ML20136B246
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MEMORANDUM FOR:
V. Noonan, Director Comanche Peak Project FROM:
H. H. Livermore, QA/QC Group Leader
SUBJECT:
OPEN TRT STAFF COMMITMENTS In the exit meeting with allegers conducted at the Granbury Inn on Dec.10, 1984, you and Mr. Zudans made commitments to prrform additional work of an investigatory nature. Most of the verbal cocwitments were made while discussing the QA/QC group allegations (AQ) a d therefore may possibly delay final release of the SSERs. These items are detailed in the transcript on pages 23, 30, 81, 82, 83, 94, 98, 101, 102, 103, 107, 111-114, 121-123, 157, 158, 163-165.
Please advise as to your or Mr. Zudans' follow up or disposition of these items.
LLeu c. 7 H. H. Livermore, TRT QA/QC Group Leader cc:
J. Zudans b C. Posiusny '
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Revision: 2 Page 1 of 7 ITEM NUM3ER I.a.1 Heat Shrinkable Ccble Insulation Sleeves
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC The TRT found a lack of awareness on the part of quality control (QC) electrical inspectors to document in the inspection reports when the installation of the " nuclear heat-shrinkable cable insulation sleeves" was' required to be witnessed.
2.0 ACTION IDENTIFIED BT NRC Accordingly, TUEC shall clarify procedural requirenents and provide additional inspector training with respect to the areas in which nuclear heat-thrinkable sleeves are required on splices and assure that such sleeves are installed where required.
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3.0 BACKGROUND
3.1 Information Supplementing NRC Description of Issue It is our understanding that the scope of the issue actually encompasses. three (3) basic observations:
- Inspection reports for cables containing splices do not consistently indicate witnessing of nuclear heat-shrinkable material as an inspectable quality attribute.
- Inspection reports for post-installation inspections are used in lieu of in process er witnessing inspection reports.
- Through the TRT interview pro' cess with several quality control inspectors, it appears the inspectors are uncertain when' documentation of the nuclear heat-shrinkable material is required.
These observations centrally address inspection reports documenting inspections of heat-shrinkable insulation sleeves.
Heat-shrinkable insulation sleeves are required only in areas of high radiation or " harsh" environments. The requirements for these installations and additional engineering considerations are appended to the construction procedure.
During the TRT review, no instance was observeo where the insulation sleeve was required and the inspection report failed to address the attribute.
An inspection, based on sampling, will be used to assure that the sleeves are installedwhererequiredbydesign\\
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1 Revision: 2 Page 2 of 7 ITEM NUMBER I.a.1 (Cont'd)
3.0 BACKGROUND
(Cont'd) i 3.2 Preliminary Determination of Root Cause and Generic Implications The preliminary reviews conducted to date have not identified a root cause for this item.
Implementation of the Action Plan is necessary before'a root cause determination can be made.
Generic implications will be evaluated based on the results of the implementation of the Action Plan and the results of the root cause determination.
4.0 TUEC ACTION PI.AN i
4.1 Scope and Methodology i
A plan has been developed to ensure, by sampling, that the installed sleeves have been correctly inspected and documented. Additionally the plan includes steps to preclude recurret e of this item through review and revision of the
. applicable procedures.
The plan consists of two basic parts, Part 1 involves the revision of the construction and inspection procedures, and the retraining of the TUGC0 QC inspectors. Part 2 consists of i
a sampling and re-inspect.on program as required to verify that installed cable splices have been, inspected and documented. Provisions are made for the expansion of the sampling program if the documentation reviews or re-inspection do not satisfy the acceptance criteria of the initial sample plan.
4.1.1 Part 1 - Procedure Revision i
i Under Part 1, the following specific action will be taken to clarify procedural requirements and provide additional inspection training:
- Revise construction installation procedure eel-8,
" Class 1E and Non-Class 1E Cable Termination" to clearly ideu:1'y splice installation of nuclear heat-shrinkable cat 1e insulation sleeves.
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- Revise ~ inspection procedure QI-QP-11.3-28, " Class 1E l
Cable Terminations" to assure proper documentation of j
inspection of nuclear heat-shrinkable material when required.
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Revision: 2 Page 3 of 7 ITEM NUMBER I.a.1 (Cont'd) 4.0 TUEC ACTION PLAN (Cont'd)
- Revise inspection procedure QI-QP-11.3-40 " Post Construction Inspection of Electrical Equipment and Raceways" to ensure that inspection of nuclear heat shrinkable insulating sleeves is documented.
- Train and certify inspecto'rs to the revised inspection procedures in accordance with CP-QP-2.1,
" Training and Certification of Inspection Personnel".
- Review revised inspection forms te assure inspection attributes regarding the use of nuclear heat-shrinkable material are included.
4.1.2 Part 2 - Sampling and Reinspection Program 4.1.2.1 Sampling A sampling inspection program will be initiated to ensure that nuclear a
heat-shrinkable sleeves are installed where required.
The sampling plan will be based on a 95%
confidence level at the 5% maximum defective rate. The sampling plan is divided into two parts:
" Identified Splices" are those cables which are known to contain splices (penetrations, motor leads, electrical devices and known cable reduction splices),
" Reduction Splices" are splices used to splice a cable of larger diameter to a cable of smaller diameter to facilitate connection to equipment where cable size is limited.
"Other Possible Splices" consist of:
a)
Similar Cables These are cables that are not known to have reduction splices in them, however cables of this type with a similar application are known to have reduction splices.
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Revision: 2 22;e 4 of 7 ITEM NUMBER I.a.1 i
l (Cont'd) 1 4.0 TUEC ACTION PLAN (Cont'd) b)
Similar Equipment This is equipment 'chere cables terminated in them c:: or may not 4
have reduction splicas; hcwever, cables terminated in like equipment are known to have reduction splices.
i The applicability of cable recuccion splices for both of these cate7er12s cannot be easily identified by drawing yeview.
Identified Splices - Based on a kncwn pcpulation of 1132 heat-shrinkable sleeves, a randem sample of 60 will be selected and the inspection records for these sleeves will be reviewed. If the inspection records do not reflect the installation of a heat-shrinkable sleeve, the sample will be visually inspected for such.
