Text

Rev 5 to Final Wire & Cable Program Rept for Rancho Seco Nuclear Generating Station
	ML20151U024
Person / Time
Site:	Rancho Seco
Issue date:	02/29/1988
From:	Basu M, Divsalar F, Vinquist J; SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	;
Shared Package
ML20151T987	List: ML20151T983; ML20151U024;
References
	GCA-88-136, NUDOCS 8804290232
	Download: ML20151U024 (141)
	v • d • e

{{#Wiki_filter:i t .i-Enclosure To GCA 88-136 WIRE AND CABLE PROGRAM REPORT RANCHO SECO NUCLEAR GENERATING STATION SACRAMENTO MUNICIPAL UTILITY DISTRICT SACRAMENTO, CALIFORNIA REVISION 5 JANUARY / FEBRUARY l988 (FINAL) i PREPARED BY: APPROVED: l I i f r I /V4 N4 ukL st 4RTS PROGRAM COORDINATOR J.fECTOR, NUCLEAM' QUALITY DI F. Divs lar V. Vinquist ~J kW

- /

ET(T5 PROGRAM MANAGER MARAGER, NUCLEAR ENGINEERING I M. Basu G. V. Cranston i 8804290232 880410 - DR ADOCK 050 2 b c.

Enclosure To GCA 88-136 WIRE AND CABLE PROGRAM REPORT

1. INTRODUCTION The Rancho Seco Nuclear Generating Station at plant turnover in 1975 had a cable population of about 14,000 cables installed mostly in ventilated type cable tray and in steel conduit.

Since 1975 about 9,000 cables have been added while a few have been deleted. In common with all large modern power plants in the United States, Rancho Seco tracks its raceway and cable data in a computerized program run on a mainframe computer. The current program has an acronym'of CRTS (Cable Raceway Tracking System) and performs some checks and calculations as well as recording and reporting data. CRTS has been in place since July of 1980. The original cable population of 14,000 was installed by Bechtel Power Corporation (BPC). BPC was both designer and constructor. Until the CRTS program was put in place in 1980, the cable and raceway was tracked by a BPC Program EE-553. This program has been used for over 20 nuclear power plants.

2. BACKGROUND DISCUSSION 2.1 INITIATING EVENTS Although some questions concerning CRTS completeness, missing CRTS cards and conflicting procedures were raised by resident inspectors as early as 1983, major concerns did not arise until 1985 and 1986.

In 1985, questions arose concerning the degree of design control exercised following spurious actuations reported in LER 85-16. In 1906, questions arose concerning the degree of control exercised during the inst 311ation process and the validity of "as-built" information in the CRTS data base following issuance of LER 86-10. Employee allegations regarding overfilled cable trays and incomplete data in CRTS added to the level of concern. The July Wire and Cable Program Report contained 56 CRTS Action Items, including entries for 16 Non-Conformance Reports [NCRs] and 12 Occurrence Description Reports [0DRs]. The Aug"st Report was reformatted and lists ODRs and NCRs separately from the CRTS Action Item List [ Attachment (1)]. CRTS Action Items 1 through 22 remain the same, Item 23 of the July Report is now listed under NCR S-5270 in the CRTS NCR List, Items 24 and 25 of the July Report nave been combined and are now Item 23. 00Rs and NCRs listed as Items 26 through 52 of the July Report are now listed by the appropriate ODR or NCR number in either the CRTS ODR List (Attachment (2)] or the CRTS NCR List LAttachment (3)] as appropriate. CRTS Action Items 53 through 56 of the July Report now appear as CRTS Action Items 24 through 27, respectively. The August Report added Item 28. The September / October Report added Items 29 and 30. -2 j J

Enclosure To GCA 88-136 WIRE AND CABLE PROGRAM REPORT (Continued) Identified problems and questions are listed, with appropriate refererences, in the CRTS Action Item List ( Attachment (1)], the CRTS ODR List [ Attachment (2)], and the CRTS NCR List [ Attachment (3)]. The separate 00R and NCR lists have been expanded and now provide descriptions of the occurrences or nonconformances, direct causes, corrective actions, and reference to the CRTS Action Item Ccmentaries LAttachment (4)], where appropriate. 2.2 INITIAL ACTIONS Initial action taken by SMUD, in mid-1986, was to hire a contractor (Impell - Task 271J to provide computer applications and electrical engineering expertise required to resolve CRTS database discrepancies and verify that the CRTS database correctly reflected the plant "as-built" configurati This task was essentially an engineering review and checking pt.;ess aided by microcomputer programs written to sort CRTS data and to print data lists as requested by the engineers. Checks were made of raceway overfills, violations of separation criteria, intermixing of instrument cables with power and control cable, and other discrepancies as listed in the Action Plan. Although a number of discrepancies were "bookkeeping" problems generated by the enhancement, a significant number could, potentially, have been of real concern. Identified discrepancies are documented in reports from the SMUD contractor (Impellj to SMUD and their dispositions described in Item 2 of tne CRTS Action Item List and supported by calculations in SMUD files. Late in 1986, a decision was made to signal trace a significant sample of the approximately 2400 safety cables installed from 1975 through 1936 and compare the "as-built" condition with plant documents and the CRTS data base to establish a level of confidence in tr.e reliability of tne data base. The signal tracing found sufficient number of major defects in both Lot 1 (397 cables) and Lot 4 (78 cables) to require 100% inspection of eacn lot. In late June 1987, sampling was complete in Lots 2, 3, and 4. However, in July 1987, a decision was made to semple Lot 2 to the "one-defect" level, increasing the size of Lot 2 by 35 cables. Circuit tracing was completed on December 8, 1987 with a total of 617 cables either traced visually or by signal tracing. During the final checking and revision of the Sample Plan [ Appendix (1)], cables deleted from the plant (af ter the populations were established] were deleted from each lot as follows: Lot 1 Lot 2 Lot 3 Lot 4 Was 422 1702 190 78 Is 398 1434 183 78 -3

Enclosure To GCA 88-136 ' WIRE AND CABLE PROGRAM REPORT (Continued) Additionally, in Lot 2, 76 Class 2 (Appendix "R"] cables and 3 Class 1 [ Appendix "R"] cables were found to be pre-commercial operation vintage. Seventy nine pre-comercial cables were deleted from Lot 2. Three of the 76 were included in the lot 2 inspection total of 91. Three more cables were traced in Lot 2 in December and were found to be correct [no defects). Final inspection totals and statistical inferences are given in Table 1 of the comentary to CRTS Action Item 28. Simply stated, the intent was to establish 95 percent confidence that the true' percentage of discrepant circuits [ major defects] in the sampled population is no greater than 5 percent. Inspection totals are, in fact, higher for Lots 2 and 3 than are required to establish this confidence level. See commentary to CRTS Action Item 28. 2.3 ACTION PLAN SMUD has provided a document [ Appendix (2)] to the NRC which i describes a five-part Action Plan to consolidate the various activities of the Nuclear Engineering Department, which deal with the cable and raceway questions. Altnough the scope of the plan is complete, the details and the individual actions require additional definition to enable a reviewer to easily determine the acceptability of the resolution of each item i (i.e., question or issue raised). The Wire and Cable Program Report is intended to replace the Action Plan and to provide additional definition and schedule infonaation on a monthly basis. 2.4 CRTS ACTION ITEM LIST AND COMMENTARY This report provides a listing of thirty CRTS action items [ Attachment (1)j with a detailed commentary on each LAttachment (4)]. This list is intended to serve as a record of all questions _j raised and of all known problems, other than ODRs and NCRs. For each item, the list includes an item number, description, source, status, j and scnedule for resolution, if appropriate. A coniaentary will be provided on each item covering chronology, generic implications, causes, and corrective action.s as appropriate. Tnis report contains all comentaries and final inspection totals [see the commentary to CRTS Action Item 28]. To understand the significance of each item, it is necessary to read j the attendant commentary. The major concerns are summarized in Section 3. -4

1 Enclosure To~ GCA 88-136 WIRE AND CABLE PROGRAM REPORT (Continued) 2.5 CRTS RELATED ODRS AND NCRS CRTS related 00Rs and NCRs are listed separately [ Attachments 2 and 3] with descriptions, causes, corrective actions, and reference to the CRTS Action Item Commentaries, where appropriate. 3. MAJOR CONCERNS I ISSUES CONCERNS-Procedures The level of control exercised on-cable installation. Sampling Plan Accuracy of CRTS data on caule locations. Data Base Completeness Omission of cables from data base. Raceway Fill Control of ' cable tray fill (weight and ampacity questions). Design Control Mixing of instrument cables [with power and i control] in design process. CRTS Discrepancies Control and entry of data into CRTS. Records Control of documents of record. 4 Miscellaneous Problems Completeness of licensee action in resolving problems. i Root Causes Identification and correction of all ] identified root causes. Status of each issue is, in summary, as follows: 3.1 PROCEDURES Procedures in place during the original construction period are ] addressed in Item 7 of the CRTS Action Item List. Procedures in place from 1975 through 1986 are addresset in the commentary to CRTS 3 Action Item 25. 3.2 SAMPLING PLAN This issue is fully addressed in the commentary to Item 1 of the CRTS l Action Item List. -{ z \\ ) -5

Enclosure .i To GCA 88-136 WIRE AND CABLE PROGRAM REPORT (Continued) t 3.3 DATABASE COMPLETENESS The "completeness" issue of the CRTS data centers on the data concerning the telephone and security cables. - This issue, although real, has no significant safety implications. The issue also includes questions cor.cerning the verification of CRTS software. Items 10,11,12 13, and 14 of the CRTS Action Item List cover the completeness issu,e. 3.4 RACEWAY FILL The cable tray fill and weight questions have been reviewed. Percentage fill and weights for all cable trays have been checked.- Although some relatively minor questions remain to be answered, no significant problems nave been found. Changes are planned to USAR which will reconcile differences between the USAR and Nuclear Engineering Procedures and will clarify design limits. Enhancements planned to the CRTS sof tware will, when in place, automatically prevent fill and weight limits from being exceeded, j These questions are addressed in Items 2 [ partial], 6, and ODR 86-125, 3.5 DESIGN CONTROL The design control issue is more complex than the raceway fill issue, but problems are limited to a relatively small number of instrument cables which mix with power and control cables and violate design cri teria. No evidence has been found of a programmatic failure following a review of the original 14,000 cable population. Checking continues on the 9000 cables added af ter commercial operation, but is not expected to change the outcome of the evaluation, i The question of a possible generic design problem in the original 14,000 cable population is addressed in Item 5 of the CRTS Action 1 Item List. Other specific mix questions are addressed in Items 2 Lpartial), 9, and by ODR 87-307 and NCRs S-6523, S-6561, S-6562, S-6563, S-b564, S-6565, and S-6566. 3.6 CRTS DISCREPANCIES i The large number of CRTS discrepancies listed by the SHUD contractor [ImpellJ in Task 271 is another complex question. Although the large number is initially disquieting, upon examination none nave any safety significance as detailed in the commentary on CRTS Action Item 2. One example of this is the total of 763 reported mixes of Class I with Class 2 or 3 cables. Almost all the 763 cables are in the original cable population which permitted mixing. None violated safety criteria. All of the 1967 Class 1 discrepancies and some -6 1

Enclosure To GCA 88-136 WIRE AND CABLE PROGRAM REPORT (Continued) Class 2/3 discrepancies have been carefully analyzed, with documentation, without finding any significant concerns. The reason for this, detailed in the commentary, is that the Impell review process itself generated the discrepancy lists which then had to be addressed. One benefit of the CRTS discrepancy process is that the total population of 23,000 cables and related raceways has been scrutinized closely and results provide additional confidence in the lack of significant safety concerns in the cable population. This issue is addressed in Item 2 of the CRTS Action Item List. 3.7 RECORDS Record control at Rancho Seco is a simpler issue. The customary industry documents of record for installed cable and raceway are the signed installation cards. The computer tracking system is used as a convenient source of data while the verification record is the installation card. At Rancho Seco the originals of the installation cards for the initial 14,000 cables and 13,000 raceways have not yet been found, although facsimile record copies do exist. As discussed in the comentary to CRTS Action Item 3, records for the original cables and raceways are apparently complete, although the clerical task of checking each cable and raceway card is not complete. Card records for the cables and raceways installed af ter commercial operation are mostly complete. Replacement cards for Cidss 1 and Appendix R pull cards were generated through dispostion of NCRs S-6549, S-7651, S-7652, S-7719, S-7741, and S-7770, af ter tLe cables were cnecked against the design documents. All other missing cards are identifed on NCRs for dispostion. 3.8 MISCELLANEOUS PROBLEMS This issue deals with the completeness of SMUD actions in identifying and resolving all cable and raceway problems. Together, the CRTS Action Item List [ Attachment (1)], CRTS 00R List LAttachment (2)], CRTS NCR List [ Attachment (3)], and the CRTS Action Item Commentary [ Attachment (4)J is the vehicle which records all questions and probl ems. All identified items with safety significance will be resolved before restart. All identified items with no safety significance will be resolved before the end of the Cycle 8 Outage. All items in the CRTS Action Item List wi;l be reviewed for generic implications before resolution. When a concern has been identified, the basic steps taken by SMUD are:

1) Take imediate act;on to prevent repetition.

2) Identify the direct cause and take corrective action. 3) Investigate and identify the root cause and, if required, supplement the cor ective action. -7

Enclosure To GCA 88-136 WIRE AND CABLE PROGRAM REPORT (Continued) 3.9 ROOT CAUSF.S Where applicable, root causes have been established for each item in the CRTS Action Item List. The Incident Investigation / Reviews Group [IIRG] established root causes for significant issues identified during the investigation of problems encountered in the 9,000 cables installed 1975 through 1986. This issue is addressed in Item 15 of the CRTS Action Item List. 4. APPENDICES 1. Sampling Plan for Cable Raceway Tracking System Database (Impell Task 271, SMUD calculation No. Z-ZZZ-E0694, Revision 6, dated March 4, 1988). 2. Rancho Seco Wire and Cable Program Description and Action Plan (District submittal dated April 3,1987 JEW 87-478). 3. Justification for the Exclusion of the Original Rancho Seco Cable Population from the CRTS Sampling Program (District submittal dated July 24,1987 GCA 87-338). 4. Prior Use of 95/95 Acceptance Criteria in Nuclear Power Plant Sampling Applications Involving Safety-Class Components and Technical Basis for Rancho Seco Sampling Plan (included in District submittal dated August 18,1987, GCA 87-400). 5. Cable Discrepancies / Root Cause Investigations of the Cable Issues (District submittal dated November 9,1987, DTS 87-103). 6. Construction Inspection Data Reports EC-13, dated October 16, 1978 dnd EC-48, Rev. 1, dated February 22,1980 (included in District submittal dated December 4,1987 GCA 87-780). 5. ATTACHMENTS l. CRTS Action Item List (5 pages) l 2. CRTS ODR List (4 pages) 3. CRTS NCR List (8 pages) 4. CRTS Action Item Comentary (116 pages) -8

~. - _ ~_. Page No. 1 ATTOCHMEDT 1 ENCLOSURE TO GCA 88-136 02/29/88 CRTS Ald ON ITEM LIST REVISION 5 ITED DESCRIPTION SOURCE ACTION STATUS / SCHEDULE REMARKS OPEN/ NUM - CLOSED 1 DEMONSTRATE THAT CRTS RECORDED LERs 86-10 AND 87-13 SAMPLING PLAN FOR CRTS DATA PRIOR TO RESTART ACTUAL COMPLETION DATE IS CLOSED i CABLE LOCATIONS MATCH BASE. DECEMBER 8, 1987. AS-BUILT. 2 RESOLVE ALL CRTS DATABASE ACTION PLAN SEE CopeqENTARY. MAJOR - COMPLETE SEE COMMENTARY FOR INDIVIDUAL - OPEN DISCREPANCIES. MINOR - CYCLE 8 ITEMS. 3 DEFINE SMUD DOCUMENT OF RECORD ACTION PLAN REVIEW CRTS, 101Ds, AND CARDS, COMPLETE SEE COMMENTARY. CLOSED CONTROLLINu CABLE LOCATION. AND MAKE DETERMINATION. 4 000JMENT LEVEL OF CONTROL LERs 86-10 AND 87-13, ODR DETEPMIME PROCEDURES AND SEE COMMENTARY SEE COMMENTARY. CLOSED EXERCISED BY SMUD IN 86-12$ ORGANIZATIONS INSTALLING INSTALLING CABLE 1975-86. CA8LE. 9 5 DEMONSTRATE THAT NO BECHTEL LER 85-16 REVIEW EE-553 DATA 8ASE AND CLASS 1 AND APP R COMPLETE SEE CopeqENTARY. OPEN i GENERIC DESIGN PROBLEM DOCUMENT RESULTS. NON CLASS 1 CYCLE 8 EXISTED. 6 RESOLVE OVERFILL /OVERWEIGNT ODRs 86-125 AND 87 204, COMPLETE REVIEW OF OVERFILLS COMPLETE SEE CapeqENTARY. CLOSED QUESTIONS; INCLUDING USAR & LER 87-24 AND OVERWEIGHTS. 50.59. P JUSTIFICATION 50R NOT SAMPLING NRC MEETING MINUTES, MAY DEMONSTRATE BECHTEL QUALITY COMPLETE C0pqPLETE PER GCA 87-338, CLOSED ORIGINAL CABLE POPULATION. 6, 1987 PROGRAM SUFFICIENT TO CONTROL DATED JULY 24, 1987. . CABLE INSTALLATION. 8 RESOLVE ALL KNOWN PHT$! CAL ACTION PLAN SEE COMMENTARY. MAJOR - COMPLETE SEE COMMENTARY FOR INDIVIOUAL OPEN PROBLEMS. MINOR - CYCLE 8 ITEMS. m .-i w m.-- w -w r .1--w e-a, w-_- e

Page No. 2 ATT!.CMMEKT 1-ENCLOSURE TO CCA 88-136 02/29/88 CRTS ACTION ITEM LIST REVISION 5 ITE3 DESCRIPTION SOURCE ACTION STATUS / SCHEDULE REMARKS OPEN/ CJM CLOSED 9 RESOLVE .ER 87-26 AWAITING SMUD ACCEPTANCE OF CLASS 1. COMPLETE 16 NON CLASS 1 INTERMIXES TO OPEN POWER / CONTROL / INSTRUMENT CABLE IMPELL CALCULATIONS. NON CLASS 1 - PRIOR TO END OF BE DISPOSITIONED VIA NCII MINING CONCERNS. CYCLE 8 OUTAGE PROCESS PRIOR TO END OF CYCLE 8 OUTAGE. 10 DEMONSTRATE COMPLETENESS OF ACTION PLAN COMPLETE SAMPLING PLAN AhD SAMPLING - COMPLETE SEE ITEM 1. OPEN CRTS; INCL 12ING SOFTWARE PERFORM SOFTWARE VERIFICATION V AkD V - CYCLE 8 VERIFICATION AND VALIDATION. AND VALIDATION. 11 SHOW TO WHAT EXTENT SECURITY ACTION PLAN REVIEW CRTS FOR $[CURITY COMPLETE COMPLETE AUGUST 28, 1987. CLOSED CABLES DOCUMENTED IN CRTS. ODR 87-409 APRIL 9,1987 CABLES. 12 COMPLETE SEQJRITY CABt E ACTION PLAN REVIEW CRTS FOR SECURITY CYCLE 8 SEE COMENTARY. OPEN DOCUMENTATION. 00R 87-409 APRIL 9, 1987 CABLES. 13 SHOW TO WHAT EXTENT ACTION PLAN REVIEW CRTS FOR COMMUNICATION COMPLETE / ' SEE CopN4ENTARY. CLOSED COMMUNICATION CABLES ODR 67-409 APRIL 9,1987 CABLES. DOCUMENTED IN CRTS. 14 COMPLETE ComuMICAT10N CABLE ACTION PLAN REvlEW CRTS FOR COMMUNICATION CYCLE 8 SEE COMMENTARY. OPEN DOCUMENTATION. CDR 87 409 APRIL 9,1987 CABLES. 15 FORMAL AND COMPLETE ROOT CAUSE MRC LETTER TO SMLD, MAY IIRG TO PERFORM ROOT CAUSE PRIOR TO RESTART COMPLETE. CLOSED EVALUATION OF ALL CA8tE 1, 1987 ANALYSIS. PROBLEMS. 16 DEFINE MAJOR / MINOR / NRC KETING MINUTES, MAY SUPPLEMENT DECISION TREE WITH COMPLETE SEE COMMENTARY. CIOSED INSIGN!FICANT DEFECTS. 6, 1987 FORMAL DEFINITIONS. .-_..__.,_--,m... m. .~#. 4 v. .m .m,,, ~.m

. ~ - - - -. ~. =... _ -. Page No. 3 ATTACNME*T 1 ENCLOSURE To GCA 88-136 02/29/88 CRTS ACTION ITEM LIST REVISION 5 ITEM DESCRIPTION SOURCE ACTION STATUS / SCHEDULE REMARKS OPEN/ CJM CLOSED 17 REVISE USAR. ACTION PLAN PROVIDE DEFINITIONS AND CYCLE 8 REFER TO ITEMS 6 AND 9. OPEN l RESOLVE DISCREPANCIES. l l 18 ISSUE NEAP 4127 LER 85-16 RESOLVE DISCREPANCIES. COMPLETE NEAP 4127, "CABLE AND RACEWAY CLOSED TRACKING SYSTEM;" ACTUAL TSSUE DATE JUNE 15, 1987; REVISED DECEMBER 14, 1987. 19 PROVIDE BASIS FOR NRC MEETING MINUTES, MAY DEVELOP JUSTIFICATION; COMPARE COMPLETE SEE COMMENTARY. CLOSES l ACCEPTABILITY OF 95-95 AS 6, 1987 WITN OTHER PLANTS. SUFFICIENT ASSURANCE OF SAFETY. 20 RESOLVE NRC CONCERNS ABOUT NRC MEETING MINUTES, MAY RESOLVE BIAS QUESTION. COMPLETE SEE COMMENTARY. CLOSED POSSIBLE BIASING OF SAMPLE. 6, 1987 t 21 PROVIDE NRC WITN LOCATION OF NRC MEETING RWC 87-20, DETERMINE LOCATION OF CABLE COMPLETE SEE ITEM 3, DEFINITION OF CLOSED CA81E PULL CARDS. JANUARY 7,1987 PULL CARDS. MISSING CARDS. 22 PROVIDE Nec WITN FUTURE PLANS NRC MEETING RWC 87-20, DEVELOP FUTURE PLANS. COMPLETE SEE ITEM 3. CLOSED FOR CA8LE PULL CARDS. JANUARY 7,1"#87 23 REDUNDANT CASLING IN THE SAME LER 86-10 JUNE 16, 86 DETERMINE CAUSE/S. PRIOR TO RESTART

1. LER 86 10:

CLOSED FIRE AREA. LER 87-13 MARCN 6, 87-NCR S-5597; ECW R-0765, REV. O ISSUED TO CORRECT FIELD CONDITION; .2. LER 87-13: NCR S-6374; WR 128636 ISSUED TO CORRECT FIELD CONDITION;

3. IIRG REPORT 9EF DTS 87-103; NOVLn8ER 9,1987.

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- - ~ _..__... ~_ _ ..~ - -- -. -...~ ...--, ~ ~.. i Page No. 1 ATTACMMENT 2 ENCLOSURE TO GCA 88-136 I C2/29/88 CRTS RELATED EDRs REV. 3 ITEM ODR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE. ACTION OPEN/ NUM NUMBER CLOSED F 1 86-125 CLASS 1 AND 2 RACEWAY OVERf!LL. FEBRUARY 27, 1986 INADEQUATE PROCEDURAL QHDANCE. SEE COMMENTARIES TO CRTS ACTION CLOSED ITEMS 2 AND 6. 2 36-221 SEVEN APPENDIX R CABLES NOT MAY 22, 1986 PERSONNEL ERROR.

1. NCR S-5597.

CLOSED INSTALLED IN FIRE WRAPPED CONDUIT

2. IER 86-10.

X44154.

3. SEE COMMENTARY TO CRTS ACTION ITEM 2J.

3 87-066 E-1010s ARE NOT BEING PROCESSED AND JANUARY 17, 1967 UNKNOWN. ALL CHANGES TO CRTS RELATED - CLOSED CONTROLLED IN ACCORDANCE WITN DRAWINGS WILL SE PER THE REFERENCED PROCEDURES NEP 4109 AND NEP 4112. PROCEDURES AS DIRECTED SY MEMO EECS 87-005, DATED MAY 1,1967.' 4 87-109 caste ROUTING DISCREPANCY. FEBRUARY 3, 1967 ACCEPTA8LE ALTERNATIVE. CRTS CORRECTED TO REFLECT AS-8UILT. CLOSED .) 1 i 5 87-120 CA8tE IN DIFFERENT TRAY RISER TNAM FEBRUARY 2,1987 ACCEPTA8tE ALTERNATIVE. NCR S-6362 ISSUED. CLOSED I AS SHOWN IN CRTS. J 6 87-127 APPENDIX R CA8tE IN WRONG FIRC FEBRUARY 4,1967 ' PERSONNEL ERROR.

1. NCR S-6374 CLOSED ZONE.

2. LER 87-13

3. SEE COMMENTARY TO CRTS ACTION ITEM 23.

7 87-135 FIVE ADDIT.ONAL APPENDIR R CASLES FEBRUARY 6, 1967 PERSONNEL ERROR. SEE CORRECTIVE ACTION FOR ODR CLOSED IN WRONG FIRE ZONE. 87-127. 8 87-171 CABLE ROUTING DISCREPANCY-LIMIT FEBRUARY 9, 1987 PERSONNEL ERROR. WORK REQUEST 127363. CLOSED SWITCM COVE 45 SWAPPED. A i --e-v-- --m-m.# - w-. - - +e - = + - = - -w-- -e. -r-~- r i,e-r .e ~-e ea:s & ~e-ww,-..--,e=w--- -S--r u .4+-- .---,e-, e.--- -u.-

... _ _ ~ _ ~ _ _ _ - - ~._-_. _ ~.- - -. Page No. 2 ATTACNMECT 2 ECCLOSURE TO GCA 88-136 02/29/88 CRTS RELATED ODRs REV. 3 I TE*3 ODR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION OPEN/ CUM NUMBER CLOSED 9 87-204 POWER CONTROL CA8LE TRAY FILL LIMIT MARCN 27,1987 UNKNOWN. REVISE USAR; SEE C0pWEENTARIES TO CLOSED OF 40% MAY VIOLATE USAR CA8LE TRAY CRTS ACTION ITEMS 5, 6, AND 17. SUPPORT. 10 87 259 CABLE ROUTIRG VERIFICATION DOCUMENT FEBRUARY 23, 1987 PERS01.alEL ERROR.

