ML20195H788

Rev 0 to Project Status Rept,Electrical,Comanche Peak Steam Electric Station Unit 1 & Common Corrective Action Program

ML20195H788
Person / Time
Site:	Comanche Peak
Issue date:	01/15/1988
From:	Ackley R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20195H762	List: ML20195H788 TXX-8809, Forwards Rev 0 to Project Status Rept,Electrical,Comanche Peak Steam Electric Station,Unit 1 & Common Corrective Action Program. Resolution to Issues in Electrical Generic Issues Rept Contained in Apps a & B
References
TAC-R00285, TAC-R285, NUDOCS 8801200352
Download: ML20195H788 (118)

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COM ANCHE PEAK STE AM ELECTRIC STATION UNIT 1 and COMMON CORRECTIVE ACTION PROGRAM O

PROJECT STATUS REPO9T ELECTRICAL a

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TV ELECTRIC

, COMANCHE PEAK STEAM ELECTRIC STATION i UNIT 1 AND CO M N STONE & WEBSTER ENGINEERING CORPORATION PROJECT STATUS REPORT  ;

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() TABLE OF CONTENTS Section Title Pa2e EXECUTIVE

SUMMARY

iii ABBREVIATIONS AND ACRONYMS vi

1.0 INTRODUCTION

1-1 Figure 1-1 Corrective Action Program (CAP) - Electrical 2.0 PURPOSE 2-1 3.0 SCOPE 3-1 4.0 SPECIFIC ISSUES 4-1 5.0 CORRECTIVE ACTION PROGRAM (CAP) METH1D0 LOGY 5-1 I AND RESULTb l 5.1 METHODOLOGY AND WORK PERFORMED 5-1 5.1.1 Licensing Commitments, Design Criteria and 5-1  !

t' ' Design Basis Documentation

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5.1.1.1 Verification of Design Criteria and Resolution of Issues 5-1 5.1. 2 Design Validation Process 5-2 5.1.2.1 Electrical Systems Validation 5-2 5.1.2.2 Interfaces 5-8 5.1.2.3 Final Rsconciliation Process 5-8 L 5.1.3 Prst Ccnstruction Hardware Validation 5-9 Irogram (PCHVP) 5.2 RESULTS 5-14 1 F 5.2.1 Design Validation Results 5-14 l 5.2.2 Post Construction Hardware Validation 5-15 Program (PCHVP) Results 5.3 QUALITY ASSURANCE (QA) PROGRAM 5-16

! 5.3.1 Summary of SWEC Engineering Assurance (EA) 5-18 Audits 5.3.2 Summary of Audits by TV Electric 5-19 Quality Assurance (QA), Inspections ,

by HRC"0SP and Anf.its by SWEC-QAAD I

5.4 CORRECTIVE AND PREVENiiVE ACTION 5-20  ;

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Section Title Pm Figure 5-1 Corrective Action Program (CAP)

Technical Interfaces - Electrical Figure 5-2 Post Construction Hardware Validation Program (PCHVP)

Table 5-1 Electrical Design Basis Documents Table 5-2 SWEC Project Procedures Applicable to the Electrical Portion of the Corrective Action Program (CAP)

Table 5 3 Post Construction Hardware Validation Program (PCHVP) - Electrical Table 5-4 Sumary of SWEC Engineering Assurance (EA)

Audits Table 5-5 Sumary of TV Electric Quality Assurance (QA) Audits

6.0 REFERENCES

6-1 APPENDIX A COMANCHE PEAK RESPONSE TEAM (CPRT) AND A-1 EXTERNAL ISSUES APPENDIX B ISSUES IDENTIFIED DURING THE PERFORMANCE B-1 0F THE CORRECTIVE ACTION PROGRAM (CAP)

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( EXECUTIVE

SUMMARY

This Project Status Report (PSR) summarizes the systematic validation process implemented by Stone & Webster Engineering Corporation (SWEC) for safety-related electrical systems at Comanche Peak Steam Electric Station (CPSES) Unit 1 and Common2 . This Project Status Report (PSR) presents the results of the design validation and describes the Post Construction Hardware Validation Program (PCHVP). SWEC's activities were governed by the TV Electric Corrective Action Program (CAP) which required SWEC to:

1. Establish a consistent set of CPSES safety-related electrical design criteria that comply with the CPSES licensing commitments.

2. Produce a set of design control procedures that assures compliance, with the design criteria.

3. Evaluate safety-related electrical syst ens and direct the corrective actions recommended by the Comanche Peak Response Team (CPRT), and those determined by Correctice Action Program (CAP) investigations to be necessary to demonstrate th0t safety-related electrical systems are in conformance with the design criteria.

4. Assure that the validation resolves the safety-related electrical design issues identified by t!.e Comanche Peak Response Team (CPRT), external sources2 and the Correct've Action Program (CAP).

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1 Common refers to areas in CPSES that contain both bnit 1 and Unit 2 systems, structures and components.

2 External sources include:

. NRC Staff Special Review Team (SRT-NRC)

. NRC Staff Special Inspection Team (SIT)

. NRC Staff Construction Appraisal Team (CM;

. Citizens Association for Sound Energy (CASE)

. Atomic Safety and Licensing Board (ASLB)

. NRC Region IV Inspection Reports

. NRC Staff Technical Review Team (TRT) [SSERs 7-11]

. CYGNA Independent Assessment Program (IAP)

Comanche Peak Response Team (CPRT) issues are identified by the following:

. Design Adequacy Program (DAP)

. Quality of Construction Proaram (QOC)

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5. Validate that the safety-related electrical conformance with the licensing commitments and that the installed systems are in hardware is in conformance with the validated design.

6. Produce a set of consistent and validated design documentation.

A consistent set of design criteria for CPSES Unit 1 and Common safety-related electrical systems has been developed and used by SWEC for the design validation process. This set of design criteria is in conformance with CPSES licensing comt.,itments. It has been independently and extensively overviewed by the Comanche Peak Response Team (CPRT). CYGNA Energy Services (CYGNA) independently reviewed the design criteria for safety-related electrical systems for those issues identified during the Independent Assessnent Program (IAP).

SWEC established design control procedures to govern the work flow and technical interfaces with other disciplines for both the design and hardware validation processes. These procedures specify the processes (such as the validation of design inputs, documentation control, and final reconcil-iation) that have been implemented throughout the electrical portion of the Corrective Action Program (CAP).

SWEC has performed analyses and reviewed design documentation to validate the design of CPSES Unit 1 and Common safety-related electrical systems.

The as-built conditions of safety-related electrical systems are being G validated to the design by the Post Construction Hardware Validation Program V (PCHVP).

The Post Construction Hardware Validation Program (PCHVP) assures that safety-related electrical systems are installed in conformance with the validated design. SWEC has reviewed, revised and validated the CPSES electrical installation specification and reviewed the revised construction procedures and Quality Control (QC) inspection procedures for consistency with the validated design and hardware requirements of the Corrective Action Program (CAP). The Post Construction Hardware Validation Program (PCHVP) for safety-related electrical systems including inspections, engineering walkdowns and evaluations, implements the corrective actions recommended by the Comanche Peak Response Team (CPRT), as well as those determined by Corrective Action Program (CAP) investigations.

SWEC will provide TV Electric a complete set of validated design documenta-tion for CPSES safety-related electrical systems including electrical calculations, drawings, specifications and design changes. This documentation r:an provide the basis for CPSES configuration contro13 to facilitate maintenance and operation throughout the life of the plant, 3 Configuration control is a system to assure that the design and hardware bs} remain in compliance with the licensing commitments throughout the i U life of the plant, iv

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In-depth quality and technical audits have been performed by SWEC Quality Assurance (QA), TV Electric Quality Assurance (QA) and the independent Engineering Functional Evaluation (EFE). These audits assured that SWEC procedures, design criteria and design comply with the licensing comitments. The SWEC Quality Assurance (QA) audits verify that the implementation of the Corrective Action Program (CAP) is in conformance with the applicable 10CFR50 Appendix B r6quirements.

The CPSES Unit 1 and Common electrical portion' of the Corrective Action Program (CAP) validates that:

. The design of safety-related electrical systems complies with the CPSES licensing commitments.

. The as-built conditions of safety-related electrical systems and components comply with the validated design.

. The safety-related electrical systems and components comply with the CPSES licensing commitments and will perform their safety-related functions.

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t ABBREVIATIONS AND ACRONYMS A, a Ampere AC, ac Alternating Current A-H Ampere-Hour ANSI American National Standards Institute ASLB Atomic Safety and Licensing Board BOP Balance of Plant C Degrees Centigrade CAP Corrective Action Program (TV Electric)

CAR Corrective Action Request CARDS Cable and Raceway Data System CASE Citizens Association for Sound Energy CAT Construction Appraisal Team (NRC)

CFR Code of Federal Regulations CPE Comanche Peak Engineering CPRT Comanche Peak Response Team CPSES Comanche Peak Steam Electric Station CYGNA CYGNA Energy Services DAP Design Adequacy Program DBA Design Basis Accident DBCP Design Basis Consolidation Program DBD Design Basis Document DC, de Direct Current DIR Discrepancy Issue Report (CPRT)

DR Deficiency Report O DSAP DVP Discipline Specific Action Plan Design Validation Package EA Engineering Assurance (SWEC)

Ebasco Ebasco Services Incorporated ECSA Electric Conductor Seal Assemblies EFE Engineering Functional Evaluation ERC Evaluation Research Corporation F Degrees Fahrenheit FSAR Final Safety Analysis Report FVM Field Verification Method GDC General Design Criteria GIR Generic Issue Report HELB High Energy Line Break HVAC Heating, Ventilation and Air Conditioning IAP Independent Assessment Program (CYGNA)

IE Inspection and Enforcement (NRC)

IEEE Institute of Electronics and Electrical Engineers Impell Impell Corporation IRR Issue Resolution Report ICEA Insulated Cable Engineers Association ISAP Issue Specific Action Plan kV Kilovolt LOCA Loss of Coolant Accident MELB Moderate Energy Line Break MSLB Main Steam Line Break O NCR NE0 NIS Nonconformance Report Nuclear Engineering and Operations Nuclear Instrumentation System vi

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N00 Notice of Deviation NOV Notice of Violation NRC United States Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG NRC Document OSP Office of Special Projects (NRC)

PCHVP Post Construction Hardware Validation Program PIES Preinsulated Environmental Sealed PSR Project Status Report QA Quality Assurance '

QAAD Quality Assurance Auditing Division (SWEC)

QC Quality Control QOC Quality of Construction and QA/QC Adequacy Program (CPRT)

RCP Reactor Coolant Pump RES Radiant Energy Shield RIL Review Issues List (CYGNA)

SBM Separation Barrier Material SDAR Significant Deficiency Analysis Report (TV Electric)

SER Safety Evaluation Report (NRC, NUREG-0797)

SIT Special Inspection Team (NRC)

SSER Supplemental Safety Evaluation Repnrt (NRC, NUREG-0797)

SSII Safety System Inoperable Indication SRT Senior Review Team (CPRT)

SRT-NRC Special Review Team (NRC)

SWEC Stone & Webster Engineering Corporation SWEC-PSAS Stone & Webster Engineering Corporation Pipe Stress and Support Project SWRI Southwest Research Institute SWSQAP Stone & Webster Quality Assurance Program TAP Technical Audit Program (TV Electric)

TERA Tenera, L.P.

TRT Technical Review Team (NRC)

TDR Test Deficiency Report UPS Uninterruptible Power Supply V Volt (AC) ,

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1.0 INTRODUCTION

In October 1984, TV Electric established the Comanche Peak Response Team (CPRT) to evaluate issues that have been raised at CPSES and to prepare a plan for resolving those issues. The Comanche Peak Response Team (CPRT) program plan was developed and submitted to the NRC.

In mid-1986, TU Electric performed a qualitative and quantitative review of the preliminary results of the Comanche Peak Response Team (CPRT). This review identified that the Comanche Peak Response Team (CPRT) issues were broad in scope and included each discipline. TV Electric decided that the appropriate method to correct the issues raised and to identify od correct any other -issues that potentially existed at CPSES would be through one integrated program rather than a separate program for each issue. TV Electric decided to initiate a comprehensive Corrective Action Program (CAP)

(References 1, 2, and 3) to validate CPSES safety-related designs.1,2 The Corrective Action Program (CAP) has the following objectives:

. Demonstrate that the design of safety-related systems, structures and components complies with licensing commitments.

Demonstrate that the existing systems, structures and components

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are in compliance with the design; or develop modifications which will bring systems, structures, and components into compliance with design.

Develop procedures, an organizational plan, and documentation to O .

maintain compliance with licensing commitments throughout the life of CPSES.

The Corrective Action Program (CAP) is thus a comprehensive program to validate both the design and the hardware at CPSES, including resolution of specific Comanche Peak Response Team (CPRT) and external issues.

1 1 Nuclear Steam Supply System (NSSS) design and vendor hardware design and 4

their respective QA/QC programs are reviewed by the NRC independently of 1 CPSES as noted in SSER 13 and are not included in the Corrective Action Program (CAP); however, the design interface is validated by the CAP.

2 Portions of selected non-safety-related systems, structures and compo-nents are included in the Corrective Action Program (CAP). These are Seismic Category II (Reference 32) systems, structures and components, and fire protection systems.

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i TV Electric contracted and provided overall management to Stone & Webster Engineering Corporation (SWEC), Ebasco Services Incorporated (Ebasco), and  ;

Impe11 Corporation (Impell) to implement the Corrective Action. Program (CAP) ,

and divided the CAP into eleven disciplines as follows:

Discipline Responsible Contractor Mechanical SWEC i

-Systems Interaction Ebasco

-Fire Protection Impell Civil / Structural SWEC Electrical SWEC Instrumentation & Controls SWEC I

Large Bore Piping and Pipe SWEC-PSAS Supports ,

Cable Tray and Cable Tray Hangers Ebasco/Impell Conduit Supports Trains A,B, & C >2" Ebasco Conduit Supports Train C s 2" Impe11 Small Bore Piping and Pipe Supports SWEC-PSAS Heating, Ventilation and Air Ebasco Conditioning (HVAC)

Equipment Qualification Impell .

' A Design Basis Consolidation Program (DBCP) (Reference 4) was developed to define the niethodology for SWEC performance of the design and hardware i

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validation. The approach of this Design Basis Consolidation Program (0BCP) is consistent with other contractors' efforts and products.

The design validation portion of the Corrective Action Program (CAP) .

identified the design-rclated licensing commitments. The design criteria were established from the licensing commitments and consolidated in the  !

Design Basis Documents (DB0s), The DBDs identify the design criteria for i the design validation effort. If the existing design did not satisfy the design criteria, it was modified to satisfy the design criteria. The design validation efforts for each of the eleven Corrective Action Program (CAP) r disciplines are documented in Design Validation Packages (DVPs). The Design i Validation Packages (DVPs) provide the documented assurance (e.g.,

calculations and drawings) that the validated design meets licensing O commitments, including resolution of all related Comanche Peak Response Team (CPRT) and external issues. ,

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The design validation effort revised the electrical installation specification to reflect the validatni design requirements. the validated electrical installation specificat,i n also contains the inspection requirements necessary to assure that the as-built hardware. complies with the va?idated design.

The hardware validation portion of the Corrective Action Program (CAP) is implenented by the Post Construction Hardware Validation Program (PCHVP) which demonstrates that existing safety-related systems, structures and components are in compliance with the electrical installation specification and design drawings (validated design), inciuding the modifications that are necessary to bring the hardware into compliance with the validated design.

> The results of the performance of the Corrective Action Program (CAP) for eacn discipline are described in a Project Status Report (PSR). This Project Status Report (PSR) describes the results for the electrical portion of the Corrective Action Program (CAP).

SWEC has performed a comprehensive design validation of safety-related electrical systems for CPSES Unit 1 and Common in order to demonstrate that the design of safety-related elec.trical systems complies with licensing commitments. SWEC is performing the Post Construction Hardware Validation Program (PCHVP) to demonstrate that tne as-built safety-related electrical

systems and components comply with the validated design. The validation process is conducted in accordance with the Design Basis Consolidation O Program (DBCP) which controls implementation of the SWEC portion of the TU V

Electric Corrective Action Program (CAP), shown schematically in Figure 1-1.  :

The safety-related electrical systems design bases are contained within a l consolidated set of CPSES Design Basis Documents (DBDs).

The methodology used in implementing both the design and hardware-related validations for CPSES Unit 1 and Common safety-related electrical systems and the results of the validation effort are presented in this Project Status Report (PSR).

The electrical Project Status Report (PSR) describes the validation effort from the early stages of design criteria development through the implementa-tion of the Post Construction Hardware Validation Program (PCHVP). Tnis report addresses the updating of the installation specifications, construction procedures and Quality Control (QC) inspection prncedures, the development of the Post Construction Hardware Validation Program (PCHVP) used to validate the as-built safety-related electrical systems and components to the validated design, and the completion of the CPSES Unit 1 j and Common Design Validation Packages (DVPs).  :

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.1 e FIGURE 1-1 f CORRECTIVE ACTION PROGRAM (CAP)

EL ECT RlC AL 4 IDf,fiTIF Y LIC ENSING FSAR COM MITM ENT S C OTHER LIC ENSING DOCUM ENTS 1 r DEVELOP DESIGN S ASIS DOCUM ENTS 1080s) 1 P

. PERFORM DESIGN CPRT (DAP & OOC) ISSUES V ALID ATIO N C EXT ERN AL ISSUES:

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15 MO DIFIC ATION R EQ UI R E D YSS m DEST 0N MO DIFIC ATIO N S

- NRC INSPECTION REPORTS 7

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2.0 PURPOSE ,

• O The purpose of this Project Status Report (PSR) is to demonstrate that the safety-related electrical systems of CPSES Unit 1 and Common are in conformance with the CPSES licensing commitments, satisfy the design criteria, and that the electrical systems will satisfactorily perform their  !

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,O 3.0 SCOPE V

The scope of the electrical portion of the Corrective Action Program (CAP) implemented for CPSES Unit 1 and Common included all safety-related elec-trical systems. The validation included the following electrical systems:

. 6.9 kV Electrical Power System i

. 480 V and 120 V Electrical Power Systemt

. Uninterruptible Power Supply System 2

. DC System In addition, the non-safety-related Preferred Power Systen was validated for compliance with 10CFR50, Appendix A, General Design Criterion (GDC) 17.

The electrical portion of the Corrective Action Program (CAP) is shown schematically in Figure 1-1 and is discusnd below. The program required:

1. Establishment of electrical design criteria which comply with licensing commitments.

2. Development of the electrical Design Basis Documents (DBDs) for CPSES which contain the design criteria.

3. Implementation of design and hardware validations, consisting of analysis, identification and implementation of necessary modifications, and field verifications as identified in the Post Construction Hardware Validation Program (PCHVP). The electrical hardware as-built configur-ation is validated to the electrical design by Quality Control (QC) inspections, engineering walkdowns, and engineering evaluations.

1 Portions of this system are non-safety related. The electrical portion of the Corrective Action Program (CAP) validated the safety-related portions of this system.

2 Portions of this system are designed by the NSSS vendor. The electrical portion of the Corrective Action Program (CAP) validated the design inter-face and is validating the as-built configuration of this system as part of the Post Construction Hardware Validation Program (PCHVP).

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p 4. Resoh lon of the design and hardware-related CPSES electrical relatea issues and implementation of corrective action for closure Q of these issues. These issues include external issues, Comanche Peak Response Team (CPRT) issues, and issues identified during the performance of the Corrective Action Program (CAP) (See Section 4.0).

5. Development of validated design documentation to form the basis for CPSES electrical configuration control. The validated design documentation (calculations, design drawings, and specifications) and Design Basis Documents (DB0s) can be utilized by TV Electric to facilitate operation, maintenance, and future modifications following issuance of an operating license.

Section 5.1 of this electr'ical Project Status Report (PSR) describes the methodology and work performed in the electrical portion of the Corrective Action Program (CAP). Section 5.1.1 describes the methodology by which CPSES licensing commitments were identified, the design criteria were established, and the Design Basis Documents (DBDs) were developed.

Section 5.1.2 describes the design validation process including the basis of validating the parameters for such items as calculation reviews and interface requirements with other disciplines. The subsection also describes interfaces among participants in the Corrective Action Program (CAP) and the final reconciliation process. -

Section 5.1.3 describes the Post Construction Hardware Validation Program O- (PCHVP) and the procedures for field validations (Quality Control inspections, engineering walkdowns, and engineering evaluations) required to be implemented to validate that the as-built systems and components are in compliance with the design documentation.

Section 5.2 presents a summary of the design validation results and the Post Construction Hardware Validation Program (PCHVP) results, including the hardware modifications resulting from the electrical portion of the Correc-tive Action Program (CAP).

Section 5.3 describes the quality assurance program implemented for the validation process, including the SWEC Engineering Assurance (EA) audits, the Engineering Functional Evaluation (EFE) audits, and the TU Electric Quality Assurance (QA) audits.

I Section 5.4 describes SWEC electrical inputs to the TV Electric preventive actions, including the transfer of a complete set of validated design documentation and procedures to Comanche Peak Engineering (CPE). This set of documentation and procedures can provide the basis for CPSES configuration control throughout the life of the plant.

Appendix A of this Project Status Report (PSR) describes the details of the Corrective Action Program (CAP) resolution of the electrical related Comanche Peak Response Team (CPRT) and external issues.