If the heat-shrinkable sleeve was not installed because it was not required, the sample will be discarded. If the heat-shrinkable sleeve was installed but an acceptable inspection record does not enist, this will constitute a defective sample. If the number of defective samples found is more than zero, (that is, i
one), an additional sample of 35 will be taken and combined with the original sample. The acceptance i
number for the combined sample is 1 (ene).
If the cumulative. number of defectives found is greater than the acceptance number for the combined sample, a 100%
inspection record review, will be made.
Other Possible Splices - In addition, in order to i
ensure cable reduction splices not identified.by the sample population are also subject to verification, seven (7) similar cables and twenty-six (26) similar pieces of equipment such as termination cabinets or I
distribution panels, will be visually inspected for additional reduction splices required for termination in the equipment. The 26'are all of the items of equipment in which it may have been necessary to reduce the size of the cable to facilitate termination. These are splices made in accordance with the requirements of Detail 13 of Drawing 2323-El-1701. Upon identification-of spliced cables, the documentation will be checked to verify that the nuclear heat shrink sleeves were witnessed by QC, I
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1 Revision: 2 Page 5 of 7 ITEM NUMBER I.a.1
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(Cont'd) 4.0 TUEC ACTION PLAN (Cont'd) 4.1.2.2 Inspection Program t
The program will be divided into two parts: a documentation review, and where required, a re-inspection program.
Documentation Review Identified Splices - The documentation review
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will consist of a review of the inspection reports for the cables selected under the sampling progr'am to determine that the splice and sleeve was inspected and documented by QC.
Other Possible Splices - After a cable has been identified as containing a splice, the documentation will be reviewed to ensure that the splice and sleeve were inspected and witnessed by PC.
4.1.2.3 Reinspection Identified Splices - If the documentation does not mention splices, or if for any reassn the splice inspection was not completely or correctly documented, the cable installation will be re-inspected to.
determine whether the cable does or does not actually contain splices. If it does, in fact, co2tain a splice, the heat-shrinkable installation will be inspected to determine if it is satisfactory and acceptable. If the sample selected contains cables which do not contain splices, additional cables will be selected to ensure that the number of splices equals the selected sample size.
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Other Possible 3plices - If the documentation for the additional cables that'are found to have reduction splices does not mention the i
splices, er if for any reason the splice l
inspection was not completely or correctly documented, the reduction splices will be inspected to verify that the sleeves are in place, and tightly shrunk to the jacket with a uniform ring of adhesive extruded frem each end. The results of this inspection will be
Revision: 2
?ags 6 of ITEM NUMBER I.a.1 (Cont'd) 4.0 TUEC ACTIOP PLAN (Cont'd) evaluated by the Team Leader and recommendations for further action, if any, will be directed to the SRT.
All anomalies found during the inspection program will be corrected using existing procedures. Documentation generated will become a part of the response record.
4.2 Resoonsibilities The Review Team Lesder is Mr. M. B. Jones, Jr.,
Electrical / Instrument. Cable sampling vill be done by third party inspectors from a list furnished by TUGC0 Engineering, using the sampling technique furnished by the R.T.L.
Document review will be jointly done by Evsluation Research Corporation (ERC) third party Quality Control or other qualified third party personnel, and the Review Team Leader. Reinspections will be cenducted by third-party QC inspectors (ERC).
Determination of root causes and generic implications will be by the Review Team Leader. Review comments will be directed to the appropriate TUGC0 department for inclusion in the appropriate documents.
4.3 Oualification of Personnel Where tests or inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. Third party inspectore will be certified to the requirements of the third party employer's quality assurance program, and specifically trained to the requirements of the CPSES quality procedures.
Other participants will be quaitfied to the requirements of the CPSES quality assurance prcgram, or to the specific requirements of the Program Plan.
4.4 Procedures The sampling and re-inspection attributes will be based principally upon che requirements of Construction Installation Procedure EEI-8 " Class IE and Non-Class 1E Cable Termination" and Inspection Procedure QI-QP-11.3-28 " Class 1E Cable Terminations". Where applicable specific procedures will be developed for certificatica of, or inspection by, third party QC inspectors.
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1 Revision: 2 Page 7 of 7 3.0 SCliEDL'.l.E No inspections will be made prior to having the procedures revision and training completed. Action Plan completion is scheduled for February 1. 1985.
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Revision: 2 Page 1 of 4 ITEM NUMBER I.a.2 Inspection Reports on Butt Splices
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC The TRT found inspection reports that did not indicate th'at the required witnessing of splice installation was done. Examples are as follows:
IR ET-1-0005393 IR ET-1-0005396 IR ET-1-0005394 IR ET-1-0006776 IR ET-1-0005395 IR ET-1-0014790 2.0 ACTION IDENTIFIED BY NRC Accordingly TUEC will assure that all-QC inspection requiring witnessing for butt splices have been performed and properly documented; and verify that all butt splices are properly identified on the appropriate drawings and are physically identified within the appropriate panels.
3.0 BACKGROUND
3.1 Information Supplementing NRC Description of Issue It is our understanding that this issue involves cables that had been spliced in accordance with the design-documents but did not have inspection reports. The inspection report would document witnessing of the splice installation by a QC inspector.
In addition to the inspection reports listed above, the TRT also reviewed:
IR ET-1-0007162 IR ET-1-0051217 IR ET-1-0.750419 IR ET-1-0033666 IR ET-1-0051218 IR ET-1-0033669 The cables associated with these twelve inspection reports will be used as a basis for an initial evaluation of this item.
3.2 Preliminary Determination of Root Cause and Generic Implications The preliminary reviews conducted to date have not identified a root cause for this item.
Implementation of the Action Plan is necessary before a root cause determination can be made.
Generic implications will be evaluated based on the results of the implementation of the Action Plan and the results of the root cause determination.
Revision: 2 Ec39 2 of 4 ITEM NUMBER 1.a.2 (Cont'd) 4.0 TUEC ACTION Pl.AN 4.1 Scope and Methodology The scope of this plan includes all butt-spliced control cables in Class 1E cabinets located in the control roem and cable spreading room, which use the Amp insulated splicto.
This action plan is divided into two phases.
4.1.1 Phase 1 Phase 1 consists of a review of the in process, post-installation.and final inspection reports for the twelve cables reviewed by the TRT. This review is to determine if required documentation for splice witnessing existed and is acceptable. Further, an additiodal twelve (12) cables containing butt splices were selected and the documentation will be submitted to the same review. Failure of any cable to meet the requirement for splice witnessing will require the implementation of Phase 2.