1. NCR S-6457.

CLOSED DISCREPANCY. 11 87-260 caste ROUTING DISCREPANCY; LIMIT MARCN 4, 1987 PERS0aHIEL ERROR. WORK REQUEST WR 127135 CLOSED SWITCM COVERS SWAPPED. 12 87-274 NEP DIGITAL CABLE ROUTING MARCN 10, 1987 INADEQUATE PROCEDURAL

1. LER 87-26 CLOSED INSTRUCTIONS CONFLICT WITN USAR IMPLEMENTATION OF USAR

2. REVISION OF MEP 5204.22 SECTION 8.2.2.11.N.5 CABLE ROUTING REQUIREMENTS.

AND 5204.43 TO PROVIDE RESTRICTIO8tS. ADDITIONAL GUIDANCE ON ROUTING REQUIREMENTS FOR POWER / CONTROL / INSTRUMENTATION CASLE (COMPLETE). 13 87-275 TEN INSTRUMENTATION CA8tES ROUTED MARCH 10,1987 REFER TO DIRECT CAUSES FOR WCRs 1. REFER TO CORRECTIVE ACTIONS CLOSED IN POWER AND CONTROL TRATS S-6562, S-6563, S 6564, S 6565, AND FOR NCRs S 6562, S-6563, SEVENTEEN POWER CA8tES ROUTED IN S 6566. 5-6564,.5 6565, AND S 6566. INSIMCITATION TRATS. 2. SEE COMMENTARY TO CRTS ACTION ITEM 9. 14 87 284 CABLE ROUTING DISCREPANCY. FEBRUARY 6,1987 ACCEPTABLE ALTERilATIVE. CRTS CORRECTED TO REFLECT AS-BUILT. CLOSED 15 87 307 NIssE CONTROL CABLES ROUTED IN CLASS MARCN 19, 1987 DESIGN ERROR. 1. ECM R 1786 TO REROUTE CABLES. ' CLOSED 1 INSTRUMENTATION CABLE TRAYS. 2. SEE COMMENTARY TO CRTS ACTION ITEM 9.

_ms. .__._m m.. - _ __m ~.m..__ f Page No. 3 OTTACHMEDT 2 ENCLOSURE Tc GCA 88-136 02/29/88 CRIS RELATED ODRs REV. 3 ITEM ODR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION OPEN/. NUM NUMBER CLOSED 16 87-322 CRTS caste VER:FICATION WORK MARCN 23, 1987 PERSONNEL ERROR. DRAWING CHANGE ONLY TRANSMITTAL -CLOSED REQUEST WR 127122 TO SE CLOSED R-1536 ISSUED TO INCORPORATE WITNOUT CORRECTIVE ACTION TO AS-BUILT CASLE ROUTING. RESOLVE DRAWIf4G DISCREPANCIES. 17 87-409 630 TELEPHONE AND SECURITY SYSTEM APRIL 9, 1987 CONFLICTING PROCEDURES. 1. COMPLETE DESIGN DOCUMENTATION OPEN CABLES INSTALLED IN PLANT WITN PRIOR TO COMPLETION OF CYCLE 8 INCOMPLETE DESIGN DOCUMENTATION. DUTA3. 2. SEE COMMENTARIES TO CRTS ACTION i ITEMS 11, 12, 13, AND 14. 18 87-412 RPS AND SFAS CASLES ROUTED IN CASLE MARCN 7, 1987 INADEQUATE PROCEDURAL REVISE USAR; SEE Co mENTARY TO CRTS ' CLOSED TRATS CONTRARY TO USAR SECTION IMPLEMENTATION OF USAR ACTION ITEM 17 8.2.2.11.W.2 WHICH REQUIRES REQUIREMENTS. DEDICATED CONDUIT. i 19 87-502 USAR AND NEP CONTRADICT ON MAY 4, 1987 INADEQUATE PROCEDURAL REVISE USAR; SEE C0fMEENTARY TO CRTS OPEN INSTRUMENTATION CABLE TRAY FILL IMPLEMENTATION OF USAR ACTION ITEM 17. LIMITS. REou!REMENTS. 20 87-604 CONTROL CABLE 1MA171C INSTALLED IN MAY 21, 1987 DESIGN ERROR. 1. ECN R-1786 TO REROUTE caste. CLOSED CONFLICT WITN INSTALLATION CARD AND 2. SEE COMMENTART TO CRTS ACTION CRTS AND IS ROUTED IN 2 CLASS 1 ITEM 9. INSTRUMENTATION TRAYS. } 21 87-723 10 CLASS 1 POWER AND CONTROL CASLES JUNE 16, 1987 DESIGN ERROR. 1. ECNs R 1785 AND R-1756 TO CLOSED ROUTED IN CLASS 1 INSTRUMENTATION REROUTE CAELES. + CASLE TRAYS. 2. SEE C0fM4ENTARY TO CRTS ACTION ITEM 9. I i i ,-s =.

O*9e NO-0 OTTACHMEDT 2 ENCLOSURE TO GCA 88 136 02/29/88 CRTS RELATED ODRs REV. 3 ITED ODR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION OPEN/ NUM NtMBE R CLCSED 22 87-735 1 CLASS 1 POWER CABLE ROUTED IN JUNE 18, 1987 SEE DIRECT CAUSE FOR 004 87-723. SEE CORRECTIVE ACTION FOR ODR CLOSED CLASS 1 INSTRtmENTAT104 CABLE TRAY 87-723 (INCLtDED IN ODR 87-723). 23 87-860 CLASS 1 CA8tE 1L1A210AD RUNS IN AUGFST 14, 1987. CONSTRUCTION ERROR. ENTEND CONDUIT L44053 TO ILOOR SLOT CLOSED NON CLASS 1 CABLE TRAY 744CC7 N81575 BY ECM t-1590. l i

__._m_. _.m._ _m._. m__ .. _ _.. _ __ _.. ~ =. ~ i 1 l Page No. 1 ATTACMME:;T 3 ENCLOSURE TO GCA 88136 02/29/88 CRTS RttATED NCRs REV. 3 C.. ITED NCR DESCRIPTION DATE DIRECT CAUSE CORRECTIYE ACTION CPEN/ CUM NUMBER CLOSf.4 ' s l 1 l 1 5-5263 DECAY MEAT RCS PRESSURE INTERLOCK JANUARY 16, 1986 PERSONNEL ERROR.

1. ECNs 4 0459 AND R-T295.

CLOSED FROM PT-21099 INSTRUMENTATION CABLE

2. ISSUE W AP 4127.

l ROUTED IN POWER AND CONTROL 3.~ CRTS DATA SASE VER!!! CATION. RACEWAYS. 2 S-5270 WRONG ID ON C00UIT IN MND-22 JANUARY 20, 1966 UNENOWN. RESOLVED BY IMPELL TASK 271. CLOSED 3 S-5597 SEVEN APPENDIX R CASLES IN WRONG MAY 22, 1966 PERSONNEL ERROR.

1. ECM R-0765.

CLOSED FIRE 2ONE.

2. WIRE AAD CASLE ACTION PLAN.

3. REVISION TO MP/IS TO DEFINE CASLE INSPECTION REQUIREMENTS.

4. SEE COMMENTARY TO CRTS ACTION ITEM 23.

4 5- % 71 4KV CAELE ROUT (D DIFFERENT TNAN AS JULY 9, 1966 UNENOWN. RESOLVED BY IMPELL TASK 271. CLOSED SHOWN 87 DRAWINGS AND CRIS. t 5 5-5968 DECAY MEAT SYSTEM RCS PRESSURE OCTosER 13, 1966 DESIGN ERROR.

1. ECM R-1295.

CLCSED INTERt0CE FROM PT 21092

2. SEE CapoIENTARY TO CATS ACTION INSTRUMENTATION CASLE ROUTED IN ITEM 9.

INSTRUMENTATION RACEWAYS WI!N POWER AND CONTROL CASLES. 6 S-6278 E 1010s ARE NOT BEING PROCESSED IN JANUARY 19, 1987 OutN0hAl. ALL CHANGES TO C#fS RELATED CLOSED ACCORDANCE WITN PROCEDUES NEP 4109 DRAWINGS WILL SE PER THE REFEREWCED AND WEP 4112. PROCEDU5t$ AS DIRECTED SY MEM3 EEGS 87-005, DATED MAY 1,19u7, t i

.v,4-----

v.-w-e--,=-,--e .-,.,--..e--* v,= ~+w+,- ww,,r-- --*w-- --+-.=++e=-w.--wr#- y w -*---,-o -mm-er - -- + -, - -em . + a v. ,,,,c%,-,e ..m-- .-e- .r-c......-w w-. w-----

______.._.._-_____.m.._ ..__m.._._m-m.__._ m_ m_. l Page Es. 2 ATTACNME%T 3 ENCLOSURE TO GCA $8-1M 02/29/88 CRTS RELATED NCRs REV. 3 ITE:1 NCR DESCRIPflou DATE DIRECT CAUSE CORRECT!WE ACTION OPES /' NUM NUMBER . CLOSED l 7 S-6286 CA8tE JACCET DAMAGE. JANUARY 21, 1967 UNKNOWu CASLE REPAIRED MR WORK REQUEST WR CLOSED. l 132118. CONSTRL1: TION SAFETY l MEETING MELD ON MARCN 5,1967 TO TO DISCUSS CASLE PROTECTION Aes DAMAGE l PREVENTION. I 8 S-6M2 CABLE tu DIFFERENT TRAY RISER TNAM FEBRUARY 3, 1967 ACCEPTABLE ALTERmATIVE. DRAWING CHANGE ONLY TRANSMITTAL CLOSED AS SMOWN IR: CRTS. R-15 M IS5UED TO luc 0RPORATE AS-SUILY CASLE ROUTimC.' 9 S-6374 SEVEN APPENDIX R CASLES IN WRONG FEBRUARY 4, 1967 PERS0mWEL ERROR.

1. WORE REQUEST WR 128636 RERbUTESCLOSED FIRE 204E.

CASLES PER EXISilbG DESIGN 000mENTS.

2. SEE CORRECTIVE ACTION FOR NCR S-5597.

10 5-6454 CAELE TERMINATION DISCREPA#CY. FESRUARY 24, 1967 UNEMOWu. WORE REQUEST WR 132121 CDRRECTS CLOSED DISCREPANCY. 11 5-6455 CABLE TERM!hATION DISCREPAseCY. FEBRUARY 23, 1967 UNEm0Wu. REWORKED PER WORE REQUEST WR CLOSED 132117. 12 S 6457 MV-21505 POWER CAPLE IN WRouG FEBRUARY 23, 1967 UNE40Wu. ORAWIIeG CnAmGE OutY TRANSMITTAL CLOSED CONDUIT. R-1536 ISSUED TO ImCDRPORATE AS-SUILT CASLE ROUTIIeG. 13 S-6458 caste JACKET DAMAGE. FEBRUARY 20, 1967 UmKm0Wu. NouE REQUIRED; DUPLICATE OF eCR . CLOSED e 'S 6286.

Page No. 3' AsTACMMENT 3 ENCLOSCE TO GCA 88-136 OI/29/88 CRTS RELATED NCRs REV. 3 ITEM NCR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION OPEN/ NUM NUMBER CLOSED 14 S-6459 CONDUIT CARDS ASSOCIATED WITH ECNs FEBRUARY 24, 1987 PERSONNEL ERROR. NCR REQUIRES DISPOSITION. OPEN A 2980 AND A-3065 WERE RETURNED WITHOUT 6eING SaGNED BY 'HE FIELD ENGINEER OR BY QC. 15 S-6460 DEBRIS IN TRAYS. FEBRUARY 20, 1987 UNKNOWN. MONE REQUIRED; SURVEILLANCE REPORT . CLOSED 20.855 INDICATES DE8RIS IN TRAfS IS AN ISOLATED INCIDENT. 16 'S-6523 CRTS CABLE TRAr%*NG; UNACCEPTA8LE MARCH 10, 1987 REFER TO SUPERCEDING NCRs. NCR IS REPLACED BY NCRs S-6561, CLOSED INTERMIXING OF POWER / 6542, 6563, 6564, 6565, AND 6566. CONTROL / INSTRUMENTATION. 17 S-6547 "3LE CARDS RETURNED WITHOUT QC MARCH 18, 1987 PERSONNEL ERROR.' 10 CARDS WERE FOUND.- FOR THE CLOSED b!GNATURES. REMAINING MISSING CARDS (10) CABLE INSTALLATION VERIFICATION BY FIELD ENGINEER AND QUALITY CONTROL INSPECTOR VERFIFIED BY QC SIGNATURE ON THE APPLICABLE WORK REQUESTS. 10 S-6549 CABLE CARDS RETURNED WITHOUT QC MARCN 18, 1987 PERSONNEL ERROR. NCR REQUIRES DISPOSITION. OPEN SIGNATURES. 19 S 6561 NINE CONTROL CABLES IN CLASS 1 MARCH 20, 1987-CO,PLETE.

1. ECN R-1786 CLOSED INSTRUMENT TRAY.

2. REVISION TO NEP 5204.22 AND 5204.43 TO PROVIDE ADDITIUNAL CUID4NCE ON ROUTING REQUIRE-MENTS FOR POWER / CONTROL / INS'-

RUMENTATION CABLES (COMPl.ETE).

3. SEE COMMENTARY TO CRTS ACTION ITEM 9.

u i = vw r --7 e e

Page No. 4 ATTACHMEOT 3 ENCLOSCE TO GCA 88-136 02/29/88 CRTS RELATED NCRs REV. 3 ITEM NCR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION OPEN/ ' CM NUMBER CLOSED 20 S-6562 FOURTEEN POWER CABLES IN CLASS 1 MARCH 20, 1987 INADEQUATE DEFINITION OF NCR DISPOSITIONED TO ACCEPT. CLOSED INSTRUMENT TRAY. POIKR/ CONTROL / INSTRUMENTATION SERVICE LEVELS. 1 21 S-6563 RAD MONITOR P'MR CABLE IN CLASS 1 MARCH 20, 1987 PROPOSED CABLE, NEVER INSTALLED IN NONE REQUIRED. CLOSED INSTRUMENT TRAY. PLANT. 22 S-6564 HV-20609 AND HV-26513 POWER CABLES MARCH 19, 1987 UNKNOWN. REFER T') CORRECTIVE ACTION FOR NCR CLOSED IN INSTRUMENTATION TRAYS. S 6561. 23 S-6565 BATTERY CHARCER CABLES IN MARCH 19,1987 ACCEPTABLE ROUTING; CABLES ARE NONE REQUIRED. CLOSED POWER / CONTROL RACEWAYS. CONTROL CABLES AND ARE ROUTED AS SUCH. 26 S-6566 DHS CROSS-TIE FLOW TRANSMITTER IN MARCH 19, 1987 INADEQUATE DEFINITION OF

1. ECN R-1786 CLOSED POWER / CONTROL RACEWAYS.

POWER / CONTROL / INSTRUMENTATION -2. R: VISION TO NEP 5204.22 AND SERVICE LEVELS. 5204.43 TO PROVIDE ADDITIONAL CUIDANCE ON ROUTING REQUIRE-MLNTS FOR POWER / CONTROL / INST-RLMENTATION CA8tES (COMPLETE).

3. SEE COMMENTARY TO CRTS ACTION ITEM 9.

25 S-6584 CABLE IN DIFFERENT CONDUIT THAN AS APEIL 1, 1987 ACCEPTABLE ALTERNATIVE. DRAWING CHANGE ONLY TRANSMITTAL CLOSED SHOSN BY CRTS. R-1863 ISSUED TO INCORPORATE AS-8UILT CABLE ROUTING. 2o S-6504 205/SFAS CABLES R0l'TED IN CABLE APRIL 7. 1987 INADEQUATE PROCEDURAL NCR DISPOSITIONED TO ACCEPT. CLOSED TRAY VERSUS CONDUIT AS REQUIRED BY IMPLEMENTATION OF USAR. REVISE USAR AS SHOWN IN COMMENTARY USAR. REQUIREMENTS. TO CRTS ACTION ITEM 17.

Page No. 5 ATTACHMENT 3 ECCLOSC2E TO GCA 68-136 02/29/88 CRTS RELATED NCRs REV. 3 + ITEM WCR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION-OPEN/ CM NUMBER CLOSED 27 S-6800 CABLC 12181448 AS-BUILT ROUTING JULY 1, 1987 ACCEPTABLE ALTERNATIVE. D00 R-1981 ISSUED TO INCORPORATE CLOSED OMITS TRAY M44v10. AS-BUILT ROUTING IN CRTS. 28 S-6830 CABLE 1M18147C CRTS ROUTING OMITS JULY 11, 1987 ACCEPTABLE ALTERNATIVE. DC0 R-2000' ISSUED TO INCORPORATE ~ CLOSED TRAY M39BB8. AS BUILT ROUTING IN CRTS. 29 S-6858 CABLE 1R1C7250 CRTS ROUTING OMITS JULY 17, 1987 ACCEPTABLE ALTERNATIVE. DC0 R-2013 ISSUED TO INOORPORATE CLOSED TRAY M43v10. AS-BUILT ROUTING IN CRTS. 30 S-6860 CABLE 1M181".4E AS-BUILT ROUTING JULY 18, 1987 ACCEPTABLE ALTERNATIVE. DC0 R-2014 ISSUED TO INCORPORATE CLOSED OMITS CABLE TRAY M44V10. AS-BUILT ROUTING IN CRTS. 31 S-o880 CABLE 1P1800F ROUTED THROUGet EMBED JULY 23, 1987 CONSTRUCTION ERROR. DC0 R-2033 ISSUED TO INCORIORATE OPEN M03102 INSTEAD OF M03104. CRTS AS-BUILT ROUTING IN CRTS. WIRE LISTED VIA M43039 SHOULD BE M43093. MARKER TO BE REPLACED Bi WORK CONDUCTOR C21 PER CRTS IS C12 IN REQUEST. THE FIELD. 32 S-6882 CABLE 1R1C723C CRTS ROUTING OMITS JULY 25, 1987 ACCEPTABLE ALTERNATIVE. DC0 R-2030 ISSUED TO INCORPORATE CLOSED TRAY M43V10. AS-BUILT ROUTING IN CRTS. 33 S-6884 ~ TWO CLASS 1 CABLES RUN IN NON-CLASS JULY 26, 1987 CONSTRUCTION ERROR. EXTEND CONDUIT L44053 TO FLOOR SLOT CLOSED - 1 CABLE TRAY 744CC7. H8FS75 LY ECN R-1590. 34 S-6894 CABLES 1M1A121D AND 1M1A137E CRTS JULY 28, 1987 ACCEPTABLE ALTERNATIVE. DC0 R 2029 ISSUED TO INCORPORATE CLOSED-ROUTING OMITS VIAS L44V20 AND AS-BUILT ROUTING IN CRTS. L44BT2, AS-BUILT ROUTING OMITS VIA L44V63. l

i Page Co. 6 ATTACHMECT 3 ENCLOSLCE TO GCA 88-136 02/29/88 CRTS RELATED NCRs REV. 3 ITEM NCR DCCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION OPEN/ CJM NUMBER CLOSED 35 S-6939 CABLE 1Y10A902A PULL CARD DOES NOT AUGUST 10, 1987 UNKNOWN. NEW PULL CARD SIGNED, CONFIRMING CLOSED MATCH E-1010 DCN, CRTS ROUTING,, OR CABLE ROUTING. AS-BUILT. 36 S-6957 CABLES 1R1SO4A1D AND 1RIC210A1 ARE AUGUST 14, 1987 CONSTRUCTION ERROR. DC0 R-2108 ISSUED TO INCORPORATE CLOSED ROUTED THROUGH A28100 VERSUS A28031 AS-BUILT ROUTING IN CRTS. NEW PULL PER CRi'S, E-1010 DCN, AND PULL CARDS' ISSUED CONFIRMING CA8LE CARD. ROUTING 2 ~ 37 S-6963 CABLE 1M18117D CRTS ROUTING OMITS AUGUST 17, 1987 ACCEPTABLE ALTERNATIVE. DC0 R-2112 ISSUED TO INCORPORATE CLOSED VIA M39587. AS-8UILT ROUTING IN CRTS FOR CABLE PLUS SEVEN OTHERS. NEW PULL CARDS ALSO ISSUED. 30 S-6%7 CABLE 1M18173C AS BUILT ROUTING. AUGUST 19,1987 ACCEPTABLE ALTERNATIVE. DC0 R-2186 ISSUED TO INCORPORATE ' CLOSED-OMITS VIAS M44V12, M43V12, AND. AS-BUILT ROUTING IN CRTS. NEW PULL M43V10, AND SUBSTITUTES M44V10 AND CARDS ALSO ISSUED. M43V10. 30 S-6972 CABLE 1G1DG82U AS-BUILT ROUTING AUGUST 20, 1957 ArCEPTABLE ALTERNATIVE. DC0 R-2119 !SSUED TO INCOR*0 RATE CLOSED ' INCLUDES CABLE TRAYS M81S5 THRU AS-BUILT ROUTING IN CRTS. M81Y5 AND M81J1 NOT SHOWN BY CRTS- ' AND OMITS VIAS M8181, M81M1, AND M81L1. ~ 40 S-6991 CABLES SY1DA621A, 1R1C215A2,'AND A' GUST 25, 1987 . ACCEPTABLE ALTERNATIVE. DC0 R-2119 ISSUED TO INCORFORATE CLOSED U 1T10A621C ARE ROUTED THROUGH AS-BUILT ROUTING IN CRTS. I CONDUIT A28031 VERSUS A28100. i N i m I ,e 4 + .=-i .T-" v e. d r-

Page No. 7 ATTACHMECT 3 ENCLOSCE TO GCA 88-136 02/29/88 CRTS RELATED NCRs REV. 3 j ITEF* NCR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION OPEN/ C2JM NUMBER CLOSED 41 S-6999 CLASS 1 POWER AND CONTROL CIRCUITS AUGUST 21, 1987 UNKNOWN. NCR DISPOSITIONED TO PROVIDE CLOSED ARE C XED WITH INSTRUMENTATION OEPARATION FOR ANALOG CIRCUITS AND CIRCUITS IN MNHOLES MH046 AND ACCEPT COMPUTER DIGITAL CIRCUIT MH047. INTERMIX. 42 S-7003 Cast.E 1M1A152F AS-BUILT ROUTING AUGUST 26, 1987 ACCEPTABLE ALTERNATIVE. DC0 R-2132 ISSUED TO INCORPORATE CLOSED OMtTS VIAS L44V62 AND L448T1. AS-8UILT ROUTING IN CRTS. NEW PULL CARDS ALSO ISSUED. 43 S-7028 ONE CABLE ROUTED DIFFERENT THAN AS AUGUST 27, 1987 CONSTRUCTION ERROR. CABLE PULLED BACK AND ROUTED CLOSED SHOWN SY CRTS. THROUGH CORRECT VIA PER ECN R-2233. 44 S-7029 FOUR CABLES ROUTED DIFFERENT THAN AUGUST 31, 1987 ACCEPTABLE ALTERNATIVE. ISSUE NEW PULL CARDS FOR SIGdATURE CLOSED AS SHOWN SY PULLCARD. 8Y QE. 45 S-7042-CABLE II2U1081F ROUTED THROUGH SEPTEM8ER 4, 1987 ACCEPTABLE ALTERNATIVE, DC0 A-5415Y ISSUED TO INCORPORATE CLOSED - TRAYS 744V29 AND 743V29 AND OMITS AS-8UILT ROUTING IN CRTS. NEW PULL CABLE TRAY 744V30. CAROS ALSO ISSUED. 46 S-7044 CABLE 1218145A CRTS ROUTING OMITS. SEPTEMBER 5,1987 ACCEPTABLE ALTERNATIVE. DC0 R-2251 ISSUED TO INCORPORATE CLOSED TRAY M41P3. AS-8UILT ROUTING INTO CRTS. NEW PULL CARDS ALSO ISSUED. 47 S-7063 Cf.3LE ROUTING FOR 1P1800c OMITS SEPTEMBER 9,1987 ACCEPTABLE ALTERNATIVE. DC0 R-2252 ISSUED TO INCORPORATE CLOSED CABLE TRAY M43V11. A5-8UILT ROUTING INTO CRTS. NEW PULL CARDS ALSO ISSuf9 48 S-7071 CABLE 1RIC536FC CRTS ROUTING OMITS SEPIEMBER 9, 1987 ACCEPTABLE ALTERNATIVE. DCO'R-2293 ISSUEP TO INCORPORATE CLOSED CABLE TRAY M44AY1. AS-8UILT ROUTING INTO CRTS. HEW a PULL CARDS ALSO ISSUED. 4 c.

Page No. 8 ATTCCHMECT 3 ENCLOSLCE To GCA 88-136 02/29/GD CRTS RELATED NCRs REV. 3 ITEM NCR DESCRIPTION DATE DIRECT CAUSE CORRECTIVE ACTION OPEN/ CJM NLMBER CLOSED 69 S-7079 CABLE 1M1A151F ROUTED DIFFERENT SEPTEMBER 11, 1987 ACCEPTABLE ALTERNATIVE. DC0 R 2214. ISSUED TO INCORPORATE CLOSED FROM PULL CARD, E-1010, DCN AND AS-Bulti ROUTIES IN CRTS. NEW PULL CRIS. CABLE 1G1DGA2E PULL CARD CARDS ALSO ISSUED. DIFFERENT FROM AS-BUILT, E-1010 DCN, AND CRTS. 50 S-7097 JUNCTION BOXES H7J2738 AND H7J2739 SEPTEMBER 18, 1987 CONSTRUCTION ERROR. NCR DISPOSITIONED TO REWORK COVERS. OPEN HAVE THEIR COVERS AND LABELS NEW INSTALLATION CARDS ALSO INTERCHANGED. ISSUED. 51 S-7439 CLASS 1 POWER / CONTROL CABLE TRAYS NOVEMBER 19, 1987 UNKNOWN. NCR REQUIRES DISPOSITION. OPEN OVERFILLED IN EXCESS OF 40% USAR FILL LIMIT. 52 S-7440 INTERMIXING OF CLASS 1 DIGITAL N0/ EMBER 11,1987 ACCEPTABLE ALTERNATIVE. NCR DISPOSITIONED TO ACCEPT. . CLOSED INSTRUMENT CABLES IN CLASS 1 POWER / CONTROL RACEWAYS. 53 S-7490 DISCREPANCIES BETWEN CRTS AND DECEMBER 3, 1987 UNKNOWN. NCR REQUIRES DISPOSITION. OPEN AS-8UILT NOTED DURING MANHOLE WALKDOWN. 54 S-7533 CONDUlf CARDS ASSOCIATED WITH ECNs DECEMBER 16, 1987 UNKNOWN. NCR REQUIRES DISPOSITION. OPEN A-2980 AND A-3065 WERE RETURNED. WITHOUT BEING SIGNED BY THE FIELD ENGINEER OR BY QC.

