -eee- ,*e.yirv- g - - g -- --W*

anc.;

: t.;: #chruarr ir.. .. .G .'. c 1.1. No. 3. 3. !. --

.. "...T.". . . .\ . ST.tF II.t. . . P. " c ' ". . n." ' ' . . 9'-?7 Fo11. Up Aud!.t F . *.-C C .'

Cont..-tor./C ..ni atica Cbsc-vce: 'ro.%ct Cotic tt,in tion .

C i a got., : (lu) .

l (Qtection '1):

N,um.r :.1 .

<'er ta s ;- '.n LctSa'.' c ".ounty S tat! cr r5t.P, '. saf<.tr ssocia.ted cableu Thi.,

.;. c f url to ham. 'r'.olcted (tus c.'. ::,u.r. tion c:'tcric.

c'onst itut:.d : tot:1 :.C 17, of the etal ssociateu .. ;ble- excmined end

~).3% c f i 1 casociat d and clast ':' ch l c cudited.

"unduit carr/f.nc, c.c.S'.c 1DC04 *. do. . no . have a onc inch hori7.ontal :.: '

"artic.1 ;c.;c at!nn :ith c b?e t et -.cd. 35:B. '.l c o c:.Sl: .; ' T H T.:. ,

'M061 are burdled tc: t'1;r .:r cross!r: dif f.:: .?nt d4.vi., ion

'PT071 cn er,bl:s in oan:1c t.;here c. 3 foot . cra'. ion is to b. attJcv d. '? ue

.t ta:. 5 ncnt ' I . " tF 2 audit rcculta 'Cor 1... ions s.,f deficf ansics.

.  :.'it . . Rcspo"sa : l Jt. . Cec.tvuction a;rces that -he cer 9:it carr 'm: 'JC043 7 101 :> + .

c s. cr: tic.r criccric_. Thi.s condu!.t .i!I be raio.J h a 1 ' miniw.t.

.ar e ica "e r the cc,:ble 30 t' , n  : corf o r ..: to th>. cr'r riu. 'AL

...u .1.c. ,i , , .fer . mo.

.a.. ci, . p a u ,l ... ,

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ciat ett the E ~ ~1,; gc- :i w

}

• .e 1R','0 6 7 , 1RT071.nd int:171

.' :. . t. . - Pra iact Constrt': tion ,r;;; .n_ will rcz's: 0e panels 5

b: S&L.

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^

._t ._c.c 4v .'.cticn nd D-te of Full Cemr,' Once: -

D . idu4' : .: . "" 0 4 3 't. . - 'oc an :: ised :n the fi .1.'. .m s. ., nou 4.n

,,p t'a s - . .m e xy.

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2 ?.c 1RT-':, 1RT, 71 and U.H171 .c .! . r t . litter.1 ter ': to 4 '.11-

u. p;. ; n t ru ,6 be e r.n,cted when r.vbec, drawing

w rc. . ive a:.1 it .

, , ' . ..10- U; ..t,an; T"-  : r.'.u i "or cable 1DC013 was "' rifi. ." to h t* - E .n : . iced n thr. .

T' 11 t3:u 4" aber2 the 2.:bic p.- ' . Thi , rc"i ' <.' the neces sa: y i ' r. t c 2  : thc ccbic so that n x .v.n f o r c. . ' '.' t tN La5r.c

2. ion riteria. .ZL 'tas rc'r ,ed th. 'r: . tin ,. Mr c 41: 3 o,TO '

9. '.'07 i. and inM171 ':0 confe"m to t'u LaSch. scyw .': ion critori.. .

5 f ,

~ _

Follow Up Action Con' t Foley Work Instruction 103 provides a traveller and the sequence to be followed in order to assure that w2. ring type design changes on safety related items are incorpcrated and inspected. Traveller packages for cables 1RT051 andThese 1RT071twohave beenpackages traveller written and areissued to Foley for field revision.

scheduled to be completed no later than 3-9-81.

It was established in discussion with the senior S&L audit team member, that during the course of the audit additional panels other than the panels being audited were also examined for separation This audit coverage criteria which incluaed antry point violations.

constituted examininn at least 90% of all Unit I safety related n'anels. Since a low percentage ou panel entry point vio).ations were identified for the large sample exanined, it appears that these were isolated cases. Based upon the fact that the work has been scheduled to correct che panel entry point violations for cables llT061 &

1RT071, plus 1RH171 will be scheduled within the same system, which requires Q.C. verification. This observation is considered closed.