Appendix B of this Project Status Report (PSR) describes the details of resolutions of issues identified during the electrical portion of the .

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Corrective Action Program (CAP). These are issues that have been determined to be reportable under the provisions of 10CFR50.55(e). These issues are identified in Significant Deficiency Analysis Reports (SDARs) initiated by i

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4.0 SPECIFIC ISSUES The electrical portion of the Corrective Action Program (CAP) resolved all the related Comanche Peak Response Team (CPRT) issues, external issues, and issues identified during the performance of the CAP. This section presents a listing of electrical related issues addressed in this Project Status Report (PSR). Technical review, resolution, and corrective and preventive actions of all external and Comanche Peak Response Team (CPRT) issues are described in Appendix A. Technical review, resolution and corrective anG preventive actions for all issues identified during the performance of the Corrective Action Program (CAP) are described in Appendix B. The issues

- contained in Appendix B are those which have been determined to be report-able under the provisions of 10CFR50.55(e).

Comanche Peak Response Team (CPRT) and external issues are listed below with issue numbers corresponding to the subappendix. number in Appendix A which addresses the issue. Issues Al and A2 came from Issue Resolutien Reports (IRRs); Issues A3 through A7 were Issue Specific Action Plans (ISAPs); and Issues A8 through A14 were Independent Assessment Program (IAP) issues raised by CYGNA.

Issue No. Issue Title Al Electrical Separation A2 Electrical Calculations A A3 Heat Shrinkable Cable Insulation Sleeves AMP Preinsulated Environmental Sealed (PIES) Butt Splices

' V A4 A5 Agreement Between Drawings and Field Terminations A6 Vendor Installed AMP Terminal Lugs A7 Electrical Equipment Installation A8 System Short Circuit Currents A9 AC Distribution System Voltages A10 Overcurrent Protection All Power Cable Oerating Inside Containment A12 Voltage Orop Calculations A13 Cable Tray Fill for Maintained Space Cables A14 Cable Ampacity Calculations Issues identified during the performance of the electrical portion of the Corrective Action Program (CAP) which have been determined to be reportable under the provisions of 10CFR50.55(e) are listed below with issue numbers corresponding to the subappendix number in Appendix B which addresses the issue.

Issue No. Issue Title B1 SDAR CP-87-03, 6.9 kV Switchgear Installation 82 50AR CP-87-40, Electrical Isolation Between Class 1E and Non-Class IE Equipment 1 B3 SDAR CP-87-51, 480 V Containment Electrical Penetration

! Backup Protection B4 SDAR CP-87-79, Cable and Raceway Data System (CARDS)

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I B5 SDAR CP-87-101, Class IE Cable Arrangement O B6 B7 SDAR CP-88-10, 6.9kV Cable Bus Ampacity SDAR CP-88-09, Electrical Penetrations Overloading Protection Devices and Short Circuit Related Defi- l ciencies B8 SDAR CP-87-85, Degradation of Class 1E Circuits B9 SDAR CP-88-11, Potential Battery Charger Failure Due to Heating 810 SDAR CP-88-08, Class 1E Battery Room Temperature Bil SDAR CP-87-49, Solid State Safeguards System (SSSS)

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5.0 CORRECTIVE ACTION PROGRAM (CAP) METHODOLOGY AND RESULTS pJ 5.1 METHODOLOGY AND WORK PERFORME0 5.1.1 Licensing Commitments, Design Criteria and Design Basis Documentation A review was performed of licensing documentation in order to identify licensing commitments related to CPSES electrical systems and components.

Documentation reviewed included the FSAR, SER, SSERS, NRC Regulatory Guides, IE Bulletins and TV Electric /NRC licensing correspondence.

SWEC then established the design criteria based on the identified licensing commitments. The design criteria, which assure compliance with the licensing commitments, were consolidated and documented in Design Basis Documents (OB0s). The design criteria served as the basis for the valida-tion effort.

The electrical Design Basis Documents (DB0s) include electrical systems design criteria as well as design criteria for those aspects of the CPSES Unit 1 and Common design which are common to more than one electrical system. The electrical Design Basis Documents (DB0s) are listed in Table 5- 1.

5.1.1.1 Verification of Design Criteria and Resolution of Issues Technical audits have been performed to provide additional assurance that

- the design criteria are technically correct. and embody the electrical licensing commitments and that all related Comanche Peak Response Team (CPRT) issues, external issues and electrical Corrective Action Program (CAP) identified issues have been resolved. To assure that the licensing commitments related to electrical design have been identified, and appro-priate design criteria have been established, SWEC Quality Assurance (QA) and the Comanche Peak Response Team (CPRT) conducted overviews. SWEC Quality Assurance (QA) audits were performed as described in Section 5.3.

The Comanche Peak Response Team (CPRT) overview is being performed by the Engineering Functional Evaluation (EFE) and TV Electric Quality Assurance (QA) as described in Section 5.3.

The TV Electric Quality Assurance (QA) Technical Audit Program (TAP) is auditing the Corrective Action Program (CAP) to assure that the design criteria are reconciled with the licensing commitments. In addition, CYGNA Energy Services (CYGNA) is reviewing SWEC's resolution of electrical issues (Issue Numbers A8 through A14, as identified in Section 4.0) that were identified by the CYGNA Independent Assessment Program (IAP).

SWEC's resolution of the Comanche Peak Response Team (CPRT) and external issues is described in Appendix A of this Project Status Report (PSR).

SWEC's resolution of issues identified during the performance of the electrical portion of the Corrective Action Program (CAP) is described in Appendix B of this Project Status Report (PSR).

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5.1. 2 Design Validation Process The CPSES Unit 1 and Common electrical design was validated by comparison of the design documentation for each electrical system and component (calculations, drawings, specifications and related design documents) to the criteria embodied in the Design Basis Documents (0B0s). Where the existing design did not satisfy the design criteria, it was modified to satisfy the design criteria.

The electrical portion of the Corrective Action Program (CAP) design validation process was performed in accordance with comprehensive design control procedures throughout all phases of the CAP. The key design control procedures implementing the electrical portion of the Corrective Action Program (CAP) are listed in Table 5-2. These design control procedures assure compliance with the design criteria and the resolution of the Comanche Peak Response Team (CPRT) issues, external issues and issues identified during the performance of the Corrective Action Program (CAP).

Design documents were reviewed to assure that (1) they were in conformance with Design Basis Documents (DB0s), and (2) they were correct and consistent with interfacing design documents. In order to provide an efficient approach to the organization of design data, the electrical design was divided into 11 Design Validation Packages (DVPs). Each Design Validation Package (DVP) identifies or contains the following items:

• Design Basis Documents (DB0s) which serve as the primary basis for design validation

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• Design Documents (e.g., calculations, drawings and specifications)

• Other related documents (e.g., NSSS interface requirements, Significant Deficiency Analysis Reports (SDARs), and Comanche Peak Response Team (CPRT) and external issues resolution documents) 5.1.2.1 Electrical Systems Validation The design validation process of the CPSES Unit 1 and Common electrical systems identified in Section 3.0 included the following:

• Calculations

• One Line Drawings

• Electrical Equipment Procurement Specifications

• Electrical Installation Specification

• Electrical Components

• Electrical Separation and Independence b')

v

• Cable and Raceway Data System (CARDS) 5-2 c

(

• NSSS Design Interface

• Electrical and Motor Loads l Calculations  ;

The SWEC electrical design validation is based on SWEC validated calculations which substantiate the design. Validation of the original calculations was performed using four approaches:

1) Validation of original calculations .

Original calculations were validated by review or by alternate calculations which showed that the results of the original calculations we e acceptable.

2) Validation of original calculations by developement of i supplemental calculations l Supplemental calculations were developed for designs for which the original calculations needed only mir.or revision or enhancement to  :

assure compliance with design criteria specified in the Design Basis Documents (DB0s). The combination of the existing and these supplemental calculations form the basis for the validation of the design.

3) SWEC calculations which replace the original calculations Replacement calculations were developed which completely replaced i and superseded the original calculations.  ;

4) Development of new calculations New calculations were developed, when required, to provide ,

complete documentation of the electrical design validation.

j SWEC reviewed 86 original safety-related electrical calculations. The review  !

of calculations validated that design inputs are correct and current, and i that the assumptions, methodology, and criteria used in the calculations i were consistent with the design criteria established and documented in the  :

~

Design Basis Documents (DBUs). In addition, 60 safety-related electrical calculations were developed by SWEC as part of the electrical portion of the ,

Corrective Action Program (CAP) to replace or supplement original  :

calculations or to provide new calculations. These calculations, in '

conjunction with the validated original calculations, demonstrate compliance with the design criteria.

Types of design calculations which were validated for each electrical system identified in Section 3.0 included:

• Voltage profile (

f - l I Calculations to demonstrate that adequate voltage is available at l electrical equipment. Design changes were developed and l 5-3

/] modifications are being implemented where voltages did not meet

\.s the design criteria.

• Short circuit capability Calculations to demonstrate that the maximum short circuit current does not exceed the equipment design rating. Design changes were developed and modifications are being implemented where the short circuit current exceeded the equipment design rating.

• Transformer loading Calculations to demonstrate that the power requirements do not exceed the design capacity of the transformers. Design changes were developed and modifications are being implemented where the power requirements exceeded the transformers design capacity.

? Cable sizing Calculations to demonstrate that cables to equipment have the required current capacity and provide an acceptable voltage at the equipment. Design changes were developed and modifications are being implemented where the current capacity or voltage did not meet the design requirements, g

• Diesel generator lo'ading U Calculations to demonstrate that the maximum power requirements imposed on the diesel do not exceed its design capacity.

• Electrical protaction Calculations te demonstrate that the proper electrical protection equipment (including circuit breakers, fuses and relays) is speci-fied and that the settings and ratings furnish protection (e.g. ,

overload and short circuit) in accordance with design require-ments. Design changes were developed and modifications are being implemented where protection of equipment did not meet design requirements.

• Battery and battery charger sizing Calculations to demonstrate that the batteries and battery I chargers supply the rcquired current and voltage to meet the power requirements of the connected de loads.

• Equipment sizing Equipment sizing calculations to demonstrate that equipment design and ratings are adequate to meet design load requirements and withstand maximum short circuit currents from the electrical system and loads.

. 5-4

• Cable pulling Calculations to demonstrate proper cable installation for cables installed in raceways.

.i The calculation validation effort included reviews of other interfacing

, documents to assure a complete integrated electrical design. Inconsisten-cies between the validated calculations and any of these Interfacing docu- 7 ments were identified and resolved.

One line Drawings Validation of electrical one line drawings, which depict the configuration of electrical systems and design parameters, was performed by validating that the system designs are in compliance with the design criteria as speci- l fied in the Design Basis Cecuments (DB0s). The validation also demonstrated that system designs are in compliance with validated design esiculations.

Inconsistencies between these drawings and system design requirements were ,

resolved.

The following items were considered in the review and validation of the one ,

line drawings: '

• Bus configuration

• System redundancy,' separation and independence O

• Single failure criterion

• System and equipment protection

• Control requirements

• Load identification and rating l

• . Drawing nuclear safety classification

• Component identification and rating Electrical Equipeent Procurement Specifications Electrical equipment procurement specifications were reviewed and validated to assure consistency with other documents such as Design Basis Documents (OB0s), installation specifications, one line diagrams, and calculations. ,

In addition, a comprehensive review of the technical content of the l 1 electrical equipment procurement specifications for each safety-related i electrical system was performed to validate that safety-related electrical i;

equipment complies with the design criteria specified in the Design Basis  ;

Documents (DBDs). l

! Electrical Installation Specification [

i  !

, The original electrical installation specification was reviewed, revised and validated to the design criteria specified in the Design Basis Documents 5-5 w . . , _ _ . . - - - - _ _ , - - - _ _-__, _ _ .

. - , .-. -e. - _ _ _ . _ . _

i O (DB0s) and to identify the required inspection attributes and acceptance d criteria. The revised electrical installation specification also resolves all electrical related Comanche Peak Response Team (CPRT) - Quality of Construction (QOC) issues. SWEC then reviewed the revised construction and Quality Control (QC) inspection procedures to assure consistency with the installation specification. The validated installation specification received interdisciplinary and interorganizational review for design inter- '

face consistency.

Electrical Components The vendor component interface documentation was reviewed for compliance with the validated system design. The ability of individual components to meet system performance requirements was validated using vendor document-ation (e.g. , speed-torque curves, vendor drawings, nameplate data). Inter-face design parameters validated for electrical components include:

• Motors -

Starting capability, service fwtor

• Switchgear/ -

Bus rating, short circuit rating, Motor Control Centers circuit breaker rating, trip settings

• Batteries -

Equalize, float and discharge voltage; discharge rate; capacity

• Battery Chargers -

Voltage regulation capability, charge rate,

, input and output breaker ratings

• Inverters -

Output rating, ac input voltage tolerance,

, de input voltage tolerance, ac output voltage regulation, output frequency and transfer time (static switch)

• Containment Elec- -

Pressure capability, voltage rating, trical Penetrations short circuit capability, ampacity, and

{ cable type 4

• Cables -

Voltage rating, insulation material, con-ductor size, jacket material type, shield-ing, fire retardancy, overall diameter and weight

• Protective Devices - Setting, contact requirements / ratings, coil requirementt/ ratings, timer require-i ments/ ratings.

Electrical Separation and Independence The design of the electrical separation and independence was validated by demonstration of the following:

e That the separation requirements defined in the electrical instal-O lation specification (Reference 5) for raceway, cable and 5-6

( ) equipment comply with design criteria as specified in the Design

'/ Basis Document (0B0) (Reference 6).

• That the separation requirements defined in the electrical installation specification between cables and between cables and flexible con /.uit within panels comply with the design criteria specified in the Design Basis Document (0B0).

• That electrical isolation between safety and non-safety-related circuits complies with the design criteria as specified in the Design Basis Document (0B0).

• That the electrical one line drawings comply with the electrical

- separation and independence design criteria as specified in the Design Basis Document (DBD).

• That the separation barrier requirements defined in the electrical installation specification comply with the design criteria as specified in the Design Basis Document (DBD).

• That the NSSS interface separation requirements are complied with.

Cable and Raceway Data System (CARDS)

The Cable and Raceway Data System (CARDS) is an on-line computer program.

(q 7

',)

The CARDS is a source of data attributes relating to cables and raceways (cable tray and conduit). It provides a controlled means of routing cable through raceway by performing such design control checks (computation) as raceway percent fill (amount of cross-sectional area of installed cables divided by the total cross-sectional area of the raceway) and cable tray load (weight).

Validation of the computerized Cable and Raceway Data System (CARDS) was performed by reviewing program objectives for accuracy and purposes, by demonstrating that input data (i.e. cable tray / conduit di ;ensions, cable tray / conduit weight, cable diameters and cable weight) were validated and by performing alternate manual calculations to validate program calculation methods (e.g. for total cable weight in cable tray and conduit, and for cable tray / conduit fill).

Data attributes (e.g. cable routing, type and size) of CARDS that describe the installed configuration for cable and raceways (Table 5-3) are being validated as part of the Post Construction Hardware Validation Program (PCHVP).

NSSS Design Interface Westinghouse is the NSSS supplier for CPSES. SWEC validated that the inter-face design criteria for the NSSS were properly applied and implemented for the CPSES Unit 1 ana Common electrical design.

(] The NSSS supplier provided Design Basis Documents (DB0s) (References 9

(/ through 14) and interfacing documentation (Reference 15) which describe the specific interfacG requi re.nents between the NSSS and interfacing systems 5-7

n design. SWEC reviewed the above interface requirements and validated that

( ) these interfaces were properly implemented.

Electrical and Motor Loads The SWEC developed Electrical and Motor Load list is a validated compilation of significant electrical and motor load data. These data were developed from review of design documents and vendor documents. Typical load data includes motor horsepower, equipment operating modes and bus assignment.

The information is identified within a computerized database and is con-trolled in accordance with SWEC design control Project Procedure PP-077 (Reference 33). These data were utilized as input to various design valida-tion processes such as calculation and drawing validations.

The load list is a source of electrical load data at CPSES Unit 1 and Common. it provides a controlled means of using electrical load information among interfacing disciplines. Additional or modified load data is entered into the database, and periodically the load list is updated and reissued.

5.1.2.2 Interfaces The electrical validation process involved internal interfaces among SWEC design disciplines, as well as external interfaces with TV Electric and other organizations involved in the Corrective Action Program (CAP).

Organizational interfaces as shown in Figure 5-1 include those with other SWEC disciplines, TV Electric; Westinghouse, Ebasco, and Impell. Interfaces p with these organizations are procedurally controlled to assure:

• Consistency of design criteria

• Completeness of the information incorporated in each Design Validation Package (DVP)

• Proper transfer of design data between interfacing organizations

• Uniform application of design control procedures

• Coordination of corrective and preventive actions 5.1.2.3 Final Reconciliation Process The purpose of the final reconciliation process is to consolidate the design validation analyses, hardware modifications, preoperational test results, and inspection documentation to assure consistency of the electrical design.

The final reconciliation of electrical design incorporates the following:

• The Post Construction Hardware Validation Program (PCHVP) results o Resolution of the electrical hardware related Comanche Peak Response Team (CPRT) and external issues, Final reconciliation also includes confirmation that the interfacing organ-izations have accepted the electrical results as compatible with their vali-(mV) dated design. Interfacing organizations are depicted on Figure 5-1.

5-8

(] In addition, open items, observations, and deviations related to the elec-(/ trical portion of the Corrective Action Program (CAP) that were identified by the TV Electric Technical Audit Program (TAP) and Engineering Functional Evaluation (EFE) are resolved prior to the completion of this reconciliation E.hase. Open items from TV Electric Significant Deficiency Analyris Reports (SDARs) (10CFR50.55(e)) are also resolved during the final reconciliation.

At the conclusion of final reconciliation, the CPSES Unit 1 and Common Design Validation Packages (DVPs) are compiled.

5.1.3 Post Construction Hardware Validation Program (PCHVP)

The Post Construction Hardware Validation Program (PCHVP) (Reference 16) is the portion of TV Electric's Corrective Action Program (CAP) which validates the final acceptance attributes for safety-related hardware. The Post Construction Hardware Validation Program (PCHVP) process is shown diagrammatically in Figure 5-2.

The input to the Post Construction Hardware Validation Program (PCHVP) is contained in the installation specifications. The installation specifica-tions implement the licensing commitments and design criteria of the Design Basis Documents (DBDs), which were developed during the Corrective Action Program (CAP) design validation process.

Final acceptance inspection requirements identified in the validated installation specifications were used to develop the Post Construction Hardware Validation Program '(PCHVP) attribute matrix. This matrix is a tO V

complete set of final acceptance attributes identified for installed hardware. The Post Construction Hardware Validation Program (PCHVP), by either physical validations or through an engineering evaluation methodology, assures that each of the attributes defined in the attribute matrix is validated.

Physical validation of an attribute is performed by Quality Control (QC) inspection or engineering walkdown, for accessible components. Quality Control (QC) inspections and engineering walkdowns are controlled by appropriate Field Verification Method (FVM) procedures.

The Post Construction Hardware Validation Program (PCHVP) engineering evaluation depicted in Figure 5-2, is procedurally controlled to guide the Corrective Action Program (CAP) responsible engineer through the evaluation of each item on the attribute matrix to be dispositioned by the engineering evaluation method. Dispositions of each attribute will be clearly r documented. If the technical disposition of the final acceptance attribute is "not acceptable" or the attribute cannot be dispositioned based on available information, an alternate plan consisting of additional evalua-tions, testing, inspections /walkdowns or modifications, as necessary, will be developed to demonstrate and document the acceptsbility of the attribute.

Recommendations from the Comanche Peak Response Team (CPRT) effort comprise a v.ignificant portion of the evaluation. A major component of the Comanche Peak Response Team (CPRT) program has been the inspection of a comprehen-s sive, random sample of existing hardware using an independently derived set Q of inspection attributes. The inspection was performed and the results were evaluated by Third Party personnel in accordance with Appendix E to the 5-9

l Comanche Peak Response Team (CPRT) Program Plan (Reference 17). The scope of the inspection covered the installed safety-related hardware by segregating the hardware into homogeneous populations (by virtue of the work activities which produced the finished product). Samples of these popula-tions were inspected to provide reasonable assurance of hardware acceptability in accordance with Appendix D to the Comanche Peak Response Team (CPRT) Progrim Plan.

Corrective action recommendations were made to TV Electric based on the evaluated findings when e Construction Deficiency existed, an Adverse Trend existed, or an Unclassified Trend existed, as defined in accordance with Appendix E to the Comanche Peak Response Team (CPRT) Program Plan.

The Post Construction Hardware Validation Program (PCHVP) assures that all Comanche Peak Response Team (CPRT) recommendations are properly dispositioned.