Enclosure To GCA 88-136, Page 1 CRTS ACTION ITEM COMMENTARY ITEM NO. 1 DESCRIPTION Demonstrate that the CRTS recorded cable locations match the as-built configuration. COMMENTARY CHRON0 LOGY Employee allegations and statements as early as 1983 indicated possible deficiencies in the CRTS data with the possibility of both missing and inaccurate information. SHUD Nuclear Engineering Department [NE0] actions were pulled together into a single Action Plan in January 1987. SMUD IIRG assumed responsibility for the root cause analysis of the CRTS problems and relea ERs in April 1987. l In July 1986, NED authorized a contractoe [Impell] to institute a review and evaluation of the CRTS program which would identify data j discrepancies, evaluate and document their significance, and report to SMUD. Approximately 43,000 manhours were expended on this effort through j 1987 and work will continue through the Cycle 8 Outage. Completion of i this effort is Item 2 of the CRTS Action Item List. l In early December 1986, NED made a decision to signal trace a sample of safety-related cables installed from 1975 through 1986. This program is i detailed in the Sample Plan LAppendix (1)]. The plan is designed to statistically ensure that the overall quality level achieves at least a 95% compliance with a 95% confidence level. A decision was also made not to signal trace a sample of the original 14,000 cables on the basis that the original designer / constructor Bechtel Dower Corporation [BPC) had exercised an acceptable level of control. The supporting rationale for this decision is referenced in Item 7. By late June 1987, the finding of ten major defects in Lot 1 initiated a complete inspection of all 397 cables. Cable tracing was completed on December 8,1987 with 152 completely checked and 245 inspected in the rerouted portions. Twc additional major defects were identified as described in NCR S-0884, bringing the total number of Lot i defects to twelve. During the final checking and revision of the Sample Plan LAppendix (1)] cables deleted from the plant [after the populations were established] were deleted from each lot, as follows: Lot i Lot 2 Lot 3 Lot 4 j Was 422 1702 190 78 Is 398 1434 183 78 i

. Enclosure i To GCA 88-136, Page 2 ITEM N0. 1 CONTINUED Additionally, in Lot.2, 76 Class 2.[ Appendix R] cables and 3 Class 1 [ Appendix Rj caoles were found to be pre-commercial operation vintage. Seventy-nine pre-commercial cables were deleted from Lot 2. Three of the 76 were included in the Lot 2 inspection total of 91. Three more cables were traced in Lot 2 in December and were found to be correct [no defects). Final inspection totals ~and statistical inferences are given-in Table 1 of the commentary to CRTS Action Item 28. Sampling of Lots 2, 3, and 4 is complete. Appendix 1 [SMUD Calculation Z-ZZZ-E0694] was revised to remove ' deleted cables and also to remove 79 pre-1975 vintage Appendix R cables from Lot

2. The revised [and final) totals for inspection are given in the comentary to CRTS Action Item 28.

Population Lot 4 consists of a group of 78 cables which were all signal traced. This was done because the signal tracing uncovered seven Appendix R cables which were documented as rerouted from Fire Area 36 to Fire Area 31 This actually had not been done as described in LER.87-13. These cables were part of the group.of 28 cables installed under one ECN. This group includes the seven cables found with incorrect routes in LER 86-10. All cables in this group [28] have now been traced with the fourteen cables described having incorrectly recorded routes. The direct and root causes of LERs 86-10 and 87-13 have been addressed by the SMUD IIRG. See the Item 4 coriaentary. GENERIC IMPLICATIONS With the completion of the Sampling Plan activity, SMUD has established a 95% confidence that the CRTS database is 95% accurate with respect to the location of the 2034 safe shutdown / safety-related cables installed from 1975 through 1986. This is viewed by SMUD as acceptable and comparable with industry norms as described in the commentary to CRTS Action Item 28. The SMUD evaluation of the level of control exercised in installing the j original le.000 cables indicates a level of confidence at least equal to 1 the 95/95 target for the 9000. See Item 7 of the CRTS Action Item List. New procedures and planned CRTS enhancements will be adequate to control the validity of CRTS as-built data. The completeness issue concerning CRTS data is a separate question and is addressed in Items 10, 11, 12, 13, and 14 of the CRTS Action Item List.

~. Enclosure To GCA 88-136, Page 3 ITEM N0. 1 CONTINUED CAUSES The-root cause of the problems related to the CRTS and its use is that neither Nuclear-Engineering management nor the CRTS Supervisor were adequately involved in the CRTS. Root Cause evaluations are referenced in the comentary to CRTS. Action Item 4. Corrective actions are described in the commentary to CRTS Action Item 29 and are reviewed against Root Causes in the commentary to CRTS Action Item 30. From the sampiing plan results the as-built record appears adequate. CORRECTIVE ACTIONS The current process mandates that the installation of. safety cables LClass l_ and Appendix R3 is witnessed by the'QC inspector. This corrects - a major deficiency in past practice. A new procedure, NEAP 4127, "Cable and Raceway Tracking System," was issued June 15, 1987 and revised December 14, 1987. The procedure controls the methods by which changes are made to the CRTS database and.the issuance and processing of all installation cards. Corrective actions have been reviewed against the IIRG root cause evaluations [See the comentary to CRTS Action Item 30].

4 Enclosure To GCA 88-136, Page 4 ITEM N0. 2 CESCRIPTION Resolve all CRTS database discrepancies. COMMENTARY CHRON0 LOGY Since July 1986, a SMUD contractor (Impell] has been performing a review. and evaluation of the CRTS data for the total population of 23,000 cables. This review has been conducted under control of the Impell-QA Program and all results have been documented and submitted to SMUD for acceptance. Progress reports have been issued, the most current of which is Report No. 25 dated October 9,1987. The large number of discrepancies reported is not a cause for concern. Many are not real discrepancies, but are bookkeeping corrections. Still others are caused by incorrectly applying current criteria to cables which were installed to older criteria. These discrepancies are, therefore, incorrectly reported, and no discrepancy actually exists. The Class 1 and Appendix R discrepancies were reviewed, evaluated, and dispositioned with documentation. Class 2 and Class _3 discrepancies will be dispositioned in the same manner af ter restart, but before the end of the Cycle 8 outage. GENERIC IMPLICATIONS Each discrepancy has to be evaluated separately. The evaluations may be sumarized as follows. Note that the Action Plan totals have, in some cases, changed as indicated: Class 1, Item 1.0 - Intermixing of Class 1/2/3 Cables (Total 763) None of the 763 discrepancies are valid. - The totals are as follows: 669 Are part of the 14,000 original cables and are correctly installed. This is because the original criteria allowed mixing, provided that no Class 2/3 cables bridged redundant Class 1 separation groups. 82 Are either deleted or are routed in special raceways so that no mixing occurs. 12 Were installed post-1975, but under the original plant criteria. All may be grouped with the 669.

. Encl osure-To GCA 88-136,, Page 5 ITEM N0. 2 CONTINUED Class 1 Item 2.0 - Overfilled Trays (Power and Control) Total 38 The 38 cable trays were reviewed to oetermine their fill at the time of-commercial operation and their current fill,'with the results given below. The~ 38 were checked for both ampacity derating and 'for weight. EE-553-CRTS EE-553 CRTS 10/14/75 02/26/88 10/14/75 02/26/88 Tray- '%~ Fill % Fill Tray % Fill % Fill L43AZ3 44 37 M41F1 36 35 L44AK1 45 43 M41G1 34 36 L44AU1 41 37 M41 H4 36 32 L44BF1 36 34 M41M3 42 39 L44BM2 17 39 M41 P1 34 36 L44BN2 34 42 M41X1 39 39 L44BY3 47 39 M41 Y1 39 39 L44CF1 45 42 M4121 31-37 L44P1 39 35 M43V10 47 33 L44P2 39 40 M43V11 34 34 L44V36 49 38 M44A31 39 35 M39BA7 40 35 M44AY1-34 35 M40AM2 36 38 M44AY4 49 44 M40AQ2 37 38 M44V10 61 49 M41 AA1 30 33 M44V11 36 40 M41 AD) 34 37 M44V70 38 36 M41 AE1 32 34 M4581 48 40 M41 AT1 32 34 M45V10 38 35 M41B01 35 31 M45V8 48 31 An issue raised by the Resident NRC Ir oector concerned the documentation of ampacity and weight checks. The specific question was, "Did SMUD perform 10CFR50.59 reviews of overfilled trays?" The review process for tne original 14,000 cables and the later 9,000 added cables was as follows: Original Installation Power and control cable trays filled in excess of 40% were checked to verify that the cable loading was not in excess of 50 pounds per linear foot. Instrumentation cable trays filled in excess of 60% were checked to verify that the cable loading was not in excess of 50 pounds per linear i foot. Instrumentation cable tray fill between 40% and 60% was accepted ) based upon a generic calculation. In addition, ampacity checks were made on all power and~ control cable trays filled in excess of 40%. No documentation of the design checking.nas been found in Bechtel or dMUD fil es. Retention of sucn documentation was not a common practice. As detailed later in this commentary, all fills and weights have now been checked and documented.

Enclosure To GCA 88-136 -, Page 6 ITEM NO. 2 CONTINUED Cables Installed After Commercial Operation Power and control cable trays filled in excess of 40% were dispositioned as described for the original installation, the cable loading was verified to be less than 50 pounds per linear foot, and the ampacity was checked. The results were not documented by calculation, and no formal reviews were performed te verify that weight limits were met. Instrumentation cable trays filled in excess of 50% were checked to verify that the cable loading was not in excess of 50 pounds per linear foot. Instrumentation cable tray fill between 40% and 50% was accepted based upon a generic calculation. The results of the instrumentation cable tray weight checks were also not documented, and no formal 50.59 reviews were performed. Resul ts By July 1,1987, all cable trays and conduits had been reviewed for fill and for weight problems. Percent fill is a feature of the CRTS program. Weight calculations were performed by a separate program run on a PC using data dumped from the main computer. Results are as follows: Instrument Tray Fills The USAR limit is 40% versus the Nuclear Engineering design criteria which has a 50% fill limit for instrument cable trays. All trays have been checked for weight, regardless of fill level. No trays were found to exceed the USAR limit of 50 pounds per linear foot. Visual checks are being performed for heaped or mounded conditions indicating possible problems during a design basis earthquake. At this time, no significant problems have been found. The USAR fill limit will be changed, (see CRTS Action Item 17]. Power and Control Tray Fills The USAR limit is 40%. All trays have been checked for weight, regardless of fill level. One Class 2 cable tray is overweight by 1.16 pounds, assuming that the cables in the tray run the entire length of the tray. However, because cables enter and leave.the cable tray along the length of the tray, in no case is the cable tray support loading in excess of 50 pounds per linear foot. In order to resolve the apparent overweight and 1 to allow future cable additions to the tray without having to revise i calculations that justify the adequacy of the cable tray, the cable tray was made into two cable trays by ECN R-2015,' issued on October 2,1987. No other trays have been found with real fills in excess of 50 pounds per linear foot. A few additional false fills have been found and were corrected. False fills occur when long tray sections includo all cables in the weight calculations and exceed 50 pounds per linear foot, even if some of the cables only run a short distance in the raceway section. whereas, the weight borne between supports does not exceed 50 pounds per j i

Enclosure To GCA 88-136, Page 7 ITEM N0. 2 C_0NTINUED linear foot. Documentation is provided by Impe11 under Task 334. Ampacity checks have been made on all power and control cable trays with fills in excess of 40%. No ampacity problems have been found. Suninary of Overfilled Tray Review No significant problems have been found to date. Final checks are required to check special conditions to verify that their impact is minimal: Weight contribution from telephone / security cables. Weight contributions from fire wrapping and cable tray covers. The final cable tray checking, to be performed prior to restart, was performed on December 28, 1967. Only one cable tray exceeds the 50 pounds per linear foot limit (X44RFI] and this tray is acceptable, since it is at grade elevation and is supported by concrete pads. Causes of Overfilled Trays No significant problems have been found, and there appears to have been a reasonable degree of conservatism in the original design. Nevertheless, the lack of documented reviews in the period 1976 to 1986 is an omission in the design process which should not have occurred. The direct cause was a lack of procedural guidance. Enhancements planned for the CRTS software will, in the future, automatically block cable additions which exceed fill and weight limitations. Class 1, Item 3.0 - Overfilled Conduits (Power / Control) (Total is 108, Was 107) All 108 are either incorrectly recorded fills because the as-built conduit is larger than recorded, or are acceptable for other reasons such as very short length. Quite obviously, conduits cannot easily be overfilled, unlike trays, and all 108 have documented dispositions indicating a complete lack of either fill or ampacity problems. Class 1, Item 4.0 - Overfilled Conduits (Instruments) (Total is 14, Was 13) All 14 are dispositioned as false fills or similar. No ampacity problems exist witn instrument cables. Class 1, Item 5.0 - Raceway Connections (Total is 293, Was 200) The CRTS program establishes linkages or nodes to chect that connecting raceways in cable vias do, in fact, connect. When nodes are missed by designers making the drawing changes, each missed node generates a oiscrepancy report for each cable usirg the via. All missing nodes have been checked and the bookkeeping errors corrected.

Enclosure To GCA 88-136 Attachinent 4, Page 8 ITEM NO. 2 . CONTINUED Class 1, Item 6.0 - Duplicated Numbers (Total is'2, Was 35) These are two bookkeeping errors, both of which have been dispositioned as having no significance. Class 1, Item 7.0 - Document Discrepancies (Total is 555, Was 551) The 555 are a miscellany.of minor data discrepancies dealing with entries covering equipment numbers, raceway numbers, cable codes, cable data (conductor size / number), and others. All have been checked and the data corrected as needed. No data questions remain open. Class l', Item 8.0 - Tagging / Identification Discrepancy (Total is 0, Was 7) The original seven items are now reported in the Item 5.0 totals. Class 1 Item 9.0 - Missing / Unsigned Construction Cards (Total is 114, Was 53) The total of 174 missing / unsigned Class 1 cards is made up [Ref. Impell Calculation 271-101-107) as follows: NCR #

of cards Problem Status WH 41 Class 1 raceway cards w/o sig Open S-6549 26 Class 1 pull cards w/o sig Work Request w/Elec Maint S-6547 15 Class 1 term cards w/o sig Closed 11-27-87 S-6459 59 Class 1 raceway cards w/o sig Open 28 Resolved in calc 271-101-107 Closed 04-15-87 5

Terminations included in error N/A in calculation 271-101-107 Total 174 For the 26 Class I missing cable pull cards in NCR S-6549, replacement cards were generated after the cables were checked against the design documents. The other open items (NCRs S-7533 and S-6459) associated with missing tennination/ raceway cards will be completed before the end of the-Cycle 8 outage. The microfilming process Ldescribed on page 11 of. J is largely complete with about 8000 cards left to mic rofilm. The work nas, so far, found approximately 100 cards which are missing signatures. Of these, thirteen [13] are Class 1 and are listed on an NCR for disposition by the end of Cycle 8 Outage. i l

Enclosure To GCA 88-136, Page 9 ITEM'NO. 2 CONTINUED The following Non-Class 1 discrepancies have all been dispositioned without finding any safety problems. Non-Cla:.s 1, Item 1.0 -Intermixing of Pos.er/ Control / Instrument Cables TToTil i.s 400; was 125) The USA 1 wording requires separation of instrument cables from power and. contrc!. cables for RPS and SFAS. USAR does not clearly address mixing for other systems and does not address or define what constitutes instrument, control, end power cables. StiUD Nuclear Engineering Procedures (NEP's, Criteria and Guides) also did not clearly oefine instrument, control,- and power cables.

However, various types of signals (analog, digital) were discussed, and digital signal cables are oermitted to mix with control cables.

The NEPs have betn revised to define the separation required between instrument and power and/or control cables and to define the instrument circuits requiring seoaration. Details are given in the commentary in CRTS Action Item 9. The 400 reported Non-Class 1 mixes have been dispositioned as follows: 367 Accepted as meeting NEPs. 16 To be rerouted. 17 Which require drawing cnanges to clarify service level. 400 Total The original design process used twisted shielded pair (TSP) or coax /triaa I cables for all circuits considered as instrumentation. This has led to some confusion, since'no cable service levels are established in CRTS. A future CRTS enhancement will identify service levels for all cables, j i Non-Class 1, Item 2.0 - Overfilled Trays (Power and Control) (Total is 153, Was 131) All trays have been checked for weight. Only one tray exceeded the 50 pounds per linear foot USAR limit, as discussed previously. Ampacity checks have been made on all cable trays with fills over 40%. No ampacity problems have been found. Non-Class 1, Item 3.0 - Overfilled Trays (Instrument) (Total is 18, Was 19) All trays have been checked for weight. None exceeds the 50 pounds per-linear foot USAR limit.

Enclosure To GCA 88-136 l, Page 10 ITEM N0. 2 CONTINUED Non-Class 1, Item 4.0 - Overfilled Conduit (Power and Control)'(Total-is-644, Was 039) All 644 are either incorrectly recorded, because the as-built conduit is larger than recorded in CRTS, or are acceptable for other reasons. f40 ampacity problems exist. Resolution of Minor CRTS Data Discrepancies A number of minor Non-Class 1 data discrepancies exist as reported. -in Impell Task 271 Status Report 9, dated January 12, 1987. These are. sunaarized below.. None have any safety significance. These data discrepancies will be resolved af ter restart but not later than the Cycle 8 scheduled outage. Non-Class 1 1.0 Overfilled Conduits (Instrument / Telephone) 151 2.0 Raceway Connections 1390 3.0 Duplicated Numbers 33 4.0 Document Discrepancy 1594 5.0 Tagging / Identification Discrepancy 130 6.0 Missing / Unsigned Construction Cards 92 Subtotal 33W Securi ty 7.0 Raceway Connections 177 8.0 Duplicated Numbers 29 9.0 Documentation Discrepancy 276 10.0 Tagging / Identification Discrepancy 4 11.0 Missing / Unsigned Construction Cards 88 Total 3T64 Causes of Discrepancies The enhancement of the CRTS software generated the list of discrepancies. The direct cause of the discrepancies was the database conversion and errors entered into the database in the 1980 to 1982 timeframe. The root i cause of the CRTS problems has been determined by the IIRG. The level of l control exercised is addressed in Item 4 of the CRTS Action Item List. CORRECTIVE ACTIONS Major [ safety-related] discrepancies were reviewed and dispositioned, with documentation, prior to restart. Minor [non-safety-related] discrepancies will be reviewed and dispositioned, with documentation, prior to the end of the Cycle 8 outage. Disposition of each discrepancy includes verification that plant design documents, the CRTS database, and the as-built plant configuration are all in agreement.

Enclosure 'To GCA 88-136 -Attachment' 4, Page 11 ITEM N0. 3 DESCRIPTION Define SMUD document of record controlling cable location. . COMMENTARY CHRON0 LOGY In a January 7,1987 meeting, the Region V Electrical Inspector (Mr.' Andy Hon] asked where cable pull cards are now kept and what will be done with cable pull cards in the future. To answer the question concerning SMUD future actions required defining the SMUD document of record for cable locations. Answers to the two original questions and the additional definitions are as follows: 1. NRC Question: Where are cable pull cards now kept [ January, 1987]? District Response: The cable pull cards, together with equipment and raceway installation cards, were kept in either locked metal card files in an office area of the Bechtel Building, which is a temporary on-site construction office, or in boxes in trailers used as temporary offices. 2. NRC Question: What will be done with cable pull cards in the future [After January,1987]? District Response: The cable and raceway installation cards are now being kept in a vault in the Bechtel Building. The record documents are a mixture of original cards and facsimiles when the originals cannot be found. The vault is a secure, locked room with cement walls and a Halon fire protection system. At this time, records are being checked to see how many cards are missing. When original cards are not found, facsimiles from the construction records will be substituted to create a complete record. A duplicate record is being created on microfilm. As of December 31, 1987 approximately 29,000 cards have been microfilmed and returned to the Bechtel Building vault. This process will continue until a complete duplicate record is established.

Enclosure To GCA 88-136, Page 12 ITEM'NO.-3 CONTINUED ADDITIONAL INFORMATION 1. INSTALLATION VERIFICATION RECORDS FOR INSTALLED CABLE AND RACEWAY The present installation verification records for installed cable and raceway are the pull cards, termination cards, and raceway installation cards, respectively. Replacement cards for all Class 1 and Appendix R missing pull cards (97 cards) were generated through disposition of NCRs. All Class 1 and Appendix R pull cards with missing QC signatures will be completed by the end of the Cycle 8 Outage. Full details of missing cards (all types) are given in Section 4 of this commentary. 2. ENGINEERING RECORDS FOR DESIGNED CABLE AND RACEWAY These records are the input oocuments to the CRTS program. They are designated as "forms" and are engineering drawings by SMUD definition. i Originally, new forms were issued for changes. As of June 15,1987, all new cable and raceway input documents have been handled as Drawing Change. Notices. Originals of input documents are being marked to show changes instead of issuing new forms. [ Reference memo EEGS 87-005, f rom E. J. Gough to the Electrical Engineering staff, dated May 1,1987) CRTS input drawings / forms are as follows: E-1008 Raceway Input Document 5-1010 Scheme Cable Input Document E-1026 Raceway Code Input Document E-1027 Cable Code Input Document E-1028 Electrical Equipment Input Document 3. CRTS PROGRAM AND DATA BASE The function of the CRTS program and database is twofold: I a. An engineering design tool which is used by the design group to perform design checks and calculations. Currently, the CRTS program checks for: Raceway continuity Percentage fill Mixing of redundant separation channels Verifies raceway service levels for compatibility The CRTS is being enhanced to perform: Weight calculations Checks on mixing of instrument cables with power and control cables ~

Enclosure To GCA 88-136 l l

Attachment:

4, Page 13-ITEM NO.'3 CONTINUED -b. A convenient data source wh,ich is used-for. engineering design in formation. Typical uses of the CRTS generated information are: Identification of cable routes Calculation of totals of combustible materials (Btu totals) Weight calculations for cable tray sections c. Installation Status. 4 GENERIC IMPLICATIONS Plant cables provide many diverse functions. The cables of safety systems provide both power supply and control functions, as well as important indications to operators. The control and separation of redundant safety groups of cables and of all cables required for safe shutdown are important safety factors. The existence of reliable and accurate records concerning the location of the cables is essential to plant safety. With the completion of the Action Plan, SMUD will have established a record file of installation cards (originals and facsimiles) and a duplicate microfilm record. SMUD will also have confirmed that the CRTS database is accurate to an acceptable confidence level. With adequate maintenance of both records and CRTS data, the necessary level of control will exist. CAUSES Difficulties in tracing records indicate a need for greater management interest in record storage and an increased awareness on the part of SMUD employees of the importance of records. CORRECTIVE ACTIONS Current Process: NEAP 4127, "Cable and Raceway Tacking System," was issued on June 15, 1987 and revised on December 14, 1987. This procedure is considered adequate to ensure that all cards are returned to CRTS. Replacement Cards: The detailed procedure for the replacement of missing CRTS cards was provided in Revision 1 to NEAP 4127, effective December 14, 1987. 4. TOTAL NUMBERS OF MISSING CARDS The following are details of missing cards as of February 29, 1988:

Enclosure To GCA 88-136, Page 14 ITEM NO. 3 CUNTINUED Cable Raceway Tracking System (CRTS) ANALYSES OF FORMER 2,397 MISSING CABLE INSTALLATION CARDS February 29, TW Nuclear (l) Nuclear (2) Both(3) (4) Operation Engineering Depts. Pre-ECH Total Missing Cards 1170 = 49% 1039 = 43% 33 = 2% 155 = 6% Pull Cards 178 = 7% 204 = 8% 17 = 1% ll = 0.4% From Termination Cards 483 = 20% 245 = 10% 8 = 0.5% 20 = 1% To Tenaination Cards 450 = 19% 285 = 12% 8 = 0.5% 20 = 1 % Delete Cards 59 = 3% 304 = 13% 0 = 0% 104 = 4% Total Cables in Data Base (CRTS Revision Level 1810) 22,803 Total Cables Having Missing Cards 1,41 2 Fraction of Cables Having Missing Cards 6.19% Total Missing Pull Cards (Prior to Restart Dispositions) 410 = 17% Total Class 1 and Appendix R missing cards were 146 cards (previously reported as 183). Af ter analyses, 97 replacement cards were made in accordance with NEAP 4127. Af ter analyses, 49 alleged missing cards needed no replacement. (Cables were spare or non-fire protection, or original pull cards were found). Net Remaining Pull Cards (410 - 146) 264 = 11% (Nont; Class 1 or Appendix R) Total Missing Termination (From and To) Cards 1,519 = 63% Net Remaining Missing Termination C:rds (1519 - 165) 1,354 = 56% Total Missing Delete Cards 468 = 20% Net Re:::aining Missing Delete Cards (468 - 7) 461 = 19% Former Total Missing cad 1e Cards 2,397 = 100% Missing Cards Dispositioned Sir,ce Last Report 318 = 13% Current Net Missing Cable Cards _, 2,079 = 87% (1) Nuclear Operations (NO] initiated ECN. (2) Nuclear Engineering [NE) initiated ECN. (3) N0/NE jointly initiated ECN. (4) Propo ed cables entered 1976-1980, no ECN.