? ---.-n--------- ----------------------------------------------------------------

Reported 'oy: f e/ , / Date: 3/ /

/' 'I Reviewed by: [./[ k _u, 1 N Date: J fE' Approved by C e.s. IvI':.. Date: 3 !Tk/

cc: W. J. Shewski/G. F. Marcus L. J. Burke /ti. H. Donaldson T. E. Quaka/Q. A. File Contractor

3. R. Shelton B. B. Stephenson

D e r o .1b e r 2.1, 1980 f- .

S(cject:- ' Audit'l-80-G3, Electrical Separation i

l l

Mr T.E.-Quaka: . I I

Station Constructioq tak a s except i om ito . Ca ::c gary. A ..' : Locakio"e j of conduit segregation ~ tags, and does.not consider it a s ere a t i on I violation. Their feeling-is that, since the flexib b conduit length i- H limited to.between 13"'and a 6' maxi.1.um, th is p rac-t ic 2 is a ;agitimate l and acceptable method of tagging the conduit. .Both '1ED and S&L are la j i

l agreement with this interpretation of the rel'ated spr:ifjcation. j

.' .tC , J An exception is also taken on Category A.2 it is felt tha' l while construction is still underway it would be ex :nely difficilt.

not impossible, co protect t'1e integrity of segrati.:" tags. Upor.

. completion of construction, prior to an area being im ened o m, comprehensive walkdoun inspection of this area will

• 2 performed by Station Construccion and any tagging deficiencies sbrild be located ud corrected at this time. Engineering agrees tnat th.: .ia l k d own inspecei -

which will be .dene by proceduras, will be an ef f ect i'.e aeans o f b correcting deficiencies-on an area by area basis cataar tha.. trying ."

repair / replace tags on an individual basis.

.The third and final exception ta . items in .this audit is takeo o

.$. 'Ca.tegory 1.1, which-involves cable. tags.wh'ich were not legible. S r. a *

'v Construction', stand in this instance is that since other cable identifying mesheds are availcale an.d the percentage if tags that we' o not legiole is quite low, no further action ot1er th.n reple ino Dillegitic tags on an as focad basis is required. Scr1 & S&L ari in ,

agreement with Station Construction's dispos); ion on ..'s probic:t ano also feel tha? the illegible ': cgs are not a major pre;iem.

1 It app, cars that most deficiencies pointed o"t. in the audit .' .

'0

.in'the area of ident fication rather than separation isolations and t the critaria set forth in the LaSalle County FSAR for ,saparatio.i are being aanere co.

l

'C.5 1 1 T.E. Watts 1

! JFP/sb/9191A 4.3 s'

l

' February'4, ;9; i S ubj ec t : Sup:lemental Response to Anci' 1-80-63 E1ectrical Separatfon Mr. T.E. Quaka:

Station Construction has tf<en exception to certain additional items not addressedThe in the letter from purpose T.E.

of tiiis Watts letter is toto resolve r.E. Quaka datnd or a.iswer December 23, 1980.

these exceptions.

Category 8.3. addresses mar'<ing of cables :nside panels.

S ta t i on F.hns tr uc ti on 's pos i t ion on this cate.,ary is '. hat due to the inv pe-cdntage of cables found unmarked inside the panel (5/393 l or 1.5%) ni the .najo-icy c f the c 2bies were marked ou Project tside the p ine s (per Engineering concure H.P. f.;I?"

orncedure) no further action is required.

d i t ri this decision.

't 4 Due to the low percentage (.25%) of cables found 'in categor -

Sta ian :enst jetion feels no further action is required on this item.

Pr c ;.ac t Jngic:aring agrees that this.does not appear to 'ce a major pr , l' and agrees with S tation Construction's resolu tion in this category.

Category S.5 appears to have been a result of misinter*. ret'.

r of the 'dentificaion criteria as pointed o'u in S&L ietter 059 dated i Oc )ber 31, 1980. Category S.5.b. addresses cables not markedatTer~~' above panal, wtich is in f act a requirement of H.P. Foley :mpany the LaSalle FSAR. Projec t- Engineering concurs with 7tation Construction's cecision that aa action is necessary.

Observation #1 addrasses violations of the '.41a1': criteri These violac'on's ' ave bt?cn

..h i ch' wa. c i de n t i fi ed by the aud i t team.

wii' be corrected upon receip! 'cf revised SC. Jrowings. E n g i n ee r i n e; in.agreetant n ith the resolution of these violations.