Figure 5-2 illustrates that during the evaluation of a given attribute from the Post Construction Hardware Validation Program (PCHVP) attributo matrix, the initial task of the Corrective Action Program (CAP) responsible engineer is to determine if any of the following statements are true:

a. The attribute was recommended for reinspection by the Comanche Peak Response Team (CPRT) p b. Design validation resulted in a ' change to design or to a hardware V final acceptance attribute that is more stringent than the original acceptance attribute or the Comanche Pe6k Response Team (CPRT) did not inspect the attribute

c. Design validation resulted in new work, including modification to existing hardware If the Comanche Peak Response Team (CPRT) had no recommendations and Items

b. or c. above do not apply, the attribute under consideration will be accepted. This conclusion is justified by the comprehensive coverage of the Comanche Peak Response Team (CPRT) reinspection and the consistently conservative evaluation of each finding from both a statistical and adverse trend perspective. The attribute matrix is then updated to indicate that neither the engineering walkdown nor Quality Control (QC) inspection of the attribute is necessary. A completed evaluation package is prepared and forwarded to the Comanche Peak Engineering (CPE) organization for concurrence. The evaluation package becomes part of the Design Validation Package (DVP) after Comanche Peak Engineering (CPE) concurrence is obtained.

If any of the three statements above are true, it is assumed that the final acceptance attribute must be further evaluated as follows:

Determine Attribute Accessibility The Corrective Action Program (CAP) responsible engineer will determine O if the attribute is accessible. If the attribute is accessible, a field validation of the item's acceptability will be performed and 5-10

j-O documented in accordance with an approved Field Verification Meth'od (FVM).

If the Corrective Action Program (CAP) responsible engineer reaches the  ;

conclusion that the attribute is inaccessible, an engineering ,

evaluation will be conducted by technical disposition of available information.

l i

Af ter completing Action Program (CAP)the attribute responsible accessibility engineer review, will update thethe Corrective attribute matrix, as nvcessary, to reflect the results of that review.

TechnicgDjsyosition The Corrective Action Program (CAP) responsible engineer identifies the data to be censidered v.aring the subsequant technical disposition

process. Exar.ples of such . items used in this disposition may include, but are not limited tc

i

• Historical documents (e.g., specifications, procedures and  ;

inspection results)

• Comanche Peak Response Team (CPRT) and external issues

• Construction practices i

• Quality records

• Test results

• Audit reports

• Authorized Nuclear Inspector (ANI) records e

• Surveillance reports -

j

• NCRs, DRs, SCARS and CARS

• Inspections conducted to date

• Results of Third Party reviews ,

3

• Purchasing documents j

• Constructi.n packages

• Hardware receipt inspections .

j. After compiling the data identified as pertinent to the attribute, the  ;

j technical disposition will be performed. The actual steps and sequence  !

3 of actions required for each technical disposition will differ; i 1

however, the tangible results from each technical disposition will be i

, consistent. These results will include as a minimum:  !

) 6-11 f i l

(~  ;

• A written description of the attribute; LJ

• A written justification by the Corrective Action Program (CAP) responsible engineer for acceptance of the attribute;

• A written explanation of the logic utilized to conclude that the attribute need not be field validated;

• A chronology demonstrating that the attribute has not been significantly altered by redesign;

• All documents viewed to support the disposition;

• Concurrence of the acceptance of the attribute's validity by Comanche Peak Engineering (CPE).

If the Corrective Action Program (CAP) responsible engineer concludes that the data evaluated represent evidence of the attribute's acceptability, the conclusion will be documented. The documentation will be reviewed and approved by Comanche Peak Ergineering (CPE) and filed in the Design Validation Package (DVP). If the Corrective Action Program (CAP) responsible engineer determines that the data reviewed do not provide evidence of the attribute's acceptability, the documentation will explain why the attribute cannot be accepted and recommend an alternate course of action. The alternate course of 7 action may take various ' forms such as' making the attribute accessible

( ,) and inspecting it, or testing to support the attribute's acceptability.

'l This alternate plan, after approval by Comanche Peak Engineering (CPE),

will be implemented to validate the attribute.

In summary, the Post Construction Hardware Validation Program (PCHVP) is a comprehensivo process by which each attribute in the PCHVP attribute matrix is validated to the validated design. The TV Electric Technical Audit Program (TAP) will audit the Post Construction Hardware Validation Program (PCHVP). This audit program is complemented by the Engineering Functional Evaluation (EFE) being performed by an independent team comprised of Stone & Webster, Impell and Ebasco engineering personnel working under the Stone & Webster Quality Assurance (QA) Program and subject to oversight directed by the Comancho Peak Response Team's (CPRT) Senior Review Team (SRT). The Post Construction Hardware Validation Program (PCHVP) will orovide reasonable assurance that the validated design has been impkm.*ted for safety-related hardware.

SWEC prepared Post Construction Haroware Validation Program (PCHVP) implementation procedures (References 18 and 34) for the electrical portion of the Corrective Action Program (CAP). The hardware validation process includes modifications, whenever necessary, to bring the electrical related hardware into compliance with the validated design. The attributes contained within the Post Construction Hardware Validation Program (PCHVP) attribute matrix for electrical related 77 hardware incorporate the Comanche Peak Response Team (CPRT)-Quality of (s~ j Construction (QOC) recommended corrective actions. A summary of electrical final acceptance attributes is presented in Table 5-3. The 5-12

specific final acceptance attributes are contained in the Commodity Attribute Matrix (Reference 35).

O I

lO 5-13

b(3 5.2 RESULTS 5.2.1 Design Validation Results The validation of the CPSES Unit 1 and Common electrical design has been completed as described in this Project Status Report (PSR). This effort included:

• Review of 86 original calculations

• Review of more than 150 design drawings

• Development of 60 replacement, supplemental and new calculations

• Revision of the electrical installation specification

• Resolution of 278 Tenera, L. P. (TERA) Discrepancy Issue Reports (DIRs)

The electrical design validation developed hardware modifications which are being implemented including:

• The Preferred Power System has been augmented by dedicating the existing startup transformers to the safety-related buses. In o addition, two new .startup transformers have been added to power Q the non-safety-related buses.

• The structural embedments and concrete floor were reworked to provide a level foundation for the 6.9 kV switchgear.

• The 6.9 kV nonsegregated phase bus capability was adjusted by improving the bus ventilation so the bus rating (ampacity) complies with the design criteria.

• Control circuits were modified to assure that supply voltages are within operating ranges required by the control device.

• Cable sizes, for certain power circuits, were increased to assure that circuit ampacity or supply voltage meets load requirements.

• Power and control circuits and protective devices were modified to assure adequate penetration electrical protection, ampacity and short circuit capability.

• Circuits are being modified to add isolation devices between Class 1E and non-Class 1E equipment used in the circuits (Solid State Protection System (SSPS) power supply, reactor coolant pump underfrequency trip signal), or non-Class 1E equipment was l disconnected from Class 1E sources (motor control center space i

heaters).

• Damaged equipment (bus insul6 tors, electric conductor seal assemblies, and enclosure door gaskets) or incorrect devices (dc l relay, fuses) were replaced.

5-14 l _. - .. . .-- __ --. _ - _ - - -

(

• The essential ac and emergency de lighting systems are being

( ]j modified to bring the systems into compliance with the require-ments of the design criteria.

• Control circuits were redesigned to assure adequate terminal voltages. Panel circuits were reassigned to provide compatability between load and panel types.

• Separation Barrier Material (SBM) used to septrate cables and raceways was removed, due to its high derating factor on ampacity. Where required, it is being replaced with a material requiring less derating.

• Design changes were implemented to provide electrical separation between Class IE and non-Class 1E radiation monitoring circuits and fire protection circuits.

• The 6.9 kV control circuits for the reactor coolant pumps and for the Class 1E 480 V load center bus tie breakers were modified to assure adequate containment penetration protection.

• Cables using Thermolag for a fire barrier were rerouted or replaced with larger cables or a combination of both if required to comply with ainpacity design criteria.

• Battery chargers were modified to assure adequate cooling.

• Weidmuller terminal blocks that were identified as not being environmentally qualified are being removed and replaced by butt splices with environmentally qualified insulating material.

• Cables which were designated as Class 1E cables but which do not perform a safety-related function are being properly redesignated as non-Class 1E and are being rerouted in non-Class 1E raceways.

• Cables that did not meet Class 1E requirements, associated with the Safety System Inoperable Indication (SSII), are being replaced with qualified cable with proper isolation.

• Cable arrangements, for certain power circuits, are being modified to agree with the revised installation specification requirements to assure balanced currents in each cable of circuits with "multiconductor per phase" design.

The design validation effort, in conjunction with the design modifications, results in an electrical design and associated documentation that is in conformance with CPSES licensing commitments and provides assurance that the electrical systems and components are designed to perf cm their safety functions.

5.2.2 Post Construction Hardware Validation Program (PCHVP) Results O The Post Construction Hardware Validation Program (PCHVP) is being imple-V mented through the validation of final acceptance attributes for systems and components for CPSES Unit 1 and Common as discussed in Section 5.1.3.

5-15

~'\ 5.3 QUALITY ASSURANCE (QA) PROGRAM (d All SWEC activities of the CPSES Unit 1 and Common electrical portion of the Corrective Action Program (CAP) were performed in accordance with SWEC's Quality Assurance (QA) program. This program implements applicable requirements of SWEC's Topical Report SWSQAP 1-74A (Reference 19), "Stone &

Webster Standard Quality Assurance Program," which has been approved by the NRC.

in accordance with the SWEC Quality Assurance (QA) Program, a project-specific QA Program 1 ccvering the essentials of the SWEC Corrective Action Program (CAP) was developed, including detailed procedures (Reference 20).

These procedures were distributed to supervisory engineers and were readily available to electrical Corrective Action Program (CAP) personnel. The issuance of design criteria, validation procedures, and major revisions was followed up with detailed training programs for the applicable personnel.

In particular, engineers on the project received training in the procedure for preparation, review, and approval of Design Basis Documents (DBDs)

(Reference 21) and in the design validation procedures for calculations, drawings / diagrams, and specifications (References 7, 8, and 22).

A project Quality Assurance (QA) manager, who is directly responsible to the SWEC Vice President of QA and has management experience in auditing and QA Program procedure development for engineering activities, was assigned to the project in the earliest stages of the project. This reporting

, n responsibility assures independence of the Quality Assurance (QA) functions.

/ The SWEL Quality Assurance (QA) manager has a staff assigned to assist him in his duties. These individuals provide assurance that the Quality Assurance (QA) Program properly addresses project activities and assist SWEC personnel to implement the QA Program properly.

To date, more than 45,000 man-hours have been expended by SWEC in activities directly attributable to the overall Project Quality Assurance (QA) Program (i.e., training, procedure development, auditing, and the project QA Manager's staff).

The adequacy and implementation of this Quality Assurance (QA) Program and the adequacy of the work performed under the QA Program was extensively audited by SWEC's Engineering Assurance (EA) Division 2, SWEC's Quality Assurance Auditing Division (QAAD), and TU Electric's Quality Assurance (QA)

Program. A total of 21 audits of the electrical discipline were performed by these organizations to date for CPSES Unit 1 and Common as follows:

1The overall (SWEC) Quality Assurance (QA) Program encompasses the mechani-cal, electrical, instrumentation and controls, and civil / structural portions of the Corrective Action Program (CAP).

2The SWEC Engineering Assurance (EA) Division is an integral part of SWEC's Corporate Quality Assurance Program (Reference 19).

b o

5-16

/7 SWEC - EA 6 1

(,/ SWEC - QAAD TU Electric QA 14 Collectively these audits evaluated the technical adequacy of the engineering product (e.g., Design Basis Documents (DBbs), validation activities, calculations, drawings, and specifications) ano assessed the adequacy and implementation of the SWEC Quality Assurance Program. These audits have resulted in enhancements to the procedures and methods and, thus, contributed to the overall quality of the CPSES electrical design. A summary of these audits is presented in Sections 5.3.1 and 5.3.2.

In addition to the audits described above, TV Electric has snitiated the Engineering Functional Evaluation (EFE) (Reference 23). T ie EFE began auditing the electrical portion of the Corrective Action Program (CAP) in June 1987. The Engineering Functional Evaluation (EFE) is an overview program which is performing an independent, in-depth technical evaluation of the Corrective Action Program (CAP) to provide additional assurance that the CAP is effectively implemented. The Engineering Functional Evaluation (EFE) is conducted under the SWEC Quality Assurance (QA) Program and is directed

, by a Program Manager who reports to the SWEC Chief Engineer, Engineering Assurance. The Engineering Functional Evaluation (EFE) is performed by highly qualified and experienced engineers from SWEC, Impell and Ebasco who have not been involved with previous engineering and design work at CPSES.

The Engineering Functional Evaluation (EFE) is performed in a formal, preplanned and fully documented mannar to provide objective evidence of completion of the planned scope of the evaluation and to provide documentation of its results and conclusions. The Engineering Functional Evaluation (EFE) is comparable in scope, level of effort and personnel qualifications to integrated, independent design inspections and verifications conducted at other nuclear plants.

The NRC - Office of Special Projects (0SP) also conducted inspections of the project in SWEC offices beginning in August 1987. The inspections involved technical evaluations of the design validation process and focused primarily on the review of calculations and Design Basis Documents (DBDs), and their compliance with licensing commitments. In addition, the NRC-0SP inspections included a review of activities performed under the Engineering Functional Evaluation (EFE).

Surveillance activities have been conducted by SWEC Engineering Asturance (EA) to assure conformance to procedures and standards.

The activities described above collectively represent a very detailed and complete assessment of the following:

1. Adequacy of the Quality Assurance (QA) Program.

2. Implementation of the Quality Assurance (QA) Program.

3. Technical adequacy of the design criteria and procedures.

4. Implementation of the design criteria and procedures.

5-17

(m These activities identify instances in which action is required to clarify

( ,) or to modify procedures to define some activities more clearly; revise calculations to provide clarifying statements; or more properly address a situation, and provide additional training. A complete response was developed for every item identified throughout the audit process. For each audit item identified, the cause, extent of conditions, and any required corrective / preventive actions are determined, properly documented, and implemented. Subsequent audits verify that appropriate actions are taken to address previously identified items.

In addition to the audits and surveillances, a rigorous Quality Control (QC) inspection program is in place on the CPSES site. Quality Control (QC) personnel are responsible for inspections of attributes, as aelineated in the inspection procedures, prior to acceptance of any installation.

In summary, an appropriate level of attention has been given to the quality of activities; the Quality Assurance (QA) program is appropriate for the scope of work; project performance has been demonstrated to be in compliance with the QA program, and appropriate corrective and preventive actions were taken whenever they were required.

5.3.1 Summary of SWEC Engineering Assurance (EA) Audits To date, SWEC Engineering Assurance (EA) has performed 5 audits of the Corrective Action Program (CAP) Audits were conducted at the Boston office

and at the CPSES site. An ' average of seven subjects was reviewed during each of these audits. The following list of audit subjects describes the

( depth of auditing that has been performed:

1. Adequacy of project procedures

2. Calculations - technical adequacy and documentation

3. Nonconformance Reports (NCRs)/ Test Deficiency Reports (TORS)

4. Specification validation

5. Drawing / diagram validation

6. Calculation validation j 7. Record maintenance

8. Generic Issue Reports (GIRs)

9. Discrepancy Issue Resolution Reports (DIRs)

10. Design Basis Documents (DBDs)

11. Indoctrination and training A 12. Licensing activities l

t} 13. Corrective Action Requests (CARS) 5-18

't 14. Personnel qualification and experience verification '

15. Design modifications A - chronological tabulation of SWEC Engineering Assurance (EA) audits is presented in Table 5-4.

5.3.2- Summary of Audits by TU Electric Quality Assurance (QA),

Inspections by NRC-0SP and Audits by SWEC QAAD To date, TU Electric Quality Assurance (QA) has performed.14 audits of the project. A chronological tabulation of the TV Electric audits is presented in Table 5-5~.

TU Electric Quality Assurance (QA) performs programmatic audits under its vendor compliance and internal audit program and technical audits under it Tecnnical Audit Program (TAP).

The TV Electric Technical Audit Program (TAP)3 evaluates the technical adequacy of the design activities at CPSES through audits of the development and implementation of Design Basis Documents (DBDs), calculations, drawings, ,

specifications, and compliance to those procedures governing these technical activities.

The SWEC Quality Assurance Auditing Division (QAAD) performed one audit of SWEC. This audit was performed to assess the project Quality Assurance (QA) 9-O manager's adherence to Corporate QA Program requirements and the adequacy of the Project's QA Program, Management Plan for Project Quality, PP-001.

(Reference 20).

The NRC-Of fice of Special Projects (OSP) conducted an inspection of the project in August 1987 and reported its results in October,1987. These results have been evaluated and appropriate corrective action initiated.

"The TU Electric Technical Audit Program (TAP) has been in effect since January 1987. Prior to January 1987, the TU Electric Quality Assurance (QA) Department performed audits of selected engineering service contrac-tors using technical specialists as part of its vendor audit program.

O 5-19

- 5.4 CORRECTIVE AND PREVENTIVE ACTION i

k SWEC has developed Design Basis Documents (DBDs) and updated the electrical installation specification to implement the corrective actions resulting from the electrical portion of the Corrective Action Program (CAP). These Design Basis Documents (DBDs) contain the design criteria for validating the el d rical design of CPSES Unit 1 and Common. As a result of the electrical portion of the Corrective Action Program (CAP) design validation, the CPSES Unit 1 and Common electrical systems and components are validated as being capable of performing their safety-related functions.

This validation is documented in the drawings, calculations, and specifica-tions which are contained in the Design Validation Packages (DVPs). This validated design documentation will be provided to TV Electric at the completion of the Corrective Action Program (CAP). The Design Basis Documents (DBDs) used for validation will also be 'rovided to Comanche Peak Engineering (CPE). The validated design documentation and Design Basis Documents (DBDs) can provide the basis for configuration control of CPSES electrical design and can be utilized by TV Electric to facilitate operation, maintenance, and future modifications in accordance with licensing commitments following issuance of an operating license.

Interfaces between organizations have been identified and addressed in detail within project procedures. Those electrical interfaces are discussed in Section 5.1.2.2.

3 Practical experience has been provided to Comanche Peak Engineering (CPE) engineers who have worked alongside SWEC engineers during the ongoing validation process. Experience gained by CPE engineers included changes in design documents, and familiarization with procedures followed and regulatory requirements.

TU Electric Comanche Peak Engineering (CPE) is developing a program to assure a complete and orderly transfer of the engineering and design function from SWEC to CPE. The program provides for the identification of those tasks presently being performed by SWEC which are to be transferred to Comanche Peak Engineering (CPE) and the identification of all procedures, programs, training, and staffing requirements. The program is based upon three prerequisites: (a) the Corrective Action Program (CAP) effort to support plant completion is finished for the particular task; (b) the electrical Design Validation Packages (DVPs) are complete; and (c) any required preventive action taken, as discussed in Appendices A and B, is complete.