Enclosure To GCA 88-136, Page 15 ITEM N0. 4 DESCRIPTION Document the level of control exercised by SMUD in installing cable 1975-86. CHRONOLOGY Questions concerning the completeness of CRTS data, missing installation cards, and conflicting procedures have been raised beginning in 1983. The existence in 1978 of Quality Control Instruction QCI 107, which required the destruction of installation cards, raised questions concerning records. Employee allegations and statements to.the SMUD Ombudsman also tended to indicate some possible proDiems in controlling the installation process. LER 86-10 identified seven Appendix R cables which should have been relocated but were not. The SMUD IIRG has completed their investigations and forwarded a sumary of their Root Cause Reports in DTS 87-103 dated November 9,1987. CRTS ACTION DESCRIPTION FORECAST ITEM 23 Determination of the cause of the redundant Complete cabling in same fire area (LER 86-10) and the determination of the cause of redundant instrument cables routed through same fire area (LER 87-13). 25 Document a thorough engineering evaluation Compl ete of the procedures and specifications used to install cable in the period 1975-1986. 26 Description of the events and LER 85-16 Complete circumstances leading to the LER 86-10 Compl ete misrouting of cable described LER 87-13 Complete in LERs. LER 87-26 Compl ete 27 Description of the events and Complete circumstances leading to the discrepancies discovered between the as-built cable routes and the routes recorded in CRTS. Rafer to Appendix 5 for a sumary of the Root Cause investigations.

Enclosure To GCA 88-136 'l,.Page 16 ITEM N0. 5 ' DESCRIPTION Demonstrate that no Bechtel' generic design prob'em existed. COMMENTARY - CHRON0 LOGY With the discovery of a misrouted RCS pressure transmitter instrument cable as being a possible cause of the August and December 1985 spurious closures of the Decay Heat System (DHS) valve HV-20002 -(LER 85-16), and the further identification that the misrouting of the instrument circuit occurred during the original design of the plant, investigation of the original cable population was begun for any evidence of a generic design probl em. GENERIC IMPLICATIONS The original Rancho Seco cable population consisted of nearly 14,000 cables, routed in 13,000 raceways. The original Rancho Seco EE-553 circuit and raceway schedules were reviewed for any evidence of a generic design problem in the original cable population. Since the present CRTS database has been reviewed for raceway fills and weights, channel separation and channel bridging, and would have identified any such problems in the original caole population, only intermixing of power, control, and instrumentation cables was examined in the original cable popul ation. The EE-553 raceway schedules were reviewed for any indication of a generic problem concerning power / control / instrumentation intermixing. Approximately 3200 pages were manually reviewed, representing approximately 13,000 raceways. Approximately 10 cases of Class 1 intermixing were identified and approximately 60 cases of Non-Class 1 intermixing were identified (Table 1), with no evidence of a generic intermixing problem. It should be noted that of the 10 Class 1 cable intermixes, that 8 no longer exist in the plant. The remaining 2 cables provide tachometer indication signals to local panels of the Bruce GM Diesels [ Reference Drawings E204 sheet 65 and E334 shcets 1, 4, and 5] and have no safety features actuation or reactor protection function. The Class 2 Appendix R cables listed in Table 1 have been reviewed. On the basis of this review, the Class 2 control cables 1M2C3271, IM202280, and 1M202290 are the only Appendix R circuits. These cables are routed in a four-foot long, Non-Class 1 instrumentation tray X45V20 to test panel H3TP.

. Enclosure To GCA 88-136, Page 17 ITEM NO. 5 CONTINUED i The distance [4 feet] and the shielding on the low level instrumentation cables indicate no unacceptable cross-coupling [ noise]-is possible to the control cables. The converse is also' true and the Class 2 shielded i instrument circuits will not see unacceptable noise levels. Therefore, the above cables can remain as routed and no corrective action is requ'i red. The remaining Non-Class 1 cables will be reviewed by the end of the Cycle 8 outage. CAUSES Both the FSAR and USAR require separate cable tray, conduit, and penetration systems for 600-volt power and control cables and for instrumentation cables. The cable scheme numbering system used at Rancho Seco requires a "1" in the first location of the cable scheme number to designate Rancho Seco Unit 1. A digit in the second location of the cable scheme number designates a power cable; a letter in the second location of 1 the cable scheme number designates either a control cable or an instrumentation cable. Without a method to differentiate the scheme cable i number of a control cable from that of an instrumentation cable, intermixing may have occurred. CORRECTIVE ACTION Upon the consolidation of SMUD efforts to resolve Rancho Seco wire and cable problems ( Action Plan, JEW-478, April 3,1987), Bechtel was asked to review the 1975 cable and raceway schedules fir any evidence of a widespread problem concerning the intermixing of power, control, and tstamentation cables. The intermixing of instrumentation cables in rwar and control raceways was identified by examining the 1975 EE-553 rian schedules for any shielded cables in power and control raceways. in order to identify the power and control cables intennixed with intrumentation cables in instrumentation raceways, the 1975 EE-553 raceway schedule was examined for non-shielded cables in instrumentation raceways. The results are given in Table 1. In order to prevent any further occurrences of power, control, and instrumentation intermixing, SMUD has directed, by memo, that an additional column be added to the 1010 drawings and DCNs to indicate the service level of the cable being added. For each added cable, the new column will indicate either P, C, or I for power, control, or instrumentation service, providing the physical designer with the necessary information to properly route newly added cable. [ Reference memo EEGS 87-006, from E. J. Gough to the Electrical Engineering staff, dated May 4,1987. ] Additional service level designators are under consideration and include T [ Telephone], S [ Security] and IE [ Instrumentation - Exempt - may mix with P and/or C cables]. ] l l i )

Enclosure To GCA 88-136, Page 18 ITEM N0. 5 CONTINUED Table 1 Original Cable Population Power / Control / Instrumentation Intermixing Class 1 Intermixing Power Cable in Instrumentation Raceway None Control Cable in Instrumentation Raceway IM1 A1310

1M1 A131 E
IMlB1390
IMIB139E
Instrumentation Cable in Power and Control Raceway 1GlQ886CS 1GlQ686DS 1 RIC260AA
1RIC260AB
1RIC260.r.*

1RIC260BB

Non-Class 1 Intermixing Power Cable in Instrumentation Raceway ll2E07A ll20SIGC
112SDPS6A
ll2EllD ll 2GSI GF
ll2SDPSlB
112EllE ll2GSIGG
112SDPS2B
ll2E09CN ll2JllEA
ll2SDPS3B
ll2E09CO 112SDPS1A
ll2SDPS4B
ll2E0901
ll2SDPS2A
112S0P553
ll2F15Z ll2SDPS3A
112SDPS6B
112GSIGA
112SDPS4A
1120230B 112GSlGB
ll2SDPSSA
113C109A
Cable deleted, no longer installed in plant

Enclosure To GCA 88-136, Page 19 ITEM NO. 5 CONTINUED Table 1 (cont. ) Control Cable in Instrumentation Raceway 1A3A26503 II28360CA 1M2C327I 1A38470A1 II28360T 1M202028

1A38470A2 II2B365CA iM202241 1A38470A4 lI28365X 1M202280 1A3P20082 II2G996D 1M202290 1A3P20086 112N150LF lH2E203B
1A3X5208 1A3X520H Instrumentation Caole in Power and Control Raceway 112G201 112R3018 1 R214608 112G202 112Rb20AB IR2PBTPA 112G203 II2R520AF 1R2T250A II2G204 II2R620AJ II2G417 II2R532AB
Cable deleted, no longer installed in plant

Enclosure To GCA 88-136, Page 20 ITEM N0. 6 DESCRIPTION Resolve overfill / overweight questions; including USAR and 50.59. COMMENTARY . CHRON0 LOGY In February 1986, ODR 86-125 was prepared as a result of an investigation following allegations of raceway overfilling. The 00R examined instrument cable tray overfilling, because instrument trays are filled to a higher level than power and control trays, and determined that for the cable tray with the highest fill, that the cable loading did not exceed 50 pounds per linear foot. In addition, it was verified that _the actual cable tray loading was used in the fire hazard analysis and also that the cable tray heat derating was acceptable with respect to the cable ampacity. As a l result of the above investigation, 38 Class 1 overfilled trays and 150 Non-Class 1 overfilled trays were identified and subsequently reviewed for overweight, as described in the commentary to CRTS Action Item 2. DDR 87-204 was initiated in February 1987 as a result of concerns that cable trays witn fills less than 40% might, in certain unique circumstances, exceed the cable loading of 50 pounds per linear foot. LER 87-24 was also initiated to determine the reportability of the identified problem. GENERIC IMPLICATIONS 2 The Rancho Seco USAR limits the fill of redundant cable trays to 40%, so as not to exceed the cable loading of 50 pounds per linear foot used in the cable tray support design. Cable trays do exist whose fill exceeds 40% and were dispositioned during the original design process. Power and control cable trays filled in excess of 40% were checked to verify that the cable loading was not in excess of 60 pounds per linear foot. In addition, an ampacity check was perforned. Instrumentation cable trays filled in excess of 60% were checked to verify that the cable loading was not in excess of 50 pounds per ifnear foot. Cable tray fill between 40% and 60% was accepted cased upon a generic calculation. Altnough the above calculations were performed during the original design process, the calculations have not been found.

m, e

Enclosure To GCA 88-136, Page 21 ITEM N0. 6 CONTINUED Power and control cable trays filled in excess of 40% after comercial operation were dispositioned as described for the original installation. For instrumentation cable trays filled in excess of 50%, the cable loading was verified not to exceed 50 pounds per linear foot. The results of the weight checks performed after comercial operation were not documented, and no fonaal 50.59 reviews were performed. As of May 1987, all cable trays have been reviewed for fill and weight problems with only one Class 2 power and control cable tray requiring physical modification as described in the commentary to CRTS Action Item 2. The USAR limit is 40% for power and control tray fills. All trays have been checked for weight (regardless of fill level). Only one tray has been found with an apparent fill in excess of 50 pounds per linear foot requiring pnysical modification. False fills have been found where a long tray section includes all cables in the weight calculations (and exceeds 50 pourids per linear foot), whereas the weight borne between supports does not exceed 50 pounds per linear foot. Ampacity checks have been made on all power and control cable trays with fills in excess of 40%. No ampacity problems have been found. The USAR limit is 40% for instrument tray fills and is at variance with the Nuclear Engineering criteria which has a 50% fill limit for instrument cable trays. All trays have been checked for weight (regardless of fill l evel ). No instrumentation trays were found to exceed the USAR limit of 50 pounds per linear foot. Visual checks are being performed for heaped or mounded conditions indicating possible problems during a design basis eartnquake. At tnis time, no significant problems have been found. ihe USAR wording will be revised, [see commentary to CRTS Action Item 173, and the fill limits will be defined in the NEPs. In summary, no significant problems have been found to date. Final checks on weight contributions from telephone / security cables and weight contributions from fire wrapping are required to verify that their impact is minimal. l l 1 y a r

Enclosure To GCA 88-136 i, Page 22 ITEM NO. 6 CONTINUED CAUSES As evidenced by the-discovery of only one apparent problem concerning overfilled cable trays, the original 40% fill limit was a very conservative requirement in the original plant design. However, the absence of documented 50.59 reviews for those cable trays whose fill was exceeded [ post-comercial operation] is a cause for concern. The direct cause of both overfill and overweight conditions lacking the documentation validating their acceptability was a lack of procedural guidance. CORRECTIVE ACTION Immediate corrective action has been to review all cable tray weights regardless of fill level (see commentary on'CRTS Action Item 2]. Additionally, for new design work [added cables), all power and control trays which exceed 40% fill are checked for weight and ampacity; all instrument trays whose fill exceeds 50% fill are checked for weight. HEAP 4127 requires all DCNs which generate error reports (e.g., cable tray fills above 40%] to be referred back to NED for review and documented analysis. In addition, the 50.59 review concern was resolved through the NCR S-7439 disposition process. Until the CRTS sof tware is enhanced to provide automatic blocking of cable additions to specific raceways, those trays which require blocking are controlled by a list of controlled trays issued in ERPT-E0312 and referenced in Electrical Design Criteria E5104.2 on February 5,1988. The blocking of cable additions is not referenced in MP/IS 307 as stated in the Wire and Cable Program Report, Revision 4, because the cable blocking is a concern of design processing and should be controlled at the source during the design of the cable routing and during input into the CRTS data base. Issues to be resolved post-restart, but before the end of the Cycle 8 outage are as follows: Resolve the concern of security and comunication cables [ Class 2 and 3] on raceway fill and weight. Resolve the concern of firewrapped cables on raceway fill and weight. Resolve the concern of coiled cables not connected to equipment, on raceway weight. Resolve the concern of cable tray covers on cable tray weight.

q Fnclosure ~ To GCA 88-136, Page 23 1 ITEM N0. / DESCRIPTION JustitiGation for not sampling the original cable population. COMMENTARY CHRONOLOGY As a result of employee allegations as far back as 1983, and with the June 1996 identif ecation of seven misrouted. Appendix R cables, a decision was made in December 1986 to signal trace a sample of safety-related cables installed af ter commercial operation in 1975. The original cable population of 14,000 cables was excluded from the sampling plan because the design, installation, and inspection of the original cable population by Bechtal Power Corporation, Rancho Seco A & E and Constre. tor, was governed by a quality program sufficient to control the physical design and installation of the original cable population.

SUMMARY

e Justification 'or excluding tne original cable population was presented by SMUD during the June 1987 NRC utspection visit in ths ?;rm of-a report. The report, titled "Justification.cor Not Sampling The Original Rancho Seco Cable Population," was formally transmitted by GCA 87-338, dated July 24, 1987. The report demonstrates that Bechtel had in place and used a rigorous quality program suf ficient to cont.ol the physical design of the r"iginal cable population. In contrast to those cables installed after comercial operation, the original cable population was installed while tne pi ant.;as in a construction mode, under a uniformly consistent set of ruies sad proceduras. The procedures did not vary during the design, installation, and inspection of the original cable p1pulation and, as shown in A."pendix 3, these pr:cedures were rige.ousiy followed by a relatively stable and well-trained workforce. The justification for not sampling the original cable population was transmittcd by GCA 87-338, dit2d d'1y 24,1987, and is Appendix 3 to the Wire and Cable Program Report. P e e --,- ~

Encl osure ~ - To GCA 88-136, Page 24 ITEM NO.- 8 DESCRIPTION Resolve all known physical problems. COMMENTARY CHRON0 LOGY Physical problems'related to the Rancho Seco cable and raceway installation have been identified by LERs 85-16, 86-10, 87-13, 87-24, and 87-26. In addition, Impell, under Task 271, identified, witt documentation submitted to SMUD, additional CRTS database discrepancies, although not all are physical problems [See comraentary to CRTS Act00n Item

23. The identified physical problems are of the following types:

Overfilled /0verweight Cable Trays (LER 87-24) Refer to commentaries to CRTS Action Items 2 and 6 for discussion. Intermixing of Power / Control / Instrumentation Cables (LER 85-16 and 87-26) Refer to commertaries to CRTS Action Items 2, 5, and 9 for discussion. Lack of Configuration Control (LER 86-10 and 87-13) l-Refer to commentaries to-CRTS /.ction Items i, 4, and 23 for discussion. Lack of Redundant Class 1 Channel Separation l No identified problems of this type have been found to date. Lack of Class 1/Non-Class 1 Separation As described in the cocientary to CRTS Action Item 2, none of the 763 intermixes of Class 1, 2, and 3 cables is a valid discrepancy. The cables were either installed under the original plant criteria, wnich 1 allowed mixing, are deleted, or routed in special raceways so that r.o mixing occurs. CAUSES i Refer to cnamentary to CRTS Action Item 15, i e 4

Enclosure To GCA 88-136, Page 25 ITEM N0. 8 CONTINUED CORRECTIVE ACTIONS The following corrective actions have been taken to resolve known Rancho Seco cable and raceway pnysical problems, and to prevent their recurrence: Overfilled /0verweight Cable Trays Immediate correcti',e action taken as a result of 00R 86-125 and LER 87-24 was the review of all cable tray weights, regardless of fill level. As a result of the cable tray weight review, one Class 2 power and control cable tray was found to be overweight. ECN R-2015 was issued in Octobe-to divide the tray into two trays to resolve the apparent oven!eight. Corrective action to prevent recurrence has been the revision of procedure NEAP 4127, "Cable and Raceway Tracking System," effective December 14, 1987, to require that data contained in DCNs to CRTS-related drawings be error-free when input to the proposed CRTS database. Should an error report indicate an overfill condition, then the DCN is returned to the originator for resoluticn. In addition, the USAR will be revised to reconcile discrepancies in fill limits for inscrumentation cable trays to be consistent with NEP 5204.22, LSee coimnentary to CRTS Action Item 17). Intermixing of Power / Control / Instrumentation Cables Immediate corrective action taken as a result of tne identification of an SFAS instrument cable routed through power and control raceways in LER 85-16 was the review of the CRTS database for further intermixing [see commentary to CRTS Actior. Items 2 and 9), as well as the examination of the original cable population for a generic intermixing problem (see commentary to CRTS Action Item 5). The intermixing identified by LER 85-10 has been corrected by ECNs R-0459 and R-1295. Further intermixing has been identified by CRTS database reviews, as identified in LER 87-26, and by cable signal tracing as identified by 0DRs 87-604 and 87-723 and are corrected by ECNs R-1785 and R-1786. Sixteen Non. Class 1 interaixes requiring 1 relocation were identified by Impell as dor.umented by CPRs 0611, 610, 885, 638, 640. 622, 642, and CONS 584 and 742 contained in Impell Calculation No. 271-101-109, Rev. O. The Non-Class 1 intermixes will oe documented oy NCR and will be resolved prior to the end of the Cycle 8 outage. Corrective action to prevent recurrence of power / control / instrumentation cable intermixing has been the revision of Design Guides NEP 5204.22, "Cable System Design, General," and NEP 5204.43, "Instrumentation Systems shielding and Grounding and Surge Protection," to clearly define the

Enclosure To GCA 88-136 Attachment '4, Page 26 + ITEM NO. 8 CONTINUED physical separeti)n requirements for power, control, and instrumentation circuits and to provide definitions of the cable service levels [See commentary to CRTS Action Item 9). In addition, the USAR will be revised-to remove any ambiguity as to'the applicability'of intermixing restrictions to RPS'and SFAS in USAR section 8.2.2.ll.H lsee co.amentary to CRTS Action Itam 17). Lack of Configuration Control t Immediate corrective action taken, as a result of the identification of the cable misroutes in LER 86-10, Nas to initiate the Rancho Seco cable sampling to establish a level-of confidence in the cable installation. The LER 86-10 cable raisroutes'were corrected by ECN R-0765, which is construction complete. The additional cable misroutes identified during the cable sampi'ing activities end documented by LER 87-13 were rerouted by work request. Corrective action taken to prevent the recurrence of cable misroutings has been to revise the Modification Procedure / Inspection Standard MP/IS 307, "Cable Installation," to require the use of design drawings of the latest revision when installing cable, and the requirement that the cable routing information on the E-1010 series drawing match that on the applicable cable installation card. Witnessing requirements for cable pulls have also been clarified in MP/IS 307 to require that cable installation verification shall consist of witnessing the installation of tha cable. Lack of Class 1/Non-Class i Separation j No corrective action necessary, as none of the 763 intermixes of i Class 1, 2, and 3 cables are valid discrepancies, j

= Enclosure To GCA 88-136, Page 27 ITEM N0. 9 t Description Resolve power / control / instrument cable mixing concerns. Comaentary Chronology LER 85-16 Rev. 0 was the first documented evidence that instrument cables had been mixed with power and/or control cables at Rancho Seco. Since this discovery, additional mixings were found,~ and details are provided in the commentaries to CRTS Action Items 2 [ partial) and 5. ' Generic Implications The concern is the avoidance of unacceptable noise levels caused by cross-coupling between adjacent conductors in instrument circuite. The level of noise is a concern for analog circuits and some digital ci rcui ts. No concern attaches to cable-insulation levels since all power, control, and instrument cables have 600-volt insulation ratings and additional protection in the form of a protective outer jacket. The ability of a circuit to tolerate noise is a function of the equipment connected to it. The type of equipment and-the provision of noise filtering components both play a part.' The original design approach at Rancho Seco was typical of plants of similar vintage. The raceway design for the original 14,000 cables provided two service levels for 600-volt class cables (NEP 5103 Section 5.4.5.1 J (1.b) 480-volt (and below) power, DC, and control and (l.c) instrumentation. No explicit definitions existed for either power, cu.itrol, or ir,strument circuits. Service levels were indicated for i i raceways as follows: For Class i power and control raceway, the raceway designator begins-with either the letter L, H, P, or W for Channel A, B, C, or D, i respectively. For Non-Class I power and control raceway, the raceway designator begins with the numeral 7. l For Class 1 instrumentation raceway, the raceway designator begins with either tha letter A, 8, C, or D for Channel A, B, C, or D, respectively. For Non-Class 1 instrumentation raceway, the raceway designator begins with the letter X. 1 i

Encl osure ~To GCA 88-136, Page 28 ITEM NO. 9 CONTINUED Conduit is differentiated from cable tray by having all digits after the first letter or number; cable tray is identified by having both letters and numbers after the first letter or number raceway designator. For exampie: L27AFI - Channel A Power and Control Cable Tmy H47223 - Channel B Power and Control Conduit 7278Al - Non-Class 1 Power and Control Cable Tray 732007 - Non-Class 1 PoWr and Control Conduit A32AB2 - Channel A Ir.strumentation Cable Tray 044301 - Channel D Instrumentation Conduit X44AD3 - Non-Class 1 Instrumentation Cable Tray X56032 - Non-Class 1 Instrumentation Conduit Scheme cable numbers did not indicate the service level (P. C or I] for cables; however, a standard practice was used which identified all 600 volt shielded cables [ twisted shielded pairs, coax, triax, etc.] as instrument cables. This practice allowed latitude to the designers in classifying circuits as instrument when the circuits were shielded. For example, with this approach, low amperage (0.5 amp) 120 Volt power supplies could be installed using shielded, twisted-pair cable and run 1 with signal cables. When a field component (e.g., flow transmitter) was provided with only one entry [ conduit hub], this was an obvious practical approach to meet the equipment supplier's intent. For safety circuits, an unacceptable noise level is a plant safety issue. For this reason, the USAR wording requires separation of instrument cable from power and control cables.for RPS and SFAS, while not explicitly addressing other systems. In practice, the design intent i has always been to maintain the same separation for all systems. Design Guides written in 1984 and later have attempted to provide more explicit direction with the result that the design intent for the original 14,000 4 cables and cables installed later has become blurred. Causes The direct cause for each identified problem [CRTS Action Items 2 (partial), and 5] will be addressed in each individual commentary. Not all identified problems are, upon examination, real problems. A major cause of both real and incorrectly identified mix problems is an inadequate definition of design intent in both USAR and design documents. l 4

Enclosure To GCA 88-136, Page 29 ITEM 10. 9 CONTINUED A descriptian of the events and circumstances leading to the discrepancies identified in LER 87-26 has been prepared by IIRG [See Appendix 5). Corrective Actions - Physical Rework The physical reworking of cables because of mix problems is idatified in the following: Manholes. Underground manholes are concrete structures, below grade, wnich serve to provide convenient pulling areas for cables run in underground duct. Manholes are used to marshal (i.e., redirect) cable. Mix problems in manholes were investigated by a SMUD contractor [Impell) under Task 346. Non-cenfor21ances were recorded in NCR S-6999 for manholes MH006, MH046, MH047, NH048, and MH049. The non-conformances were analyzed and the results recorded in Engineering Report ERPT-0293. The mixing in MH046, MH047, MH048, and MH049 was identified as mixing of Class 1 digital inputs to the Class 2 IDADS multiplexers and was e cepted since noise filtering is adequate to limit noise to acceptable level s. Rework was required in manhole MH006. This rework i: complete. A minimum separation of three inches is established between power / control cables and instrument cables per :S-E-5304.8. Installation specification IS-E-5304.8 Addendum 2 was issued on September 18,1987 to impose the 3-inch minimum separation in manholes. LER 85-16. Seven cables required relocation. NCRs S-5263 and S-5968 were issued. ECNs R-0459 6nd R-1295 detail the work. LER 87-26. Twenty-eight cabler required relocation. NCRs S-6561, 5-6562, S-6563, S-6564, S-6565, and S-6566 were issued. ECN R-1785 and ECN R-1786 detail the work. ECN R-1785 was issued on July 23,1987 and was completed with a closu e date of October 28, 1987. ECN R-1786 was 4 issued on June 29, 1987, aid is complete with a closure date of November 23, 1987. CRTS Database Discrepancies LCRTS Action Item 2] Sixteen Non-Class 1 power, control, and instrumentation intermixes requiring relocation were identified by Impell as documented by CPRs 0511, 610, 885, 638, 640, 622, 642, and CONS 584 and 742 contained in Impell Calculation No. 271 -101 -109, Rev. O. The Non-Class 1 intermixes will be documented by NCR and resolved prior to the end of the Cycle 8 outage.

Enclosure To GCA 88-136, Page 30 ITEM N0. 9 CONTINVED Corrective Actions - Changes to USAR and Design Process CRIS Database Since July 1987, the cable input documents (E-1010] have been required to carry a designation P [ Power), C [ Control), or I [ Instrumentation) to indicate service level and assist in routing the cable in raceways of the proper service level. Additional service level designators are under consideration and include T [ Telephone], S [ Security] and IE [ Instrument-E).empt--may mix with P and/or C cables]. A CRTS software enhancement is planned [CRTS Action Item 10] which will:

Add a field for cdble service level [P, C, I, etc.]
Add a program feature to check cable service level against raceway service level.

Revisions to Design Documents The physical separation requirements for power, control, and instrument circuits are defined as follows: Separate conduits, ducts, penetrations, and cable trays should be provided for the following types of circuits: (1 ) Medium voltage (6.9kV) circuits. (2) Medium voltage (4.i6kV) circuits. (3) Low voltage power (480V) circuits from 480V switchgear with maintained spacing in trays. (4) Low voltage power (480V and below), control, and annunciator win 'ow input circuit:, and selected shiulded instrument circuits approved by the Electrical and I & C Supervising Engineers. (5) Instrument circuits requiring separate routing. In vertically stacked trays, cable trays should be arranged in the order given above with the medium voltage cables in the highest position in the stack. Control cables may be pulled with low voltage power cables, except when their respective concuctor sizes differ too greatly.