The additional twelve cables were selected by TUGC0 Engineering-prior to the implementation of the sampling methods described in CPRT-12.
w' C#4 Wi t G o Gy G EiL 4.1.2 Phase 2 Phase 2 will consist of the following items:
- Review of all drawings design change documents and drawings involving butt splices of control cables in Class 1E cabinets in the control room and cable spreading room to assure that the splicee are documented in the design document.
- Inspection of all spliced cables identified to ensure that drawings correctly reflect the as-built condition, that the splices meet the FSAR and procedural requirements, and that the requirements of the SER are met.
This inspection will include a documentation review of these spliced cable's inspection reports to ensure that the splices were witnessed. Acceptable documentation may be u.ed to determine that the quality attributes (i.e., correct splice connec'ts, wire size, color code, installation, etc...) of a splice have been met.
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ITE" TCMBER I.a.2 (Cont'd) 4.0 TUEC ACTION PLAN (Cont'd)
Scope 1
-,To be sure that no undocumented butt splices exist, the population of Class IE cabinets in the control room and cable spreading room where butt splices are not supposed to exist will be sample inspected to confirm that no splices are present. The sampling plan will be based on a 95% confidence level at the 5% defective rate.
4.2 Responsibilities
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The Review Team Leader is Mr. M. B. Jones, Jr.,
Electrical / Instrument RTL. The review of drawings and design changes, and the selection of additional cables is the responsibility of TUGC0 Project Electrica1' Engineering.
Documentation review is the responsibility of TUGC0 QA with overview by the RTL. Re-inspection of the cables will be by the third-party QC inspectors (ERC). Determination of root causes and generic implications will be by the Review Team Leader.
1 4.3 Qualification of' Personnel Where tests or inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. Third party inspectors will be certified to the requirements of the third party employer's-quality assurance program, and specifically trained to the requirements of the CPSES quality proc 3dures.
Other participants will be qualified to the requirements of the CPSES quality assurance program, or to the specific requirements of the Program Plan.
4.4 Procedures i
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The following procedures will be used in the implementation of this Action Plan:
- Drawing Corrections: Engineering Procedure - CP-EP-4.6
" Field Design Change Control".
- Field Inspections: Quality Inspection Procedure -
QI-QP-11.3-28 " Class IE Terminations".
- Special procedures will be developed as required for centinuity.
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i...-...a :2 I..:. 2 (Cenc'd) 5.0 SCHEDULE Quality Engineering review of the inspection reports on the twelve cables reviewed by the TRT ia coenlete. Inspection activities will begin the week of December 20, 1984. The Action Plan is a scheduled for cospletion Febru,4 y 8,1985.
a Revision: 1 Page 1 of 4 i
ITEM NUMBER I.a.3 i
l Butt Splice Qualification a
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC The TRT found a lack of splice qualification requirements and provisions in the installation procedures to verify the operability-of those circuits for which splices were being used, e
2.0 ACTION IDENTIFIED BY NRC Accordingly,TUEC shall develop adequate installation / inspection procedures to assure that the wiring splicing materials are-qualified for the appropriate service conditions, and that splices are not located adjacent to each other.
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3.0 BACKGROUND
3.1 Information Supplementing NRC Descriptions of Issue It is our understanding that the issue'is as fellows:
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- Adequate provisions are not included in the installation procedu'res to verify the operability of those circuits in which splices aro used.
- Adequate provtsions are not included in the installation procedures to assure the splices are staggered within the panel so as to preclude splices in the same panels from.
pressing against adjacent splices.
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- Adequate requirements are not included :bi the int.tallation procedures to assure the splices are qualified for j,
appropriate service conditions.
In order *to address these issues, the following should be considered:
-- All cable work involving termination, de-termination or splicing is required to be tested or ratested in accordance F
with Startup Administrative Procedures (SAP)-6. " Control of j
Work on Station Components After Release From Construction to TUGC0"; SAP-22 "Retast Control"; and XCP-EE8 " Control*
Circuit Functional Testing". These tests provide the necessary verification of operability after splicing.
- FSAR amendment 44 was issued to encompass the use of' butt splices in panels. The staggering of butt splices in the panel was not addressed in the FSAR. The NRC's "The Safety Evaluation Of Field Splices Inside Control Panels", dated e
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3.0 BACKGROUND
(Cont'd)
SepteF2a
- 74. sets forth the SIC criteria, requiring that 47' ices te at1??ered in panels. This additional guidance --
- a ;;2C vill be 'ised in the implementation of this A::ien I'.:n.
- Consideration ves given to the mild environment in which the splices vera : Ec used. The construction of'the splice and the method of installation of the splice is similar to terminal lugs used'in the panels. In addition, the splices are'used in ics power applications as specified in the FSAR.
3.2 Preliminary Determinatien of Root Cause and Generic Implications The preliminary reviews conducted to date have not identified a root cause for this item.
Implementation of the Action Plan is necessary before a root cause determination can be made.
Generic implications will be evaluated based on the results of j
the implementation of the Action Plan and the results of the root cause determination.
4.0 TUEC ACTION PLG 4.1 Scope And Methodology 4.1.1 Procedure R'evisions 1
Construction procedure EEI-8, " Class 1E and Non-Class IE Cable Terminations" has been revised (10/15/84) to require a continuity check of all circuits in which splices are placed. The procedure now requires th'at splices be staggered within bundles in the panels to comply with the additional NRC's "The Safety Evaluation of Field Splices Inside Control Panels".
Inspection procedure QI-QP-11.3-28, " Class IE Terminations" was revised on 12/8/84 to add the' attributes necessary to ensure that continuity checks are made, and that j
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splices are staggered when enclosed in bundles.
Where required additional test and inspection procedures will be developed to carry out the l
activities' described below, i
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Revision: 1 Page 3 of 4 1
l ITEM NUM3ER I.a.3 (Cont'd) l 4.0 'TUEC ACTION PLAN (Cont'd) 4.1.2 Inspections and Tests As part of the requirements of Item I.a.2 all cable bundles containing splices will be inspected to insure that no splice in a bundle is adjacent to and pressing upon another splice. Corrections to the configuration of the bundles will be made where violations are found.
4.1.3 Oualification Data A qualification data package, based primarily on vendor documentation, has been developed for the butt-splices 4
I used in the control panel applicationJ. This data package will be reviewed and issued as part of the Action Plan Results Report.