O 5-20

FIGURE 5-1 D CORRECTIVE ACTION PROGR AM (CAP) TECHNIC AL INTERFACES b EL ECTRIC AL TU ELECTm C COW ANCME Pt At ENGINE Emiko JL CPSES UNifI * .CA' ESASCO iWPtLL C0mponAfl0" OWEm , gnag guiggion *MVAC

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HBLE5-1 ELECTRICAL DESIGN BASIS DOCUMENTS (OB0s)

'0B0 No. Title OBD-EE-038, Revision 1 Offsite Power System DBO-EE-040, Revision 1 6.9 kV Electrical Power System OBD-EE-041, Revision 1 480 V and 120 V ac Electrical Pcwer System OBO-EE-043, Revision 1 118 V ac Uninterruptible Power Supply System OBO-EE-044, Revision 1 OC Power Systems DBO-EE-051, Revision 1 Protection Philosophy DBD-EE-052, Revision 1 Cable Philosophy and Sizing Criteria 080-EE-053, Revision 1 Starter Control Circuit Parameters / Requirements DBD-EE-054, Revision 1 Control Circuit Parameters / Loading Requirements DBO-EE-057, Revision 1 ' Separation Criteria OBD-EE-062, Revision 1 Containment Electric Penetration Assemblies V

.,_-_._.._,__.___m. . _ _ . . , _-_m._- ,,. -_._ , ,_, ,, y,. ,

, TABLE 5-2 (d SWEC PROJECT PROCEDURES APPLICABLE TO THE ELECTRICAL P0RTION OF THE CORRECTIVE ACTION PROGRAM (CAP)

Procedure No. Title PP-001, Revision 2 Management Plan for Project Quality PP-003, Revision 0 Preparation, Review, and Approval of Generic Issue Reports (GIRs)

PP-006, Revision 2 Procedure for Processing Corrective Action Requests (CARS)

PP-008, Revision 2 Preparation and Approval of Task Descriptions PP-009, Revision 2 Preparation and Control of Manual and Computerized Calculations PP-011, Revision 1 SWEC-CAP /TV Electric Interface PP-012, Revision 1 Westinghouse Interface p PP-014, Revision 2 SWEC-CAP /Ebasco Interface O PP-015, Revision 2 SWEC-CAP /Impell Interface PP-019, Revision 2 Change Controls for Licensing Documents PP-020, Revision 2 Control of Design Related Project Documents PP-022, Revision 1 Performing Project Surveillances PP-023, Revision 5 Processing of Design Change Authorizations (OCAs) and Change Verification Checklists (CVCs)

PP-024, Revision 1 Review of Construction, Quality Control, Startup, and Pre-Operational Procedures PP-026, Revision 5 Processing of Nonconformance Reports (NCRs)

Conditional Release Requests and Test Deficiency Reports (TORS)

PP-027, Revision 0 System for Processing Items of Reportability PP-030, Revision 1 Preparation, Review and Approval of Design l Engineering Packages (DEPs) i PP-031, Revision 0 Preparation and Issue of Design Modifications (DMs) l Os 1

TABLE 5-2 (cont'd)

Procedure No. Title PP-032, Revision 3 Preparation, Review, and Approval of SWEC Project Orawings PP-033, Revision 1 Review of Contractor Specifications PP-034, Revision 3 Processing of Procurement Documents PP-035, Revision 0 Project Training Program PP-036, Revision 1 Procedure for Computer Aided Design (CAD) Drawing Conversion PP-037, Revision 0 Definition of Design Document ~ Classification and Marking of Design Documents PP-040, Revision 0 Procedure for the Review of Wiring Diagrams PP-041, Revision 2 Nonconformance Evaluation Procedure PP-042, Revision 1 SWEC-CAP /PSAS Interface PP-048, Revision 1 Maintenance of the TV Electrii Calculation File PP-049, Revision 0 Control of Engineering Sketches PP-050, Revision 2 Preparation of Field Verification Method (FVM)

Procedures PP-053, Revision 2 Review and Approval of Vendor Documents PP-056, Revision 3 Preparation, Approval, and Issue of Specific Technical Issue Reports (STIRS)

PP-058, Revision 1 Processing of Licensing Correspondence PP-059, Revision 0 Procedure for Processing of Deficiency Reports (DRs)

PP-062, Revision 0 Processing Temporary Software and Data Base Modifications to In-Plant Computers PP-063, Revision 0 Specification, Procedure and Drawing Update (SPA 0U)

Program PP-064, Revision 1 Preparing and Documenting Safety Evaluations on Preoperating License Design Modifications  :

PP-066, Revision 1 Initiation of Design Modification Requests (DMRs)

PP-067, Revision 1 Resolutions of Discrepancy / Issue Resolution Reports l PP-075, Revision 1 Computerized Cable and Raceway Data System (CARDS)

! i I

2

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TABLE 5-2 (cont'd)

Procedure No. Title PP-076, Revision 1 Technical Procedure for Maintain Spaced Cable Design PP-077, Revision 0 Control of Computerized Comanche Peak Electrical Data Base (CPED)

PP-078, Revision 1 Procedure for Engineering Review of CPSES Equipment /

Materials Storage and Maintenance Requirements PP-200, Revision 1 CPSES Design Basis Consolidation Program Plan PP-201, Revision 2 Preparation, Review and Approval of Design Basis Documents PP-202, Revision 0 Design Validation Packages (DVPs)

PP-203, Revision 1 Calculation Validation Pro edure PP-204, Revision 2 Drawing / Diagram Validation n'rocedure PP-205, Revision 3 Specification Validation Proci. dure PP-208, Revision 0 Post Construction Hardware Validation Program Engineering Evaluations PP-209, Revision 0 Technical Specification Validation PP-212, Revision 1 Design Validation Related Documents PP-214, Revision 1 Component Validation Procedure PP-215, Revision 0 Preparation, Review, Approval and Control of Project Status Reports PP-216, Revision 0 Technical Procedure for 480 V System Short Circuit Calculation PP-217, Revision 0 Technical Procedure for Station Service Voltage Profile Calculation Down to 480 V PP-218, Revision 0 Technical Procedure for Voltage Drop Calculations for AC and DC Control Circuits PP-220, Revision 1 Commodity Attribute Matrix O

3

l TABLE 5-3 POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP) i ELECTRICAL

(

Construction Final Acceptance PCHVP Attribute Work Category Attribute Validation Method Cable Tray Presence of separation CPE-SWEC-FVM-EE/ME/IC/

barriers CS-088 (Reference 24)

Clearance (spatial separa- CPE-SWEC-FVM-CS-068 tion) - distance between (Reference 25) tray and adjacent hot pipe /

equipment Presence of correct color ECE 9.04-05 (Reference 26) code and cable tray identification markers Grounding / cable termina- CPE-SWEC-FVM-EE/ME/IC/

tion configuration CS-090 (Reference 28)

Presence of color code and ECE 9.04-05 cable tray identification markers for tray with thermolag (fire protection material)

Cable tray covers: type, ECE 9.04-05 size, location and attachments Presence of damage ECE 9.04-05 Cable fill in trays ECE 9.04-05 Cable fill in trays CPE-SWEC-not above the siderail FVM-EE/ME/IC/CS-090 Routing ECE 9.04-05 Spatial separation CPE-SWEC-FVM-EE/ME/IC/

of cable trays CS-088 Cable - Power, Installed cable length CPE-SWEC-FVM-EE/ME/IC/

Control and CS-089 (Reference 29)

Instrumentation Configuration of pre- CPE-SWEC-FVM-EE/ME/IC/

insulated environmental CS-090 sealed (PIES) electrical splices in harsh environment Bend radius outside of ECE 9.04-05 equipment 1

TABLE 5-3 (Continued)

-I Construction Final Acceptance PCHVP Attribute

\> -Work Category Attribute Validation Method Cable - Power, Trained radius inside of CPE-SWEC-FVM-EE/ME/IC/

Control and equipment CS-090 Instrumentation (continued) Effect from cable pull ECE 9.04-05 overtension Cable drop length in free ECE 9.04-05 air at transition point Cable pulling aids removed CPE-SWEC-FVM-EE/ME/IC/

at fire seals and open CS-090 conduit ends Presence of cable slack CPE-SWEC-FVM-EE/ME/IC/

CS-090 Location and type of cable CPE-SWEC-FVM-EE/ME/IC/

support grips CS-089 Presence of damage CPE-5'dEC-FVM-EE/ME/IC/

CS-090 ,

Q Presence of cable jacket CPE-SWiiC-FVH-EE/ME/IC/

Q indentations CS-090 Distance between pull FCE 9.04-05 points Configuration of cable ECE 9.04-05 fieldjumpers Configuration of splices / ECE 9.04-05 repairs Fire detection wiring ECE 9.04-05 conductor size and number and detector type and location Cable identification ECE 9.04-05 markers, number, and 4 location Installation of splice ECE 9.04-05 connectors Insulation resistance ECE 9.04-05 (megger/ continuity) 2

TABLE 5-3 (Continued)

. Construction Final Acceptance PCHVP Attribute Work Category Attribute Validation Method Cable - Power, Presence of cable termin- CPE-SWEC-FVM-EE/ME/IC/

Control and ations for unscheduled con- CS-089 Instrumentation duits entering the control (continued) room Material type of pigtail ECE 9.04-05 extension wire Power cable minimum length CPE-SWEC-FVM-EE/ME/IC/CS-090 Addition and testing of NIS ECE 9.04-05 triaxial cables into a con-duit already containing NIS cables Presence of NIS triaxial ECE 9.04-05 cable with Tefzel jacket within containment NIS able bend radius CPE-SWEC-FVM-EE/ME/IC/CS-090 Support configuration for ECE 9.04-05 1 cables inside panels -

Configuration of cable CPE-SWEC-FVM-EE-064 splices and terminations (Reference 30) &

with Raychem heat shrink- ECE 9.04-05 able tubing Routing ECE 9.04-05 Arrangement of single CPE-SWEC-FVM-EE/ME/

conductor cables used in IC/CS-086 (Reference 27) multiple conductor per phase circuits

> Separation for redundancy CPE-5WEC-FVM-EE/ME/ '.

and voltage classification, IC/CS-088 & ECE 9.04-05 and presence of barriers Spacing of power cables CPE-SWEC-FVM-EE/ME/

in trays IC/CS-086 Presence and spacing of CPE-SWEC-FVM-EE/ME/

permanent cable ties IC/CS-086 Type, size, and color code ECE 9.04-05 Instrumentation cable manu- CPE-SWEC-FVM-EE/ME/IC/

facturer and make CS-086 3

' TABLE 5-3 (Continued)

( ,/ Construction Final Acceptance PCHVP Attribute Work Category Attribute Validation Method Cable - Terminations Termination configuration ECE 9.04-05 of shield and drain wires Lugs free of damage (degree CPE-SWEC-FVM-EE/IC/

of bend and twist) CS-090 f

Type of bolt .g hardware ECE 9.04-05 for electrical connections, cable terminal pads and equipment terminal pads and buses Coaxial and triaxial cable ECE 9.04-05 installation configuration Termination configuration ECE 9.04-05 of instrumentation cable Type and configuration of ECE 9.04-05 insulated splice connec-tors, (PIES / terminal lug connectors, pin plug con-

[. nectors, terminal connec-x tors and spade lug Connectors i Landing configuration of CPE-SWEC-FVM-EE/ME/IC/

field cables, shield and CS-087 (Reference 36) drain wires Installation configuration ECE 9.04-05 of low voltage taping Installation and termin- ECE 9.04-05 ation configuration of thermocouple extension wires Torque of power cable ECE 9.04-C5 terminations, splices and uninsulated lug connectors Presence and extent of ECE 9.04-05 damage on vendor lugging (degree of bend and twist)

Terminal screw CPE-SWEC-FVM-EE/ME/

O tightness IC/CS-087 4

TABLE 5-3 (Continued)

[ Construction Final Acceptance PCHVP Attribute L Work Category Attribute Validation Method Cable - Terminations (continued) Type and_ configuration of CPE-SWEC-FVM-EE/

Weidmuller terminal blocks ME/IC/CS-090 Conduit System Rigid and flexible conduit ECE 9.04-05 bend radii Presence of insulated bush- ECE 9.04-05 ings at conduit ends Location of color coding ECE 9.04-05 and identification markers Presence of expansion fit- ECE 9.04-05 tings on conduit runs greater than 75' Junction box-material ECE 9.04-05 Percent conduit fill ECE 9.04-05 Presence of damage to ECE 9.04-05 g conduit U Conduit routing ECE 9.04-05 Clearance - spatial separa- CPE-SWEC-FVM-CS-068 tion between conduit and hot pipes / equipment Presence of Identification ECE 9.04-05 number / color code applied over Thermolag Type of flexible conduit CPE-SWEC-FVM-EE/ME/IC/CS-089 Presence of weep holes in CPE-SWEC-FVM-EE/ME/IC/CS-090 junction boxes within containment Grounding / cable termin- CPE-SWEC-FVM-EE/ME/IC/CS-090 ation configuration Identification number of CPE-SWEC-FVM-EE/ME/IC/CS-089 unscheduled conduit entering the control room O

5

TABLE 5-3 (Continued) .

. Construction Final Acceptance PCHVP. Attribute Work Category Attribute Validation Method Conduit System Presence of watertight CPE-SWEC-FVM-EE/ME/IC/CS-090 (continued) enclosures and accessories on outdoor Class 1E junction

• boxes Separation distance and/or CPE-SWEC-FVM-EE/ME/IC/CS-088 presence of barriers for conduits Separation distance of NIS CPE-SWEC-FVM-EE/ME/IC/CS-088 conduits NIS conduit bend radii and ECE 9.04-05 distance between pull points Presence of damage to ECE 9.04-05 flexible conduit Presence of damage, foreign CPE-SWEC-FVM-EE/ME/IC/CS-090 materials, and cleanliness for junction boxes Junction box NEMA type CPE-SWEC-FVM-EE/ME/IC/CS-089 Service level separation CPE-SWEC-FVM-EE/ME/IC/CS-090 between conduits containing power cables Installation configuration CPE-SWEC-FVM-EE/ME/IC/CS-090 of covers, gaskets, screws,

, bolts, nuts in junction boxes Sleeve size, location, CPE-SWEC-FVM-EE-023 identification, color code (Reference 31)  ;

and bushings i

Number and size of cables CPE-SWEC-FVM-EE-023 in sleeve Conduit to cable tray ECE 9.04-05 interface configuration 4

!O 4

l

' i 6

i

~ - - - , , . , - . - , , - , - ,,-. . . . . - . , , , _ , . ,- , - , , , , _ . . , - .--, ,, - .. -

TABLE 5-3 (Continued) ,

r^N (d Construction Work Category Final Acceptance Attribute PCHVP Attribute Validation Method Electrical Equipment - Clearance distance or space CPE-SWEC-FVM-CS-068 General between equipment and adjacent structures and/or commodities Electrical equipment to CPE-SWEC-FVM-EE/ME/IC/

raceway separation CS-088 Grounding / cable termin- CPE-SWEC-FVM-EE/ME/IC/

ation configuration CS-090 Equipment identification ECE 9.04-05 nameplates and lettered tags - train / channel background color and placement ,

Presence of separation CPE-SWEC-FVM-EE/ME/IC/CS-088 barriers within equipment Clear air distance between CPE-SWEC-FVM-EE/ME/IC/CS-088 i Class 1E cables, and between O

d Class 1E and non-Class 1E cables or presence of sepa-ration barriers for internal wiring I

Fuse rating CPE-SWEC-FVM-EE/ME/IC/

CS-89 & ECE 9.04-05

. Electrical Equipment - Configuration of equipment ECE 9.04-05 6.9 kV Switchgear sections (assembly) and other connections Configuration of covers, ECE 9.04-05 gaskets, vapor barrier and associated hardware for doors Presence of damage, equip- ECE 9.04-05 ment cleanliness and foreign materials Configuration of internal ECE 9.04-05 components used in field modifications and rework Equipment ratings CPE-SWEC-FVM-EE/ME/IC/CS-089 7 ,

l TABLE 5-3 l (Continued)

[ Construction Final Acceptance PCHVP Attribute V' Work Category Attribute Validation Method Electrical Equipment - Configuration of equipment ECE 9.04-05 480 Volt Unit Substation sections / components (assembly) and other connections Configuration of covers, CPE-SWEC-FVM-EE/ME/IC/CS-090 ,

gaskets, vapor barrier and associated hardware for doors Presence of damage, ECE 9.04-05 equipment cleanliness and foreign materials Configuration of internal ECE 9.04-05 components used in field modifications and rework Equipment ratings CPE-SWEC-FVM-EE/ME/IC/CS-089 Torque of bus insulators ECE 9.04-05 l A Electrical Equipment - Configuration of equipment ECE 9.04-05

\j 480 Volt Motor Control sections / components Centers (assembly) and other connections Configuration of covers, CPE-SWEC-FVM-EE/ME/IC/CS-090 gaskets, vapor barrier and associated hardware for doors Presence of damage, equip- ECE 9.04-05 ment cleanliness and pres-ence of foreign materials Configuration of internal ECE 9.04-05 components used in field modifications and rework

Equipment ratings CPE-SWEC-FVM-EE/ME/IC/CS-089 Electrical Equipment - Equipment is clean and ECE 9.04-05 125 Volt DC Charger free of foreign materials Electrical Equipment - Configuration of covers, CPE-SWEC-FVM-EE/ME/IC/CS-090 125 Volt DC Charger, gaskets, vapor barrier and 125 Volt DC Distribution associated hardware for Panels, 125 Volt DC doors switchboards. ,

8 t

TABLE 5-3 (Continued)

Construction Final Acceptance PCHVP Attribute

[L Work Category Attribute Validation Method Electrical Equipment - Presence of damage, equip- ECE 9.04-05 125 Volt DC Charger, . ment cleanliness and pres-125 Volt DC Distribution ence of foreign materials Panels, 125 Volt'OC Switchgear Configuration of internal ECE 9.04-05 (continued) components used in field modifications and rework Equipment ratings CPE-SWEC-FVM-EE/ME/IC/CS-089 Electrical Equipment Configuration of batteries ECE 9.04-05 125 Volt Batteries and racks Presence of damage ECE 9.04-05 Configuration of internal ECE 9.04-05 components used in field modifications and rework Torque of intercell bolts ECE 9.04-05 I Battery ratings CPE-SWEC-FVM-EE/ME/IC/CS-089 Electrical Equipment - Equipment is clean, presence ECE 9.04-05 120 Volt AC Distribution of foreign materials Panels and Transformers 118 Volt Uninterruptible Configuration of covers, CPE-SWEC-FVM-EE/ME/IC/CS-090 Power Supply (UPS) and gaskets, vapor barrier and panels associated hardware for doors Presence of damage ECE 9.04-05 Configuration of internal ECE 9.04-05 components used in field modifications and rework Equipment ratings CPE-SWEC-FVM-EE/ME/IC/CS-089 Mounting configuration of ECE 9.04-05 equipment Electrical Equipment - Configuration of equipment ECE 9.04-05 Control Panels and Racks sections / components (assembly) and other connections

, Configuration of covers, CPE-SWEC-FVM-EE/ME/IC/CS-090 l O gaskets, vapor barrier I and associated hardware for doors 9

b

TABLE 5-3 (Continued)

Construction Final Acceptance PCHVP Attribute v Work Category Attribute Validation Method Electrical Equipment - Presence of damage, equip- ECE 9.04-05 Control Panels and Ricks ment cleanliness and pres-(continued) ence of foreign materials Configuration of internal ECE 9.04-05 components used in field modifications and rework Equipment ratings CPE-SWEC-FVM-EE/ME/IC/CS-089 Component type (York CPE-SWEC-FVM-EE/ME/IC/CS-090 equipment)

Electrical Equipment - Bend radius of pigtails ECE 9.04-05 Electrical Conductor Seal Assembly (ECSA) Configuration of ECSA ECE 9.04-05 assembly Presence of damage, equip- ECE 9.04-05 ment cleanliness and pres-ence of foreign materials Identification, location ECE 9.04-05 and configuration Electrical Equipment - Torque switch settings ECE 9.04-05 Limitorque Valve Operators Electrical Equipment - Configuration of covers, CPE-SWEC-FVM-EE/ME/1C/CS-090 Local Control Stations gaskets, vapor barrier and associated hardware for doors Presence of damage, equip- ECE 9.04-05 ment cleanliness and pres-ence of foreign materials Configuration of internal ECE 9.04-05 components used in field modifications and rework Electrical Equipment - Tightness of solenoid C9E-SWEC-FVM-EE/ME/IC/CS-090 Valve Solenoids housing, and presence of damage Electrical Equipment - Configuration of cable ECE 9.04-05 Penetration Assembly pigtails (bend radius, shrinkable tube or taping, l O' and presence of damage) i 10 1

TABLE 5-3 (Continued)

Construction . Final Acceptance PCHVP Attribute (b Work Category Attribute Validation Method Electrical Equipment - Location (building / ECE 9.04-05 Penetration Assembly elevation and quadrant)

(continued) and orientation Configuration of penetra- ECE 9.04-05 tion retaining ring Equipment cleanliness, pres- ECE 9.04-05 ence of foreign materials Identification ECE 9.04-05 Assembly configuration and ECE 9.04-05 field modifications Correct component configu- ECE 9.04-05 ration (via part numbers)

Pigtail supports (every ECE 9.04-05 36 inches or less)

Configuration of lead wool ECE 9.04-05 (radiation protection)

Bolting torque ECE 9.04-05 Continuity check and ECE 9.04-05 insulation resistance test for pigtail-damaged termina-tions l0 11

TABLE 5-4

SUMMARY

OF SWEC ENGINEERING ASSURANCE (EA) AUDITS AUDIT REPORT AUDIT RESPONSE AUDIT NO. LOCATION

• DATES OF AUDITS TRANSMITTAL TRANSMITTAL PROJECT 1 BOS 01/26/87-03/04/87 IOM-87/077 04/10/87 SITE 1 CP 03/02/87-03/06/87 10M-87/82 04/14/87 PROJECT 2 BOS/CH 04/27/87-05/22/87 10M-87/183 07/06/87 SITE 2 CP 05/18/87-05/22/87 10M-87/204 07/13/87 PROJECT 3 BOS 07/20/87-08/28/87 10M-87/313 10/13/87 SITE 3 CP 11/16/87-11/20/87 10M-87/521 IN PROGRESS

• BOS - Boston Office CP - Comanche Peak Site CH - Cherry Hill Office O

J s i

i 0

9 l

l

TABLE 5-5 p \.

V SUlHARY OF TV ELECTRIC QUALITY ASSURANCE (QA) AUDITS AUDIT REPORT AUDIT RFSPONSE AUDIT NO. LOCATION

• DATES OF AUDITS TRANSMITTAL TRANSMITTAL TCP-87-04 CP 02/02/87-03/03/87 QIA-7096 SWTU-1524/2580 TCP-87-07 CP 03/09/87-04/22/87 QIA-7159 SWTU-3025 ATP-87-16 BOS 06/01/87-06/05/87 ATP-7100 SWTU-2844 ATP-87-11 CP 04/27/87-05/01/87 ATP-7056 SWTU-3027 ATP-87-507 CP 06/15/87-06/23/87 ATP-7187 SWTU-3486 ATP-87-518 CP 07/27/87-08/07/87 ATP-7425 SWTU-4952 TCP-87-24 CP 07/22/87-10/30/87 NE-14415 IN PROGRESS ATP-87-29 BOS 07/13/87-07/17/87 ATP-7192 SWTU-3473 ATP-87-43 BOS 08/31/87-09/04/87 ATP-7314 SWTU-4080 ATP-87-521 CP G8/17/87-09/29/87 ATP-7480 SWTU-5382 TUG-87-10 CP 05/04/87-05/15/87 QIA-7256 NONE REQ'O TCP-87-27 CP 08/04/87-08/11/87 QIA-7291 SWTU-4102 TCP-87-37 CP 10/12/87-10/21/87 QIA-7394 IN PROGRESS ATP-87-544 CP 12/07/87-12/16/87 IN PROGRESS

• BOS - Boston Office CP - Comanche Peak 4

l

[

iO l 1

6.0 REFERENCES

b V 1. TV Electric Engineering and Construction Policy No. 1, CPSES Corrective l Action Program, Revision 2.