- Enclosure To GCA 88-136, Page 31 _ ITEM NO.-9 CONTINUED The instrument circuits requiring separate routing are the following: (1) All signal circuits from process instruments such as thermocouples, RTDs,-transmitters, neutron flux detectors, accelerometers, level elements, radiation monitors, etc. (2) All signal input circuits to computer and Anatec multiplexers, except for selected circuits which the Electrical and I & ^ Supervising Engineers specifically approve in writing for routing through power and control raceways. (3) All low energy level circuits (analog or digital), interfacing between ' instrument cabinets, and signal output circuits from instrument cabinets which control the plant equipment or device. (4) All circuits requiring coaxial, twinaxial, triaxial, and fiberoptic cables, (C1' ass 1 ex-core detector cables such as those for source range and power range ion chamber circuits must be run in dedicated rigid steel conduits.) (5) All low level and higher level analog circuits as addressed in Electrical Design Guide NEP 5204.43, sections 5.5.4 and 5.5.5. (6) All signal circuits to panel mounted instruments that are part of a process. instrument loop and shown on instrument loop diagrams. (7) All other circuits designated by the Instrument and Control Group as instrument circuits. Revisions to the following Engineering Design Documents were completed in July 1987. These revisions are being applied to all new cable work. NEP 5204.22 Design Guide - Cable System Design, General NEP 5204.43 Design Guide - Instrumentation Systems Shielding and Grounding and Surge Protection Revisions to USAR L See commentary to CRTS Action Item 17. i t i i -~e g

Enclosure To GCA 88-136, Page 32 ITEM N0.10 Description Demonstrate completeness of LRTS, including sof tware verification and validation [V & V]. COMMENTARY CHRONOLOGY General background and initial actions concerning the CRTS program are described in CRTS Action Item 1 [as-built verification] and 2 Ldata discrepancies j. The completeness question has two issues: 1. Installed But Unrecorded Cables: Whether the CRTS data base includes all cables installed in the CRTS listed raceways. 2. Dependable CRTS Program: Whether the CRTS sof tware is complete, reliable, ano error free. GENERIC IMPLICATIONS 1. Installed But Unrecorded Cables Cables of two specific systems have been identified as having incomplete cable records: Security System - CR1S Action Item 11; approximately 180 cables of a total population of 2000 not in CRTS. Comunication System - CRTS Action Item 13; approximately 450 cables, of a total population of 1500, not in CRTS, [ Refer to referenced Action Items for additional detail.] The possibility has also been raised as to whether procedures existed which permitted cables [other than security /cotraunicationj to be installed without entries being made in the CRTS database. The procedure question has been investigated by IIRG. An IIRG report was issued [ Reference DTS 87-103 dated Nov. 9,1987] which indicates no evidence that other cables [other than the security /comunication cables identified] were installed without the CRTS database being updated. As of October 1987, the problem of unrecorded cables appears confined j to some security and comunication systems without generic impliction i for other systems. Security and comunication cables are installed only in non-safety-related raceways, which lessens the level of concern.

Enclosure To GCA 88-136,_Page 33 1 ITEM NO. ~ 10 CONTINUED Concerns with installed but unrecorded cables exist related to raceway weight,- raceway fill, and to the quantity of combustible - material in open cable trays, .lowever, the quantities are small .and without significant safety _ impact. 2. Dependable CRTS Progran The CRTS software program was written by Control Data Corporation [CDC] for SMUD. The p ogram was run from 1980 through 1986 on a 1 CDC mainframe computer in Sunnyvale, CA; then Rockville, MD; then Kansas City,_M0. The program is currently run on a CDC Cyber 180 Model 830 Supermini Computer System. installed at the Rancho Seco jobsite. Maintenance and enhancement is provided by CDC. The CRTS data is downloaded to a local area network of IBM PC/AT computers when special data sorts and unit tray weights are needed. The CRTS sof tware program is not-a verified program meeting Nuclear Quality Standards. However, some subroutines written for and executed on the PC network are verified under a contractor (Impell] t QA program. The CRTS software program inventories cable and raceway data and perfortas design checks. The CRTS database is.also a source of data for other calculations (e.g., combustible loadings of caDie insulation] and a source of information on cable routes. The dependability of the CRTS sof tware is, therefore, of safety' significance to the plant, and the sof tware requires verification to the requirements of the SMdD Quality Program. The design documents issued for construction have included both the input documents as well as the CRTS generated installation cards. l This process provides verification of the cable route, since _any difference between design intent [ input document] and CRTS record [ output cards] is readily apparent, i-l e 1 c i 1

Enclosure To GCA 88-136 Attachment.4, Page 34 ITEM NO.10 CONTINUED The original sofesare program used [EE-553) was a Bechtel Program which was consistently maintained, enhanced, and verified by its owner. The CRTS sof tware was written by CDC for SMUD, but recebed no forinal verification. The current software has 54 modules, some of which show evidence of problems [bugsJ. The database is not impacted, but some reports generated from the data contain errors. Corrective Actions 1. Immediate' Actions ~ Pre Restart At the end of Febrt.ary 1988, 52 software bugs were identified. Four personnel have been added [1 Programmer and 3 Engineers - 2 on V8V and 1 on data discrepancies). All sof tware bugs are tracked through resolution. All problems which impact restart commitments were identified and corrected. 2. Future Actions - Post Restart SMUD Information Services [IS] is preparing a schedule and budget for the provision of upgraded (enhanced] CRTS sof tware,1ncluding verification and validation. Part of this process is making a decision to either: 0 Enhance and verify the existing CRTS sof tware or 0 Purchase new sof tware with verification. The senedule will show the upgraded software verified and validated and in place before the end of the Cycle 8 Outage. I 1

i Encl osure To GCA 88il36 -, Page 35 f ITEM NO 10 CONTINUED A Ifsting of future CRTS enhancements was provided by the CRTS group as follows: Sof tware Enhancement List These enhancements are in a format for policy decision-making. Once given initial approval, the enhancements must be translated into software specification format, then given final approval before sof tware enhancement implementation. Needed, Sorted-by'CRTS Staff Recommended Priority N1. Add a new type of CRTS report, for all report options, that gives the proposed dat& base only. Type 3 is recommended for this option, to compliment TYPE = 1 as-built database only, and TYPE = 2 as-built and proposed, now in use. N2. Revise raceway fill logic to be consistent with NEPs and to have complete software control over overfill disallowances, and implement use of justification codes for overfill si tuations. Precedence of deleting cables prior to insertion of other cables must be enforced to keep fills below NEP limi ts. Sparing cable logic is to be revised so as not to inflate the overfill calculation if an Misting included cable is merely having its scheme designati;n changed. LPresently, the computer tracks both old and new na'nes and counts both in fill calculation, which unnecessarily inflates the result.] t N3. Add a new feature for cable weights for tray receways, to keep fills within USAR limits; justification codes for overweight situations. New sof tware has to handle split trays, where a partition separates a tray into instrumentation and power / j control sections--unit weight for such occurrences has to be combined to meet the USAR 50 pound per linear foot limit. ) l l

Enclosure To GCA 88-136 ,.- Page 36 ITEM NO.10 CONTINUED

N4.

Provide a utility feature to search the entire CRTS database for every violation of its current cable-raceway-equipment design logic, at CRTS operator initiation. This should be incorporated immediately af ter the two items above. Thereafter, as each new logic feature is done, the utility feature should be revised to incorporate each new logic feature. N5. Revision to Quality Class 1, 2, and 3 intermixing input screening. Class 1 screening is adequate.- Non-Class 1 screening needs revising to make use of justification codes for presently acceptable configurations that may violate newer, non-applicable requirements. N6. Revision to service level intermixing input screening to disallow power / control / instrumentation cable intermixing in same raceways. Use of justification codes for violations of-updated logic. N7. Reserved element tracking, i.e., organizing the cable numbers, i raceway numbers, and equipment designations reserved by designers so that whea ECN/DCN packages get to the CRTS staff, there are no conflicts among the various packages. The reserved element tracking will become an adjunct database to the existing pro)osed and as-built CRTS databases now used by CRTS sof tware. As a productivity maasure, this is being implemented at the microcomputer level.] N8. Appropriate, limited read-only access to CRTS database via computer terminal placement within Design City (Trailer 2] and among Modifications personnel. This would free time now used to answer many questions by CRTS staffers, to do other necessary CRTS work. Designers and constructors could interroga.e the CRTS database on their own. N9. Add the capability to generate a repull card when an existing installed cable is rerouteo, in order to differentiate between new installation of cable and revision to an existing cable's j route. I I

~ _ _. O Enclosure To GCA 88-136: 4 Page 37 4 ITEM-NO.~10 ' CONTINUED Desired, Sorted by CRTS Staff-Recommended ^ Priority l D.1 Additional cableL and raceway enhancements -to assist construction personnel--new database fields: type of service, 4 cable jacket, conductor diameter [versus overall diameter), bending radius, pulling tension, sidewall pressure, unit weight, etc.. D.2 10 CFR 50 Appendix R supplementary information, i.e., fire i protection features, such as fire area in which CRTS element resides, Appendix R wraps on raceways, whether a given cable is related to safe-shutdown-considerations, whether a cable is associated with spurious. opera' ions equipment, etc. D.3 Change of CRTS database ' principle frea "position" orientation to "complete history audit trail" orientation. I i i e l s I 1 t 1 l J 1 1

i Enclosure To GCA 88-136 ., Page 38 ITEM NO.11 DESCRIPTION Show to what extent security cables are documented in CRTS. COMMENTARY CHRONOLOM I 00R 87-409, dated April 9,1987,- reports that 630 telephone and. security system cables are installed in the plant with incomplete documentation. Approximately 180 cables of a total population of 2000 security cables are not in CRTS. All security cables are recorded in one of three data bases: 1. EE-553 (KL) 2. CRTS 3. PC Data Base All security cables are in Non-Class 1 raceway. i GENERIC IMPLICATIONS The concern with the incocplete documentation of the plant security cables is due to potential impacts upon cable tray weight, fill, and combustible content, as well as separation and mix concerns.

However, since the security cables are in either dedicated conduit or in Non-Class I raceways, there is no significant impact upon safety cabl es.

Resolution of this problem will be completed by the end of the Cycle 8 outage. .i CAUSES The cause of the incomplete security cable documentation has not yet been determined. f CORRECTIVE ACTIONS The insnediate action to prevent further undocumented security cable additions to the plant has been to require all design work to be reviewed by the Nuclear Engineering Department. Additior,al actions may be taken later after further investigation of causes. 1 L l 4 i t i

Enclosure' To GCA 88-136 ' ', Page '39: i ITEM NO.12 t l DESCRIPTION Complete security cable documentation. COMMENTARY ], To be performed prior to the end of the Cycle 8 outage. s 4 i e t t 8 1 j 41 ] l j 3 t i I h 4 I ? t f d i-r i M i a i k i i _. ~. -

Enclosure To GCA 88-136, Page 40 ITEM NO.13 Description Show to what extent comunication cables are documented in CRTS. Comentary Chronology 00R 87-409, dated April 9,1987, reports that 630 telephone and security system cables are installed in the plant with incomplete documentation. The comunication cables include those from the following systems: PA - Puolic Address [ Dedicated Conduit] SP - Sound Powered [ Dedicated Conduit] CBX-Computer Based (Non-Safety Tray and Conduit] Exchange [ROLM] CBX cables include circuits for VHS radio and microwave link. Comunication cables are shown on series 700 drawings and ECNs. Generic Implications The concern with the incomplete documentation of the plant comunication cables is due to potential impacts upon cable tray weight, fill, and combustible content, as well as separation and mix concerns.

However, since the communication cables are in eitner dedicated conduit or in Non-Class I raceways, there is no significant impact upon safety cabl es.

Resolution of this problem will be completed by the end of the Cycle 8 outage. Causes ) The cause of tne incomplete comunicatior; cable documentation has not yet been cetermined. A poteritial cause is that since the communication cables were installed by the Electrical Maintenance Department, conflicting procedures may have led to incomplete communication cable documenta tion, i Corrective Actions The imediate action taken to prevent further undocumented communication cable additions to the plant has been to require all design work to be reviewed by the Nuclear Engineering Department. Additional actions may be taken later af ter further investigation of causes.

. ~,. _ Enc'losure To GCA 88-136 >, Page 41 I i . ITEM NO.14 I DESCRIPTION Complete comunication cable documentation, j - COMENTARY I i I'- To be performed prior to the end of the Cycle 8 outage. t-i r i i i h h I l l ? J l 1 I h f c I I P 1 i l 3 1 b 4 l.r l i i i I i l h I

Enclosure To GCA 88-136 ,. Page 42 ITEM NO.15 l . DESCRIPTION Formal and complete root cause evaluation of all cable l probl ems. COMMENTARY Thorough Root Cause evaluations have been performed for the major cable i problems. Reports summarizing these investigations and providing the l causes have been previously transmitted [0TS 87-103, dated levester 9, 1987] under separate cover to the NRC. I 4 b I t 4 I P v i + I i 1 I 1 I ? i i

Enclosure To GCA 88-136 l, Page 43 ITEM N0.16 DESCRIPTION Define major / minor / insignificant defects. B COMMENTARY l CHRONOLOGY The Sample Plan [ Appendix (1)], prepared by Impell under SMUD Task 271, provides (Figures 9.1, 9.2, and 9.3) a flowchart methodology to classify the types of defects discovered by the circuit tracing walkdowns into major, minor, or insignificant defects. The NRC requested, in the May 6,1987 meeting between the District and the NRC, that the District provide fonnal, written definitions of the types of defects. -Major, minor, and insignificant defect definitions were given verb (11y to NCR during a site visit June 15 througn 18, 1987. Definitions (see below] will be included in the next revision of the Sampling Plan. The following was explained to NRR. The word defect is used in the Sampling Plan to describe a cable route which is checked and found to dif fer from the CRTS recorded route. Defects are classified as eitner major, minor, or insignificant. The classification is detennined by reference to a set of decision 3 diagrams included as Figures 4.1, 9.2 and 9.3 in the Sample Plan j ( Appendix (1)]. For the convenience of reviewers, the following definitions will also be included: Major Defect j A major defect is a cable route wnich differs from the CRTS recorded route end the dif ference constitutes a violation of the plant safety or a design criteria. Corrective action is required. Minor Defect A minor defect is a cable route which differs from the CRTS recorded I route and the dif ference does not constitute a violation of the plant safety or design criteria. The corrective action is to correct the q engineering record with no enange to plant configuration. l Insignificant Defect j An insignificant defect is a cable route which differs from the CRTS recorded route only to the extent that typographical errors exist in the recorded data. The corrective action is to ccrrect the errant data, j 1 f 4

.= Enclosure To GCA 88-136 Attachrtent 4 Page 44 ITEM NO. ~ 17 i DESCRIPTION Revise USAR C0fMENTARY q CHRON0 LOGY f The investigations into the direct cause of a number of CRTS problems has ) identified the need to revise and clarify the wording used in Sections 5 l -and 8 of the USAR in a numoer of areas, as follows: i f 1. Section 5.1.2.1.0.C.I.(b) [ Cable Tray and Bus Duct Supports) The criteria for cable tray supports limits the loading imposed on the tray to 50 pounds per linear foot. In fact, the 50 pounds per linear foot is a minimum figure, and supports have been designed which accept higher j pounds per linear foot values. This change is made for clarification: Existing Text t "1. (b) Cable tray loading of 50 pounds per linear foot is used throughout regardless of tray width or anticipated weight of wire and cable, in no case does actual weight of wire, cable and tray exceed this figure." Revised Text "1. (b) A standard cable tray live loading of 50 pounds per linear foot is used throughout regardless of tray width or anticipated weight of wire and cable. Some cable tray [ supports are designed for loads which exceed 50 pounds per l linear foot. In no case does the actual weight exceed the design limit." l \\ 2. Section 8.2.2.ll.H i This section provides criteria for the separation of redundant cables of i safety circuits, but is unclear because it mixes general criteria for al) safety circuits with specific criteria for RPS and ESFAS circuits, and does not clearly indicate what is general criteria and its applicability. This change is made for clarification: Existing Text l "H. The separation of redundant cables of the reactor protection j system and safety features Actuation system circuits is accomplished by spatial uiparation in accordance with the following criteria:" i i

) Enclosure To GCA 88-136, Page 45 ITEM NO.17 CONTINUED Revised Text "H. Tr.e separation of redundant cables of safety systems is accomplished by spatial separation in accordance with the criteria given in this section. Specific criteria applicable only to Reactor Protection System [RPS) and Engineered Safety Features Actuation System (ESFA3] cables is included." 3. Section 8.2. 2.ll.H.1 As a result of NCR S-6594 and LER 87-26, the District has performed a Safety Analysis, 50.59 log No.1020, which requires the following change to the USAR text: Existing Text "1. Separata cable tray conduit and penetration systems are......." ... Class I instrumentation circuits are routed in rigid metal conduits as explaineo in (2) below." Revised Text ). S parate raceway (cable tray, conauit and penetration) systems are ... Class I instrumentation circuits are routed in metal racetray as explained in (2) below." 4. Section 8.2.2.ll.H.2 As a result of NCR S-6594 and LER 87-26, the District has performed a Safety Analysis, 50.59 log No.1020, which requires the following change to the USAR text, because the Babcock & Wilcox design interface criteria for RPS and ESFAS cables requires separate raceway and does not specifically require separate conduit. Existing Text "2. Reactor protection system and safety features actuation system instrumentation each have their channels routed in separate conduits and are physically separated from each other throughout the plant." Revised Text "2. Reactor protection system and safety features actuation system instrumentation each h6ve their channels routed in separate raceways and are physically separated from each other throughout the plant."

Enclosure To GCA 88-136.. Page 46 ITEM NO.17 CONTINUED 5. Section 8.2.2.ll.H.S As a result of NCR S-6562 and LER 87-26, and per the Safety Analysis, 50.59 log No.1002, the USAR will be changed as follows: Existing Text "5. Power and control circui+.s are not mixed with instrumentation circuits in any raceway for any system." Revised Text "5. Power and Control circuits are not mixed with instrumentation circuits in any raceway for any system unless an engineering analysis for acceptability is performed." 6. Section 8.2.2.ll. H.9 Per the disposition of LER 87-24, the following change to the USAR has been committed to because both weight and ampacity considerations are different for power and control cables versus instrument cables. Tne following text change to USAR Section 8.E.2.ll.H.9 is planned to provide clarification and agreement wi tn NEP 5204.22: Existing Text "9. The maximum percentage fill in redundant trays is 40 percent and wherever possible, it is kept at a much lower value." Revised Text "9. The maximum fill in trays is limited to prevent exceeding the cable ampacity rating in accordance with IPCEA No. P-46-426 and ICEA No. P-54-440, and the designed weight of cable on the tray supports." i Cable tray fill limitations are typically imposed because of the following: 0 All cable trays - Load bearing capacity of tray and supports O Power cable trays - Ampacity ratings of cables j

Enclosure-To GCA 88-136, Page 47 I ITEM NO.17 CONTINUED l The current status of these (tems at Rancho Seco~are as follows: Load Bearing Capacity of Cable Trays All tray weights [without regard to percent fill] have beer, checked i against the 50 pund_gr linear foot USAR limit and were again checked on December 28, 1987 wim results as described in the commentary to CRTS Action ~ Item 2. An enhancement is planned to the CRTS sof tware to L calculate cable tray weights for all future design changes without regard to fill level. Ampacity Rating of Cables The ampacities for 600 volt 900C power and control cables routed through randomly filled cable trays are based on either the number of conductors (IPCEA No. P-46-426) or percent fill per ICEA No. P-54-440, typically 40% of a 4-inch tray. Scheduled USAR Revision d 1 These changes are scheduled for inclusion in the next annual update of the i USAR in July 1988. l l r 3 i i i l i 1 l I 3 a

i Enclosure To GCA 88-136, Page 48 ITEM N0.18 DESCRIPTION Issue NEAP 4127. _COMMENTAR Y CHRONOLOGY The identification of concerns regarding CRTS completeness and missing CRTS cards, followed by the further identification of cable installation problems associated wi th LERs 85-16 and 86-10, led to the overall review of Rancho Seco cable installation' procedures and practices as described in the Action Plan and this report. Initial direct cause determination, confirwd by the preliminary root cause evaluations, has identified that the lack of a formal procedure, by which proposed changes to the CRTS database are made, and describing and controlling the issuance and return of cable and raceway construction cards, was a contributing factor in cable and raceway instellation and documentation problems. It should be noted that no specific cabling problem appears to have been directly associated with or caused by the CRTS computer program itself, but that problems arose through not formalizing the procedure by which cable additions, modifications, and deletions are made to the plant, and controlled c'id inventoried by the cable and raceway construction caras and the CRTS database. GENERIC IMPLICATIONS Lack of a formal procedure to control changes to the CRTS database and hence control cable ind racewey additions, modifications, and deletions to the plant, was a factor in the following types of cable problems at Rancho Seco: Cable Tray Overfill's and Overweights Prior to June 1987, formal procedures for the engineering review and acceptance of overfilled cable trays did not exist. Rancho Seco cable tray supports are designed to support, as a minimum, a cable loading of 50lbs/ linear foot. The USAR specifies a cable tray fill limit of 40% so that the cable tray support design of 50lbs/ linear foot is not exceeded. In the past, undocumented engineering reviews were made when cable additions to cable trays exceeded the cable tray fill limit. Neither the informal checks nor the supervisory approvals were proceduralized. and no documentation is available to show that such reviews have been made.

Enclosure To GCA 88-136, Page 49 ITEM N0.18 CONTINUED Presently, NEAP 4127 "Cable and Raceway Tracking System" prevents the issuance of DCNs to CRTS-ralated drawings [E-1008,1010,1026, 1027 and 1028] unless an error-free report can be produced when the data is entered into the proposed database. If a design error is detected, then the DCN is returned to the originating engineer for resolution. Once an error-free report is produced, the DCN is then submitted to the Electrical Supervising Engineer for approval. Should the CRTS error report indicate an overfilled cable tray, the DCN is returned for the engineering review and evaluation of the cable tray's included cables to verify that the cable tray support design basis cable loading has not been exceeded. CRTS Completeness The completeness issue is discussed in the commentaries to CRTS Action Items 1, 2, 3, and 10. Concerns relate to whether or not CRTS recorded cable locations match as-built, the resolution of CRTS database discrepancies, cables not recorded in the CRTS database, and missing CRTS caras. The formalization of CRTS procedures in NEAP 4127 provides the definitions and responsibilities suf ficient to control future cable and raceway additions, modifications, and deVetions to the plant. NEAP 4127 formalizes the flow of DCNs to the CRTS-related drawings, as well as the flow of the CRTS generated cable ana raceway installation cards to ensure the retention of completed cards to ensure CRTS cable and raceway locations match the as-Duilt and to ensure that CRTS data is entered without crrors. By procedure, error reports are run on data to be entered into the proposed data-base and again, once construction is complete, during the final processing of completed cards, in order to ensure that the proposed data, as well as the as-built data, is erro.'-free and reflects the actual plant configuration. CAUSES A sunraary os overall root cause evaluations is contained in Appendix 5. CORRECTIVE ACTION Corrective action nas been to issue NEAP 4127 "Cable and Raceway Tracking System," on June 15, 1987, to control c6anges to the CRTS database and control cable and raceway modifications to the plant. l

Enclosure To GCA 88-136, Page 50 ITEM NO.19 DESCRIPTION Provide bases for acceptability of a 95/95 level of assurance regarding cable routing. COMMENTARY CHRON0 LOGY The basis for 95/95 is given in the Sampling Plan [ Appendix (1)J. Cable sampling started in February 1987 and was completed on October 26, 1987. Following a meeting wi th SMUD on May 6,1987, and a subsequent telephone conference call on May 11, 1987, the NRC requested additional infonnation. SMUD RESPONSE The additior.al information requested has been provided in an appendix to the commentary to CRTS Action Item 19 of the July Wire and Cable Program Report, GCA 87-400, dated August 18, 1987, and, therefore, will no longer be included with this commentary, but will be referred to as Appendix 4 to this submittal of the Wire and Cable Program Report. Following issuance of the SER supplement and final acceptance of the Sampling Plan, the supporting documentation will be maintained in NED files for audit or re-inspection. Appendix 4 will be forwarded to NRR [in final form with inspections complete] with the monthly Wire and Cable Program Report. The appendix has been prepared by a SMUD consultant [Impell] and: 1. Provides information on established precedents. 2. Provides additional information on the technical basis for the Sampling Plan and provides a comparison Detween the Rancho Seco Sampling Plan and Militar.y Standard 105D and related plans. 1

p Enclosure To GCA 88-136, Page 51 ITEM NO.'20 DEiCRIPTION Resolve NRC concerns about possible biasing of sample. CONNENTARY ' CHRON0 LOGY Section' 9.1 (3), Evaluation Process, of tne Rancho Seco Sampling Plan [ Appendix (1)] contains the following statement:- "If a deviation does exist between the CRTS database routing and the ' as-built routing, the results are first checked against existing CPRs or CONS to determine if the deviation has already been dispositioned. If this problem has been dispositioned by a CPR or CON, no defect for that 'e lot exists." The question was raised, by Mr. Faust Rosa, at the May 6,1987 meeting as to whether the dispositioning of deviations, by CPR or CON, introduced a bias into the sampling. SMUD RESPONSE The response to the concern is provided in this commentary. The process described in Section 9.1 (3) is essentially only a correction of minor bookkeeping errors, none of which impacted the cable route. Only seven cables had deviations which were dispositioned as described. - All are detailed herein and none had deviations which affected the route. No bias was introduced into the sampling by Section 9.1 (3). This connentary is added to the Sample Plan.

Enclosure To GCA 88-136

, Page 52 ITEM NO. 20 CONTINUED TABLE 1 List of Circuit Tracing Walkdown Cables with CONS or CPRs The following-list of cables are part of the CRTS circuit tracing sample cables and have CRTS problems identified as CONS (*) or CPRs(**).

I Item Cable Work Request Number - CON or CPR Designation i l 1GlQ886AR 108063 CON-Oll8 CPR-0053 2 IM1A137 C 127745 CON-0001 3 iPIA06 D 126992 CON-1018 4 1RIC260BB 128755 CPR-0865 5 1RIC469CL 127708 CPR-0031 i 6 1R21R2H C 127006 CPR-0534 CPR-0672 7 1118314 A 127022 CPR-0866

Conversion Error Reports (CONS) were generated for equipment, raceway, and caole problems identified from the June 1980 computer conversion error reports prepared by SMUD's contractor, Control Data Corporation, when Bechtel Power Corporation's EE-553 database was converted to the present CRTS database.
- CRTS Problem Reports (CPRs) were generated for equipment, raceway, ano cable problems identified af ter the June 1980 conversion.