1 4.2 Responsibilities The Review Team Leader is Mr. M. B. Jones, Jr.,
Electrical / Instrument RTL. Procedure revisions are the.
responsibility of *.he appropriate _TUGC0 department.
Inspections will be conducted by the third-party QC inspectors (ERC)..The qualification data package'will be prepared by l
TUGC0 Project Electrical Engineering (W.I. Vogelsang) for review by the RTL. Determination of root causes and generic -
implications, will be.the responsibility of the Review Tiam Leader.
1 4.3 Personnel Qualification Requirements 1
Where tests.or inspections require the use of certified inspectors, qualification will be to.the requirements of ANSI N45.2.6 at-the appropriate level. Third party inspectors will be certified to the requirements of the third party employer's quality assurance program and specifically trained to the requirements of the CPSES quality procedures.
Other participants will be qualified to the requirements of the CPSES quality assurance program, or to the specific requirements of the' Program Plan.
4.4 Precedures 4.4.1 Construction Procedure eel-8 " Class IE and Non-Class 1E Termination".
4.4.2 Inspection Procedure QI-QP-11.3-28 " Class IE l
Terminations".
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Reviaion: 1 Page 4 of 4 ITEM NUMBER I.a.3 (Cont'd) 4.4.3 Special procedures will be developei for cable continuity and impedance testing.
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5.0 Schedule Procedure revisions will be completed by January 3, 1985.
Inspection of cable bundles, and any necessary corrective actions will be completed by January 12, 1985. A draft of the Qualification Data Package has been written. Completion of this item will be done by February 8, 1985.
Revision: 2 Page 1 of 5 ITEM NUMBER I.a.4 Agreement Between Drawings and Field Terminations 1.0 DE.CRIPTION OF ISSUE IDENTIFIED BY NRC Selected cable terminations were found that did not agree with their 2acations on drawings. Examples are as follows:
2anel CPI-ECPRCB-04, Cable E0139880*
Panel C?l-ECPRTC-16, Cable E0110040 Panel CPI-ECPRTC-16, Cable E0118262 Panel CPI-ECPRTC-27, Cable EC104796 Panel CPX-ECPRC*i-01, Cable ECO21856 Panel CPI-ECPRC3-02, Cable NK139853 (nonsafety)
- Panel CP1-ECPRC3-04 was incorrectly identified.ar CP1-ECPRCB-14 in tl.2 September 18, 1984 letter. The TRT verbatly advised TUEC of this information.
2.0 ~ ACTION IDENTIFIED BY NRC Accordingly, TUEC shall reinspect all safety-related and associated terminations in the :entrol room panels and in the termination cabinets in the cable spreading room to verify that their locations are accurately depict'ed'on drawings. Should the results of this reinspection reveal an unacceptable level of nonconformance to drawings, the scope of this reinspection effort shall be expanded to include all safety-related and associated terminations at CPSES.
3.0 BACKGROUND
3.1 Information Supplementing NRC Description of Issue It is our understanding that this issue involves cable terminations that are not in agreement with the drawings as to the location of the conductor on the terminal blocks.
At CPSES, the specific cables identified above have been re-inspected and the "as built" configurations reviewed by Engineering. The engineering review has considered design.
changes and temporary modifications authorized prior to the TRT identification.
The results of this review are as follows:
The TRT review and subsequent written statement of the issue did not include a listing of all the documents used to formulate their conclusions. Based on a preliminary review, after considering design changes and drawings, it appears that
~ hree of the cables are connected correctly.
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Revision: 2 Page 2 of 3 ITEM TUM3ER I.a.4 (Cent'd)
3.0 BACKGROUND
(Cont'd)
One cable, a two conductor cable, was found to have wires interchanged on the terminal points indicated on the drawing. This connection has no polarity requirement thus the interchange of vires has no affect on the :perability of the circuit.
One cable was found to be a designated " spare" per a properly issued design change doeurent'(DCA 19948, Rev. 1).
Hewever, one end of the cable is terminated which indicates that the review and drawing ucca:e cycle ia it.e:co le t e.
One esbie was found to be properly conrected in accordance with the document ravisien in effect at the time the termine. tion was made.
However, a subsequent drawing change changed the color code of the conductor for no apparent reason.
In the course of normal practices, after construction has been completed and the equip =ent is in the startup cycle, a wiring check 4
is done pe: Prerequisite Test Instruction (XCP-EE-8).
Any design changes required per the Startup Procedure for Temporary System Modification (CP-SAP-13) are controlled and requested in accordance' with the Startup Procedure for Design Requests (CP-SAP-14).
Although TUEC has concluded that the. issues identified by the TRT have no advarse safety significance, TUEC agrees with the NRC that there should be consistency between the drawings and the physical installation.
3.2 Preliminarv Determination of Root Cause and Generic Implications The preliminary reviews conducted to date have not identified a root cause for this item. Implementation of the Action Plan is necessary before a root cause determination can be made.
Generic implications will be evaluated based on the results of the implementation of the Action Plan and the results of the root cause determination.
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Revision: 2 Page 3 of 5 ITEM NUMBER I.a.4 (Cont'd) 4.0 TUEC ACTION PLAN 4.1 Inspection of Terminations 4.1.1 An inspection plan has been developed to re-inspect cable terminations in the Control Room and Cable Spreading Room. The cables selected for sampling are those cables required to prevent eore damage.
(For the purposes of this action plan, these are defined as the class 2E circuits interfaced with the Alternate Shutdown Panel.) A total of 3812 terminations meeting these requirements were identified. The Aample _rw 4 inspection plan was chosen to provide a(95% ercent e /e-confidence that a maximum fraction ~ defective of 0.01 will be detected. Corresponding to this sampling plan, a random sample of 300 terminations were selected for reinspection with an acceptance number of zero.
All terminations of the sample will be inspected to verify that the physical location of the termination and the location required by the drawing as modified by applicable design change are in agreement. Location of each termination will be documented. Design documents used in the sampling program will be identified in the final report.
4.1.2 The differences between the as-built condition i
documents and the approved engineering drawings will be reconciled by Project Engineering. In reconciling the differences, appropriate action will be taken to make the necessary corrections.
4.1.4 The follow conditions. define the acceptance criteria for this inspection:
- If the inspection shows that a termination is physically in agreement with the drawing it is acceptable. Also acceptable is the use of a conductor of a size larger than that indicated on the drawing, provided that the' termination is acceptable
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from all other standpoints.