2. TV Electric Letter TXX-6500, W.G. Counsil to U.S. Nuclear Regulatory Commissicn, Response to Request for Additional Information in Conjunc- i tion with Program Plan Update, dated June 25, 1987.

3. TV Electric Letter TXX-6631, W.G. Counsil to U.S. Nuclear Regulatory .

Commission, Comanche Peak Progtams, dated August 20, 1987.

4. SWEC Comanche Pu k Project Procedure PP-200, CPSES Design Basis Consol-idation Program Plan, Revision 1, dated January 12, 1988.

5. CPSES Specification, Electrical Installation, Class I, II and l Non-Safety, 2323-ES-100, Revision 4, dated November 5, 198/.

6. CPSES Design Basis Document DBD-EE-057, Separation Criteria. Revision

. 1.

7. SWEC Comanche Peak Pro,iect Procedure PP-203, Calculation Validation Procedure, Revisicn 1, dated Au;ust 19, 1987.

8. SWEC Comanche Peak Project Procedure PP-204, Drawing / Diagram Validation

'rocedure, Revision 2, dated September 9, 1987.

) 9. CPSES Design Basis Document DU ME-250, Reactor Coolant System.

Revision 1.

10. CPSES Design Basis Documen . OBD-ME-255. Chemical and Volume Control System, Revision 1.

11. CPSES Design Basis Document DBD-ME-258, Boron Recycle System, Revision 1.

12. CPSES Design Basis Document OBD-ME-266, Residual Heat Removal (RHR)

System, Revision 1.

13. CPSES Design Basis Document DBD-ME-261, Safety Injection System, Revision 1.

14. CPSES Design Basis Document DBD-ME-20, Caseous Waste System, ;

Revision 1.

15. Westinghouse CPSES Significant Interface Identification Packages for Reactor Coolant, Chemical and Volume Control, Boron Recycle, Residual Heat Removal, Safety Injection, and Control and Protection System.

16. TU Electric EC-9.04, Engineering and Construction Procedure, Post Constructica Hardwara Validation Program, Revision 1, September 23, 1987.

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17. Comanche Peak Response Team Program Plan and Issue Specific Action Plans, Appendix 0, CPRT Sampling Policy, Applications and Guidelines, Revision 1, January 31, 1986, and Appendix E, Resolution of Discrepan-cies Identified by the CPRT, Revision 3, dated June 18, 1987.

18. SWEC Comanche Peak Procedure PP-050, Preparation of Field Verificathn Method Procedures, Revision 2, dated September 3, 1987.

19. SWEC Topical Report SWSQAP 1-74A, Stone & Webster Standard Nuclear Quality Assurance Program, Revision E, dated February 21, 1986.

20. SWEC Comanche Peak Project Procedure PP-001, Management Plan for Project Quality, Revision 2, dated January 6, 1988.

21. SWEC Comanche Peak Project Procedure PP-201, Preparation, Review, and Approval of Design Basis Documents, Revision 2, dated June 23, 1987.

22. SWEC Comanche Peak Project Procedure PP-205, Specification Validation Procedure, Revision 3, dated September 10, 1987.

23. TV Electric Letter TXX-6676, W.G. Counsil, to U.S. Nuclear Regulatory Commission, Technical Audit Program and Engineering Functional

Evaluation, dated September 8, 1987.

24. Field Verification Method, Post Construction Hardware Validation Program Engineering / Quality Control Reverifications, CPE-SWEC-FVM-O EE/ME/IC/CS-088, Revision 1, dated September 21, 1987.

O 25. Field Verification Method, Commodity Clearance. CPE-SWEC-FVM-CS-068, Revision 0, dated July 30, 1987.

26. TU Electric ECE 9.04-05, Post Construction Hardware Validation Program Engineering Evaluations, Revision 0, dated September 1, 1987.

27. Field Verification Method, Fost Construction Hardware Validation Program Construction / Quality Control Reverifications, CPE-SWEC-FVM-EE/ME/IC/CS-086, Revision 2, dated October 15, 1987.

28. Field Verification Method, Post Construction Hardware Validation Program Quality Contrni Reinspections, CPE-SWEC-FVM-EE/ME/IC/CS-090, Revision 2, dated October 15, 1987.

29. Field Verification Method, Post Construction Hardware Validation Program Engineering Walkdowns, CPE-SWEC-FVM EE/ME/IC/CS-089, Revision 2, dated October 15, 1987.

i 30. Field Verification Method, Instruction to Acquire Data for Heat Shrinkable Sleeve Installations, CPE-SWEC-FVM-EE-064, Revision 1, dated

• October 15, 1987.

31. Field Verification Method, Instruction to Acquire Data for Cable Percent-Fill Calculations and Identification of Thru-Floor and Thru-O Wall Embedded Conduit Sleeves, CPE-FVM-EE-023, Revision 2, dated March 26, 1987.

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32. CPSES Final Safety Analysis Report, Section 3.2. i O' -

33. SWEC Comanche Peak Procedure PP-077, Control of Computerized Comanche l

Peak Electrical Data Base (CPED), Revision 0, dated July 14, 1987.

34. SWEC Comanche Peak Procedure PP-208, Post Construction Hardware  !

Validation Program Engineering Evaluations, Revision 0, dated December 11, 1987. ,

35. SWEC Comanche Peak Procedure PP-220, Commodity Attribute Matrix, 3

Revision 1, dated October 15, 1987.

36. Field Verificatiur. Method, Post Construction Hardware Validation Pro-gram Startup Verifications, CPE-SWEC-FVM-EE/ME/IC/CS-087, Revision 0, '

dated January 7, 1988.

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APPENDIX A COMANCHE PEAK RESPONSE TEAM (CPRT) AND EXTERNAL ISSUES This appendix contains a comprehensive summary of the SWEC eva'uation, resolution and corrective and preventive action for all Comanche Peak Response Team (CPRT) and external issues which are related to the electrical design. Specific references to the design criteria, procedures and specifications which have resolved the issues are provided.

To report the resolution of the Comanche Peak Response Team (CPRT) and external issues, an individual subappendix was developed for each issue.

Each subappendix includes: a definition of the issue; issue resolution; and corrective and preventive action.

The issues contained in Subappendices Al through A7 were initially raised by the Comanche Peak Response Team (CPRT)1,2 The issues contained in Subappendices A8 through A14 are included in the CYGNA Energy Services (CYGNA) Review Issue List (RIL)3 The preventive action is embodied in the procedures, and specifications and the Design Basis Documents (DB0s) developed and used in the electrical portion of the Corrective Action Program (CAP). These procedures, specifications and the Gesign Basis Documents (DB0s) resolve all related Comanche Peak Response Team (CPRT) and external issues. Implementation of these preventive actions can ' assure that the electrical design and hardware

,q for CPSES Unit 1 and Common will continue to comply with the licensing commitments throughout the life of the plant as described in Section 5.4.

Q Comanche Peak Response Team (CPRT) and external issues contained in Appen-dix A are listed below:

IL. P. (TERA) Electrical Issue Resolution Reports (IRRs) DAP-E-EIC-501 and 504, 2TU Electric Comanche Peak Response Team Issue Specific Action Plans (ISAPs)

I.a.1, 2, 3, 4, 5; I.b.1, 2, 3, 4; and VII.c (Appendices 1-6).

3CYGNA Electrical Review Issues List (RI! ) Comanche Peak Steam Electric i Station (CPSES) Independent Assessment Program - All Phases, Revision 3, transmitted to TV Electric by CYGNA Energy Services in letter No. 84056.095 dated November 26, 1985, i

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4 Issue No. Issue Title

• Al Electrical Separation A2 Electrical Calculations  ;

A3 Heat Shrinkable Cable Insulation Sleeves .

A4 AMP Preinsulated Environmental Sealed (PIES)  !

Butt Splices i A5 Agreement Between Drawings and Field Terminations A6 Vendor Installed AMP Terminal Lugs  :

.A7 Electrical Equipment Installation A8 System Short Circuit Currents  :

A9 AC Distribution System Voltages A10 Overcurrent Protection  !

All Power Cable Oerating Inside Containment i A12 Voltage Orop Calculations

- A13 Cable Tray Fill for Maintained Space Cables i

A14 Cable Ampacity Calculations i i

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SUBAPPENDIX Al e

(_)i ELECTRICAL SEPARATION (IRR DAP-E-EIC-504) (ISAPs 1.b.1, I.b.2, I.b.3 and I.b.4)

1. 0 Definition of the Issue The issues were as follows:

1.1 Inadequate Separation Within Panels (IRR DAP-E-EIC-504)(ISAP I.b.1, I.b.2 and I.b.4)

Class 1E, associated Class IE and nun-Class 1E cabling, wiring, and equipment separation within panels was not consistent with the guidance provided in Regulatory Guide 1.75 and IEEE 384.

1.2 Safety-Circuit Degradation Due to Non-Safety Interface (IRR DAP-E-EIC-504)

Interconnections between non-Class 1E circuits and Class 1E circuits were not consistent with the guidance provided in Regulatory Guide 1.75 and IEEE 384.

1. 3 Inadequate Separation for Conduit / Cable / Tray Configurations (IRR DAP-E-EIC-504) (ISAP I.b.3)

(n',) Spatial separation between Class IE, associated Class 1E, and non-Class 1E cable, conduit (including flexible conduit) and cable tray were not consistent with the guidance provided in Regulatory Guide 1.75 and IEEE 384. In addition, after acceptance of cable tray installations, modifications to trays resulted in some non-safety class cable tray covers being removed. The removal of these covers would have resulted in a decrease in the spatial separation requirements.

1.4 Inadequate Sensor / Tap Separation Requirements (IRR-E-EIC-504)

The separation requirements for redundant sensors and sensor taps were not consolidated in a single installation specification.

1. 5 Electrical Equipment Separation Concerns (IRR DAP-E-EIC-504)

Class 1E, associated Class 1E, and non-Class 1E electrical equip-ment were not physically separated in accordance with the guidance provided in Regulatory Guide 1.75 and IEEE 384 and IEEE 420.

2.0 Issue Resolution Issues 1.1, 1.2, 1.3 and 1.5 were resolved by incorporating the guidance of Regulatory Guide 1.75, IEEE 384 and IEEE 420 (References 4.1, 4.2 and 4.3) into the design criteria specified in the Design

/' Basis Document (DBO) (Reference 4.4). The electrical installation b specification (Reference 4.5), has been revised to incorporate the Al-1

4 h l revised electrical' separation design criteria.  !

The electrical one line drawings have been validated to comply with the f' electrical separation (independence) design criteria contained in the Design Basis Document (DBD) (Reference 4.4). I s ,

Inconsistencies between the drawings and the Design Basis Document  !

(DBD) (Reference 4.4) have been resolved. Physical separation of I electrical cable, raceway (conduit, cable tray) and electrical equip- l men' is being validated during the Post Construction Hardware Valida- i tion Program (PCHVP) in accordance with a Field Verification Method j (FVM) (Reference 4.6). j Hardware not in accordance with design criteria is being corrected by  :

retraining cables, adding barriers, adding isolating devices, or i rerouting cable as required.  !

The resolution of issue 1.4 is addressed in the Instrumentation and control Project Status Report (PSR).  ;

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution ,

of this issue.

, The issues (1.1,1.2, and 1.3) were determined to be reportable under I O the provisions of 10CFR50.55(e). They were reported as Significant  :

d Deficiency Analysis Reports (SOARS) by TU Electric to the NRC in the 1etters listed below:

l SDAR CP-87-85, TXX-7124, dated December 23, 1987.

SDAR CP-87-136, TXX-88065, dated January 11, 1988. ,

SDAR CP-88-07, TXX-880C6, dated January 11, 1988.

j SDAR CP-88-12, TXX-88071, dated January 11, 1988.

SDAR CP-87-13, 1XX-88059, dated January 11, 1988.  !

1 3.1 Corrective Action The guidance of Regulatory Guide 1.75, IEEE 384 and IEEE 420

, (References 4.1, 4.2 and 4.3) has been incorporated into the design criteria specified in the Design Basis Document (DBD)

(Reference 4.4). The electrical installation specification  :

(Reference 4.5), has been revised to incorporate the revised i, electrica! separation design criteria.

The electrical drawings have been validated to comply with the electrical separation (independence) design criteria contained in the Design Basis Document (DBD) (Reference 4.4). Inconsistencies  !

, between the drawings and the Design Basis Document (DBD)  ;

i (Reference 4.4) have been resolved. Physical separation of electrical cable, raceway and electrical equipment is being validated during the Post Construction Hardware Validation Program O

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(PCHVP) in accordance with Field Verification Method (FVM) I j (Reference 4.6). l I

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t Hardware changes are being implemented, as required. ,

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3.2 Preventive Action Electrical separation design criteria have been established and documented in the Design Basis Document (DBD) (Reference 4.4) and in the electrical . installation specification (Reference 4.5).

Construction procedure (Reference 4.7) has been revised to require the issuance of removal notices when tray covers are removed.

4.0 References 4.1 Regulatory Guide 1.75, Revision 1, Physical Independence of Electric Systems 4.2 IEEE 384-1974, Trial-Use Standard Criteria for Separation of Class 1E Equipment and Circuits j 4.3 IEEE 420-1973, Trial-Use Guide for Class IE Control Switchboards 1 for Nuclear Generating Stations 4.4 CPSES Design Basis Document DBD-EE-057, Separation Criteria, Revision 1 4.5 CPSES Specification, Electrical Installation, Class I, II and j'~% Non-Safety, 2323-ES-100, Revision 4, November 5, 1987 0 4.6 Field Verification Method, Post Construction Hardware Validation (PCHV) Program Engineering / Quality Control Reverifications, CPE-SWEC-FVM-EE-/ME/IC/CS-088, Revision 1, dated September 21, 1987 4.7 Construction Procedure CP-CPM 6.10, Inspected Items Removal Form, Revision 13 dated April 16, 1986 and Document Change Notice (DCN)

No. 4 dated January 12, 1987.

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p SUBAPPENDIX A2 ELECTRICAL CALCULATIONS (IRR DAP-E-EIC-601)

1. 0 Definition of the Issue r

The issues were as follows: ,

1.1 Assumptions '

Assumptions in some original calculations were undocumented, invalid or incorrect. Some assumptions were inappropriately and inconsistently used.

1.2 Inputs Inconsistencies were noted between the inputs cited in the original calculations with plant design criteria or as-built equipment ratings,  ;

1.3 Documentation The omission of acceptance criteria and the presence of untrace-able references were noted in several original calculations.

1.4 Computer Programs In some original calculations there was a lack of computer program documentation (e.g., program numbers and revision dates were miss-

, ing and printout pages were insufficiently identified).

1. 5 Methodology

Errors in the methodology existed in some original calculations.

1.6 Results calculations did not The results of some of the original adequately demonstrate that the existing electrical equipment conformed to design requirements. I 2.0 Issue Resolution

SWEC resolved these issues by validating the original calculations or ,

preparing supplemental or new calculations in accordance with SWEC t design control Project Procedures PP-009 and PP-203 (References 4.1 and 4.2). These calculations adequately identify assumptions and input

. data and meet the documentation requirements of ANSI N45.2.11 (Refer-

ence 4.3). Validation of original calculations included a check and an i independent review in accordance with SWEC design control Project ,

Procedure PP-203 (Reference 4.2) to assure proper methodology and  !

O correct results. New and supplemental calculations have t'een checked and independently reviewed in accordance with SWEC design control i

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Project Procedure PP-009 (Reference 4.1) to assure proper methodology and correct results. Where calculation results have not demonstrated compliance to the design criteria, design changes were developed and are being implemented. The validated original, supplemental and new calculation results, in conjunction with the developed design changes, ,

demonstrate that the electrical equipment complies with the design criteria specified in the Design Basis Documents (DBDs) (References 4.4, 4.5, 4.6, 4.7, 4.8, 4.9, 4.10, 4.11 and 4.12). In addition, all ,

computer programs used by SWEC for the electrical calculations have been qualified and documented in accordance with SWEC design control Project Proceoure PP-009 (Reference 4.1).

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

The issues were determined to be reportable under the provisions of 10CRF50.55(e). They were reported as Significant Deficiency Analysis Report (SDAR) CP-87-134, in letter number TXX-88064, dated January 11, 1988 from TU Electric to the NRC.

3.1 Corrective Action i

Original electrical calculations have been validated in accordance with the design control Project Procedure PP-203 (Reference 4.2). '

In addition, new and supplemental calculations were developed in O accordance with design control Project Procedure PP-009 (Reference 4.1). Where calculation results have not demonstrated compliance to the design criteria, design changes were developed and are 4

being implemented. The validated original, supplemental and new

• calculation results in conjunction with design changes demonstrate ,

that the electrical equipment complies with the design criteria specified in the Design Basis Documents (DBDs) (References 4.4,  !

4.5, 4.6, 4.7, 4.8. 4.9, 4.10, 4.11 and 4.12).

3.2 Preventive Action l SWEC design control Project Procedure PP-009 (Reference 4.1) was issued to assure consistency in the preparation of calculations. '

The procedure provides requirements for adequate preparation of calculations to assure compliance with design criteria as

specified in the Design Basis Documents (DBDs) (References 4.4,

4.5, 4.6, 4.7, 4.8, 4.9, 4.10, 4.11 and 4.12).

SWEC design control Project Procedure PP-009 (Reference 4.1) f requires assumptions, inputs and references to be documented to allow for traceability and methodology and results to be independently reviewed. In addition, it requires computer  !

programs to be qualified and documented. t A2-2

D 4.0 References k

4.1 SWEC Project Procedure PP-009, Preparation and Control of Manual and Computerized Calculations, Revision 2 4.2 SWEC Project Procedure PP-203, Calculation Validation Procedure, Revision 1 4.3 ANSI N45.2.11, Draft 2, Revision 2, Quality Assurance for the Design of Nuclear Power Plants 4.4 CPSES Design Basis Document DBD-EE-038, Offsite Power System, Revision 1 4.5 CPSES Design Basis Document DBD-EE-039, Onsite Power System, Revision 1 4.6 CPSES Design Basis Document DBD-EE-040, 6.9kV Electrical Power System, Revision 1 4.7 CPSES Design Basis Document DBD-EE-041, 480V and 120V AC Electrical Power System, Revision 1 4.8 CPSES Design Basis Document DBD-EE-043, 118V AC Uninterruptible Power Supply System, Revision 1 4.9 CPSES Design Basis Document DBD-EE-044, DC Power System, v Revision 1 4.:(0 CPSES Design Basis Document DBD-EE-051, Protection Philosophy, Revision 1 4.11 CPSES Design Basis Document DBD-EE-052, Cable Philosophy and Sizing Criteria, Revision 1 4.12 CPSES Design Basis Document DBD-EE-057, Separation Criteria, Revision 1 o

A2-3

t SUBAPPENDIX A3 b HEAT SHRINKABLE CABLE INSULATION SLEEVES (ISAP 1.a.1)

1. 0 Definition of the Issue '

The issue was that heat shrinkable cable insulation sleeves may not have been installed correctly and may not have been installed where ,

required.

2.0 Issue Resolution SWEC resolved the issue by revising the electricai installation speci-fication (Reference 4.1) to include location, installation and inspec-tion criteria. In addition, SWEC reviewed the revised construction procedure (Reference 4.3) and Quality Control (QC) inspection procedure (Reference 4.4) to assure that they were consistent with the revised electrical installation specification.

SWEC is validating the location of and correct installation of heat shrinkable cable insulation sleeves during the Post Construction Hardware Validation Program (PCHVP) using a Field Verification Method (FVM) (Reference 4.2) and an Engineering Evaluation Procedure c (Reference 4.5).

3.0 Corrective and Preventive Action i No additiunal issues were identified during the review and resolution of this issue. ,

The issue was determined not to be reportable under the provisions of .

10CFR50.5F(e).

3.1 Corrective Action u

6 SWEC revised the electrical installation specification (Reference  !

4.1) to provide requirements for heat shrinkable cable insulation sleeve location, iacta lation and inspection criteria.

The Post Construction Hardware Validation Program (PCHVF) is t validating that the heat shrinkable sleeves have been installed

where required and that they are installed such that they will i perform their design function using a field verification method e j (FVM) (Reference 4.2) and an Engineering Evaluation Procedure (Reference 4.5). Inconsistencies will be identified and corrected. '

t 3.2 Preventive Action  !

, i t The installation and inspection requirements provided in the y

! revised electrical installation specification (Reference 4.1) and i implemented in the revised construction procedure (Reference 4.3)  !

j and Quality Control (QC) procedure (Reference 4.4) will assure A3-1  :

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(N that all heat shrinkable cable insulation sleeves will be Q installed correctly and where required.

4.0 References 4.1 CPSES Specification, Electrical Installation, Class I, II and ,

Non-Safety, 2323-ES-100, Revision 4, dated November 5, 1987 4.2 Field Verification Method. Instruction to Acquire Data for Heat Shrinkable Sleeve Installations, CPE-SWEC-FVM-EE-064, Revision 1, dat1d October 15, 1987 4.3 Construction Procedure EEI-08, Class 1E and Non-Class 1E Cable Terminations, Revision 8, dated August 31, 1987 r 4.4 Quality Control Procedure, NQA-3,09-3.05 Quality Control Inspec-tion of Termination Activities, Revision 1, dated August 31, 1987 4.5 TV Electric ECE-9.04~05, Post ionstruction Hardware Validation Program Engineering Evaluations, Revision 0, dated September 1, 1987 .