. l The following describes the problems and resolutions stated on the associated CONS /CPRs and their impact on the circuit tracing walkdown effort. f a _y ,.~.. -4._,v... ,.g

Enclosure To GCA 88-136 ., Page 53 ITEM NO. 20 CONTINUED r Table 1 (continued) ITEM 1 Cable: 1GlQ88 OAR on CON-0118 and CPR-0053 Problems: CON-0118 states that the CRTS raceway vias do not match 8echtel's EE-553 cable routing. CPR-0053 states that the construction card's first and last vias (red) do not match CRTS first and last vias (white). Resolutions: CON-0118 -- Junction box numbers were removed from CRTS vias and were confirmed by walkdown. 4 CPR-0053 --' Inspection verified the cable is i painted red. 000 has been issued to correct CRTS. Walkdown Impact: None on cable routing. i ITEM 2 Cable: IM1A137 C on CON-0001 Problem: CON-0001 states that CRTS vias show cable tray L43V36 connecting to L398NS, but CRTS raceway 2 connections do not show them connecting. Resolution: CON-0001 -- CRTS Revision Level 1372, 02/16/87, raceway connections show tray L43V36 connecting to L39BN5. Walkdown Impact: None on cable routing.

l

' Enclosure To GCA 88-136 ,, Page 54 ITEM NO.'20 CONTINUED Table 1 (continued) ITEM 3 Cable: IP1A06 J on CON-1010 4 Pr oblem: CON-1018 states that from termination of cable does not match equipment 10 schedules.- Resolution: CON-1018 -- From termination is a section of a pa nel. Panel is listed in equipment'10 schedule. Walkdorr. Impact: None on cable routing. ITEM 4 Cable: 1RIC26088 on CPR-0865 1 Problem: CPR-0865 states that CRTS shows the cable has a l deleted status and removal of the cable is not veri fied. Resolution: CPR-0865 -- Inspection verified the ccble ',s being spared and has been retagged to 181PA0101. Walkdown Impact: Cable is deleted. New sample cable selected. ITEM S l Cable: 1RIC469CL on CPR-0031 ~ Problem: CPR-0031 states that the pull card is not signed by QC. Resolution: NCR was issued, and when dispositioned, the pull i card will be signed by QC af ter inspection. Walkdown Impact: None on cable routing. I i 4

.i i Enclosure L To GCA 68-136 I. Page 55 ITEM NO. 20 CONTINUED Table 1 (continued) ITEM-6 Cable: 1R21R2H C on CPR-0534 and CPR-0672 Problems: CPR-0534 states that the cable is routed in Class 2 overfilled tray. CPR-0672 states that the construction card has not been received and that the number of-conductors does not match design drawings. Resolutions: CPR-0534 -- Cables in overfilled tray were analyzed. CPR-0672 -- Resolution of Non-Class 1 problem on unsigned construction cards is not completed. Walkdown Impact: None on cable routing. ITEM 7 Cable: 1118314 A on CPR-0866 Problem: CPR-0666 states that CRTS shows the cable has a deleted status and removal of tne cable is not l veri fied. I Resolution: Inspection was performed and confirmed that the cable does not exist. Walkdown Impact: Cable is deleted. New sample cable is selected. l i l

Enclosure To GCA 88-136, Page 56 ITEM NO. 21 DESCRIPTION Provide NRC with location of cable pull cards. C0!HENTARY Refer to corsnentary to CRTS Action Item 3. l

Enclosure To GCA 88-136, Page 57 ITEM NO. 22 DESCRIPTION Provide NRC with future plans for cable pull cards. COMMENTAR Y Refer to cotraentary to CRTS Action Item 3. )

Enclosure To GCA 88-136 !, Page 58 ~ ITEM NO.-23 x DESCRIPTION Redundant cabling in the same fire area (LER 86-10 and 87-13). COMMENTARY CHRONOLOGY Refer to Root Cause Investigation 86-10. GENERIC IMPLICATIONS i LERs 86-10 and 87-13 identified significant concerns with Rancho Seco cable configuration control. LER 86-10 identified seven safety-related instrumentation cables in Fire Area 17 that were not rerouted into fire-wrapped conduit as required by CRTS. LER 87-13 identified seven I safety related instrumentation cables that were not moved from Fire Area 36 to Fire Area 31 as required by CRTS. In both cases, the cable i rerouting was to nave been performed under ECN A-4942, and in fact the subject cables were correctly routed per the original issue of ECN A-4942. However, the routing of tne cables was revised several times after the initial issue of ECN A-4942, and the failure to subsequently-reroute the cables resulted in LERs 86-10 and 87-13. In addition to the safe shutdown / Appendix R concerns that arose as a result of the incorrectly routed cables, additional concerns identified by preliminary root cause investigations include that of adequate control of CRTS cable and raceway installation cards [See commentary to CRTS Action Items 3 and 18] and the failure of the Electrical OC inspectors to verify proper i location and routing of the subject cables [ Notice of Violation 50-312/87-21/-01]. CAUSES Refer to the summary of the Root Cause Investigation 86-10 LAppendix (S)] for the root cause findings. <^- CORRECTIVE ACTIONS 1 In response to LER 86-10, Rancho Seco began an inspection program of safety-related cables to establish a level of confidence in the cable 3 locations, as well as the CRTS database. Based on the analysis of the i misrouted cables in LER 86-10, and the lack of identified cable routing problems in the original plant cable population, the decision was made to sample only those safety-related cables installed af ter commercial operation in 1975 [ justification provided in commentary to CRTS Action i i i i i

Enclosure To GCA 88-136, Page 59 ITEM NO. 23 ~CONIINUED Item 7]. As described in the Sampling Plan [ Appendix (1)], the post-commercial operation safety-mlated cables have been divided into four sample populations and the objective has been to demonstrate with a 95% level of confidence that at least 95% of the sampled population is correctly installed in the plant per CRTS. Cable inspection, as part of the Sampling Plan, identified the seven additional cable misroutes described in LER 87-13, and prompted the 100% inspection of the Lot 4 sample population, which is complete with no additional major defects. Additional cable misroutes were identified as described in ODRs 87-604 and 87-723, and have required the 100% inspection of the Lot i sample population, completed on December 8,1987. Cable rerouting for those misrouted cables identified by LER 86-10 was performed by ECN R-0765 and is construction complete. Cable rerouting for those misrouted cables identified by LER 87-13 was performed by work request 128636 and is also compl ete. Misrouted cables identified by ODRs 87-604 and 87-723 will be corrected by ECNs R-1785 and R-1786, issued on July 23, 1987 and June 26, 1987, respectively. Construction completion for R-1785 was on October 28, 1987 and closure for R-1786 was on November 23, 1987. Additional corrective action has been to include in the Modification Procedure / Inspection Standard MP/IS 307, "Cable Installation," requirements to ensure that when installing cable, that the design documents are the latest revision, and that the cable routing information on the E-1010 series drawing matches that on the applicable cable installation card. Further requirements have been included in MP/IS 307 by Procedure Change Notice, in order to clarify the requirements for witnessing cable pulls, as follows: "Verify the cable is installed in the raceway specified by the applicable E-1010 series drawing. Verification shall consist of witnessing the installation of the cable."

.h Enclosure To GCA 88-136 l, Page 60 i ITEM NO. 24,' .l DESCRIPTION Provide description of the installation procedures and practices used at Rancho Seco for the. original cable population of 14,000 ' l cables. C0l#lENTARY i Refer to the comentary 1.0 CRTS Action Item No. 7. W -l i i I l 1

Enclosure To GCA 88-136, Page 61 ITEM NO. 25 DESCRIPTION Document a thorough engineering eviluation of the procedures and specifications used to install cable in the period 1975-1986. COMMENTARY CHRONOLOGY This CRTS Action Item stems from a lack of independent inspection for the installation of approximately 1100 safety cables in the period 1983-1985. This is 1dentified in a draf t Notice of Violation, included by NRC Region V, in a letter to SMUD dated July 30, 1987,

Subject:

NRC Inspection Report. The concern which exists is that the lack of independent inspection could nave resulted in not detecting damage to cable during installation. This engineering evaluation addresses the approximately 9000 cables installed 1975-1986 and covers two areas: 1) Adequacy of cable installation procedures and specifications used 1975-1986. 2) Evidence of cable damage experienced 1975-1986. The NRC Notice of Violation identifies a SMUD letter dated September 23, 1976 which stated that the Rancho Seco QA program complied with the guidance given in WASH NO.1284. This document in turn invokes IEEE Standard 336-1971 [ ANSI N45.2.4-1972). IEEE 336-1971 requires in Section 2.3 "Procedures and Instructions" that "Installation, inspection, and test procedures and work instructions shall be prepared and documented for those activities falling within the scope of this standard." Cable installation is covered in Section 4. This evaluation is made against the 1976 SMUD commitment. GENERIC IMPLICATIONS Approximately 14,000 cables were included in the original construction cable installation. Both the NRC and SMUD evaluations (NRC inspection i report 50-312/87-21 Section 2. A.(1) and CRTS Action Item 7] accept the adequacy of quality control in the original construction. The 9000 cables installed 1975-1986 may be summarized by year as foll ows. The Class I cable totals given are approximate and derive from Appendix 1 to the Wire and Cable Program Report. The Class 2/3 cable totals are ratioed from the Class I totals. i 1

~' Enclosure To GCA 88-136 , ; Page 62 ITEM NO. 25 CONTINUED 1 Approximate Cable Distribution by Year YEAR CABLES CLASS,1 NON-CLASS 1 - LECN closure] INSTALLED CABLES CABLES [3.425 X Class 1] 7 225 51 174 1975 66 15. 51 j 1976 4 1 3 i 1977 53 12 41 1978 101 23 78 j 1979 53 12 41 1980 598 135 463 1981 0 0 0 1982 0 0 0. 1983 3638 822 2816 -l 1984 828 187 641 l l 1985 3315 749 2566 1986 119 27* 92 9000 2034 6966 i Includes 25 cables whose ECNs were closed in 1987. ? = Year not con fi rmed. The period 1983,1984,1985 saw 1758 Class 1 cables installed or over 86% of the total installed 1975 through 1986. A detailed evaluation has been i made Lyear by yearj of. 3 J l Installation specifications Installation procedures ] Inspection procedures This evaluation has detennined that no Rancho Seco cable installation specifications as such, existed during the years 1975 through 1981. However, the required cable installation attributes were addressed by inspection requirements contained in Construction Inspection Data Reports [CIDRs] included witn each work request package. Copies of CIDRs for i 1978 and 1980 are included as Appendix 6 of this report. From 1982 onward, installation specifications existed and were adequate. Detail s are as follows:

Encl osure To GCA 88-136, Page 63 ITEM N0. 25 CONTINUED ADEQUACY OF CABLE INSTALLATION PROCEDURES AND SPECIFICATIONS USED 1975-1986 YEAR 1975 Installation Specifications: None Installation Procedures: EM-145 Rev. O Inspection Procedures: QCI 107 Rev. 0,1, 2, 3 Industry Guides / Standards: None Regulatory Standards: None Compliance YES NO Cable Installation Specifications Issued? X Material Handling Addressed? X Cable Tensile Strength Addressed? X Cable Sidewall Pressure Limitations Addressed? X Cable Pulling Calculations Addressed? X Installation Tension Measurem6nts Addressed? X CaDie Lubricants Addressed? X Cable Bending Limitations Addressed? X Installation Proceaures Issued? X l Inspection Procedures Issued? X YEAR 1976 Installation Specifications: None Installation Procedures: EM-163 Rev. 0 4 Inspection Procedures: QCI 107 Rev. 3 j Industry Guides / Standards: IEEE 336-1971 Regulatory Standards: Safety Guide 30

Enclosure To GCA 88-136 ,, Page 64 1 ITEM-N0.-25 CONTINUED Compliance YES N0 i Cable Installation Specifications Issued? X Material Handling Addressed? X (16) [See Comment] Cable Tensile Strength Addressed? X (11) Cable Sidewall Pressure Limitations Addressed? X (11) Cable Pulling Calculations Addressed? X (11) Installation Tension Measurements Addressed? X (11) Cable Lubricants Addressed? X (13) Cable Bending Limitations Addressed? X.( 4) I Installation Procedures Issued? X l Inspection Procedures Issued? X ~ Comment: The intent of IEEE 336 and Safety Guide 30 were met in the CIDRs. The # in parenthesis ( ) indicates the CIDR item as follows: 2 i j Inspection i Item Inspection Requirement Method i i 4. Bending radius shall be in accordance with Visual manufacturer's recommendations and necessary requirements. 1 11. Pulling tension shall not exceed manufacturer's Visual [ .i recomendations. 13. Excess lubricant shall be removed from cable Visual immediately af ter pulling, j l 16. Purchase Order number, manufacturer's reel Verify ) nuat)er, DCN number, work request number, and l Stock Code number shall be recorded on the cable pull card upon receiving cable from the warehouse. YEAR 1977 i Installation Specifications: None i Installation Procedures: EM-163 Rev. 0 l Inspection Procedures: QCI 107 Rev. 3 3 Industry Guides / Standards: IEEE 336-1971 ~ 4 IEEE 336-1977 i IEEE 422-1977 Regulatory Standards: Safety Guide 30 ) l Compliance: See 1976 Response t i

h ' Encl osure - ~ To GCA 88-136, Page 65 ITEM NO.'25 CONTINUED 4 YEAR 1978 Installation Specifications: None Installation Procedures: EM-163 Rev. 0, 2, 3 Inspection Procedures: QAP 29 Rev. 1 QCI 107 Rev.- 3, 4 Industry Guides / Standards: IEEE 336-1977 IEEE 422-1977 Regulatory Standards: Safety Guide 30 Compliance: See 1976 Response YEAR 1979 Installation Specifications: None Installation Procedures: EM-163 Rev. 3 Inspection Procedures: QAP 29 Rev. 1 QCI 107 Rev. 4 Industry Guides / Standards: IEEE 336-1977 IEEE 422-1977 Regulatory Standards: Safety Guide 30 Compliance: See 1976 Response YEAR 1980 Installation Specifications: None Installation Procedures: EM-163 Rev. 3 Inspection Procedures: QAP 29 Rev. 1 QCI 107 Rev. 4 Industry Guides / Standards: IEEE 336-1977 IEEE 336-1980 IEEE 422-1977 Regulatory Standards: Safety Guide 30 Compliance: See 1976 Response I

Enclosure To GCA 88-136 A'.tachment 4, Page 66 ITEM NO. 25 CONTINUED YEAR 1981 Installation Specifications: None Installation Procedures: EM-163 Rev. 3 Inspection Procedures: EII EC-ll Rev. 0 EII G-2 Rev. 0 EII G-4 Rev. O, 1* QAP 29 Rev. 1, 2, 3, 4 QCI 107 Rev. 4 Industry Guides / Standards: IEEE 336-1980 IEEE 422-1977 Regulatory Standards: Safety Guide 30 Compl iance: See 1976 Response

Ef fective Date Not Known YEAR 1982 Installation Specifications:

CMP Rev. O,1, 2 Installation Procedures: CMP Rev. O, 1, 2 EM-163 Rev. 3 Inspection Procedures: E!! EC-ll Rev. O, 1* EII G-2 Rev. 0 EII G-4 Rev. O, 1* QAP 29 Rev. 4 QCI 107 Rev. 4 Industry Guides / Standards: IEEE 336-1980 IEEE 422-1977 Regulatory Standards: Safety Guide 30 Effective Date Not Known i t 4 n 1

Enclosure To GCA 88-136, Page 67 ITEM NO. 25 ,CONIANULU Compl iance YES NO Cable Installation Specifications Issued? X Material Handling Addressed? X Cable Tensile Strengtn Addressed? X Cable Sidewall Pressure Limitations Addressed? X Cable Pulling Calculations Addressed? X Installation Tension bkasurements Addressed? X Cable Lubricants Addressed? X Cable Bending Limitations Addressed? X Installation Procedures Issued? X Inspection Procedures Issued? X Coments: The intent of IEEE 336, IEEE 422, and Safety Guide 30 were met. YEAR 1983 Installation Specifications: CHP Rev. 2, 3, 4, 5 Installation Procedures: CMP Rev. 2, 3, 4, 5 EM-163 Rev. 3 Inspection Procedures: EII EC-Il Rev. 1*, 2, 3 E!I G-2 Rev. O, 1, 2 EII G-4 Rev. O, 1*, 2 QAP 29 Rev. 4 QCI 107 Rev 4 QCP 330 Rev. 2, 3, 4 Industry Guides / Standards: IEEE 336-1980 IEEE 422-1977 i Regulatory Standards: Safety Guide 30 Compliance: See 1962 Response

Effective Date Not Known i

l

Enclosure To GCA 88-136 ,. Page 68 a I ITEM NO. 25 l CONTINUED ) l YEAR 1984 l Installation Specifications: CMP Rev. 5, 6 l Installation Procedures: CMP Rev. 5, 6 EM-163 Rev. 3, 4 Inspection Procedures: EII EC-il Rev. 3, 4, 5, 6 EII G-2 Rev. 2, 3, 4, 5* EII G-4 Rev. 2, 3 QAP 29 Rev. 4 QCI 107 Rev. 4 QCP 330 Rev. 4, 5 Industry Guides / Standards: IEEE 336-1980 l 1 IEEE 422-1977 i .IEEE 690-1984 j Regulatory Standards: Safety Guide 30 Compliance: See 1982 Respense

Ef fective Date Not Known i

3 YEAR 1985 i Installation Specifications: CNP Rev. 6, 7, 8, 9, 10 d NEPM 5304.8C Rev. 0* i Installation Procedures: CMP Rev. 6, 7, 8, 9, 10 1 EM-163 Rev. 4 NEP 6307 Rev. O i Inspection Procedures: E!I EC-11 Rev 6 j EII G-2 Rev. 4, 5 l EII G-4 Rev. 3, 4 QAP 29 Rev. 4, 1 l QCI 107 Rev. 4, 5 l 1 QCP 330 Rev. 5 Industry Guides / Standards: IEEE 336-1980 j. IEEE 336-1985 IEEE 422-1977 IEEE 690-1984 Regulatory Standards: Safety Guide 30 Compliance: See 1982 Response

Ef fective Date Not Known i

i 1 i

Enclosure j To GCA 88-136 l - Attachment 4, Page 69 l i i J l ITEM NO. 25 l' 4 CONTINUED 1 YEAR-1986 s Installation Specifications: NEPM 5304.8C 0*, 1, 2 } I 4 Installation Procedures:- EM-163 Rev. 3, 4 MP/IS 307 Rev. O NEP 6307 Rev. O, 1 i Inspection Procedures: MP/IS 307 Rev. O j NEP 6307 Rev. O,1 j QAP 29 Rev.1, 2 QCI 107 Rev. 5 s QCP 330 Rev. 5 l Industry Guides / Standards: IEEE 336-1980 IEEE 422-1977 i IEEE 422-1966 i IEEE 690-1984 i Regulatory Standards: Safety Guide 30 I Compliance: See 1982 Response { l

Effective Date Not Known L

YEAR 1987 i i ) Installation Specifications: IS-E-5304.8 Rev. O I NEPH $304.8C Rev. 2, 3 i Installation Procedures: EM-163 Rev. 4 5 i MP/IS 307 Rev. O I j l ) Inspection Procedures: MP/IS 307 Rev. O l QAP 29 Rev. 2 l j QCI 107 Rev. 5 i Industry Guides / Standards: IELE 336-1985 I 4 IEEE 422-1986 IEEE 690-1984 i i Regulatory Standards: Safety Guide 30 j ] Compliance: See 1982 Response l l i l I

Enclosure To GCA 88-136, Page 70 ITEM NO. 25 CONflNUED~ CONCLUSIONS Of tne 9000 cables installed 1975-1986, approximately 1080 (12.57,) were installed 1975 tnrough 1981 without issued cable installation specifications, out with the required inspections covered by CIDRs. Tne cables installed after 1981 were covered by installation specifications l wnicn were adequate to prevent cable damage. Two conclusions are apparent: 1 1. 87.5 percent of cables installed 1975-66 were installed while l adequate installation specifications and procedures existed. 12.5 percent were installed without installation specifications, but with the inspection attributes covered by CIDRs. 2. The cables installed in the 1983-1985 period were covered by adequate installation specifications and procedures. REFERENCES AND 00CtJ4ENTATION The following is a list of the cable installation documents referenced in this commentary. Availability of copies at Rancho Seco is also indicated. Cable installation related specifications and procedures CMP Construction Methods and Procedures, Section III Cable l Installation Initial Release dated 06-04-82 Revision 1 dated 07-16-82 Revision 2 dated 07-29-82 Revision 3 dated 01-28-83 l Revision 4 dated 04-06-83 l Revision 5 dated 04-25-83 Revision 6 dated 11-16-84 Revision 7 dated 03-27-85 Revision 8 dated 05-08-85 i Revision 9 dated 05-15-85 1 Revision 10 dated 08-26-85 Cancellation - dated unavailaole Note: Revisions 1, 2, 3, 5, 6, 8, and 9 were unavailable. l l l l l l

m Enclosure i To GCA 88-136-i 3 -, Page '71 { 1 ITEM NO. 25 CONTINUED i EII EC-11 Engineering and Inspection Instruction Manual - Caule-j Installation During Construction and Ma,jor Modification l l Revision 0 dated 08-12-81 Revision 1 dated unavailable Revision 2 dated 01-29-83 4 i Revision 3 dated 04-30-83 Revision =4 dated 03-20-84 i Revision'S dated 06-28-84 o Revision 6 dated 11-01-84 i Cancellation date unavailable i Note: Revisions 0 through-5 were unavailable.. Ell G-2 Engineering and Inspection Instruction Manual - Site Construction Inspector (Generation Engineering Quality Control ) Revision 0 dated 08-12-81 i Revision 1 dated 01-29-83 i Revision 2 dated 04-25-83 i Revision 3 dated 03-28-84 i Revision 4 dated 12-03-84 l Revision 5 dated 01-07-85 Cancellation date unavailable j Note: Revisions 0 through 4 were unavailable, i ) EII G 4 Engineering and Inspection Instruction Manual - Process of Construction Inspection Reports i ) Revision 0 dated 08-12-81 .l Revision 1 dated unavailable l Revision 2 dated 04-25-83 1 Revision 4 dated 11-25-85 Revision 3 dated 03-28-84 i Cancellation date unavailable Note: Revisions 0 through 3 were unavailable. j EM-163 Electrical Maintenance - Installation of Permanent i Plant Cables Revision 0 dated 11-19-75 Revision 1 dated never issued l Revision 2 dated 05-31-78 j Revision 3 dated 10-06-78 l

Revision 3 dated 10-09-80 Revision 4 dated 09-21-84
Error was made in assigning revision number, i

l l 1 ,._-- c,.-_,_

Enclosure s i To GCA 88-136 1, Page 72 c ITEM NO. 25 i i CONTINUED i IEEE 336 IEEE Standard Installation, and Testing Requiremients For Instrumentation and Electrical Equipment During j i the Construction of Nuclear Power Generating Stations Initial issue 1971 1 1 i Revised 1977 Revised 19801 i s l-Revised 19852 I Title revised to: IEEE Standard Installation, Inspection, and Testing Requirements for Class 1E i Instrumentation and Electrical Equipment at Nuclear l Power Generating Stations. 2 Title revised to: IEEE Standard Installation. Inspection, and Testing Requirements for Power, r Instrumentation, and Control Equipinent at Nuclear i Facilities. IEEE 422 IEEE Guide For The Design and Installation of Cable Systems in Power Generating Stations i l Initial issue 1977 Revised 1986 i i. IEEE 690 IEEE Standard for The Design and Installation of Cable Systems for Class lE Circuits in Nuclear Power Generating Stations Initial issue 1984 i l j IS-E-5304.8 Installation Specification - Rancho Seco Nuclear j Generating Station Installation Specification For Electrical Cable Installation and Termination l Initial issue dated 08-28-87 ) i MP/IS 307 Modificat',on Procedure / Inspection Standard j Revision 0 cated 12-12-66 NEP 6307 Nuclear Engineering Procedure - Cable Installation Initial issue cated 12-28-85 j Revision 1 dated 10-17-66 j Cancelled as of 12-12-86 ) i j J

Enclosure To GCA 88-136, Page 73 ITEM NO. 2d CONTINUED NEPH 5304.8C Nuclear Engineering Procedure Manual - Electrical Cable Installation and Termination Initial issue dated unavailable Revision 1 dated 07-03-86 Revision 2 dated 11-06-86 Revision 3 dated 02-18-87 Cancelled as of 08-28-87 QAP-29 Construction Inspection Revision 1 dated 05-14-78 Revision 2 dated 02-10-81 Revision 3 dated 05-18-81 Revision 4 dated 09-01-81

Revision 1 dated 06-05-85
Revision 2 dated 01-01-86 Cancelled 07-28-87
Error was made in assigning revision number.

QCl 107 Quality Control Instruction - Installation Inspection of Electrical Cable, Wire, and Conduit Initial issued dated unavailable Revision 1 dated unavailable i Revision 2 dated unavailable Revision 3 dated 09-30-75 Revision 4 dated 08-04-78 Revision 5 dated 03-12-85 Cancellation date not available 1 No te: Revisions 0 tnrough 2 were unavailable. QCP 330 Quality Control Procedure - Conduit and Cable Inspection Original dated 02 82 Revision 1 dated 03-15-82 Revision 2 dated 05-18-82

Revision 3 dated 02-03-83 Revision 4 dated 04-20-83 Revision 5 dated 01-18-84 Cancelled as of 09-25-86
Revision 3 changed title to Cable Installation Inspection Procedure, i

Safety Quality Assurance Requirements for the Installation, Guide 30 Inspection, and Testing of Instrumentation and Electrical Equipment Initial issue 08-11-72

~ Enclosure To GCA 88-136, Page 74 ITEM NO 25 TONTINUED Evidence of Cable Damage Experienced 1975-1987 NCRs written during the period 1975-1987 were reviewed for evidence of Class I cable damage during or af ter cable installation L$ee Table i]. The review did not uncover a consistent pattern of cable damage during the installation process. The results of the review are as follows: Twenty-tnree NCRs were written for damage done during or af ter the cable installation process. Eightecn of the twenty-three described damage that occurreo, or most likely occurred, during the installation process [ cable pulling and termination). Eight of the eighteen described damage or potential damege that occurred while cable was being installed in raceway. Tne eight NCRs involved a total of twenty-five cables, as shown on Table 2. Only one NCR (NCR S-3178) described a cable that failed in service during the period 1975-1987. The "B" phase of the 5 kV power cable feeding the "B" nuclear service raw water pump tripped on ground fault on May 18, 1983. The cause was icentified as follows: "cable was damaged on initial installation." A temporary repair of the cable was completed on June 21,1983 and the cable was placed back in service. ECN A-4905 was imad on February 16, 1984 to replace the entire cable, from the swttchgear to the pump. Durin; the replacement of the repaired cable on 1 May 21,1985, the minimum training radius and the maximum allowable sidewall pressure for the new cable was exceeded as documented on NCR S-4726. Tne new cable was subsequently replaced in accordance with ECN R-0328. Conclusions Tre evidence of NCRs written during the period 1975-1987 does not indicate a generic problem of cable damage during the cable installation process. Only 25 out of approximately 2000 Class I cables installed were identified as being damaged or potentially damaged during installation. Damaged cables were i either replaced or repaired. References and Documentstion Tables 1 and 2 are lists of the NCRs reviewed for this evaluation, j i

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Enclosure To GCA 88-136, Page 79. ITEM NO.'26 DESCRIPTION Provide description of' the events and circumstances leading to the misrouting of. cable described in LERs 85-16, 86-10, 87-13, and 87-26. C0fetENTARY Refer to Root' Cause investigations RC 85-24,'RC 86-10, an'd RC 87-09 [ Appendix 5]. I i l l l l 4 f 1 l it

. -. =. Enclosure To GCA.88-136, Page 80 ITEM NO. 27 l DESCRIPTION Provide description of the events and_ circumstances leading to the discrepancies discovere~d between the as-butit cable routes and the routes recorded in CRTS. COMENTARY See Root Cause Report 87-03 Cable Raceway Tracking System. i j ) .m.