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- If.the termination.is connected in such a way that it l
1s functionally correct but is not in agreement with the termination drawing, a separate record will be made of.the as-found condition. Examples of functionally correct terminations would include those that are connected to a terminal electrically common to that specified, or where two leads to devices that have no polarity requirements have been interchanged.
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i ITEM NUMBER I.a.4 (Cont'd) j 4.0 TUEC ACTION PLAN (Cont'd)
Any termination that cannot be shown to be acceptable using either of the above conditions will cause the sample 'to be rejected and a 100% reinspection to be made. All terminations that are determined to be functionally correct, but not in agreement with the approved drawings will be evaluated' separately. If this evaluation indicates that the number of Jifferences may adversely affect future operations, the Action Plan will be revised to provide an acceptable means of corrective action.
4.2 Responsibilities j
The Review Team Leader is Mr. M..B. Jones, Jr.,
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Electrical / Instrument RTL. The sample plan has been provided by the Review Team Leader. Cable identification and design change review is the responsibility of TUCCO Project Electrical Engineering (W. I. Vogelsang).
Reinspection of terminations is to be done by the third-party QC inspectors (ERC). The reconciliation of differences will be conducted by TUGC0 Project Electrical Engineering and the Review Team Leader. Determination of root causes and generic implications is the responsibility of the Review Team Leader.
4.3 Personnel Qualification Requirements l
Where tests or inspections require the use of certified inspectors', qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. Third party inspectors will be certified to the reguirements of the third party employer's quality assurance program, end specifically trained to the r quirements of the CPSES quality procedures.
'Other participants will be qualified to the requirements of the CPSES quality assurance program, or to the specific requirements of the Program Plan.
4.4 Procedures The following procedures will be used:
-Correction of drawing errors: Engineering Procedures 4
CP-EP-4.6, " Field Design Change Control":
TNE-DC-7,
" Preparation and Review of Design Drawings" and TNE-DC-8,
" Design Verification of Field Design Changes".
- Field Inspections: Inspection Procedure QI-QP-11.3-28,
" Class IE Terminations".
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Revision: 2 Page 5 of 5 ITEM NUMBER I.a.4 (Cent'd) 5.0 SCHEDULE Sample selection will be completed during the week of December 3, 1984 Iaspection will commence during the vaek of December 24, 1984, and be completed for the initial sample by January 4, 1984.
Evaluation of the findings will be completed by January 11, 1985.
Completian of this action item will be made by February 22, 1985.
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ITEM NUMBER I.a.5 NCRs On Vendor Installed Amp Terminal Lugs
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC
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The TRT found cases where nonconformance reports (NCRs) concerning vendor-installed terminal lugs.in GE motor control centers had been improperly closed. Examples are NCR Nos. E-84-01066 thru NCR E-84-01076, inclusivr.
2.0 ACTION IDENTIFIED BY NRC
-Accordingly TUEC shall re-evaluate and re-disposition all NCRs related to vendor-installed terminal. lugs in CE motor control centers.
3.0 3ACKGROUND 3.1 Information Supplementing NRC Description of Issue To understand fully the nature of this issue and to evaluate the action plan, additional background information is needed.
There are two types of equipment involved:
- GE motor control' centers, i
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- ITT Gould-Brown Boveri 6.9KV switchgear (the equipment associated with NCRs E-84-01066 through E-84-01076 t
identified in the TRT report).
The issue involves field bending of vendor-installed Amp loose piece terminals. This issue's history extends back to 1981.
During the termination process it became obvious that under certain configurations it was impossible to land conductors without bending the Amp loose piece terminals.
In the second quarter of 1981 Engineering contacted Amp Special Industries for guidance in field bending of Amp loose piece terminals.
It was determined that the terminals could be bent one time up
.to 60* (reference: vendor letter VBR-16624).
In the first quarter of 1984 when a GE thermal overload relay was being replaced, it was noted that the Amp terminals had to be bent 90* :o 120* to install the relay. Because this i
violated the criteria for field bending established in 1981, a non-conformance report (NCR E-84-00972) was issued.
In responding to the NCR, Amp Products Corporation (APC) was contacted in April 1984 and the existing situation, including the criteria established in 1981, was discussed. APC responded that the loose piece terminals could be field bent l
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Revision: 2 Page 2 of 4 i
ITEM NUMBER I.a.5 (Cont'd)
3.0 BACKGROUND
(Cont'd) two (2) times to 45' or one (1) time to 90*.
Bending more than 90* and up to and including 120' is acceptable if the product user evaluates the specific application by considering the length of conductor to be supported by the ter=inal and the susceptibility of the final installation to vibration.
APC also advised that, while a terminal bent more than 90*
still maintained electrical characteristics, it would not maintain full mechanical strength.
(reference: record CPPA 38,241)
As'a result of this new vendor-supplied information, field bending of terminal lugs is allowed as follows:
- Two times to 45* or ene time to 90* without a written engineering evaluation.
- Bending more than 90* (but not more than 120*) is allowed if a written engineering evaluation of mechanical strength is performed using the design considerations identified by the vendor.
In addition to the GE relay NCR, NCRs were written on field bending of terminal lugs on ITT Could-Brown Boveri 6.9KV switchgear. These NCRs involved bending more than 60*.
Site engineering reviews of the nonconformances involving the 6.9KV switchgear revealed that none of the "use as is" terminals were bent more than 90*.
. Consequently these NCRs were dispositioned based upon vendor criteria and no engineering evaluation was required.
3.2 Preliminarv Determination of Root Cause and Generic Implications The preliminary reviews conducted to date have not identified a root cause for this item.
Implementation of the Action Plan is necessary before a root cause determination can be made..
Generic implications will be evaluated based on the results of the implementation of the Action Plan and the results of the I
root cause determination.
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ITEM NUMBER I.a.5 (Cont'd) 4.0 TUEC ACTION PLAN 4.1 Dispositi)n of Non-Conformances Utilizing engineering data obtained in the initial re-i.
the non-conformances on bent and twisted terminal en :ha Could-Brown Boveri 6.9KV metal clad switchgear, the spec;f.c non-conformance reports (NRC's E-84-01066 thru E-34 r Ki;}
have been redispositioned to state more clearly the ebser.ed condition of the terminals and the en31neering justifica:1:n for "use as is" terminals. A specific engineering evaluation of mechanical strength for all (if any) "use as is" terminals bent more than 90 degrees has been_ included. A review has
. also been made to ensure the adequacy of the disposition of the NCR concern with the GE relay.