Setarai apparent internal panel t' ring deficinoce: .v e r e l

by,.he aucit team in 'inding 43. Items 1,2

nd 3 of t11's ' i n d i .19 vie addresse ' by.3&L letter 659 dated October 31, 1980 as act ' 101 1 ' i n g t h e- ,

L15alle ,20arition criteria. Project Engi.to ing is in agreement wi:

St.u's decision on these items.

l Items 4 & 5 are addressed as not di ectly violating a.y Oti' Therefore, Project Engineering and S&L are in ag-Octiait v.-

o criteria.

St, icn Construction's position that rebundling is not justifiable a:

' this time and reterminating of the cables is not necessary.

RECE!VED FE90919E 4' E 8/c2U T.E. Watts (IEdo La SALLE S!TE (I A JFp:mnh/01635 cc: J.F. Phelan E. 1ecze' (GA) /

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J-2559-G59 October- 31, 1980 Project No. 4266-00 Con =cnwoalth Edicon Ccapany La Sailo County Station - Unit 1 .

i Audit Report 1-00-63 Elect:-ical- Guo. aration a-c r

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S&L Specification J-2559 4 j l

C. E. Co. P.O. 4186454 .

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Mr. K. W. Stcolo CE('c, LE SSI.,bE Co=monuccith Edicon Company g E Q. A.

c/o La Sailo Ccunty Station R. R. 01 l Marseillac, IL G1341 Daar ::r. Stecle Tho following in in recponce to thor.c audi-c itemo uhich vo ngrecc to addrecc during otr.macting of October 21, 1980:

t, 02 Findindo 1)

Identificatica Criterica 2D2 ic inccrrect. Moither the PSAn nor Ucrient & Lundy's Cablo Identificatica Critcria for L. 50.110 Ccu:.%

Station rcquire tiv.t a c:.blo bc tagged uh:: o it entera ca enclocute.

Thoruforc, the finding.: in Attachment 2 againct the following cabi.a numbers on PLgcc 2-21 thru 2-27 and en Pceje 2-30 chould bo dropper.;:

DG019, D0020, LP013, LP015 thru LP019, KBil9, U27.12, PC064*, RI!4 01, nii4 02, nH403, n:012, 27.022, nI215, VC102, VC105, VC100, VD0lS2, VE013, VIO15, n'Oll, VY07 5, A203 5, IM032, IS037, I'.'0 3 3, an10 2, an105, an103, Un037, VQ174,

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• Theco iter.c have an cdditional finding uhich nuct be addresued by the field.

Alco, in ;.utachec.t 2, a co 2-13 and 2-10, the deceriptions in

- the cablo tabulation for cabics AP313, AP323 and AP329 are correct.

Thorofore, tha findingc against theco cablo nu=bera chould ano ho dropped (bacidca, theco " findings" aro beyond the ccope of thic audit);

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J-2559-659 October 31, 1980 Cenmonwealth Edison Company Page 2 Mr. K. W. Stoclo Wo havo reviewed the electrical inctcllation 2 with dr1 wings for the discropancies.botwann-

. _ following cabloc listed in Attachtent These are the tho cable - segrega tion code and the conduit code.

results: '

HP219 (Page 2-3) Conduit chould be marked 1GK (green) por EI drawing.

• Ra406 (Pago 2-6) Conduit is marked 12C on EI drawing, should have been IEC.

VX052 (Page 2-9) Conduit is correctly marked 1YK por Er drauing.

• Rn152 (Page 2-14) Conduit la marked 1YK on EI drawing, should.have boca llK. .

• RR154 (Page 2-14) Conduit is marked l?K on EI drawing, should have been llK.

• RR158 - (Pago 2-14) Conduit ic marked ink on EI drawing, should have been 12K.

v0175 (Page 2-17) Conduit tag (lSC) is correct for additional cables in same conduit..

v, .VQ179 (Page 2-17) Conduit tag (lYC) is correct for additional cabic in conduit.

VR090 (Page 2-19) Cabla is incorrectly marked, should be llc por tab.

VCO21 (Page 2-20) Cable is incorrectly marked,.should be IVCO21 per tab.

• EI drawings will be revised and reissued irnediately.

Findina 63 Thero is no requirc=ent in the La Salle The FSAR only for the separation requirements for of

" associated" cabica within panels.

separation of associated cabics at La Sailo apply to cabicaThereforc, Ite routed in trays and conduit.

this finding chould be dropped.