Enclosure To GCA 88-136, Page 81 ITEM N0. 28 Description Provide the bases for acceptability of a 95/95 level of assurance regarding cable routing. [ Compared with other accepted homogenous populations] Commentary The basis for acceptability of a 95/95 level of assurance regarding cable routing rests on two arguments: 1) Prior use of 95/95 acceptance criteria in Nuclear Power Plant Sampling Applications. 2) Application of 95/95 acceptance criteria to cable routings. The response concerning prior acceptance of 95/95 is given in the response to CRTS Action Item 19 and is complete. Final inspection results are given in Table 1 at the end of this commentary. Application Of 95/95 Acceptance Criteria To Cable Routings The confidence level established by the 95/95 acceptance criteria is the conditional probability that the percentage of major defects in the total population is less than or equal to five percent. Two populations [ Lots 1 and 4] have been given 100% inspections. The acceptance criteria is applied to Lots 2 and 3, both of which have been sampled with the following results: Lot 2 Lot 3 Population Size: 1434 183 Sample Size: 91 51 Major Defects: 0 0 4

Enclosure To GCA 88-136, Page 82 ITEM N0. ' 28 CONTINUED Statistical inferences using the Likelihood Density Function Method are: Lot 2 Lot 3 Maximum liklihood estimate of the percentage of improperly routed circuits in the population: 0% 0%

== Conclusion:== With 95.2% confidence, With 95.4% confidence, it can be asserted that it can be asserted that 4' 9% or more of the 95.6% or more of the v,rcuits are properly circuits are properly routed. routed. [ Note: "Confidence" is the conditional probability that the population from which the sample was drawn contains no fewer than 'X' percent acceptable items, given the evidence available from the sample.] Statistical inferences using Acceptance Sampling Methodology are: Lot 2 Lot 3 Acceptance Number 1 0 Concl usion:' Wi th 95.2% confidence, With 95.1% confidence, it can be asserted that it can be asserted that 95.0% of the circuits 95.1% of the circuits i are properly routed. are properly routed. [ Note: "Confidence" is the conditional probability of rejecting a lot containing 'X' percent discrepant items, given that a lot of that quality has been submitted.] l

Enclosure To GCA 88-136 ' Attachment 4, Page 83 ITEM N0. 28 CONTINUED The establishment of Lot 3 separately from Lot 2 was done in an attempt to establish whether the cards with questionable signatures constituted a spacial class with a common problem. With 29.0 percent of Lot 3 inspected, this is clearly.not the case,.and the questionable signatures have no significance. Therefore, Lots 2 and 3 can be examined statistically by combining the total and sampled populations. This gives a population: LOT 2 + Lot-3 Population Size: 1617 Sample Size: 14? This allows'the examination of the statistical inferences for the combined l o ts. These figures are: Statistical inferences using tne Likelihood Density Function Method are: Lot 2 + Lot 3

== Conclusion:== With 95.4% confidence, it'can be asserted that 98.0% or more of the circuits are properly routed. l [ Note: "Confidence" is the conditional probability that the population < from which the sample was drawn contains no fewer than 'X' percent i acceptable items, given the evidence available from the sample.] i

l Enclosure To GCA 88-136, Page 84 ITEM NO. 28 i CONTINUED l 1 Statistical inferences using Acceptance Sampling-Methodology are: LFor an acceptance number of zero] . Lot 2 + Lot 3

== Conclusion:== With 95.4% confidence, it can be asserted that i 98.0% of the circuits are properly routed. [ Note: "Confidence" is the conditional probability of rejecting a lot containing ' X' ercent discrepant. items, given that a lot of that quality has been submitted. A reliability level of 98% for the combined population of 1559 would indicate the possibility of 31 or fewer major defects. This possibility has to be evaluated-against the evidence produced by the inspections and other sources: Nineteen major defects were found: 7 in Lot 4 and 12 in Lot 1. These defects fall into 3 incidents as follows: 1. Seven major defects in Lot 4 were all in one incident and are documented in LER 87-13. The seven cables were to have been moved by ECN A-4942 from Fire Area 36 to Fire Area 31, but were lef t in place. Associated with this incident are the seven additional cables that were to have been rerouted into fire wrapped conduit in Fire Area 17. The cables were identified by LER 86-10 prior to the start of the Sampling Program, and are not counted as major defects. The misrouted cables could have caused a loss of redundancy if a fire had occurred in either Fire Area 17 or 36. The direct cause of the cable misrouting has been identified as personnel error. l l 1

Enclosure To GCA 88-136, Page 85 ITEM NO. 28 CONTINUED 2. Eleven [11] Major Defects were found to have been caused in a second-incident in 1981 when a power and control tray was re-tagged as an instrument tray but without the eleven power and control cables being removed. The direct cause appears to be failure by construction to pull back cable as required by design' documents. 3. One [1] Major Defect was caused in 1984 when a Class I conduit stopped short of a floor blockout, causing the cable installer to complete the last four feet of the route in a Non-Class 1 cable tray. Evidence - Other Than Inspections An examination of all sources [such as LERs, 00Rs, NCRs] for major defects in Populations 1, 2, 3, and 4 have found no major defects to add to the total of 19 found by the inspections other than the 7 major defects reported in LER 86-10 which are part of the same incident reported in LER 87-13 and discussed as part of incident #1. The major defects found are therefore limited to the three incidents described. This fact is strong evidence to suggest that there was no systematic breakdown in the design and/or installation process for cables but rather a limited number [3] of specific inciaents. This is taken as an indication that the real number of major defects, which would be found by a -100% inspection, is likely to be less than the statistically inferred totals. Correlation between earlier precedents [ established by NRC) for acceptance of 95/95 sampling of safety related components [such as structural. steel welds and concrete expansion bolts) is viewed as follows: Given a possible discrepant [ major defect] population of 31, the following must occur coincidentally to impact plant safety. 1) A major defect or defects have to exist in safety related components. 2) The major defect or defects have to involve a loss of reditndancy in safety system. 3) An incident or accident has to cause a coincident failure in redundant safety systems.

Enclosure To GCA 88-136, Page 86 ITEM NO. 28 CONTINUED The basis of the NRC acceptance of 95/95 sampling for structural steel weld inspections is assumed to be the low probability of coincident weld failure in supports of redundant systems. The following must occur to cause a loss of redundancy: 1. A defective weld must exist in the welded steel supporting a safety system. 2. A defective weld must also exist in the welded steel supporting the redundant safety system. 3. An incident or accident must cause stresses resulting in weld failures in welded supports for redundant safety systems. 4. The failures must be sufficiently severe to impair safety function [in both sets of equipment] below an acceptable level. The basis of the NRC acceptance of 95/95 sampling for concrete expansion bolts is assumed to be the low probability of coincident failures in redundant safety related equipment. The following must occur to cause a loss of redundancy: l. Defects must exist in bolts holding down safety related equipment. 2. Defects must also exist in bolts holding down redundant safety related equipment. 3. An incident or accident must cause stresses resulting in bolt failures in both sets of equipment. 4. The failures must be sufficiently severe to impair safety function j [in both sets of equipment] below an acceptable level. For major defects in the cable routes of safety related cables the possibility of coincident failures in redundant safety systems is more complex. The types of major defects identified at Rancho Seco include: A. Redundant safety cables in the same fire area [14 cables in 1 i incident]. B. Lack of acceptable separation between Class 1 cables and Non-Class 1 cables [2 cables in 1 incident]. C. Lack of acceptable separation between Class 1 instrument cables and Class 1 power / control cable [42 cables in 6 incidents]. 4

Enclosure To GCA 88-136, Page'87 ITEM-N0. 28 CONTINUED A, B, and C. defects have been identified in the Rancho Seco cable populations and are considered viable.,Possible scenarios which could impact plant safety-are: i 1. Major Defect A. A fire causing a loss of redundancy. 2. Major Defect B. An electrical overcurrent condition in a Non-Class 1 cable combir.ed with a single failure in an overcurrent device. This could cause a condition in which a cable failure could impact a Class 1 cable [ lacking adequate separation) resulting in a loss of safety function. 3. Major Defect C. An electrical transient in a power cable causing a spurious control or indication signal in an instrument cable [ lacking adequate separation]. Scenario 1 postulates a single major defect resulting in a loss of redundancy. This would appear to indicate the need to reduce the possibility of major defects to a minimum. However, for a single incident or accident to cause a loss of redundancy the following must occur: Major Defect A 1. Redundant safety cables must exist in the same fire area. 2. A fire must be initiated. 3. The fire detection / prevention system must fail. 4. The fire must cause a loss of safety function in both IEEE 383 qualified [ fire retardant) cables. 5. Neither loss of safety function is to a fail-safe condition. Major Defect B 1. A lack of acceptable separation must exist between a Class 1 cable and a Non-Class 1 cable. 2. A failure must occur in the Non-Class 1 circuit conductor. or component. 3. A failure must occur in a Non-Class 1 circuit protective device, j 4. The effects of the two failures must be sufficiently severe to cause a failure in an adjacent Class I cable. 1

Enclosure. To GCA 88-136 ', Page 88-ITEM NO. 28 CONTINUED 5. The Class 1 failure is not to a fail-safe condition. 6. A simultaneous failure must occur in a redundant Class 1 circuit. I Major Defect C ] 1. A lack of separation n";st exist between a Class 1 instrument cable and a power or control cable. j 2. An electrical transient must occur in the power or control cable causing a spike [ electromagnetic induction] in the instrument cable. 3. The magnitude of the induced spike in the Class 1 instrument cable must be sufficient to initiate a spurious action or indication in the instrument ci rcui t. '4. A simultaneous failure must occur in a redundant instrument circuit. From the evidence and discussions provided it would appear that: The number of major defects in Lot 2 and Lot 3 cable routes, that would be found by a 100% inspection is likely to be less than thirty-one [31]. The likelihood of major defects in cable routes causing a loss of redundancy in safety systems is not higher than the likelihood for welds j and concrete expansion bolts sampled to the same level. Conclusion The confidence / reliability levels for Lot 2 and Lot 3 are as stated above. To closely correlate the sample results from three diverse populations appears impractical. However, based on the logic presented in this commentary, the i acceptance of 95/95 for sampling homogeneous populations is considered to be equally valid for cable routes as it is for weld inspections and inspections of, concrete expansion bol ts. I 1 a

Enclosure To GCA 88-136 j, Page 89 ITEM N0. 28 CONTINUED Table 1 CRTS Circuit Tracing Results H = Hand Traced S = Signal Traced Description Lot 1 Lot 2 Lot 3 Lot 4- ' Lo t - 2 + 3 Population Size 398 1434 183 78 1617 H S Sample Size 245 152 91 51 78 142 Circuits Traced 245 152 91 S1 78 142 Major Defects 11 1 0 0 7 0 Minor Defects 17 21 4 1 2 5 Insignificant or No Defects 217 130 87 50 69 137 Statistical Infer. LDFM NA NA 95.2/96.9 95.4/95.6 NA 95.4/98.0 Statistical Infer. ASM* RA NA 95.2/95.0 95.1/95.1 RA 95.4/98.0 Total number of circuits traced = 617 [ Actual total was 620 but 3 Lot 2 inspections were not credited]

For an acceptance number of one [ Lot 2) or zero [ Lot 3 and Lot 2 + 3].

DEFINITION OF LOTS Lot 1: Safety related and safe shutdown circuits with rerouted vias between connercial operation and December 22, 1986. Lot 2: Safety related and safe shutdown circuits without rerouted vias between commercial operation and December 22, 1986. Lot 3: Safety related and safe shutdown circuits without revised vias and questionable cable pull card signatures. Lot 4: Safety related and safe shutdown circuits with rerouted vias and questionable cable card signatures. i

Encl osure - To GCA 88-136, Page 90 ITEM N0. 29 J DESCRIPTION Provide an itemized listing and description-of changes in~ procedures and controls for cable design and installation which have been made in. response to the identified cable deficiencies.. COM4ENTARY ^ The changes in procedures and controls made in response to identified cable deficiencies are part of the corrective actions taken by SMUD. To place the changes in context, each identified cable deficiency is discussed (when appropriate] relative to direct and root causes together with a description and detail of each corrective action. For convenience in considering corrective actions, they are presented in six groups: 1.0 CRTS Procedures and Cable Design Interface.. 2.0 CRTS Procedures and Cable Installation Interface. 3.0 CRTS and Engineering Design Problems. 4.0 CRTS and Data Discrepancies. 5.0 CRTS and Documents of Record. 6.0 CRTS and Software Problems. 1.0 CRTS PROCEDURES AND CABLE DESIGN INTERFACE 4 Report Ref: CRTS Action Items 1 and 2. Problem: Missing and discrepant CRTS data. I Direct Cause: The direct cause of problems in the CRTS cable design interface area was a lack of.CRTS use procedures. Root Cause: The root cause of the CRTS problems is that neither i Nuclear Engineering management nor the CRTS supervisor were adequately involved in the CRTS. i LRoot Cause 87-03, Appendix 5.] Corrective For a detailed review of corrective actions against Actions: root cause evaluations, see CRTS Action Item 30. Immediate Corrective Actions - Pre Restart 1.1 NEAP 4127, "Cable and Raceway Tracking System" was issued on June 15,1987 and revised on December 14, 1987. This NEAP controls tne method by which proposed changes to the CRTS data base are submitted, approved, and incorporated.

Enclosure To GCA 88-136 -, Page 91 ITEM NO. 29 CONTINUED 1.2 As described in the coranentary to CRTS Action Item 6, a NED instruction given on May 1,1987, and effective on June 15, 1987, required all CRTS input documents / forms to be handled as. Drawing Change Notices [ Reference EEGS 87-005, from E. J. Gough to the Electrical Engineering Staff, dated May 1,1987). This i corrected a practice in which new forms were issued for all changes. Future Corrective Actions - Pre or Post Restart ] 1.3 A full time CRTS Administrator [ contract employee] has been in 1 place since April 21, 1986 and is responsible for implementaticn of NEAP 4127. A CRTS Coordinator [Section 4.7 of NEAP 4127] receives and inputs data. SMUD hired a Group Lead effective January 1,1988. The Group Lead will replace the CRTS Administrator after a suitable overlap. The CRTS organization chart [ Figure (1)] is shown at the end of this section together with the organization chart for the NED Electrical section [ Figure (2)]. 2.0 CRTS PROCEDURES AND CABLE INSTALLATION INTERFACE Report Ref: CRTS Action Items 1, 2,11,13 and 23. Direct Cause: The direct cause of problems in the CRTS/ cable installation interface was a lack of CRTS use procedures. Root Cause: The root cause was a failure to have and/or use l procedures for cable design, installation, 4 inspection, and repulling. [ Root Cause 87-09, Appendix SJ. i i For a detailed review of corrective act ons against i root cause evaluations, see CRTS Action Item 30. Common CRTS problems witn past installation practice and corrective actions are as follows:

2.1 Problem

Installation cards not returned to CRTS. Corrective Action: NEAP 4127 requires cards to be returned to the CRTS Coordinator and held until the ECN is closed. The ECN cannot be closed until cards are returned to CRTS and the data accepted by the CRTS Coordinator, i

Enclosure To GCA 88-136, Page 92 ITEM ~NO.'29 CONTINUED i

2.2 Problem

As-built corrections not reported on cards . returned to CRTS. Coordinator. Corrective Action: NEAP 4127. requires Field Problem Reports to be generated if the design cannot be implemented as shown on the design drawings. Only installed length dimensions can be noted on the CRTS card; the practice of allowing field engineers to solve design problems and then to note the as-built changes on the CRTS card is not permi tted. Each related MP/IS [ Modification Procedure / Installation Specification] has been revised to reflect the CRTS card handling procedures mandated by NEAP 4127. The revision i to the procedures were effective December 22, 1987. l

2.3 Problem

MP/IS 307 did not clearly specify that the i inspection of a cable routing is a hold-point or define that verification of routing requires the installation to be witnessed. Corrective Action: PCN #4 [ dated 07-01-87] to MP/IS 307, Rev. O, l makes the route inspection a hold-point and requires the installation to be witnessed.

2.4 Problem

Rancho Seco has approximately 2500 Appendix R cables (2?00 Class 1 and 300 Class 2/3] l isted. The list is a living document which is revised on a periodic basis as ECNs are closed. The problem has been that no procedural requirement has existed to require QC inspection of Class 2 or 3 Appendix R cable routes. Corrective Actions: Immediate Corrective Actions -- Pre Restart 2.4.1 Since May 1,1987 the Quality Department has been reviewing all Work Requests against a list of 300 Class 2/3 cables. All Appendix R cables have their routes inspected and a hold-point is indicated on the cable pull card.

Enclosure To GCA 88-136, Page 93 ITEM NO. 29 CONTINUED 2.4.2 As of October 1,1987, the NED Electrical Engineering physical design group has been identifying all proposed Appendix R circuitry via field note on the E-1010 DCNs. [ Reference Memo EEGS 87-040, dated September 21, 1987.] 2.4.3 NEAP 4119 [ Nuclear Engineering Fire Protection Program Control] has been revised, effective 1 November 11, 1987, to require identification of the Appendix R circuits on the CRTS cable input document [ Form E-1010]. 2.4.4 As part of the review of procedures associated with the resolution to CRTS Action Item 25, the Quality Assurance Procedures [QAPs] was replaced with RSAP-0808 and the Modification Procedures / Inspection Instructions [MP/ISs] associated with cable installation and inspection was revised to address the i requirement to inspect the Class 2 and 3 Appendix R cables to the same requirements as for Class 1 cable installations. Future Corrective Actions -- Post Restart 1 2.4.5 CRTS sof tware enhancement to create a field in the electrical circuit schedule, as well as the cable cards, to indicate the service level of the cable [P, C or 1] and to identify the i Appendix R cables [R] will be completed prior to the end of the Cycle 8 outage [see commentary to CRTS Action Item 10]. In addi tion, the E-1010 form will be revised to allow the above information to be input into the CRTS database.

2.5 Problem

Incomplete security cable and communication cable documentation in CRTS. Corrective Action: A scoping statement was added to NEP 4109, "Configuration Control " that requires that all permanent changes to the physical or functional cnaracteristics of Rancho Seco be reviewed and controlled by Nuclear Engineering via the ECN p rocess. This change appears in Revision 7 to NEP 4109, dated July 29, 1987.

Enclosure -To.GCA 88-136 !,.Page 94 ITEM N0. 29 CONTINUED r I 3.0 CRTS AND ENGINEERING DESIGN PROBLEMS-3.1 POWER AND/0R CONTROL CABLE MIXING WITH INSTRUMENT CABLES Report Ref: CRTS Action Items 9 and 17. Direct Cause: The direct causes are either: 1. Construction error [0DRs 87-109, 87-723, 87-735, NCR S-5968] or l 2. Design error. [NCRs S-5265, S-6523, S-6561, S-6562, S-6563, S-6564, S-6566, S-6999] Root Cause: Root cause of intermixing was the failure to have and/or use procedures for cable design, 1 installation, inspection, and repulling. [ Root Cause 87-09, Appendix 5.] For a detailed review of corrective actions against root cause evaluations, see CRTS Action l Item 30. Corrective Actions: Immediate Corrective Actions -- Pre Restart j 1 3.1.1 Issue NED clarification of the physical separation i requirements for power, control, and instrument [P, C and I] cables. This clarification is included in the i comentaries to CRTS Action Items 9 and 17 and covers I changes to both NED Design Guides and USAR. No-revision is required to the installation specification for cable [IS-E-5304.8) because separation of cables by service level [P, C or I] is i defined in the design drawings and not in IS-E-5304.8. ) 3.1. 2 Issue NED direction requiring the identification of all cables on CRTS input documents (E-1010] as P 1 [ Power], C [ Control] or I [ Instrumentation]. A memo t LEEGS 87-006] from E. J. Gough to the Electrical Engineering Staff, dated May 4,1987, was issued ] directing the following: I l

Enclosure To GCA 88-136, Page 95 ITEM NO. 29 CONTINUED "Effective immediately, each new cable scheme number shall have its service level [ power, control and instrum.cntation (analog or. digital)] shown on E-1010s." 3.1. 3 Revise NEPH 5204.22 and NEPM 5204.43 to define required separation between power, control, and instrument cables in raceways and manholes (PCNs issued on both, dated July 27, 1987). Future Corrective Actions-[Before end of Cycle 8 outage] 3.1. 4 CRTS sof tware will be enhanced to screen raceways for service level mixing [P and/or C with I] and block proposed changes which violate Design Criteria. 3.2 CABLE TRAY FILL AND WEIGHT CONCERNS Report Ref: CRTS Action Items 6 and 8. Direct Cause: Inadequate procedural guidance. t Root Cause: The root cause of the overweight cable tray problem is the failure to ensure adequate implementation of USAR re [ Root Cause 87-05, Appendix 5] quirements. For detailed review of corrective actions against root cause evaluations, see CRTS Action r Item 30. Corrective Actions: H Immediate Corrective Actions -- Pre Restart J.2.1 All cable tray weights have been calculated l regardless of percent fill. This process was again repeated prior to restart, on December 28,1987, as described in the commentary to CRTS Action Item 2. 4 3.2.2 NEAP 4127 is issued and governs the CRTS process. Step 5.2.4 requires proposed changes, which violate design limits, to be returned to the originator, as follows: 4 1

l C Enclosure ~ To GCA 88-136 Attachment _4, Page 96 ITEM NO. 29 CONTINUED i "S.2.4 After entry, an error report is generated to ensure that the proposed changes are feasible and do not violate design limits. If the report indicates design errors, the CRTS coordinator notifies the originator. The originator resolves the' problems and provf des corrected DCNs to the CRTS coordina tor. " The design limits imposed by the CRTS program are process controls at this time. CRTS staff are directed to return all DCNs to Engineering when the addition of cables to trays. I Increases power and control tray fills above 40%. Increases instrument tray fills above 50%. The power and control trays are given a 50.59 review for weight and ampacity limits. Instrument trays are reviewed for weight only. Checked cable trays which exceed limits are redesigned and resutmitted. Checked cable trays which meet design limits are resubmitted to CRTS after the 50.59 review. The weight and dimensional data for the approximately 450 cable codes will be validated against available i manufacturers' data or validated against a sample or model. 3.2.3 The 50.59 review for design work done in 1975-1986 was provided through the disposition process of NCR l S-7439. Future Corrective Actions LBefore end of Cycle 8 Outage] 3.2.4 USAR wording will be revised and clarified as described in the c"mnentary to CRTS Action Item 17. 3.2.5 Following completion of the completeness checks on i CRTS content (CRTS Action Items 10,11,12,13, and 14), the impact of any added cables will be reviewed. In addition, the impact of weight 1 contributions from various sources such as cable tray 1 covers and protective fire wraps will be checked 4 against design limits. l l l

Enclosure To GCA 88-136 ,, Page 97 ITEM N0.'29 CONTINUED i 3.2.6 CRTS sof tware will be. enhanced to automatically block cable additions which exceed design limits. In addition to calculating percentage fill, CRTS will calculate weight per cable tray section. Desi gn - changes which exceed the minimum 50 pounds per linear foot limit will not be accepted without a 50.59 review.