ANP has been requested to perform tests to verify the serviceability of " bent or twisted" lugs. This report will be included in the final Action Plan report.
The NCR packages and evaluation will be reviewed by the Review Team Leader for adequacy.
4.2 Responsibilities The Review Team Leader is M. B. Jones, Jr.,' Electrical /
Instrument RTL. Disposition of the Non-conformances are the responsibility of TUGC0 Project Electrical Engineering (W. I.
Vogelsang), and TUCCO Quality Engineering (M. Warner). Review of the Non-conformance dispositions is the responsibility of the Review Team Leader. Review for root causes and generic implications is the responsibility of the Review Team Leader.
4.3 Cualification of Personnel Participants in the performance of this Action Plan will be qualified to the requirements of the CPSES quality assurance program or to the specific requirements of the Program Plan, as appropriate.
4.4 Procedures To-Be Used 4.4.1 Procedure CP-EP-16.0 " Procedure for Resolving Inspection Discrepancies".
4 4.4.2 Procedure CP-EP-16.1 " Processing Non-conformance Reports".
4.4.3 Procedure CP-QP-16.0, "Non-conformances".
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Revision: 2 Page 4 of 4 ITEM SUF3ER I.a.5 (Cent'd) 5.0 SCHEDULE Dispositions of the NCRs are to be reviewed by the Review Team Leader by January 7, 1985. Comments, if any, will be provided to Project Electrical Engineering and Project Quality Engineering by January 11, 1985. Action Plan completion is scheduled for January 30, 1985.
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Revision: 2 Page 1 of 4 ITEM NUMBER I.b.1 Flexible Conduit to Flexible Conduit Separation
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC In numerous cases, safety related cables within flexible conduits inside main control room panels did not meet minimum separation requirements. Examples are as follows:
Panel CP-1-EC-PRCB-02 Panel CP-1-EC-PRCB-07 Panel CP-1-EC-PRCB-06 Fanel CP-1-EC-PRCB Panel CP-1-EC-PRCB-09
. NOTE: Panel CP-1-EC-PRCB-06 was incorrectly identified as CP-1-EC-PRCP-06 in the September 18, 1984, letter. The TRT verbally advised TUEC of this information.
-2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall reinspect all panels at CPSES, in addition to those in the main control room for Unit 1, that contain redundant safety-related cables within conduits or safety and non-safety related cables with conduits, and either correct each
-violation of the separation criteria, or demonstrate by analysis I
the acceptability of the conduit as a barrier for each case where the minimum separation is not met.
3.0 BACKGROUND
3.1 Information Supplementing NRC Description of Issue In the control boards, many dual train hand switch modules are installed. Prefabricated cables run from the termination cabinets in the cable spreading room-to the back of these modules. It is necessary to leave slack in the control boards for these prefabricated cables in order to accommodate removal, testing, and/or adjustment. In maintaining separation between redundant trains and between Class IE and non-class IE cables, slack cable presents difficulties.
This same problem has been experienced elsewhere in the nuclear industry and successfully resolved by the installation of SERVICAIR flexible metal shielding' conduit as a barrier.
After obtaining IEEE 323-1974 and IEEE 344 qualification data j
for the SERVICAIR material and discussions with the supplier of the control board, design change documents were issued to
.use this material as a barrier for low voltage and signal cables inside control panels.
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Revision: 2 Page 2 of 4 ITZ'_'.:TMS ER I, b.1 (Cent'd) 2.0 2ACKOROUND (Cent'd) cur '2nderstanding of this 1.ssue is that sufficient
" c : mentation may not currently exist to demonstrate that this flanihla conduit (SERVICAIR) meets minimum separation r2;uirements as required per IEEE 384 and Reg. Guide 1.75.
If this material is qualified as a barrier, minimum separation raquirements would be met.
2.2 ?reliminarv Determination of Root Cause and Generic Imoi1 cations The preliminary reviews conducted to date have not identified a root cause for this item.
Inplementation of the Action Flen is necessary before a root causs determination can be made.
Generic implications will be evaluated based on the results of the implementation of the Action Plan and the results of the root-cause determination.
4.0 TUEC ACTION PLAN 4.1 Scope and Methodology This Action Plan will encompass the issue of flexible conduit-to-flexible conduit separation within the main control room panels. An analysis will be performed for-the four sections of the main control boards to establish that the specified separation are adequate. In addition, inspections
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will be made by Third-party QC inspectors to ensure that the required separations are maintained, and that no barriers have been removed without authorization. (See I.b.4)
The control boards can basically be divided into 4 sections (see Figure 1):
Control switch modules - for motors, switchgear and solenoid valves.
l Instrument controllers - Flow, pressure, level control, etc.
Meters, indicators, recorders, CRT and monitor lights.
Revisien: 2 Pace 3.i 4 ITEM NUMBER I.b.1 (Cont'd) 4.0 TUEC ACTION PLAN (Cont'd)
Figure 1 j
Control Board Side View Wiring in Sections A and B is modular prefabricated plug-in type and requires cable slack for flexibility in maintenance and service of the switches. Consequently separation is most difficult to maintain in this area. Wiring in Section C is predominantly by the control board manufacturer and 6" separation or rigid barriers have been provided where required. Wiring in Section D is also modular, containing a single multi-conductor prefabricated cable which supplies 24V power to each annunciator light box.
An analysis will be prepared which identifies circuits in Sections A and B of the control board and all circuits in the vertical panels X-CV-01 and X-CV-03 for which existing protection (exclusive of the SERVICAIR flexible conduit) precludes the need for any special separation or rigid barrier (s) between dissimilar trains to maintain circuit independence. The analysis for the main control board will address specifically the modular wiring to control switches where the required cable slack creates difficulties in maintaining fired spacial separation. Other circuits which commonly traverse the switch module wiring area will also be included in the review and documentation.