The critoria for Reactor Protection System cables require However, that thcro they bo routed wi-h no other system'a cables.are The Gonoral Cicc tricno ruins preventin Cc=pany terminal biccR with non-RPS cabica.

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/:.cnwealth Edicon Cc pany J-2559559'

'tr. K. M.- Stacle October- 31, 1980 Page 3 miteria upon which the La Salle Ccparation Criteria is based in t.nclear on how the transition frcm cable routing to cable

.ermination ic mado. We might cug(;nst that they be unbundled from cther cables but we see no need to retarninate them.

0 6 s 2 c ue.%i s n ~" I l Cabico laT061, 1?.0071 and 121!171 de not =ect the ' criteria for acparation of cabics entering panels. Sargent & Lundy will icsue details to correct the installation of those cables.

.c have noted the.0-there are conc unaccigned cablos ,,nd 2Z systc=

cables which have teen dicconnected at pancia bat wnich remain within the panel ccction to which they uare originally accigned.

f' Theco cabics chculd be re:.cVed from the pancis, ur.pecially if their segregation code differs cignificantly frem other cabics terminated in the came panol ccctica. This will climinate come of the questions raised relative to the mixture of accociated cablea in pancic. j If you have any corv.ents or quectienc rclated to the abcve, pleace contact. =c at your ccavenience.

Yourc very truly, W. G. SCHW AR f 7-W. G. Schwartz

. Senior Electrical Project Engineer 1.*GS/jrd

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Lopies:

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Enclosure 8 Item 9 Technical Specifications (16)

Commonwealth Edison provided a response to the last (August, 1980) full BWR Standard Technical Specification issue on December 17, 1980. Since that time three additional partial revisions to that " Standard" dated January 14, 1981, February 5, 1981 and March 13, 1981 have been received. On the assumption that no further changes are forwarded by the NRC Staff, Commonwealth idison expects to be prepared to review the then current "Stanoard" specification in mid-April, 1981.

It is our firmly held view that future technical specification discussions must be conducted with the technical branches responsible in addition to the NRC QA Branch. [t is our Judgement that remaining oifferences between Commonwealth Edisn involve technical substance rather than format, and therefore, demand the participation of the technical branch having responsibility for the review of any area in contest.

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Enclosure 9 l

item .10 Quality Assurance (17)

The NRC Staff has in the form of additional questions on the LaSalle County Safety Analysis Report, requested clarification ano augmentation of the "Q-list". Spec i f ic a l ly , questions 421.6, 421'.7, 421.8 and 421.9 each addresses itself to systems, components, structures and procedures existing prior to TMI as well,as similar items which came under review at ter TMI. The initital response to certain of these questions was accketed in FSAR Amendment $4 (0421.6, Q421.7), supplemental information will be submitted in amendment 56 which will be transmitted in early April, 1981.

Numerous meetings and conferences have taken place between Commonwealth Edison and the Staff regaroing the intent of these questions. Although in general, this interaction was productive, it led to the clear recognition on the part of the applicant that the Staft is proposing a major expansion of the Q-list philosophy, an expansioq which unfortunately is so broad as to be ambiguous and we believe unenforceable.

In general, it can be said that the Commonwealth Edison Quality Assurance Topical Report applies to safety-related and ASME Section III activ'ities and items, and related consumables plus fire protection, security, emergency planning, meteorology and rad waste .

shipments. This commitment is clear, and has been clearly cocumented. However, the apparently trivial adoition of such items as fire protection or emergency pain to a "Q-list" introduces uncertainties in interpretation which are broad and, therefore, ominous. Although specific commitments to the degree of applicability of the QA program to such areas as have been named have already been accepted by the NRC Staff, the addition of the Emergency Plan to the list, for example, would raise questions regaroing specific intent. Woulo all emergency facility design require QA? Woula all emergency communications systems require QA?

Would all public notificati'on systems require QA? We contend the answer is a clear no. Not even the NRC " red-phone" system is aesigned, purchased installed or maintained under a QA program.

In recent discussions with the Staff, it hos been contended that this is not an expansion of previous licensing requirements.

However, specific facts suggest to the contrary.

1. Although the Staff has agreed that certain BWR components are not safety-grade and has, through intensive discussions, allowed the use of these components based on augmented technical specification surveillance, the QA Branch requires Q-listing which for non-safety grade components ratses serious questions on regarements for replacement; e.g. level-8 trip, turbine bypass system, and main steam pipng downstream of outboard isolation valve.