4. 0 CRTS AND DATA-DISCREPANCIES Report Ref:

CRTS Action Item 2 l Direct Cause: Inadequate procedural guidance. Root Cause: The root cause of the problems related to the CRTS and its use is that neither Nuclear Engineering management nr-the CRTS Supervisor were adequately involved in tne CRTS. Corrective Actions: The large number of data discrepancies concerning the Rancho Seco Cable Raceway Tracking System originate from a number of sources. Many of these problems have occurred because of a lack of procedural i i guidance, such as the intermixing of power, control, and ) instrumentation cables; the overfilling of raceways; the misrouting l of cables; and are discussed elsewhere in this commentary, as well as in separate comentaries within this report. It is important to i note that no physical cable problem or CRTS data discrepancy has l been caused by the CRTS program itself, but have been caused by l sources external to the CRTS program. As described in Section 6.0, l the sof tware problems affect solely the ability to generate the I various CRTS reports and have not affected the accuracy of the CRTS database, nor have data been lost. An additional source of potential data discrepancies that must be-examined would be the possibility of data discrepancies occurring during the inputting of data into the CRTS database. This question was raised with the CRTS staff, and it has been determined that an t l insignificant number of data discrepancies can be attributed to this source for the following reasons-l 1) The CRTS sof tware performs checking of input data. Errant data such as non-existent cable codes or non-existent raceways [in cable routesj cannot be entered since the self-checking mechanisms in the CRTS program would block such errors. l

Enclosure To GCA 88-136,'Page 98 ITEMiNO. 29 CONTINUED v i 2) A hardcopy is made of all newly entered. data -and is checked by the CRTS staff to ensure that the data have baen input correctly. In addition,.upon ECN closure when the. proposed' data is changed to as-built data, the yellow CRTS related DCNs are checked against the data base to verify the accuracy of the

database, i

3) The Modifications Card Control Group, upon receipt of the CRTS q i generated cards, compares the data on the cards against the DCNs to the applicable CRTS-related drawings.(E-1008 and E-1010) to ensure that the data were input correctly into the da tabase, r Individually, each of the above three methods does not provide complete assurance against data input errors; however, together the three methods provide an interlocking mechanism to screen out data input errors to the CRTS utabase. Of the approximately 8000 total CRTS database discrepancies listed in the Action Plan [ Appendix (2)], approximately 2500 are document discrepancies. Of the 2500 i docament discrepancies, none is as a result of a mismatch between the CRTS-related drawings and the CRTS data base itself. 1 As a result of corrective actions for other CRTS related problems, an increased emphasis was placed on fomalizing the methods by which the CRTS staff performs its work, as well as how the CRTS staff interfaces with the other plant groups such as Hodifications Card Control and the Records Information Center. This has been done by CRTS office desktop procedures, as well-as a flow chart [ Figure (3)] delineating the CRTS staff interfaces with Modifications Card Control Group and the Records'Information Center. Forecast completion for proceduralizing the activities of the CRTS staff is prior to the end of the Cycle 8 outage. 5.0 CRTS AND DOCUMENTS OF RECORD - Report Ref: CRTS Action Items 3 and. 22. Problem: The documents of record [CRTS cards) for cable and raceway installed at Rancho Seco are incomplete. CRTS input documents [ Form E-1010, etc.] were not being controlled as Drawing Change Notices. Direct Cause: Lack of CRTS use procedures. i l 2 --n. , - - - - -. -,,.,,,., ~,. -.,,

Enclosure To GCA 88-136, Page 99 ITEM N0. 29 CONTINUED Root Cause: The root cause of the problems related to the CRTS and its use is that neither Nuclear Engineering management nor the CRTS Supervisor were adequately involved in CRTS. Corrective Actions: Corrective Actions for both Installation Verification Records and Engineering Design Records are as follows: Installation Verification Records The installation verification records for installed cable and raceway at Rancho Seco are the signed cable pull cards and raceway installation cards, respectively. The original cards for the 14,000 cables and 13,000 raceways installed during the construction of Rancho Seco have not been found. Facsimile copies exist as attachments to the Construction Inspection Data Reports (CIDRs) and require sorting and filing to verify completeness. This activity l will be performed prior to the end of the Cycle 8 outage. Presently, af ter the signed, completed CRTS generated cards are returned to CRTS, the CRTS staff prepares the cards for microfilming by the Records Information Center in order to be part of the permanent plant microfilm record. The cards are then returned to CRTS for storage in the Bechtel Building vault, a secure, locked room with cement walls and a Halon fire protection system. As described in the commentary to CRTS Action Item 3, not all CRTS generated cards have been located. Corrective action is to generate replacement cards to be checked against the design documents. Checked cards will be stamped "Replacement Card" and will then be signed by the checker. This activity was completed for Class 1 and Appendix R pull cards through disposition of NCRs S-6549, S-7651, S-7652, S-7719, 5-7741, and S-7770. All other cards will be complete before the end of the Cycle 8 outage. In addition NEAP 4127 was issued on June 15, 1987 and revised on December 14, 1987 and is considered adequate to control tne CRTS generated cards in tne future. See also Section 2.0 of tnis commentary. Engineering Design Record NEAP 4127, "Cable and Raceway Tracking System," defines the CRTS-related drawings as follows: E-1008 Shows raceway sections, including attributes and connections.

Encl osure d To GCA 88-136 i, Page 100 i ITEM N0. 29 CONTINUED E-1010 Shows cables, including termination, cable code, ( conductors, and vias as applicable. E-1026 Adds, deletes, or modifies a raceway code, j E-1027 Adds, deletes, or modifies a cable code. E-1028 Adds, deletes, or modifies an equipment number, i In January 1987, ODR 87-66 and NCR S-6278 document that the E-1010 drawings were not being processed in accordance with Nuclear 1 Engineering Procedures. As corrective action, a memo [EEGS 87-005] from E. J. Gough to the Electrical Engin:ering Staf f, dated May 1, 1987, was issued to require that the CRTS-related drawings.be issued and revised per thfen NEP 4103 and NEP 4112, respectively, now NEAP 4103 and NEAP 4112. 6.0 CRTS AND SOFTWARE PROBLEMS Report Ref: CRTS Action Item 10. i Problem: The CRTS software has 52 identified bugs. Direct Cause: The direct cause of CRTS software bugs is the lack of verification of the CDC sof tware. Root Cause: A root cause investigation is not required. The direct cause is considered definitive. l Correcti ve Actions: Immediate Actions -- Pre Restart Four personnel have been added to correct software problems. A l computer data base has bee.1 established to track the 52 identified bugs to resolution. All bugs which impact restart commitments were identified and corrected. Future -- Post Restart Information Services Department assisted by Nuclear Engineering Department is preparing a senedule and budget for providing upgraded CRTS sof tware, including verification and validation. The schedule will show the upgraded software verified and in l place before the conclusion of the Cycle 8 outage.

f Enclosure To GCA 88-136 i Attaciunent 4 Page 101 Figure 1 l RANCHO SECO NUCLEAR GENERATION STATION CASLE RACEWAY TRACKING SYSTEM (CRIS) ORGANIZATION CHART I I I DOUGLAS M. PALMER f f CRIS ADMINISTRATOR l l I I SAR8 ARA YOUNGQUIST JEFF JORGENSEN CRIS COORDINATOR APPLICATIONS ENGINEER l Operations Sapport Project Tema Lead JULIE FRANKS STEPHANIE PATTERSON MIKE KYLLO NANCY PIASTUCN ENGINEERlWG AIDE DATA ENTRY CLERK CRIS ENGINEER LEAD PROGRAfeIER CRIS Processing CRIS Processing Technical Procechares (On toast from IS) i [ 1 i I 6 ..-.s -

Enclosura To GCA 88-136 Attachraent 4. Page 102 Figure 2 RANCHO SECO NUCLEAR GENERATING STATION SYSTEMS SUPPORT ORGANIZATION CHART MOY BASU (S) Supervising Engineer 3 System Support MS 208-2 (ext 3990) ROSE CREWS (S) SEV MADDEN (SUN) UTC Clerical Stpport UTC Clerical Stoport MS 208 2 (ext 3920) MS 208-9 (ext 3848) l l RAM GUPTA (S) FRED DIVSALAR (S) SARIN KUMAR (S) Principal Engineer Principal Engineer Principal Engineer Systems SOP /MSSS Physical /CRTS EQ/Special Projects MS 208-2 (ext 3921) MS 201-111 -(ext 4125) MS 208-9 (ext 3821) I SEN SUPREMO (I) LESTER LEW (B) DOMENIC MICHEFONE (S) DOUG PALMER (I) RON WISE (I) QURAISH DIWAN (S) SOP Lead NSSS Lead Physical Lead CRis Lead EQ Lead Special Projects Lead MS 208-2 (ext 3921) MS 208-2 text 3926) MS 201-T11 (ext 4529) MS 201-111 (ext 4051) MS 2C8 9 (ext 3848) MS 208 9 (ext 3823) { I i I PAUL GILL (I) 808 ANDERSON (S) FRED AYRAM (B) JULIE FRANKS (ST) JEFF GE8HARDT (I) DEAN TL4 (8) DJ.YE LEDOUX (S) CEORGE JONES (S) ART CRUZ (B) JEFF JOR M NSEN (I) YOGESH PATEL (I) JESSIE PINEDA (I) RUDY MOSQUEDA (8) CARY ENG (8) MIKE KYLLO (I) BRONCO PETROVICN (8) STEPHANIE PATTERSON (V) I MANNY YOUKHANA (8) SARSARA YOUNGQUIST (S) f i 4 t 1 ~ t m

u. ~. :-. =..: - :-......---.....--.-.

a Enclosure

'l To GCA 88-136 ) l ., Page 103 Figure 3, Sheet 1 of 2 l i CRTS FLOWCHART CCN OR OCP CONCEPTUAL DES!CN APPROVED 1 ' r NUCLEAR ENGINEERING (ELECTRICAL) o PREP ARES DCNe FOR 199$e AND lette 2 (ALSO 19 26 e, 1927s, AND 1920e AS APPLICABLE) o CRICINAT06 AND CMECKER SIGN j u CRTS COORDINATOR o INPUTS D AT A FROM OCNe o RUNS ERROR REPORT ~~ IS RE80RT No CtROR-FREE TO CR!CINATOR YES ' r CRT.S C00R0!NATOR o INITIALS DCNe 'r SUPERv! SINC ENGINEER o SICNS DCNo o SENOS DCNe TO OC WITH TRANSMITTAL u 00CVMENT CONTROL I o ISSUES DCNe FOR PLANT REY!EW IP / No DOCUMENT CONT 0RL CONSTRUCT!91LITY o RETURNS OCNo APPROVED To ORICINATOR 1 ,,YES 00CVMENT CONTROL o ISSUES DCNe PINK I ep ins. L

...... 3 g. + :. -..a,.... ....:. =..~. .a y, n ' ' Enclosure To GCA 88-136 Attschment 4 Page 104 Figure 3. Sheet 2 of 2 CRTS FLOWCHART (CONTI.NUED) h a CRTS COCRCINATOR o PRINTS INST =LLATICN CARDS AWC TAC $

m.

USER GROUP (MA!WT/N0DIF) o O!STRIBUTCS CeROS o 'ERFORMS WORK 2 o CAN O NO ggggtfMgggy o PREP ARES FPR ORAWINGS 7 YES o NAINT/MODIF AND QC o COMPLETE WORK.AND INSPECT!0NS o $1CN OFF CARDS o CRTS C0CRDlHATOR o RECElvES CARDS o INPUTS AS-Bu!LTS DATA FRon CARDS o RVNS FINAL ERROR REPCRT ON CARDS RETVRNED o HOLDS CARDS UNTIL ECN/ DCP CLOSURE 1 DOCUMENT CONTROL o RECElvES CARDS FROM CRTS COORDINATOR o MICROFILMS CARDS o DISTRIBUTES OUPLICATE COPIES o FILES ORIGINAL CARDS wee u 7i t l

Enclosure To GCA 88-136 ', Page 105 ITEM NO. 30 i DESCRIPTION Review of corrective actions against root cause enluations. l COMMENTARY A table sumarizing direct and root causes is included at the end of this comentary. A detailed review of recomendations contained in each root cause is given in the comentary. R,00T CAUSE 66-10 l Redundant cabling in the same fire area [LER 86-10]. SUM 4ARY l The direct cause of the failure to reroute the cables is personnel error. Although the construction field engineer was aware ~ of the routing revisions, he did not initiate the field installation of the "C" revision of the cable routing. The underlying cause is that the Modifications Card Control Group did not follow EnBaering and Inspection Instruction [EII] EC-10 "Processing of Insta11atun Cards." A contributing cause of this event was Quality Assurance's failure to perform adequate inspections of cable installations. The root cause is the failure of the Card Control Group cognizant engineer to implement adequate managerial controls. He did not require the use of i adequate and formal procedures for the processing of installation cards by the Modifications Card Control. Recomendations Corrective Actions 1.-4. Issue a procedure (s) which CRTS card control is described in

7. 8.

establishes instructions for Attachment I to NEAP 4127 Rev.1. 16. the processing of cable is a CRTS flowchart which 17. installation cards, illustrates the process from ECN issue to the filing of the CRTS cards following ECN closure. l I i

Enclosure To GCA 88-136, Page 106 ITEM NO. 30 CONTINUED Recommendations Corrective Actions A more detailed card handling process is provided in a card flowchart included as part of CRTS Action Item 29 comentary. This flowchart illustrates the decision-making process used by the Card Control Group [see organization chart for CRTS also included with the Item 29 comentary) in handling cards. Electrical Engineering Instruction, j EEI-10 "CRTS Installation Card Flow." issued on February 10, 1988, describes j l the method by which the CRTS staff i l interacts in the routing of CRTS l installation cards. 5. After the procedures (NEAP Formal training is being conducted 4127. EEI-8, EEI-9, and for personnel who are either in the EEI-10) are issued, train Modifications Card Control Group or i l the Modifications Card who handle CRTS cards in the inter-1 Control Group on the facing groups (Modifications, Mainte-procedures, nance, Quality Control, etc. ). This i training will.also be conducted for new l personnel entering these groups in an l ongoing process. Training is conducted under the auspices of Nuclear i Engineering with classroom training and with records maintained in both NE i i files and by the Nuclear Training Group. l 9. Establish a SMUD signature SMUD Support Services-Records transcription policy. Management Group [RMG] establisned j policies and practices concerning records management. These policies and practices, defined in RSAP-0601, "Nuclear Records Management" do not perir't the transcription of

.ne'ures.

Section 5.2.9 "Replacing a <maged or Contaminated Document" l ,,..n as the process by which lost or damaged records are replaced.

i Encl osure To CCA 88-136 = j, Page 107 ITEM NO. 30 CONTINUED ~ Reconnendations Corrective Actions-l 9. (Continued) Recreated originals are allowed for I information [ data] documents, but control measures are imposed on other i records which require assessments and evidence to support restored records. RM; tas no plans to establish a SMUD signature transcription policy. Transcribing signatures without compliance with RSAP-0601 would be a violation of SMUD administration policy. 11. Evaluate the cable inspection MP/IS-307 will be evaluated against the 12-17. requirements as stated in findings of the CRTS Action Item 25. MP/IS-307 to ensure that Document a thorough engineering the following are adequately evaluation of the procedures and addressed: specifications used to install cable in the period 1976 - 1986. The scheduled a. Cable pulls are issue date for the revised MP/IS-307 inspected before the was December 11, 1987. However, no cable is terminated as changes are required; MP/IS 307 is required by the USAR. acceptable as-is, b. Cables are verified to be routed in accordance with the latest design drawings. c. Clear guidelines exist for the inspection of pulleo back and repulled cable. 6. Route the cablee described in LER 86-10: The cable rerouting for LER 86-10 and 8.EA 87-13 in cables identified in LER accordance with the 86-10 was performed under applicable design drawings ECN R-0765 and is (completed]. construction complete. LER 87-13: The cable reroutim for cables identified in LER 87-13 was performed under l Work Request 128636 and is construction complete. 4

r 1 Enclosure To GCA 88-136, Page 108 ITEM NO.-30 ~ CONTINUED ROOT-CAUSE 87-03 Cable Raceway Tracking System.

SUMMARY

The root cause of the problems related to the CRTS and its use is that neither Nuclear Engineering management nor the CRTS supervisor were adequately involved in the CRTS. Recommendations Corrective Actions 1. None, NEAP 4127 "Cable and Complete Raceway Tracking System" was issued on June 15, 1987. 2. Revise procedure NEP 4109 Procedure NEAP 4127, Revision 0 was "Configuration Control" to issued on June 15, 1987, and revised on address the CRTS review of December 14, 1987. It includes, in DCNs. Section 5.2, the procedure by which DCNs to CRTS-related drawings LE-1008, E-1010. E-1026, E-1027 and E-1028] are initiated, reviewed, and approved. Sections 5.2.2 through 5.2.5 specifically address the CRTS review of the DCNs to the CRTS-related drawings, and no further procedural revision is requi red. 3. Review and approve for use a An uncontrolled CRTS User's Guide in CRTS User's Guide. the CRTS staff and in Modifications Card Control was superseded by three desktop guides issued on February 10, 1988: o eel-8, "CRTS Electrical i Designer's Guide" l o eel-9, "CRTS Computer Operations l Gt,ide" o eel-10. "CRTS Installation Card i Fl ow" ---e-w +--., ,-+p-.- g - ~ -. >, ~, - - r r~ g

( Enclosura To GCA 88-136, Page 109 ITEM NO. 30 CONTINUED Recommendations Corrective Actions-4.8 Verify and validate CRTS The corrective actions are described in

software, the commentary to CRTS Action Item 10.

5.9 Develop and implement a The comentary to CRTS Action Item 2 schedule to correct all contains the general commitment that: known CRTS deficiencies. 1. All safety-related discrepancies were dispositioned with documentation. This item is complete. I 2. All non-safety-related discrepancies will be dispositioned, with documentation, prior to the end of the Cycle 8 outage. Attachments 1, 2, and 3 of the Wire and Cable Program Report provide an index to CRTS action items, CRTS ODRs, and CRTS NCRs which track all discrepancies and their dispositions. ~ 6. Include the CRTS system in NEAP 4127 was issued on June 15, 1987 the Quality Assurance and revised on December 14, 1987. NEAPS

program, are controlled by the Rancho Seco Quality Assurance program.

This item is complete. 7. Establish the design basis A CRTS System Design Basis Document for the uses of the CRTS will be written as part of the system. NED/ Electrical Discipline program to furnish design basis documents defining i the criteria for [and the scope a d function of] all electrical systems. The CRTS System Design Basis Document is scheduled for issue prior to the end of the Cycle 8 outage. J

- Encl osure To GCA 88-136 Page 110 ITEM N0. 30 CONTINUED ROOT CAUSE 87-05 Overweight cable trays [LER 87-24]. SUfHARY The direct cause of the overweight cable tray problem is inadequate procedural guidance. The root cause of the overweignt cable ~ tray problem is the failure to ensure adequate procedural implementation' of USAR requirements. Recomendations Corrective Actions 1. Perform 10 CFR 50.59 Safety The 50.59 reviews were performed via Analysis Reviews for the the NCR S-7439 disposition process. redundant [SFAS apd RPS] Class lE caole trays that 1 exceed the USAR fill limit of 401,. 2. Provide calculations to The corrective actions for overfilled verify the cable tray cable trays are contained in the loading for all overfilled comentaries to CRTS Action Item 3 6 and cable trays. 8. An additional commitment to check all tray weights (regardless of fill level] prior to restart is contained in the comentary to CRTS Action Item 2. This recheck was perforred on December 28, 1987, as described in the comentary to CRTS Action Item 2. 4. Proceduralize the approval CRTS error reports indicating tray cycle required to exceed the overfill conditions cause the DCNs to fill limits on cable trays, be returned to the originator for d resolution. This is described in the comentary to CRTS Action Item 8. This review process is proceduralized in NEAP 4127. EEI-8, and EEI-9. 5. Resolve the discrepancy The USAR revision to provide between procedure NEP 5204.22 reconciliation between USAR Section and the USAR. 8.2.2.11.H.9 and NEP 5204.22 is described in Section 6 of the comentary to CRTS Action Item 17

[ Enclosure To GCA 88-136 ,, Page 111 ITEM NO.-30 CONTINUED Reconnendations Corrective-Actions 6. Evaluate adding a subroutine The connentary to CRTS Action Item 10 to the CRTS to calculate includes a list of software cable tray weights, enhancements. Enhancement N3 will provide a weight calculation for all i cable trays regardless of fill level, i ROOT-CAUSE 87-09 Unacceptable intermixing of power / control end instrumentation cables [LER 87-26]

SUMMARY

Cable Tray A28AA3 and A28AB3 Direct Cause: Construction error. Underlying Cause: Construction personnel failure to follow Procedure EC-10. Contributing Cause: Failure of QC to detect construction error. Cable Tray A28AN3 Direct Cause: Design error. 1 Contributing Cause: Lack of a comprehensive service level designator. Cable Tray A28AAl Direct Cause: Either a design error or a construction error during-construction of the plant. Contributing Cause: Lack of a comprehensive service level designator. Routing RPS/SFAS Cables in Tray Rather than Conduit Direct Cause: Original design error. Underlying Cause: Lack of training. I I i

Enclosure To GCA'88-136, Page 112 ITEM N0. 30 CONTINUED Cables Associated with DHS X-Tie Flow Transmitters Direct Cause: Design error. Underlying Cause: Lack of training. Cables Associated with RCS Flow Transmitters Direct Cause: Original Design error. Underlying Cause: Lack of training. ROOT CAUSE (Overall) Failure to have and/or use procedures for cable design, installation, inspeccion, and repulling. Recomendations Corrective Actions (1 ) Revise electrical design The USAR text is being revised as procedures to include described in CRTS Action Item USAR requirements. Comentary 17. Corresponding revisions to Design Documents NEPM 5204.22 and NEPM 5204.43 were issued on October 5,1987. Refer to CRTS Action Item Comentary 9 for

details, j

l (2) Require the witnessing of Complete. PCN e4 [07-01-87] revised { cable pulls by electrical MP/IS 307. See cocoentary to CRTS QC inspectors. LCompleted) Action Item 29 (Section 2.3]. (3) Evaluate the training given Supervisors attend numerous training to District supervisors to programs provided by SMUD to improve j ensure that they are fully their management skills. There is no i cognizant of their areas formal training on their specific areas j of responsibilities, of responsibilities. Informal training is provided by supervisor's reyective

manager, j

(4) Assure that all QC inspectors

Complete, receive training on District procedures.

[ Completed] I

{ ] Enclosure To GCA 88-136 < Page 113 ITEM NO. 30. CONTINUED Recomendations Corrective Actions-(5) Provide a service level Since July 1987, cable input documents designator for all are marked P [ Power), C [ Control) electrical cables, or I [ Instrumentation]. Software enhancements are also planned. See CRTS Action Item Comentaries 9 at:d 10 for details. (6) Provide the necessary CRTS . Refer to the. comentary to CRTS Action sof tware for the verification Item 10. that intermixing conditions do not exist. (7) Evaluate the necessity for a Per MP/IS 307, cable installation is CRTS generated repull card. performed using both the E-1010 series drawing and the CRTS generated card. Repulls are presently indicated on the E-1010 series drawing via field note. The recomendation to generate a unique CRTS repull card will also be included in the list of CRTS enhancements in the comentary to CRTS Action Item 10. (8) Issue procedures for the use Complete. NEAP 4127 was issued of the CRTS [ Completed] June 15,1987 and revised December 14, 1987. (9) Establish the design basis See response to RC 87-03 (11 ) for the uses of the CRTS recomendation 7. (15) system [RC 87-03, recomendation 7J. ] (10) Revise / issue procedures for See response to RC 86-10 cable installation to recomendation 11.c address the pull back and rerouting of cable in revised routings. [RC 86-10, recommendation 11.c] (12) Evaluate the training given New engineers attend an orientation and i to entry level engineers to indoctrination course where specific assure that they receive Licensing Basis Documents [LBD] and training on their assigned pertinent job related references are functions, discussed. System training is also provided and is geared to the job i responsibilities of the individual employee. i

[ Enclosure To GCA 88-136 Atcachment 4, Page 114 ) I l ITEM NO. 30 CONTINUED Recommendations Corrective Actions (14) Issue a procedure for the See response to RC 86-10 1 processing of installation recommendation 1. cards. [RC 86-10, recommendation 1). (16) Ensure that all engineers, All engineers are trained [4 th including contractors, documentation) by roading selected NED receive training on USAR and project adninistrative procedures requirements for their as assigned by the NED Training job function. Coordinator. Additionally, selected SMUD and contract personnel are trained to Rancho Seco LBDs as applicable to 10 CFR 50.59 reviews. ROOT CAUSE 87-02 Pulled cables stored in safety-related breaker cubicles LLER 87-16).

SUMMARY

The direct cause of the coiled cables 5eing left in all the cabinets, other than A405 and A409, was a planning error: the cable terminations should have been scheduled to occur imediately following tr.e cable pull, but were not. The direct cause of the coiled cables being left in cabinets A405 and A409 was a design error; the effects of the coiled spare cables on the seismic analysis were not considered. The Root Cause of cables being lef t coiled and unrestrained in safety-related breaker cubicle cabinets was inadequate procedures for the installation of electrical cables. Recommendations Corrective Actions 1. Evaluate the pulling of cables See response to RC 86-10 Recomendation into and the coiling of cables 11. [For recommendations 1, 2, 3, 4, in existing plant equipment, and 5.] Based on the findings of the 1 evaluation, revise Procedure EM.187 and the commitments made in LER 87-16. Update LER 87-16, as appropriate. i d , = - - -

Enclosure To GCA 88-136 ', Page 115 ITEM NO. 30 CONTINUED Reconnendations Corrective Actions 2. Rt ise EM.187 "Control of Electrical Plant Modifications" to either: 1) provide guidelines for tne cable configuration where the cable has been pulled into existing plant equipment and cable termination will not be accomplished innediately af ter the cable pull or 2) prohibit the pulling into and coiling of cable in existing plant equipment. 3. Provide guidelines in the Maintenance and Modification Department procedures concerning what types of equipment or what equipment may have cables pulled into ano coiled when termination is not sc: eduled to occur i icnediately. 4. Revise MP/IS 307, "Cable Installation," and EM.163, "Installation of Pennanent Plant Cables," to describe the process by which cables are declared to be spares. 5. Revise Procedure AP.44, "Plant Modifications - ECN Implementation," to include the coordination of work between Construction and Electrical Maintenance personnel for electrical modifications.

I Table 1 C 4.0 S E 5 0F CA5LE D I S.C E E F A N C I E S IIRC j BC Seport and Problem Area Direct Cause/s Other causes Boot (46ee NED Direct Cause BC 86-10 + ted.edas' Cables Fer6 easel errer CCC did met follow Failure of CCC Cog e Constructica pereoasel l i 12 the Sese Fire precedure EC-10. enstaaer to laplement error. Arsa. QC failure to 1 aspect. centrole. e Inadeguate card control. / { RC S1-0) Cable sad Raceuay None stated. Mose stated. NED management and CETS e Various. O l Tsuking System empervisor act adequately e See Wire and Cable h j Lavolved la GTS. Program Esport. Major Q 4 riot,less. cause was a lack of Q TS e ese procedures. 3 sc 87-03 Ove rweight Inadequate precedural Mose stated. Failure to ensure pro-Imadequate procedural sw Cable Trays. guidance. cedural taplementatica guidance. y of USAR requirements. a pl 87-02 C planales error. None. Inadequate precedures Not a CETS-related m Pulled Cables Stored

Design error.

for the installatise of probles. 12 Saf et y-related electrical cables. Not a deelge problem. l Br:aker Cubicle RC 87-29 Various Various Failure to have and/or Construction ~ error et unaccegtable Mistag of e Comattucties error, e Failure of QC to'uso procedures for design error. Fever /Centret end e Destga error, inspecties. cable deelga, lastal-Insa r meest Cables e Fallure to laties, lampection, and follow EC-10. repellies. g = a lack of service --I m level Radicator. e lack of traintag. CI) --* ga C CD 7 CD(D s a b m .}}

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