Adequacy of separation between all other circuits in~ Sections C and D of the control board will be verified by inspection to ensure that 6" separation or a rigid barrier has been provided between redundant train wiring. Re-inspection of the vertical panels will be performed only for circuits identified on the above documentation as requiring protection. Inspection attributes needed to provide assurance that adequate I
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Revision: 2 Page 4'of 4 ITEM NUMBER I'.b.1 (Cont'd) 4.0 TUEC ACTION PLAN (Cont'd) protection has been provided will be provided by Gibbs &
Hill for review and approval by the RTL.
An analysis will be provided to show the effectiveness of SERVICAIR Ferro-Clad l
(FC33-XX) and Stainless-Steel (SS63-XX) conduits as a barrier for those circuits in which 6" separation or rigid barrier cannot be provided, or the analysis will show that adequate l~
ee'paration is provided even'if no SERVICAIR conduits were installed. Where engineering analysis may not be adequate, tests of conduits and/or wiring materials may also be conducte{. der % -l>
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- :p 4.2 Responsibilities i
The Review Team Leader is Mr. M. B. Jones, Jr.
Analysis will be performed by Gibbs & Hill (S. P. Martinovich).
Reinspections will.be the responsibility.of third-party QC inspectors, with the assistance of Gibbs & Hill, if required.
Review of the analysis and the inspection results is the i.
responsibility of the Review Team Leader and the SRT.
In addition, the analysis will be reviewed by an additional third party consultant with expertise in this particular area.
Evaluation of root cause and generic implication is the responsibility of the RTL.
4.3 Personnel Qualification Requirements Participants in the implementation of this Action Plan meet the personnel qualification requirements of the Program Plan and its implementing procedures or the CPSES quality assurance
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program as applicable.
t 4.4 Procedures The Action Plan will be conducted in accordance with CPRT procedures applicable to the review of engineering evaluations performed by CPSES personnel. Those evaluations will be prepared in_accordance with procedures normally applicable to those activities for CPSES.
5.0 SCHEDULE j
Inspection attributes will be furnished by Gibbs & Hill by December i
20, 1984. A draft of the analysis will be completed by January 18, i
1985. Inspection will be completed by February 8, 1985. Action I
Plan completion is scheduled for March 8, 1985.
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'l Page 1 of 3 ITEM NUMBER I.b.2 Flexible Conduit to Cable Separation
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC In several cases, separate safety and non-safety related cables and safety and non-safety related cables within flexible conduits inside main control room panels did not meet minimum separation requirements (Table 1 identifies examples of these cases). No evidence was found that justified the lack of separation.
2.0 ACTICN IDENTIFIED BY NRC Accordingly, TUEC shall reinspect all panels at CPSES, in addition to those in the main control room of Unit 1, and either correct each violation of the separation criteria concerning separate cables and cables within flexible conduits, or demonstrate by analysis the adequacy of the flexible conduit as a barrier.
3.0 BACKGROUND
3.1 Information Supplementing NRC Description of Issue This issue concerns free air cable to flexible (SERVICAIR) conduits in which the separation distance as delineated in IEEE 384-1974 is not maintained. The area in question is inside the control panels. Additional historical comments observed in item I.b.1 are related to this issue.
3.2 Preliminary Determination of Root Cause and Generic-Implications The preliminary reviews conducted to date have not identified a root cause for this item. Implementation of the Action Plan is necessary before a root cause determination can be made.
Generic implications will be evaluated based on the results of the implementation of the Action Plan and the results of the root cause determination.
4.0 TUEC ACTION PLAN 4.1 Scope and Methodology The review and snalysis performed in response to Action Plan Item I.b.1 is designed to envelope the concerns in this issue.
Revision:
1 Page 2 of 3
!!EM NUMBER I.b.2 (Cont'd) 4.0 TUEC ACTION PLAN (Cont'd) 4.2 Responsibilities The 3eview Team Leader is Mr. M. B. Jones, Jr.
Analysis will be performed by Gibbs & Hill (S. P. Martinovich).
Reinspections will be the responsibility of third-party QC inspectors, with the assistance of Gibbs & Hill, if required.
Review of the analysis and the inspection results is the responsibility of the Review Team Leader. The analysis will also be reviewed by an outside consuJeant with expertise in their area. Evaluation of root cause and generic. implication is the responsibility of the RTL.
3 4.3 Personnel Qualification Requirements s
Participants in the implementation of this Action Plan meet the personnel qualification requirements of the Program Plan and its implementing procedures or CPSES quality assurance program as applicable.
4.4 Procedures The Action Plan will be conducted-in accordance with CPRT precedures applicable to the review of engineering evaluations performsd by CPSES personnel. Those evaluations will be prepared in accordance with procedures normal ~y' applicable to those activities for CPSES.
5.0 SCHEDULE Inspection attributes will be furnished by Gibbs & Hill by December 20, 1984. A draft of the snalysis will be completed by January 18, 1985. Inspection will be completed by February 8,1985. Action i
Plan completion is scheduled for March 8, 19ES.
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Revision:
1 Page 3 of 3 ITEM NUMBER I.b.2 (Cont'd)
Table 1 Examples of Cases of Safety or Nonsafecy-Related Cables In Contact With Other Safety-Related Cables Within Conduits in Control Spray System 1.
Control Panel CPI-EC-PRCB Containment Spray System d
Cable No.
Train Related Instrument EG139373 B (green)
Undetermined E0139010 A (orange)
Undetermined 2.
Control Panel CPI-EC-PRCB Reactor Control System Cable No.
Train Related Instrument EG139383 B (green)
Reactor manual trip switch E0139311 A (orange)
Undetermined 3.
Control Panel CP1-EC-PRCB Chemical & Volume Control System Cable No.
Train Related Instrument EG139335 B (green)
LCV-112C E0139301 A (orange)
Undetermined 4.
Centrol Panel CP1-EC-PRCB Auxiliary Feedvater Control System Cable No.
Train Related Instrument E0139753 A (orange)
~E0139754 A (orange)
FK-2453B EG139756*
B (green)
FK-2454A EG139288 B (green)
FK-2454B NOTE: Panel CP-1-EC-?RCB-06 was incorrectly identified as CP-t-EC-PRCP-06 in the September 18, 1984, letter.
This Cable was identified as an "E0" Cable number in the TRT letter dated September 18, 1984 l
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Revision:
1 Page 1 of 2 ITEM NUMPER I b.3 Conduit to Cable Tray Separation
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC The TRT found that the existing TUEC analysis substantiating the adequacy of the criteria for separation between conduits and cable trays had not been reviewed by the NRC staff.