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SUBAPPENDIX A4 AMP PREINSULATED ENVIRONMENTAL SEALED (PIES) BUTT SPLICES (ISAPs I.a.2 and I.a.3) 1.0 Cafinition of the Issue The issues were as follows:

. Butt splice locations were not documented

. Butt splice installation criteria u"e not adequately addressed in the installation specification

. Butt splices may not have been inspected by Quality Control (QC)

. Butt splice continuity checks were not addressed in the installation specification

. Butt splices may not have been qualified for anticipated service conditions

. Staggering of butt splices in cable bundles was not add,'essed in the installation specification 2.0 Issue Resolution SWEC resolved the issues by revising the electrical installation specification (Reference 4.1) to include required butt splice location, installation and inspection requirements, butt splice continuity check requirements, and requirements for staggering of butt splices within cable bundles. In addition, SWEC reviewed the revised construction procedure (Reference 4. d and Quality Control (QC) inspection procedure (Reference 4.4) to assure that they were consistent with the revised electrical installation specification.

Electrical circuits which contained Preinsulated Environmental Sealed (PIES) butt splices were energized during preoperational testing thus demonstrating splice continuity. Butt splicr locations have been documented. Vendor qualification documentatici l Reference 4.5) was reviewed and it was determined that the Preinsuiated Environmental Sealed (PIES) splices are qualified for anticipated service conditions at CPSES.

Butt splices within instrument and control panels were visually inspected for proper installation, including staggering. Visually unacceptable splices were removed and subjected to pullout testing. In addition, a random sample of visually acceptable splices was also subjected to pullout testing. Results of these tests (Reference 4.6) confirm the splices were adequate to perform their intended function.

SWEC validated that butt splices for device pigtails hava been O installed where required and that they are installed such that they will perform their design function using a Field Verification Method A4-1

(FVM) (Reference 4.2). Those butt splices that did not comply with the O requirements of the revised electrical installation specification V (Reference 4.1) were identified.

implemented.

Hardware changes are being 3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

• The butt splice installation criteria issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-86-38, in letter number TXX-88058, dated January 11, 1988, from TV Electric to the NRC.

3.1 Corrective Action The electrical installation specification (Reference 4.1) was revised to provide requirements for butt splice location, installation and inspection, continuity check and butt splice staggering. Butt splice locations were documented.

! An Environmental Equipment Qualification Summary Package (EEQSP),

(Reference 4.5) was developed which provides adequate documentation validating the environmental qualification of the AMP Preinsulated Environmental Sealed (PIES) butt splices to the anticipated service conditions.

Engineerint; walkdowns in accordance with a Field Verification Method (FVM) (Reference 4.2) validated that butt splices for device pigtails have been installed where required and that they are installed such that they will perform their design function or design changes were identified. These design changes are being implemented.

Butt splices within instrument and control panels were visually inspected for proper installation, including staggering. Visually 4 unacceptable splices were removed and subjected to pullout testing. In addition, a random sample of visually acceptable splices was also subjected to pullout testing. Results of these tests (Reference 4.6) confirm the splices were adequate to perform l their safety-related function.

1 3.2 Preventive Action <

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! The Ssta11ation and inspection requirements provided in the i rev)..:1 electrical installation specification (Reference 4.1) and l

implemented in revised construction procedure (Reference 4.3) and  ;

i Quality Control (QC) inspection procedure (Reference 4.4) assure that butt splices will be installed correctly and where required. ,

In addition, the electrical installation specification (Reference t 4.1) requires documented engineering approval for cable splices ,

prior to their installation.

A4-2

1 4.0 References {

2 4.1 CPSES Specification, Electrical Installation, Class I, II and Non-Saftey, 2323-ES-100, Revision 4, dated November 5, 1987 ,

4.2 Field Verification Method, Instruction to Acquire Data for  !

Traceability of IE Pigtail Extensions, CPE-SWEC-FVM-EE-022, Revision 2, dated March 26, 1987 4.3 Construction Procedure eel-8, Class IE and Non-Class 1E Cable Terminations, Revision 8, dated August 31, 1987 4.4 Quality Control Procedure, NQA-3.09 - 3.05, Quality Control Inspection of Termination Activities, Revision 1, dated August 31, 1987 l 4.5 Impe11 Environmental Equipment Qualification Summary Package, i ES-100-06, Revision 0 4.6 Specific Technical Issue Report, STIR-CPRT-E-001, AMP Preinsulated Environmental Sealed Butt Splices on Control and Instrumentation ,

, Conductors, Revision 2, dated July 31, 1987

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SU8 APPENDIX A5 AGREEMENT BETWEEN ORAWINGS AND FIELO TERMINATIONS (ISAP I.a.4)

1. 0 Definition of the Issue The issue was that of 380 cables inspected, involving over 1600 individual terminations, six cables (one of which was non-Class 1E) were identified which were not terminated in accordance with the original design drawings.

2.0 Issue Resolution The six identified cables were found to be functionally correct as i terminated. The design drawings for these cables have been revised to reflect the as-installed condition. An inspection was conducted for an additional 347 terminations. This inspection demonstrated that all these terminations were in accordance with the design drawings.

3.0 Corrective and Preventive Action i No additional issues were identified during the review and resolution of this issue. ,

The issue was determined not to be reportable under the provisions of 10CFR50.55(e).

3.1 Corrective Action No corrective action is required.

3.2 Preventive Action '

No preventive action is required.

4.0 References  !

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O SUBAPPENDIX A6 VENDOR INSTALLE0 AMP TERMINAL LUGS (ISAP I.a.5) 1.0 Definition of the Issue The issue was that adequate justification was not provided in the Nonconformance Report (NCR) dispositions for the use of bent and twisted AMP terminal lugs installed by the equipment vendor.

2.0 Issue Resolution The issue was resolved by obtaining test reports (Reference 4.2) from the terminal lug vendor (AMP) which identified acceptable limitations for the bending and twisting of the lugs. The requirements in this test report were incorporated into tbs electrical installation specification (Reference 4.1). The Nonconformance Reports (NCRs) have been re-dispositioned by SWEC based on the acceptance limitations provided in the terminal lug vendor test reports (Reference 4.2).

Technical justifications for the dispositions are documented in the Nonconformance Reports (NCRs).

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

L The issue was determined not to be reportable under the provisions of -

10CFR50.55(e).

3.1 Corrective Action The issue was resolved by obtaining test reports (Reference 4,2) from the terminal lug vendor (AMP) which identified acceptable ,

limitations for the bending and twisting of the lugs. The i requirements in this test report were incorporated into the electrical installation specification (Reference 4.1). The Nonconformance Reports (NCRs) have been re-dispositioned by SWEC based on the acceptance limitations provided in the terminal lug vendor test reports (Reference 4.2). Technical justifications for the dispositions are documented in the Nonconformance Reports (NCRs).

3.2 Preventive Action SWEC design control Project Procedure PP-026 (Reference 4.3) requires that Nonconformance Reports (NCRs) include acceptable technical justification, where required, for dispositions.

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i In addition, all electrical equipment procurement specifications l O have been revised to require terminal lugs installed by equipment vendors be installed in accordance with the terminal lug vendor requirements.

i 4.0 References 4.1 CPSES Specification, Electrical Installation, Class I, II and Non-Safety, 2323-ES-100, Revision 4, dated November 5, 1987 4.2 AMP Engineering Evaluation Report EER-136, dated April 10, 1985, and AMP Qualification Test Report 110-11004, dated February 2, 1982 4.3 SWEC Project Procedure PF-026, Processing of Nonconformance Reports (NCRs), Conditional Release Requests and Test Deficiency Reports (TORS), Revision 5 O  :

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SUBAPPENDIX A7

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ELECTRICAL EQUIPMENT INSTALLATION (ISAP VII.c. APPENDICES 1-6) 1.0 Definition of the Issue Evaluation Research Corporation (ERC) was contracted by the Comanche Peak Response Team (CPRT) to perform the Quality of Construction (QOC) sample inspection of the safety-related components installed in CPSES, including electrical equipment. The electrical equipment issues identified were as follows:

1.1 Conduit ,

A. End bushings were missing from Class 1E lighting conduit.

B. Electrical separation relative to conduit was inadequate.

1.2 Cable Tray A. Electrical separation relative to cable tray was inadequate.

1.3 Cable i D. A. Maintained spacing between power cables in tray was less than V specified.

B. Some cables did not meet minimum bend radius requirements within the termination equipment.

C. Inadequate spacing of stainless steel bands used to secure Separation Barrier Material (SBM) and Radiant Energy Shield (RES) existed. [

0. Power cable tiedown spacing (cable ties in cable tray) was greater than that specified for the maintained space power cables.

E. Loose terminations existed at Weidmuller terminal blocks.

F. Quality Control (QC) attribute to verify the adequacy of i cable jacket and insulation removal from 8kV terminations may have been incorrectly marked "N/A" on some Quality Control (QC) Inspection Reports (irs).

G. The cable installation criteria and associated construction procedure and Quality Control (QC) inspection procedure may I. have been inadequate.

H. A loose screw holding a terminal lug was identified.

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I. Some wires were not terminated in accordance with the design drawings.

1. 4 Lighting Cable A. Inadequate cable terminations, incorrect cable size and type, and conductor damage associated with Class 1E lighting existed.

1.5 Electrical Equipment A. Two loose bolts and one damaged insulator (bus support) existed on the 6.9kV-480V transformers due to over-torquing during field modifications.

B. Some Class 1E enclosures had damage to doors, covers, gaskets, vapor barriers and associated hardware.

C. Two instances of damaged flexible conduit were identified.

O. One loose solenoid operated valve housing was identified.

E. An incorrect relay was installed in an auxiliary relay rack.

F. Two instances. were identified where the installed fuse was smaller than required as depicted on the design drawings.

2.0 Issue Resolution SWEC resolved these issues as follows:

Items 1.1A and 1.4A:

The lighting circuits are being reworked to the requirements of the construction procedure (Reference 4.4) and the electrical installation specification (Reference 4.2). The 14 ;thting system, from the -

distribution panels to the fixtures, has been correctly classified as non-Class 1E since it performs no safety-related function.

l The construction procedure and the electrical installation specifica-tion provide the requirements for the installation of conduit end

. bushings, correct cable terminations, correct cable size and type, and evaluation of conductor damage.

c Items 1.1B and 1.2A:

SWEC has established the electrical separation design criteria as specified in the Design Basis Document (DBD) (Reference d 4). These design criteria include the spatial requirements for separation relative to conduit and cable tray. The electrical installation specification (Reference 4.2) has been revised to include these

! criteria. The ciectrical separation is being validated during the Post Construction Hardware Validation Program (PCHVP) using a Field ON Verification Methoi (FVM) (Reference 4.30).

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t o Hardware not in accordance with design criteria is being corrected by y) adding barriers or tray covers or rerouting cable as required.

Items 1.3A and 1.30:

SWEC has identified the power cables that require maintained spacing within cable trays. These power cables are being validated during the Post Construction Hardware Validation Program (PCHVP) using a Field Verification Method (FVM) (Reference 4.5). Included in this inspection are the requirements for spacing between cable ties on a cable requiring maintained spacing.

Item 1.38:

The electrical installation specification (Reference 4.2) has been revised to include cable minimum bend radius requirements. Cable bending radius is being validated during the Post Construction Hardware i Validation Program (PCHVP) using a Field Verification Method (FVM)

(Reference 4.32) and an Engineering Evaluation Procedure (Reference 4.6).

Item 1.3C: ,

The electrical installation specification (Reference 4.2) has been revised to include revised vendor installation criteria for stainless l steel band spacing. All Separation Barrier Material (SBM) is being j removed due to its effect on power cable ampacity rating. All Radiant

Energy Shield (RES) is being removed and reinstalled where required as directed by the responsible engineering contractor to the requirements of the revised electrical installation specification (Reference 4.2).

Item 1.3E:

The electrical installation specification (Reference 4.2) and applicable construction procedure and Quality Control (QC) inspection procedure (Reference 4.3 and 4.7) have been revised to include instructions for wire termination at Weidmuller terminal blocks.  ;

Weidmuller terminal block terminations are being validated to assure tightness of terminations during the Post Construction Hardware

! Validation Program (PCHVP) using a Field Verification Method (FVM) i (Reference 4.32).

l Item 1.3F:

SWEC performed a review of the Quality Control (QC) Inspection Reports (irs) for 8kV Class 1E cable terminations and identified those on which the attribute to verify the adequacy of cable jacket and insulation removal was marked "N/A". This review revealed that another attribute  ;

i on the same Inspection Reports (irs) required installation of the ,

I termination hardware be in accordance with the vendor instructions.

The vendor instructions detail proper cable preparation, including jacket and insulation removal, prior to installation of termination hardware. This attribute was verified by Quality Control (QC) since it O- was marked as satisfactory.

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Item 1.3G:

U The electrical installation specification (Reference 4.2) has been re-vised to incorporate cable installation criteria to assure that the in-stallation is consistent with the design criteria specified in the Design Basis Document (DBD) (Reference 4.8). SWEC reviewed the revised construction procedures and Quality Control (QC) inspection procedures (References 4.3, 4.7, 4.9 and 4.10) to assure that they are consistent with the revised electrical installation specification. The Post Construction Hardware Validation Program (PCHVP) is being performed using Field Verification Methods (FVMs) (References 4.5, 4.30, 4.31 and 4.32) and an Engineering Evaluation procedure (Reference 4.27) to ,

validate the adecuacy of the cable installation.

Item 1.3H:

The loose screw was tightened. Tightness of terminal screws for electrical terminations is being validated during the Post Construction Hardware Validation Program (PCHVP) using a Field Eerification Method (Reference 4.35).

Item 1.31:

During the Post Construction Hardware Validation Program (PCHVP), the external field wiring terminations are validated to demonstrate the field wiring terminations are in accordance with the design. The Pre-

, Start Test Program will validate that the safety-related systems function in accordance with the validated design.

Item 1.5A:

4 A review was performed of the construction and Quality Control (QC) inspection records for the reinstallation of the bus insulators during field modifications. The records revealed the mounting bolts for the insulators were torqued at twice the vendor's recommended values. The 6.9kV-480V transformer insulators that had been reinstalled during the field modifications have been replaced.

A review of construction procedures for preparation, approval and control of operation travelers (Reference 4.34) has been performed and has been determined to comply with the requirements of 10CFR50

Appendix B, Criterion V.

I A review of operation travelers is being performed to confirm the

, accurate transfer of design data to travelers and to confirm that i travelers were not used to perform hardware modifications without i

corresponding documentation.

,I_ tem 1. 5B:

Identified damage is being repaired. Class 1E electrical enclosures are being inspected for damage to doors, covers, gaskets, vapor barri-

O ers and associated hardware during the Post Construction Hardware Validation Program (PCHVP) using a Field Verification Method (FVM)

(Reference 4.32).

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Items 1.5C and 1.5D:

Od The cause of the damage to the two flexible conduits and the looseness I of one solenoid operated valve housing was attributed to unrelated l construction work activities in the same areas af ter the flexible ,

conduits and subnoid operated valve had been insta11cd. These occur- -

rences are being corrected. The Post Construction Hardware Validation Program (PCHVP) is being performed using a Field Verification Method (FVM) (Reference 4.32) and an Engineering Evaluation Procedure  :

(Reference 4.6) to validate safety-related flexible conduit and solenoid operated valve housing are free of external damage.

Item 1.5E:

SWEC's review of the records related to the identified auxiliary relay ,

rack indicates the incorrect relay was installed by the vendor. The nonconforming condition is being corrected. The validation of panels supplied by the vendor for installation of correct components is being performed during the Post Construction Hardware Validation Program (PCHVP) using a Field Verification Method (FVM) (Reference 4.32). .

Item 1.5F:

SWEC's review determined this issue was a result of fuse sizes being specified on more than one drawing. The two identified nonconformances '

are being corrected. A review of electrical oneline drawings, elementary drawings and fuse schedule drawings has been performed.

i O Discrepancies have been identified and corrected to assure the design documents are consistent. Proper fuse size and type are being

! validated during the Post Construction Hardware Validation Program

(PCHVP) using a Field Verification Method (FVM) (Reference 4.31) and an Engineering Evaluation Procedure (Reference 4.6).  ;

3.0 Corrective and Preventive Action ,

No additional issues were identified during the review and resolution of these issues.

The damaged bus insulator issue (1.5A) and the field wiring ,

terminations not in accordance with design issue (1.31) were determined to be reportable under the provisions of 10CFR50.55(e). They were I reported as Significant Deficiency Analysis Reports (50ARs) by TU Electric to the NRC in the letters listed below:

i

. SDAR CP-87-20 TXX-6669, dated August 29, 1987  !

SDAR CP-87-123, TXX-88049, dated January 11, 1987 3.1 Corrective Action l 3.1.1 The following corrective action applies to items

1.1B, 1.2A, 1.3A, 1.3B, 1.30, 1.3E, 1.3G, 1.3H, 1.31, 1.58, 1.50, d -

i 1.50 and 1.5E:

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The applicable design documants (electrical installation s specification (Reference 4.2) and design drawings), and i construction procedure and Quality Control (QC) inspection procedures (References 4.3, 4. 7. 4. 9 and 4.10) have been revised as discussed in Section 2.0. Hardware validation to the validated design criteria is being performed during the Post Construction Hardware Validation Program (PCHVP).

t 3.1.2 The following corrective action applies to Items 1.1A and 1.4A:

Lighting circuits are being reworked in accordance with the construction procedure (Reference 4.4) and the electrical ,

j installation specification (Reference 4.2). The lighting 1 tystem has been correctly classified as non-Class 1E. j i 3.1.3 No corrective action is required for Item 1.3F.

3.1.4 The corrective action for Item 1.5A replaced all insulators that had over-torqued mounting bolts, a

3.1.5 The corrective action for Item 1.3C is that the electrical i installation specification (Reference 4.2) has been revised [

to include revised vendor installation criteria for stainless i steel band spacing. Separation Barrier Material (SBM) and Radiant Energy Shield (RES) is being removed. RES is being O reinstalled where required to the revised electrical instal-lation specification (Reference 4.2) requirements.

{ 3.1.6 The following Corrective Action applies to Item 1.5F. The applicable design drawings have been reviewed. Design

changes were identified and drawings revised. Proper fuse ,

installation is being validated during the Post Construction  ;

Hardware Validation Program (PCHVP) using a Field

• i Verification Method (FVM) (Reference 4.31) and an Engineering t Evaluation Procedure (Reference 4.6).

3.2 Preventive Action  !

, t The design criteria have been documented in the Design Basis l

! Documents (DB0s) (Reference 4.1, 4.11, 4.12, 4.13, 4.14, 4.15 and .

{ 4.16). Electrical installation specification (Reference 4.2 has  !

l been revised to be consistent with the design criteria specified i in these Design Basis Documents (DBDs) (References 4.1, 4.11, l 4.12, 4.13, 4.14, 4.15 and 4.16). Maintenance and operating  !

! requirements have been identified and procedures are being i

! updated. The construction procedures and Quality Control (QC)  ;

j inspection procedures (References 4,3, 4.4, 4.7, 4.9, 4.10, 4.18,  !

j 4.19, 4. 20, 4. 21, 4. 22, 4. 23, 4. 24, 4. 25, 4. 26, 4. 27 and 4. 28)  !

have been revised to be consistent with the revised electrical >

l installation specification. ,

SWEC design control Project P*ocedure PP-023 (Reference 4.17) requires identification of all affected drawings when design i I  !

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e changes are developed. SWEC design control Project Procedure

, PP-032 (Reference 4.29) provides instructions for incorporation of design information into design drawings.

l On October 27, 1987, a training memorandum (Reference 4.33) was  !

issued for sign-off by all Comanche Peak Engineering personnel. '

This memorandum included instructions on the protection of permanent plant equipment, and was transmitted to all enginaering contractors for training of their personnel.