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2. Although the NRC has expli'citly excluded safety-9 fade requirements from most systems and structures requied for the emergency preparedness program, the QA Branch specifically requires the SPOS system, Emergency Response Facilities and meteorological programs (including dose assessment program software) to be Q-listed. This requirement is, in our view contrary to the intent of NUREG-0696, and in fact is so broad a requirement that almost any system, component or structure in the plant could fall under the QA program if these same rules were to be applied uniformly.

3. NUREG-0660 Task I.F.1, "Expancea Quality Assurance List," ana

[.F.2, " Development of More Detailed QA Criteria" were not incorporated into NUREG-0694 "TMI delated Requirements for New Operating Licenses" or its subsequent claritication, NUREG-0737. These-tasks were in fact clearly relegated a lesser priocity - not to be resolved until December, 1983.

Although we recognize the well intentioned dedication or the Staff in its imposition of conservative requirements which appear to address long term tasks under NUREG-0660, until a uniform, understandable and enforceable regulatory position has been established, it is not reasonable to require upgrading everything which has an apparent relation to safe plant operation. Without

- definitive guidance, such a policy is so subjective that enforcement woula be almost impossible.

Commonwealth Edison will continue to appropriately delineate all sysems, components and structures which are, in fact,

" safety grace". In addition, we will continue to vigorously enforce through our own Quality Assurance Program all procedureal and programmatic commitments made to date including those related to We fire protection, security, emergency planning and meteorology.

woula also be happy to work with the Staff in the developement of a response to NUPEG-0660 Task [.F.

However, in the event the Staff persists in requiring the addition to a 0-list of all items "affecting safety", including such items as SPOS or emergency facilities, we must formally request a management appeal. That appeal should be at or above the level cf c ngineering in as much as Assistant Director of the Division of se already taken place with numerous discussions and negotiatior the Chief of the NRC Staff - Q A B r a ri c o .

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Enclosure 10

[ tem 11. TM[ Issues (22).

lI.a.([.r.8) Emergency' Procedures, The NRC Staff effort to monitor selected LaSalle County Emergency procedures is substantially complete. This ettort, which was initiatea in August, 1980, has resulted in the use at LaSalle County Unit I of the so-c'alled "sympton caseo emergency procedues" which implement the BWR Owners Group emergency procedures guiaelines .

The Staff has reviewed crafts of these procedures, and in November, 1980 conductec a tsimulator veritication of'the procedure adequacy.

Training on the procedures was initiated at LaSalle County in March, 1981. 'All that remains prior to fina'l procedure signoft is verification of plant specific analytical information upun which the operator response is based. This analysis verification i .s -i n 4

processianc is scheduled to be completed in early April, 1981. It is expected that final completed procedures will be submitted to the Staff by April 15, 1981. Any slippage in that date is expected to be minor. However, it is judged that the substance of the review is complete and tInal procedure implementation coula be verified by the Regional inspection 1and Enforcement authority. For these reasons, it is udged that this item can be closed.

II.b (((.B.7 and II.B:8) Hydrogen Control & Degraded Core Rulemakinq Commonwealth Edison committed in November, 1980 to the inerting of the LaSaHe County Mark Il containments. The operability of the Containment Purge Valves, which was discussed with the Staff in February, 1981 is currently being verified.

However, as was indicated to the Staff, Commonwealth Edison will complete tne program of qualification defined in t he 0. L . liemann letter to D. L. Peoples dated October 23, 1979 and will implement "

any interim required measures detined in that Staff position. The cetail design of the LaSalle County hydrogen control (inerting) system was documented in FSAR Amendment 55.

II.c. (((.E.4.2) Containment [ solation Oependabilit2 l This item also remains open pending satisfactory resolution I

of the containment purve valve operability discussed in item II.b.

a b o v e '.

11 d, (II.F.2) Instrumentation for Detection of inadequate Core Cooling As indicated in NUREG-Obl9, the applicant has, with the assistance of the BWR Owners Group, Justified the adequacy of the existing instrumentation for detection of inadequate core cooling.

Although we recognize the existence in RG 1.97 of a backtit

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requirement for what.has been called. core-exit thermocouples,-the

-Guide implementation date is in mid-1983. This applicant will participate with the BWR Owners in the generic ~ resolution of the requirements for this' future modification. At this time, however, no new.information can be. supplied, nor is any expected prior to the scheduled issuance of the LaSalle County operating license. In as much as the requirement for the device in. question-is more than 2 years off anc continuing contriversy exists between the BWR Industry and' the NRC Staf f .and the ACKq and the NRC Staff on the efficacy of the device, we request'that the item not be held open. Its resolution will result from final nodifications maoe on all operatingLplants, including LaSalle County to satisfy RG 1.97.