2.0 ACTION IDENTIFIED BY NRC Accordingly. TUEC shall submit the analysis that substantiates the acceptability of the criteria stated in the electrical specifications gov'erning the separation between independent conduits and cable trays.
3.0 BACKGROUND
I 3.1 Information Supplementing NRC Descripcion of Issue Raceway separation criteria utilized in Gibbs and Hill 3
electrical drawings and specifications were based upon the requirements of IEEE 384-1974 and Regulatory Guide 1.75 (Rev.1, 1/75). Although very specific criteria are provided in the standard and regulatory guide for separation between cable trays, no specific criteria are provided for separation l
between conduits and cable tray.
Documents internal to Gibbs and Hill were prepared to establish the engineering interpretation ot required separation between conduits and cable tray in accordance with established criteria in the standard and regulatory guide.
These documents were not submitted to the NRC staff for review because the interpretation was not considered a deviation to the standard or regulatory guide, but was considered documentation supporting the implementation of these requiremente. Such implementing documents are not'usually submitted to the NRC.
3.2 Preliminary Determination of Root Cause and Generi,c, Implications The preliminary reviews conducted to date have not identified i
a' root cause for this item.
Implementation of the Action Plar.
is necessary before a root cause determination can be made.
Generic implications will be evaluate' based on the results of the implementation of the Action Plan and the results of the j
root cause determination.
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1 Page 2 of 2 ITEM. NUMB ER I.b. 3 (Cont'd) 4.0 TUEC ACTION PLAN 4.1 -Scope and Methodology A compilation of the criteria used by 'bbs & Hill in confirming the adequacy of conduit-to-cable tray separation will be submitted to TUGC0 for review. Included will be a copy of a Sandia Report (Lable Tray Fire Tests", SAND l
77-1125C) which is the primary reference used in establishing the separation criteria. Upon approval, this documert will be submitted to the NRC for rzview.
4.2 Responsibilities The Review Team Leader is M. B. Jones, Jr.,
Electrical / Instrumentation RTL. Compilation of the criteria is the responsibility of Gibbs & Hill (S. P. Martinovich).
Review of the report is the responsibility of TUCCO Project Electrical Engineer..the Review Team Leader and SRT. In addition, the report will also be reviewed by a qualified outside consultant.
4.3 Personnel Oualification Requirements Participants in the implementation of this Action Plan meet the personnel qualification requirements of the Program Plan and its implementing procedures or CPSES quality assurance program as applicable.
4.4 Procedures The Acticn Plan will be conducted in accordance with CPRT procedures applicable to the review of engineering evaluations performed by CPSES personnel. Those evaluations will be prepared in accordance with procedures normally applicable to those activities for CPSES.
5.0 SCHEDULE A draft of the report on the separation criteria has been submitted by Gibbs & Hill. Reviews will be completed by January 11, 1985.
Submission to the NRC will be made by January 25, 1985.
9 T2"ision: 2
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l ITEM NUMBER I.b.4 Barrier Removal
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC The TRT found'two minor violations of the separation criteria inside panels CP1-EC-PRCB-09 and CP1-EC-PRCB-03 concerning a barrier that had been removed and redundant field wiring not meeting minimum separation. The devices involved with the barrier were FI-2456A, PI-2453A, PI-2475A and IT-2450, associated with Train A; and FI2457A, PI245A, PI-2476A and IT2451, associated with Train B.
The field wiring-was associated with devices ES-5423 of Train'B and HS-5574, non* safety related.
2.0 ACTION IDENTIFIED BY NRC Accordingly, TUEC shall correct two minor violations of the separation criteria inside panels CP1-EC-PRCB-09 and-CP1-EC-PRCB-03 concerning a barrier that had been removed and redundant field.
wiring not meeting minimum separation.
NOTE: Panel CPL-EC-PRCB-03 was incorrectly identified in the September 18, 1984, letter as CP1-EC-PRCP-03. The TRT verbally notified TUEC of this information.
3.0 BACKGROUND
j 3.1 Information Supplementing NRC Description of Issue Barrier material supplied by the manufacturer of the equipment was removed from inside equipment (CB-03 & CB-09) creating a separation violation. In addition, redundant field cables are within six (6) inches of each other creating a separation violation.
3.2 Preliminary Determination of Post Cause and Generic Implications The preliminary reviews conducted to date have not identified a root cause for this item. Implementation of the Action Plan is necessary before a root cause determination can be made.
Generic implications will be evaluated based on the results of the implementation of the Action Plan and the results of the
[
root cause determination.
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Page 2 of 2 ITEM NUMBER I.b.4 (Cont'd) 4.0 TUEC ACTION PLAN 4.1 Scope and Methodologv The barrier material will be replaced and the field cables in CP1-EC-PRCB-03-and CPI-EC-PRCB-09 reworked to resolve improper separation. Nonconformance reports will be issued in accordance with engineering r ocedure CP-EP-16.0, " Procedure for Resolving Inspection Dist spancies"to assure disposition of these items. Engineering will provide direction to correct the nonconforming items in accordance with Engineering Procedure CP-EP-16.1, " Processing Nonconformance Reports".
Quality engineering and control activities will be carried out under quality engineering procedure CP-QP-16.0, "Nonconformances".
Inspection and maintenance procedures will be revised to ensure that all separation requirements are met following modifications or maintenance activities. Third party QC will ensure that barriers have been properly replaced, and that no unauthorized barrier removals have been done.
(See I.b.1) 4.2 Responsibilities The Review Team Leader is M. B. Jones, Jr., Electrical /
Instrumentation RTL. Preparation of the nonconformances is the responsibility of TUGC0 Quality Control with disposition the responsibility of TUGC0 Project Electrical Engineering.
Reinspection is by third party QC. Determination of root cause and generic implications is the responsibility of the Paview Team Leader.
4.3 Personnel Qualification Requirements Personnel involved in the implementation of this Action Plan will be qualified to the requirements of the Program Plan on the CPSES Quality Assurance Program, as appropriate.
4.4 Procedures 4.4.1 Procedure CP-EP-16.0, " Procedure for Resolving Inspection Discrepancies".
4.4.2 Procedure CP-EP-16.1, " Processing Nonconformance Reports".
4.4.3 Procedure CP-QP-16.0, "Nonconformances".
5.0 SCHEDULE This action item is scheduled to be completed by January 21, l
1985.
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