4.0 References 4.1 CPSES Design Basis Document DBD-EE-057, Separation Criteria, -

Revision 1 4.2 CPSES Specification 2323-ES-100, Electrical Installation, Revision 4, dated November 5, 1987 4.3 Construction Procedure EEI-08, Class 1E and Non-Class 1E Cable Terminations, Revision 8, dated August 31, 1987

- 4.4 Construction Procedure ECP-11, Inspection of Non-Class 1E Lighting l Terminations, Revision 2, dated August 7, 1987 4.5 Field Verification Method CPE-SWEC-FVM-EE/ME/IC/CS-086, Post Construction Hardware Validation (PCHV) Program Construction / s Control Reverifications, Revision 2, dated October 15, 1987 l 4.6 Texas Utilities Electric Company Engineering Procedure ,

ECE-9.04-05, Post Construction Hardwarc Validation Program L Engineering Evaluations, Revision 0, dated September 1, 1987 4.7 Nuclear Engineering and Operations Quality Assurance Department {

4 Procedure NQA-3.09 - 3.05, Quality Control Inspection of  :

Termination Activities, Revision 1, dated August 31, 1987 4.8 CPSES Design Basis Document DBD-EE-052, Cable Philosophy and Sizing Criteria, Revision 1 r 4.9 Construction Procedure EEI-07, Cable Pulling, Revision 10, dated t November 2, 1987 i

i 4.10 Nuclear Engineering and Operations Quality Assurance Department i Procedure NQA-3.09-3.04, Electrical Cable Installation Inspection, ,

i Revision 1, dated August 31, 1987  ;

i l l 4.11 CPSES Design Basis Document DBD-EE-038, Offsite Power System, Revision 1  ;

4.12 CPSES Design Basis Document DBD-EE-039, Onsite Power System, }

l Revision 1 j 4.13 CPSES Design Basis Document DBD-EE-040, 6.9kV Electrical Power I System Revision 1 A7-7

i O 4.14 CPSES Design Electrical Power System, Revision 1 Basis Document DB0-EE-041, 480V and 120V AC l

, 4.15 CPSES Design Basis Document DB0-EE-043,138V AC Uninterruptible i Power Supply System, Revision 1 4.16 CPSES Design Basis Document DBD-EE-044, DC Power System, Revision

1 4.17 SWEC Project Procedure PP-023, Processing of Design Change Authorizations (OCAs), and Change Verification Checklists (CVCs),

Revision 4  !

4.18 Construction Procedure ECP-8, Installation of Embedded Electrical Conduit Sleeves, Revision 6, dated August 31, 1987 4

4.19 Construction Procedure ECP-10, Cable Tray and Hangers Installation i Unit 1, Revision 10, dated August 31, 1987 i

4.20 Construction Procedure ECP-108, Installation of Cable Spreading .

Room Frame Units 1 and 2 (Rooms 133 and 134), Revision 3, dated I

December 1987 r 4.21 Construction Procedure ECP-19 Exposed Conduit / Junction Box and Hanger Fabrication-and Installation, Revision 15, dated August 31, '

1987 4.22 Construction Procedure ECP-19B, Installation of New, Modified, and i Relocated Train "C" Cenduit Supports for Two Inches and Under

• Conduits, Revision 3, dated August 31, 1987 4.23 Construction Procedure ECP-20, General Installation of Electrica.1 i Equipment, Revision 1, dated August 31, 1987 l' 4.24 Construction Procedure eel-10, Electrical Termination Shack .

Operation, Revi. ion 1, dated July 8, 1987 l 4.25 Nuclear Engineering and Operations Quality Assurance Department i Procedure HQA-3,09 - 3.01, Class 1E Electrical Equipment / Cable  !

Storage and Maintenance, Revision 0, dated August 31, 1987 .

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) 4.26 Nuclear Engineering and Operations Quality Assurance Department >

j Procedure NQA-3.09 - 3.02, Electrical / Raceway -

Cable Tray,

) Revision 1, dated August 31, 1987  ;

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4.27 Nuclear Engineering and Operations quality Assurance Department '

Procedure NQA-3.09 - 3.03, Electrical / Raceway Conduit Procedure, [

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Revision 0, dated August 31, 1987

4.28 Nuclear Engineering and Operations Quality Assurance Department l

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Procedure NQA-3.09 - 3.06, Equipment Insta11atien, Revision 0 ,

i dated August 31, 1987 A7-8 4

n 4.29 SWEC Project Procedure PP-032 Preparation, Review and Approval of SWEC Project Orawings, Revision 3 (v) 4.30 Field Verification Method CPE-SWEC-FVM-EE/ME/IC/CS-088, Post Construction Hardware Validation (PCHV) Program Engineering /

Quality Control Reverification, Revision 1, dated September 21, 1987 4.31 Field Verification Method CPE-5WEC-FVM-EE/ME/IC/CS-089, Post Construction Hardware Validation (PCHV) Program Engineering Walkdowns, Revision 2, datea October 15, 1987 4.32 Field Verification Method CPE-SWEC-FVM-EE/ME/IC/CS-090, Post Construction Hardware Validation (PCHV) Program Quality Control Reinspections, Revision 2, dated October 15, 1987 4.33 TV Electric Of fice Memorandum NE-13647, CPSES Housekeeping and Equipment Protection, dated October 27, 1987 4.34 Construction Procedure CP-CPM 6.3, Preparation, Approval and Control of Operation Travelers, Revision 14, dated December 31, 1987.

4.35 Field Verification Method CPE-SWEC-FVM-EE/ME/IC/CS-087, Post Construction Hardware Validation (PCHV) Program Startup Verifications, Revision 0, dated January 7, 1988.

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m SUBAPPENDIX A8

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SYSTEM SHORT CIRCUIT CURRENTS ( N NA RIL NO. E-5)

1. 0 Definition of the Issue The issues were as follows:

1.1 Cable Impedance Values Original short circuit calculations computed cable impedances based upon a 75 degrees C operating temperature, when actual operating temperature may be lower.

1. 2 480 V Motor Subtransient Reactance Values Original short circuit calculations assumed a subtransient reactance of 25 percent for the 480 V motors, when typical values are less than 17 percent.

1. 3 Maximum Available 6.9 kV Short Circuit Contribution In determining short circuit currents at the 480 V switchgear and motor control centers, ? maximum available momentary short-circuit contribution of 36,000 A was used from the 6.9 kV system, which may not be conservative.

C/ 1.4 System Characteristics Inpu: data used for 6.9 kV short circuit calculations was based on 1974 transmission system studies which may not be the most recent.

1.5 Diesel Generator Transient Reactance The diesel generator's transient reactance, instead of subtransi-ent, was used in computing short-circuit currents at the 6.9 kV bus (switchgear).

2.0 Issue Resolution 2.1 Cable Impedance Values SWEC resolved this issue by validating the revised original short circuit calculations that used cable impedances based upon a temperature of 25 degrees C. These calculations were validated in accordance with SWEC Project Procedures PP-203 (Reference 4.7) and PP-216 (Reference 4.2).

2.2 480 V Motor Subtransient Reactance Values SWEC r? solved this issue by validating the revised original short s circuit calculations which used 480 V motor subtransient

('v') reactances based on actual (vendor data) values. These calcula-tions were validated in accordance with SWEC design control A8-1

Project Procedures PP-203 (Reference 4.7) and PP-216 (Reference

,m 4.2).

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2.3 Maximum Available 6.9 kV Short Circuit Contribution SWEC resolved this issue by validating the revised original short circuit calculation which specified the 6.9 kV system contribution to the 480V nwitchgear and motor control centers based on the max-imum short-circuit rating (70,000A) of the switchgear. This cal-culation was validated in accordance with SWEC design control Project Procedures PP-203 (Reference 4.7) and PP-216 (Reference 4.2).

2.4 System Characteristics SWEC resolved this issue by performing a comparison of the most recent system impedance values (Reference 4.3) to the values used as inputs to the original calculation. This review demonstrated the adequacy of the original calculations (1974 transmission study) 2.5 Ciesel Generator Transient Reactance SWEC resolved this issue by validating the revised original short circuit calculations which represented the diesel generator's impedance using its subtransient reactance. Calculations were validated in accordance with SWEC design control Project 73 Procedures PP-203 (Reference 4.7) and PP-216 (Reference 4.2).

O Subsequently, new system short circuit calculations have been issued by SWEC to reflect unrelated system design modifications. These new calculations include the resolution of the above issues.

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

This issue was determined not to be reportable under the provisions of 10CFR50.55(e).

3.1 Corrective Action SWEC validated the original or revised original calculations as appropriate to demonstrate that the available short-circuit currents, at safety-related buses and equipment, are within component ratings.

3.2 Preventive Action l SWEC design control Project Procedures PP-009 and PP-216

(References 4.1 and 4.2) provide requirements for utilizing appropriate input data for determining system short circuit A8-2 I

currents in accordance with the design criteria as specified. in the Design Basis Documents (DB0s) (References 4.4, 4.5 and 4.6).

4.0 References 4.1 SWEC Project Procedure PP-009, Preparation and Control of Manual

-and Computerized Calculations, Rension 2 4.2 SWEC Project Procedure PP-2% , Technical Procedure for System Short-Circuit Calculation, Revision 0 4.3 Results of the Comanche Peak SES Offsite Power System Analysis, TU Electric Memorandum, dated October 15, 1987 4.4 CPSES Design Basis Document 080-EE-038, Offsite Power System, Revision 1 4.5 CPSES Design Basis Document DBD-EE-040, 6.9 kV Electrical Power System, Revision 1 4.6 CPSES Design Basis Document DBD-EE-041, 480 V and 120 V AC Elec-trical Power System, Revision 1 4.7 SWEC Project Procedure PP-203, Calculation Validation Procedure, Revision 1 P

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SUBAPPENDIX A9 py Q ACDISTRIBUTIONSYSTEMVOLTAGES(CYGNARILN0.E-6,1

1. 0 Definition of the Issue The . issue was that the original station AC distribution system voltage calculations:

• Identified cases of unacceptable undervoltage conditions which may have remained uncorrected,

• Did not consider large 480 volt motor starting, and

• Apper. red not to properly utilize offsite system voltage variation data.

2.0 Issue Resolution This issue was resolved as follows:

• SWEC developed new and replacement AC distribution system voltage calculations in compliance with Design Basis Documents (DBDs)

(References 4.1, 4.2 and 4.3). The DBDs speci'y the criteria for acceptable voltage conditions. These calculations identified v;:t.sga conditions which did not comply with the design criteria.

Snct developed design changes which assure that the AC (7 distribution system voltage conditions comply with the design U l criteria as specified in the Design Basis Documents (DBDs)

(References 4.1, 4.2 and 4.3). These design changes are being implemented.

• SWEC developed both replacement and new AC distribution system voltage calculations that included starting the largest 480 V motor. These new and replacement calculations are based on the validated system design.

• The replacement and new systen, voltage calculations utilized input data which were based on the offsite system voltage variations containeo in TU Electric's Transmission System Load Flow Study results (Reference 4.4). Determination of TU Electric transmission system characteristics included the load requirements of CPSES Unit 1 and Common.

3.0 Corrective and Preventive Actig No additicnal issues were identified during the review and resolution of this issue.

! This iss'je was determined to be reportable under the provisions of l

10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-87-91, in letter number TXX-88097, dated p January 8, 1988 from TV Electric to the NRC.

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3.1 Corrective Action SWEC performed new and replacement calculations in accordance with the design criteria as specified in the Design Basis Documents (DBDs) (References 4.1, 4.2 and 4. 3). These calculations, in conjunction with the developed design changes, validate the design of the AC distribution system voltage profile.

3.2 Preventive Action SWEC design control Project Procedure PP-009 (Reference 4.5) requires that calculations be performed based on controlled input data, and be checked and independently reviewed to assure accuracy.

4.0 References 4.1 CPSES Design Basis Document DBD-EE-038, Offsite Power System, Revision 1 4.2 CPSES Design Basis Document DBD-EE-040, 6.9 kV Electrical Power System, Revision 1 4.3 CPSES Design Basis Document DBD-EE-041, 480 V and 120 V AC Elec-trical Power System, Revision 1 4.4 Results of the Comanche Peak SES Offsite Power System Analysis, TU Electric Memorandum, dated October 15, 1987 4.5 SWEC Project Procedure PP-009, Preparation and Control of Manual and Computerized Calculations, Revision 2 1

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SUBAPPENDIX A10 V,73 OVERCURRENT PROTECTION (CYGNA RIL NO. E-7)

1. 0 Definition of the Issue The issues were as follows:

1.1 Device Settings -

6.6 kV Safety-Related Motor Thermal Limits Motor protection device settings were based only on the motor acceleration time. The motor thermal limit curve, which is the maximum allowed tripping delay during stalled conditions, was not used.

1.2 Device Settings - Transformer Thermal Limit (ANSI Point)

Transformer protection device settings did not consider the transformer thermal limit (ANSI point).

1, 3 Coordination of Protective Devices The protective relay settings for the 6.9 kV safety bus feeders were not documented to be coordinated with the diesel generator's short circuit capability and protective devices.

,_ 1.4 Reactor Coolant Pump Containment Penetrations Containment electrical penetrations for the reactor coolant pump motor conductors require separate primary and backup electrical protection. The primary and backup protective relays shared the same current transformers. In addition, the primary and backup circuit breakers had a common de control power source. This configuration was not consistent with the guidance of NRC Regulatory Guide 1.63.

2.0 Issue Resolution 2.1 Device Settings - 6.6 kV Safety-Related Motor Thermal Limits SWEC resolved this issue by preparing a supplemental calculation based on the design criteria as specified in the Design Basis Document (080) (Reference 4.1) which validated the motor protec-tion device settings.

2.2 Device Settings - Transformer Thermal Limit (ANSI Point)

SWEC resolved this issue by preparing a supplemental calculation based on the design criteria as specified in the Design Basis Document (0B0) (Reference 4.1) which validated the transformer device setting. This calculation validated that the transformer device setting is within the transformer thermal limit (ANSI p point).

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2.3 Coordination of Protective Devices

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V SWEC resolved this issue by preparing a supplemental calculation

-based on the design criteria as specified in the Design Basis Document (DBD) (Reference 4.1), which validated the protective device settings. This calculation validated that the 6.9kV safety bus feeders coordinated with "he diesel generator's short circuit capability and protective devices.

2.4 Reactor Coolant Pump Containment Penetrations SWEC resclved this issue by developing a design change to the pow-er and control circuits for primary and backup protection of the reactor coolant pump motor conductor containment penetrations such that they are consistent with the guidance in NRC Regulatory Guide 1.63 (Reference 4.2). This design change is being implemented.

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

Issue 1.4 was determined to be reportable under the provisions of 10CFR50.55(e). This issue was reported as Significant Deficiency Analysis Report (SDAR), CP-87-45, in letter number TXX-88061, dated January 11, 1988, from TV Electric to the NRC.

p 3.1 Corrective Action b The results of the validated calculations demonstrated that the protective relay settings for the transformers, 6.6kV motors, 6.9 kV safeguard buses and emergency diesel generators comply with protection design criteria as specified in the Design Basis Document (0B0) (Reference 4.1).

The aesign for the reactor coolant pump electrical containment penetration protection was modified to include separate current transformers; and primary and backup circuit breakers powered from different power sources (separate batteries). Hardware modifications are being implemented.

3.2 Preventive Action SWEC issued Design Basis Document (DBD) (Reference 4.1) which specifies the design criteria for protection device settings.

4.0 References 4.1 CPSES Design Basis Document DBD-EE-062, Containment Electric Penetration Assemblies, Revision 1 4.2 NRC Regulatory Guide 1.63, Revision 2, Electric Penetration Assemblies in Containments for Light-Water-Cooled Nuclear Power O Plants V

A10-2

SUBAPPENDIX All Q POWER CABLE DERATING INSIDE CONTAINMENT (CYGNA RIL NO. E-8) 1.0 Definition of the Issue The issue was that power cables were derated in the original calcula-tion for a 50 degrees C ambient temperature inside containment. The FSAR states that the long-term, post-accident temperature inside containment is 65 degrees C.

2,0 Issue Resolution SWEC resolved this issue by identifying that the only safety-related power equipment required to be energized during the long-term, post-accident period was the hydrogen recombiner heaters. SWEC then prepared a supplemental calculation, in accordance with the design criteria as specified in the Design Basis Document (DBD) (Reference 4.1), which validated that the circuit feeder cables to these heaters have adequate ampacity at 65 degrees C.

3.0 Corrective and Preventive Action No additional issues were identified du ing the review and resolution of this issue. .

The issue was determined not to be reportable under the provisions of

(]

Li 10CFR50.55(e). '

3.1 Corrective Actior.

The results of the validated calculations demonstrated that the power cable derating factors were properly applied for those loads that must operate long-term in a post accident environment.

3.2 Preventive Action SWEC issued Design Basis Document (OBD) (Reference 4.1) which specifies the design criteria for cable sizing, including the application of cable derating factors.

4.0 References i

! 4.1 CPSES Design Basis Document OBD-EE-052, Cable Philosophy and Sizing Criteria, Revision 1 l

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SUBAPPENDIX A12 p

() VOLTAGE DROP CALCULATIONS (CYGNA LETTER 84056.090, ITEM N0. 17) 1.0 Definition of the Issue The issues were as follows:

1.1 AC and DC Control Circuits Voltage drop calculations were not done for Class IE ac and dc control circuits. In addition, voltage drop calculations were not done "downstream" of the distribution panels, i.e., to the end devices.

1.2 120 V Control Circuits for Motor Control Center (MCC) Starters Voltage drop calculations were not documented for Class 1E Motor Control Center Starter Circuit.s (120 V control circuits). It is necessary to demonstrate that adequate voltage exists at the starter coils 1.3 6.9 kV and 480 V Switchgear DC Control Circuits Voltage drop calculations were not done for 6.9 kV and 480 V switchgear dc control circuits which are necessary to demonstrate ,

that adequate voltage exists at end devices.

1.4 Medium (6.9 kV) Voltage Power Circuits Voltage drop calculations were not done for medium voltage power circuits which are necessary to demonstrate that computed voltages at the medium voltage safety-class buses are correct.

2.0 Issa Resolution 2.1 AC and DC Control Circuits SWEC resolved this issue by the preparation of supplemental calculations for ac control circuits and preparation of a new calculation for de control circuits. These calculations were developed in accordance with the design criteria specified in the Design Basis Document (DBD) (Reference 4.4). These calculations validate the voltage drops in the ac and dc control circuits and validate that the voltage available at the end device terminals comply with the design criteria.

2.2 120 V Control Circuits for Motor Control Center (MCC) Starters SWEC resolved this issue by preparing a replacement calculation based on the design criteria in the Design Basis Documents (DBDs)

(References 4.4 and 4.5). These calculations identified that de-sign changes were required in order to assure that adequate volt-y age was available at the starter coils. These calculations, in A12-1

conjunction with the design changes, validate that adequate voltage is available at the starter coils. These design changes

_yp) are being implemented. ,

2.3 6.9 kV and 480 V Switchgear DC Control Circuits SWEC resolved this issue by the preparation of supplemental calcu-lations in accordance with the design criteria specified in the Design Basis Documents (DB0s) (References' 4.4 and 4.6). These calculations identified that design changes were required in order to assure that adequate voltage was available at the end devices.

These calculations, in conjunction with the design changes, validate that adequate voltage is available at end devices. These design changes are being implemented.

2.4 Medium (6.9 kV) Voltage Power Circuits SWEC resolved this issue by including the voltage drops in medium voltage power circuits in the overall validation of the station system voltage profile studies. The resolution of this issue is described in Subappendix A9 of this Project Status Report (PSR).

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

(7 Issue 1.2 was determined to be reportable under the provisions of

() 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (50AR) CP-87-93, in letter number TXX- 8S074, dated January 11, 1988, from TU Electric to the NRC.

3.1 Corrective Action SWEC performed supplemental and replacement calculations in accordance with the design criteria specified in the Design Basis Documents (DB0s) (References 4.4, 4.5 and 4.6). These calcula-tions, in conjunction with the developed design char.ges, validate the Class 1E ac and de control circuits, the 120V control circuits for motor control centers, and the 6.9kV and 480V switchgear de control circuits.

3.2 Preventive Action SWEC developed Design Basis Documents (DB0s) (References 4.1, 4.2, 4.3 and 4.4) which specify the design criteria for determining voltage drop, to assure that adequate voltage exists at end '

devices.

4.0 References 4.1 CPSES Design Basis Document DBO-EE-040, 6.9 kV Electrical Power System, Revision 1 O

A12-2

4.2 CPSES Design Basis Document DBO-EE-041, 480 V and 120 V ac Elec-trical Power System, Revision 1 4.3 CPSES Design Basis Document DBO-EE-043,118 V ac Uninterruptible Power Supply System, Revision 1 4.4 CPSES Design Basis Document DBD-EE-052, Cable Philosophy and Sizing Criteria, Revision 1 4.5 CPSES Design Basis Document DBO-EE-053, Starter Control Circuit Parameters / Requirements, Revision 1 4.6 CPSES Design Basis Document DBO-EE-054, Control Circuit Parameters / Loading Requirements, Revision 1 l'

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SUBAPPENDIX A13 CABLE TRAY FILL FOR MAINTAINED SPACE CABLES (CYGNA LETTER 84056.090, ITEM NO. 18) 1.0 Definition of the Issue The issue was that the Cable and Raceway Data System (CARDS) does not accurately represent percent fill values for cable trays which contain cables scheduled and designated as maintained space cables.

2.0 1 sue Resolution SWEC has resolved this issue by developing SWEC design control Project Procedure PP-076 (Reference 4.2) to supplement CARDS and SWEC design control Project Procedure PP-075 (Reference 4.1) which provides a manual method for determining and controlling fill for maintained space cable in cable trays.

SWEC is validating that the installed maintained space cables meet the spacing requirements of the electrical installation specification (Reference 4.4) as part of the Post Construction Hardware Validation Program (PCHVP) (Reference 4.3).

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution O

O of this issue.

The issue was determined not to be reportable under the provisions of 10CFR50.55(e).

3.1 Corrective Action SWEC has issued the revised electrical installation specification (Reference 4.4) and SWEC design control Project Procedures (Refer-ences 4.1 and 4.2) which contain the requirements and methodology for maintained space cables in trays. Trays are being inspected during the Post Construction Hardware Validation Program (PCHVP)

(Reference 4.3) to validate that the maintained space cable spacing comply with the design criteria.