11.e (II.K.3.18) B&O Task Force - ADS Logic

- This item remains open'in expectation of the submittal by Apr.il -1, 1981 of the BWR Owners Group teasib111ty study for the ADS logic modification to eliminate the need for manual actuation. The results of this analysis are currently being revlewed by the the Owners Group an'd will be submitted to the NRC Staff on schedule, it can be pointed out, however, til a t the concurrent development at LaSalle County of improved" emergency procedures.(as discussed under task lI.C.8)-supports the' advantage of the increased flexibility and-increased diversity for some event sequences afforded by the present design. It is on this basis, wh.ich will be justified in greater aetail by:

i the owners group submittal, that no modificat, ions at LaSalle County Station are Judged to he necessary.'

il.f.(II.K.3.44) Analysis of Transienti with Single' Failure

.The BWR Owners Group submitted the analysis required for this tas3 in the 0.d. Waters letter toD.G. Eisenhut dated December "29,cl980. That report, which is applicable to LaSalle County, was used as a basis for the LaSalle County submittal contained in Section L.34-22 of Appendix L of the FSAR. The fundamental conclusion of tnis analysis is that BWR fuel remains covered during the worst a n t i c 1'p a t e d transient with the worst single failure and a Stuck open ~ relief. This is true without any operator action to

! manually' initiate ECCS or other make-up systems. Manual ADS may be required under certain scenarios.. The symptom based emergency procedures implemented at LaSalle County Station were developed to minimize reliance on event' oriented training. These procedures, it is judged, resolve the NRC Statf open item regarding operator .

response under degraded system conditions. l l

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' _1 1. 4 (llI.A.l.2)-Final Emergency F a'c i l i t y Design As you'are aware, the NUREG-0696 facility design definition; date is June 1, 1981. It is unlikely that submittal of information in advance of that1date is possible. However, as was indicated in '

NUREG-0519 the location and stru'ctural design of the LaSalle County Technical. Support Center and Operational Suppert Center are

.oiscussed'in' Appendix L of..the FSAR. 'The permanent LaSalle County

' EOF has not'been discussed as yet but it will be.a facility.whi '

satifies Option 2 of NUREG-0696 i.e. it will be located betwee' 10-20;mi. of the TSC. .The detailed' instrumentation design ,

description and additional configuration information will be provided by June 1. In as much as implementation of this tinal '

design is required after LaSalle County Unit I licensing, the issue shoula not prevent lic,ense issuance. However, the applicant recognizes.the need f or a license condition to control the ulti. mate resolutten of this issue.

II.h. ([II.A.2) Long Term Emergency. Preparedness Resolution of the f our outstanding issues discussed-in Appendix 0 of NUREG-0519 has in part been occomplished.

Each or those items will be addressed separately.

1. Provide predetermined EALs for b'igh range effluent monitcrs.

Resolution: This item will be completed as soon as practicable after final installation and calibration of the subject monitors. In as much'as these component's are not required until January 1, 1982, it will be some months before this effort is complete. We expect this effort.to be concluded prior to LaSalle CountyUnit i fuel loading, however, and recommend a condition for ,

the license to verity adeq'udte incorporation of the information. In as much as no contruversy exists over  !

what specifically is required, all that is needed to l close the issue is final calibration completion. This approach is reasonable because Region Ill is already  ;

conducting the emergency plan review, i

'2. Provide description of and completion schedule for permanent EOF.

Resolution: As was discussed in item 11 9 above, this information will be provided as required by June 1, 1981 with the implementation schedules defined in i

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, ~4-h NUREG,0696 expected:to be. met,;barring unforeseen problems with equipment-- deliveries or'other

. circumstances beyond the control of the. applicant.

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3. Provide upgraded Adverse Weather Evacuation Time Estimates.

R e s ol u t i o n_ : This'information was provided in the L. O.

DelGeorge. letter to 0. G. Eisenhut dated March 27, 1981.

4. Provide clarification of health physic drill content M and schedule and exercise schedules. e Resolution: This additiorial information is addressed In Sectton 8.3 of'.the updated-Commonwealth Edison Generat ing S tat. ion Emergent.1 Plan for LaSalle County Station (April,- 1981) trans"itted by the L. O.

DelGeorge letter to H. R. Denton dated March 27, 1981.

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