3.2 Preventive Action SWEC design control Project Procedures PP-075 (Reference 4.1) and PP-076 (Reference 4.2) and the electrical installation specifica-tion (Reference 4.4) provide the design and design control requirements for maintained space cables.

4.0 References 4.1 SWEC Project Procedure PP-075, Computerized Cable and Raceway Data p System, Revision 1 V

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O Space Cable Design, Revision 1 4.3 CPSES Field Verification Method, Post Construction Hardware Validation (PCHV) Program Construction / Quality Control Reverifi-cations, CPE-SWEC-FVM-EE/ME/IC/CS-086, Revision 2, October 15, 1987 4.4 CPSES Specification, Electrical Installation, Class I, II and Non-Safety, 2323-ES-100, Revision 4, dated November 5, 1987 k

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O SUBAPPENDIX A14

'd CABLE AMPACITY CALCULATIONS (CYGNA QUESTION NO. 19) 1.0 Definition of the Issue The issue was that the original cable ampacity calculations did not consider tray covers, where installed, and used an incorrect derating factor. The original procedure governing cable rating also indicated that the derating factors were not cumulative.

2.0 Issue Resolution SWEC resolved this issue by establishing the design criteria for cable ampacity derating in a Design Basis Document (DBD) (Reference 4.1) which replaced the original governing cable rating procedure. These design criteria (derating factors) were based on heat transfer calcula-tions and tests (References 4.2 and 4.3) for various types of cable enclosures. SWEC then prepared supplemental calculations in accordance with the design criteria specified in the Design Basis Document (OBD)

(Reference 4.1) which apply correct derating factors to cable to determine the cable ampacity for the cumulative effects, if any, of tray covers, fire wrap material and fire stops. Design changes have been issued consisting of cable size augmentation, cable rerouting, or reassignment of loads. Those design changes are being implemented.

3.0 Corrective and Prevention Action No additional issues were identified during the review and resolution of this issue.

This issue was deterrined to be reportable under the provisions of 10CFR50.55(e). It was reported as the following Significant Deficiency Analysis Reports (SOARS) and reported by TU Electric to the NRC in the letters listed below:

SDAR CP-86-83, TXX-6480, dated June 5, 1987.

SDAR CP-87-21, TXX-7041, dated December 23, 1987.

4 3.1 Corrective Action l SWEC has established the design criteria (Refcrence 4.1),

l evaluated the ampacity of safety-related cables to those design i criteria and issued design changes to upgrade tha design as necessary to conform with these criteria.

l l 3.2 Preventive Action 1 ,

SWEC issued a Design Basis Document (OBD) (Rderence 4.1) which contains the criteria fcr determining cable size (ampacity) including appropriate values for derating factors and cumulative '

effects.

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4.0 , References 4.1 CPSES Design Basis Document DBD-EE-052, Cable Philosophy and Sizing Criteria, Revision 1 4.2 Final Report, Southwest Research Institute (SWRI) Project Number  ;

01-8818-206/207a, Ampacity Derating of Fire-Protected Cables in

, Conduit / Cable Trays Using Promatec, Incorporated One-Hour "HEMYC"

Conduit / Cable Tray Barrier Wrap System, dated July 9, 1986 .

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4.3 Underwriters Laboratory U.L. Letter Thermal Science Inc. , Project 86NK23826, File R6802, Special Services Investigation of Ampacity

• Ratings for Power Cables in Steel Conduits and Open-Ladder Cable Trays With Field Applied Enclosures, dated January 21, 1987.

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[d APPENDIX B ISSUES IDENTIFIED DURING THE PERFORMANCE OF THE CORRECTIVE ACTION PROGRAM (CAP)

This appendix describes the details of the resolution of issues determined to be reportable under the provisions of 10CFR50.55(e) that were identified during the performance of the electrical portion of the Corrective Action Program (CAP). Included in these subappendices are electrical systems and component-related Significant Deficiency Analysis Reports (50ARs) initiated ,

by TU Electric. Specific references to the design criteria, specificatons, procedures and design changes which have resolved the issue are provided.

To report the resolution of issues identified during the performance of the Corrective Action Program (CAP), an individual subappendix was developed for each issue. Each subappendix includes: a definition of the issue; issue resolution; and corrective and preventive action.

The preventive action is embodied in the procedures and the Design Basis Documents (DB0s) developed and used in the electrical portion of the Correc-tive Action Program (CAP). These procedures, specifications and the Design Basis Documents - (DB0s) resolve the electrical Corrective Action Program (CAP) issues. Implementation of these preventive actions can assure that the electrical design and hardware for CPSES Unit 1 and Common will continue to comply with the licensing. commitments throughout the life of the plant as

, p described in Section 5.4.

V Corrective Action Program (CAP) issues contained in Appendix B are listed below:

Issue No. Issue Title B1 SDAR CP-87-03, 6.9 kV Switchgear Installation 62 SOAR CP-87-40, Electrical Isolation Between Class 1E and Non-Class 1E Equipment B3 SDAR CP-87-51, 480 V Containment Electrical Penetration Backup Protection B4 SDAR CP-87-79, Cable and Raceway Data System (CAROS)

Calculation 85 SDAR CP-87-101, Class 1E Cable Arrangement B6 SDAR CP-88-10, 6.9 kV Cable Bus Ampacity B7 SDAR CP-88-09, Electrical Penetrations Overloading Protec-tion Devices and Short Circuit Related Deficiencies B8 SOAR CP-87-85, Degradation of Class 1E Circuits B9 SDAR CP-88-11, Potential Battery Charger Failure Due to Heating B-1

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i B10- SDAR CP-88-08, Class 1E Battery Room Temperature B11 SDAR CP-87-49, Solid State Safeguards System (SSSS) Load 4 Sequencer Internal Wiring Terminations ,

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t SUBAPPENDIX B1 SDAR CP-87-03, 6.9kV SWITCHGEAR INSTALLATION 1.0 Definition of the Issue The issue was that the structural embedments and concrete floor supporting the safety-related 6.9kV switchgear were not level, and the resulting gaps were outside the vendor's tolerances to assure proper electrical contact at breaker stabs. In addition, the switchgear was not installed to the vendor's installation requirements and therefore did not meet the criteria used for the equipment's seismic qualification.

2.0 Issue Resolution The cables associated with the 6.9kV switchgear were disconnected, and switchgear cubicles removed from their foundation. The structural embedments and concrete floor were reworked to provide a level foundation within vendor tolerances. The switchgear cubicles were then reinstalled in accordance with the vendor requirements. The cables have been reinstalled and terminated and retesting has demonstrated that the switchgear meets its functional design requirements.

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-87-03, in letter number TXX-6334, dated March 16, 1987 from TU Electric to the NRC.

3.1 Corrective Action The 6.9kV switchgear and associated cables were removed, the structural foundation reworked, and the switchgear cubicles and cabling reinstalled in accordance with vendor installation requirements, and retesting has demonstrated that the switchgear meets its functional design requirements.

3.2 Preventive Action The revised electrical installation specification (Reference 4.1) provides the requirements for installation of safety-related equipment.

4.0 References 4.1 CPSES Specification, Electrical Installation, Class I, II and Non-Safety, 2323-ES-100, Revision 4, dated November 5, 1987.

81-1

U SUBAPPENDIX B2 SOAR CP-87-40, ELECTRICAL ISOLATION BETWEEN CLASS 1E AND NON-CLASS 1E EQUIPMENT 1.0 Definition of the Issue The issue was that the interconnection of the Class 1E and non-Class 1E radiation monitor communication circuits did not provide electrical separation (i.e. , isolation). In addition, there was an interconnec-tion of the Class 1E Atmospheric Cleanup Unit's Fire Protection Panel and non-Class 1E Fire Detection System.

2.0 Issue Resolution The design of the radiation monitor communication circuits and the interconnection of the Atmospheric Cleanup Unit's Fire Protection Panel and the Fire Detection System was revised to provide electrical separa-tion. These revised designs are in accordance with the design criteria as specified in the Design Basis Document (DBD) (Reference 4.1).

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Hardware modifications are being implemented.

3.0 Corrective and Preventive Action ,

No additional issues were identified during the review and resolution (O

j of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SOAR) CP-87-40 in letter number TXX-88060, dated January 11, 1988, from TV Electric to the NRC.

3.1 Corrective Action The design of the radiation monitor communication circuits and the interconnection of the Atmospheric Cleanup Unit's Fire Protection Panel and the Fire Detection System was revised to provide electrical separation. These revised designs are in accordance with the design criteria as specified in the Design Basis Document (0B0) (Reference 4.1). Hardware modifications are being implemented.

3.2 Preventive Action The design criteria for electrical separation have been documented in the Design Basis Document (DBD) (Reference 4.1).

4.0 References n 4.1 CPSES Design Basis Document DBD-EE-057, Separation Criteria,

( Revision 1 U)

B2-1

1 D SUBAPPENDIX B3

[G SOAR CP-87-51, 480 " CONTAINMENT ELECTRICAL PENETRATION BACKUP PROTECTION

1. 0 Definition of the Issue The issue was that the 480 V load center tie breakers, when in a closed position, did not include backup protection for containment electrical penetrations (load center tie breakers are normally open).

2.0 Issue Resolution SWEC resolved this issue by providing a revised load center tie breaker control circuit design which included containment electrical penetra-tion backup protection. This revised design is in accordance with the design criteria as specified in the Design Basis Occument (0B0) (Refer-ence 4.1). Hardware modifications are being implemented.

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiericy Analysis

- Report (SDAR) CP-87-51/ in letter number TXX-6710, dated September 2, 1987 from TV Electric to the NRC.

3.1 Corrective Action A revised load center tie breaker control circuit design which included containment electrical penetration backup protection was provided. This revised design is in accordance with the design criteria as specified in the Design Basis Document (OBD) (Refer-ence 4.1). Hardware modifications are being implemented.

3.2 Preventive Action The design criteria for backup protection for containment electri-cal penetrations have been documented in the Design Basis Document (DBD) (Reference 4.1).

4.0 References 4.1 CPSES Design Basis Document OBD-EE-062, Containment Electrical Penetration Assemblies, Revision 1 l

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SUBAPPENDIX B4 SDAR CP-87-79, CABLE AND RACEWAY DATA SYSTEM (CARDS) CALCULATION 1.0 Definition of the Issue The issue was that the CARDS computer program did not accurately account for tolerances used by construction for the entrance or exit of cable at cable tray segments. Consequently, the CARDS calculated values for percent fill and cable weight loading in cable trays may have been inaccurate.

2.0 Issue Resolution SWEC resolved this issue by developing values for percent fill and cable weight loading in cable trays which are consistent with the tolerances used by construction. These revised values were provided to Ebasco and Impeli for use in the cable tray and cable tray hangers portion of the Corrective Action Program (CAP).

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue. .

(~'s This issue was determined to be reportable under the provisions of Q 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-87-79 in letter number TXX-88062, dated January 11, 1988 from TV Electric to the NRC.

3.1 Corrective Action The cable weight loading and percent fill have been revised to assure that these values are consistent with the tolerances used by construction. These revised values were provided to Ebasco and Impell for use in the cable tray and cable tray hangers portion of the Corrective Action Program (CAP).

3.2 Preventive Action The CARDS computer program is being revised to provide accurate values for percent fill and cable weight loading.

4.0 References None

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/~'N SUBAPPENDIX 85 b SDAR CP-87-101, CLASS 1E CABLE ARRANGEMENT 1.0 Definition of the Issue The issue was that incorrect cable installation details were provided for use in situations where more than one cable per phase was required.

This could result in cable overload.

2.0 Issue Resolution SWEC resolved this issue by revising the electrical installation specifications (Reference 4.1) to incorporate the correct installation details for situations where more than one cable per phase is required.

These details are consistent with the design criteria specified in a Design Basis Document (080) (Reference 4.2). The installation of these cables is being inspected during the Post Construction Hardware Valida-tion Program (PCHVP) using a Field Verification Method (FVM) (Reference 4.3). The installations will be modified as necessary.

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue. .

t This issue was determined to be reportable under the provisions of l 10CFR50.55(e). It was reported as Significant Deficiency Analysis

! Report (50AR) CP-87-101, in letter number TXX 88063, dated January 11, l 1988, from TV Electric to the NRC.

3.1 Corrective Action The electrical installation specification (Reference 4.1) was revised to incorporate the correct installation details for situations where more than one cable per phase is required. These details are consistent with the design criteria specified in a Design Basis Document (DBD) (Reference 4.2). The installation of these cables is being inspected during the Post Construction Hardware Validation Program (PCHYP) using a Field Verification Method (FVM) (Reference 4.3). The installations will be modified as necessary.

3.2 Preventive Action The cable installation details for situations where more than one cable per phase is required have been documented in the electrical installation specification (Reference 4.1). These installation details are consistent with the design criteria as specified in l the Design Basis Document (DBD) (Reference 4.2).

O B5-1

4.0 References 4.1 CPSES Specification, Electrical Installation, Class I, II and Non-Safety, 2323-ES-100, Revision 4, dated November 5, 1987 4.2 CPSES Design Basis Document DBD-EE-052, Cable Philosophy and Sizing Criteria, Revision 1 4.3 Field Verification Method, Post Construction Hardware Validation (PCHV) Program Construction / Quality Control Reverifications, CPE-EE/ME/IC/CS-086, Revision 2, dated October 15, 1987 I

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SUBAPPENDIX B6 SDAR CP-88-10, 6.9 kV CABLE BUS AMPACITY 1.0 Definition of the Issue The issue was that cable bus duct ampacity ratings provided by the vendor were not accurate.

2.0 Issue Resolution SWEC resolved this issue by performing a new calculation to validate that the cable bus duct ampacity rating is in accordance with the design criteria specified in the Design Basis Document (DBD) (Reference 4.1) and identifying a design change to provide improved ventilation of the cable bus duct. A design change was developed and a modification is being implemented.

3.0 Corrective and Preventive Actions No additional issues were identified during the review and resolution of this issue:

Thfs issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-88-10, in letter number TXX-88069, dated January 11, O 1988, from TV Electric to the NRC.

3.1 Corrective Action A new calculation was performed to validate the cable bus duct ampacity rating in accordance with the oesign criteria specified in the Design Basis Document (0B0) (Reference 4.1). A design change was developed and a modification is being implemented to provide improved ventilation of the cable bus duct. This modification is being implemented.

3.2 Preventive Action The design criteria for the cable bus duct have been documented in the Design Basis Document (DBD) (Reference 4.1).

4.0 References

, 4.1 CPSES Design Basis Document DBD-EE-040, 6.9 kV Electrical Power

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SU8 APPENDIX 87

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SDAR CP-88-09, ELECTRICAL PENETRATIONS OVERLOADING PROTECTION DEVICES AND SHORT CIRCUIT RELATED DEFICIENCIES 1.0 Definition of the Issue The issue was that some electrical containment penetrations had inade-quate electrical protection, ampacity capability or short circuit capability.

2.0 Issue Resolution SWEC resolved the issues by validating the original calculations and preparing new calculations in accordance with the design criteria as specified in the Design Basis Document (DBD) (Reference 4.1). The new calculations identified design modifications that were required. These modifications included replacement of breakers, addition of breakers and fuses, re-routing of cables, paralleling and reassigning penetra-tion conductors. These calculations, in conjunction with design modifications, validate that adequate electrical protection, ampacity and short circuit capability exist for the electrical penetrations.

Design changes were developed and hardware modifications are being implemented.

O V 3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-88-09, in letter number TXX-88068, dated January 11, 1988, from TV Electric to the NRC.

3.1 Corrective Action The original calculations were validated and new calculations were prepared in accordance with the design criteria as specified in the Design Basis Document (DBD) (Reference 4.1). These calcula-tions identified that design modifications were required. These modifications included replacement of breakers, addition of breakers and fuses, re-routing of cables, and paralleling and replacing penetration conductors. These calculations, in conjunc-tion with the design modifications, validate that adequate electrical protection, ampacity and short circuit capability exist for the electrical penetrations. Design changes were developed and hardware modifications are being implemented.

O B7-1

3.2 Preventive Action '

The design criteria for electrical penetrations have been docu-mented in the Design Basis Document (OBD) (Reference 4.1).

4.0 References 4.1 CPSES Design Basis Document (0B0) 080-EE-062, Containment Electric Penetration Assemblies, Revision 1 t

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SDAR CP-87-85, DEGRADATION OF CLASS 1E CIRCUITS

1. 0 Definition of the Issue The issue was that a qualified electrical isolation device was not provided and that no documentation was available for the asweiated cables between the Safety System Inoperable Indication (SSII) logic housing and the termination cabinets. No documentation was available to indicate that these cables were qualified for Class 1E service.

2.0 Issue Resolution SWEC resolved this issue by revising the design for the cables between the Safety System Inoperable Indication (SSII) logic housing and the termination cabinets which removed them from the Class 1E raceways.

These design revisions are in accordance with the design criteria as specified in the Design Basis Documents (DB0s) (References 4.1 and 4.2). Hardware modifications are being implemented.

The electrical isolation portiun of this issue has been resolved as discussed in Subappendix A1.

3.0 Corrective and Preventive Action 1

No additional issues were identified during the review and resolution of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-87-85 in letter number TXX-7124, dated December 23, 1987 from TV Electric to the NRC.

3.1 Corrective Action The design for the cables between the Safety System Inoperable Indication (SSII) logic housing and the termination cabinets was revised, which removed the cables from the Class 1E raceways. These design revisions are in accordance with the design criteria as speci-I fied in the Design Basis Documents (OB0s) (References 4.1 and 4.2).

l Design changes were developed and hardware modifications are being l implemented.

The electrical isolation portion of this issue has been corrected, as discussed in Subappendix A1.

3.2 Preventive Action The design criteria for cable separation and installation have been documented in the Design Basis Documents (OB0s) (References 4.1 and 4.2).

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4.1 CPSES Design Basis Document DBO-EE-057, Separation Criteria, Revisicn 1 4 '4. 2 CPSES Design Basis Document OBO-EE-052, Cable Philosophy and Sizing i Criteria, Revision 1 a

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k SUBAPPENDIX 89 SDAR CP-88-11, POTENTIAL BATTERY CHARGER FAILURE DUE TO HEATING 1.0 Definition of the Issue The issue was that during site testing a Class 1E battery charger overheated at an ambient temperature of approximately 102 F which is within the normal design temperature range of the area. Battery chargers are specified to operate over an ambient temperature range of 40*F to 104'F. -

2.0 Issue Resolution SWEC resolved this issue in conjunction with the vendor by determining a design modification was required which eliminates overheating caused by internal components and assures that the Class 1E battery chargers are adequately cooled.

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue. -

O V This issue was determir.ea to b5 reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (50AR) CP-88-11 in letter number TXX-88070, dated January 11, 1988, from TV Electric to the NRC.

3.1 Corrective Action The requirements for a design modification was identified which eliminates overheating caused by internal components and assures that the Class 1E battery chargers are adequately cooled.

3.2 Preventive Action The design criteria for battery charger ambient temperature l

requirements have been documented in the Design Basis Document

! (DBD) (Reference 4.1).

4.0 References 4.1 CPSES Design Basis Document DBD-EE-044, DC Power System, Revision 1 89-1

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V HBAPPENDIXB10 SDAR CP-88-08, CiASS 1E BATTERY ROOM TEMPERATURE

- 1. 0 Definition of the Issue The issue was that the batteries are required to be sized to provide their required output at 70 F and the Heating, Ventilation and Air Conditioning (HVAC) system design allows for a minimum temperature of 40*F during a loss of Offsite Power (LOOP), when the non-Class 1E unit heaters will not be operating.

2.0 Issue Resolution Ebasco resolved this issue by revising the design of the Class IE battery room Heating, Ventilation and Air Conditioning (HVAC) system to provide a minirum room temperature of 70 F under all plant operating conditions. This revised design is in accordance with the design criteria as specified in the Design Basis Document (DBD)

(Reference 4.1). Hardware modifications are being implemented.

3.0 Corrective and Preventive Actions No additional issues were identified during the review and resolution of this issue:

1 4

This issue was determined to be reportable under the provisions of  ;

10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-88-08, in letter number TXX-88067, dated January 13, 1988 from TU Electric to the NRC.

3.1 Corrective Action The design of the Class 1E battery room Heating, Ventilation and Air Conditioning (HVAC) system was revised by Ebasco to provide a minimum room temperature of 70*F under all plant operating condi-tions. This revised design is in accordance with the design cri-teria as specified in the Design Basis Document (DBD)

(Reference 4.1). Hardware modifications are being implemented.

3.2 Preventive Action The design criteria for the ambient temperature requirements in

, the Class 1E battery rooms have been documented in the Design l Basis Documents (OBD) (Reference 4.1 and 4.2).

4.0 References

! 4.1 CPSES Design Basis Document DBD-EE-044, DC Power System, Revision 1 i\ O B10-1

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,__ SUBAPPENDIX B11 E) SDAR CP-87-49, SOLIO STATE SAFECUARDS SYSTEM (SSSS) LOAD SEQUENCER INTERNAL WIRING TERMINATIONS 1.0 Definition of the Issue The issue was that the Solid State Safeguards System (SSSS) Load Sequencers contained deficient wire crimped lugs.

2.0 Issue Resolution The issue was resolved by reviews conducted by the vendor which concluded that these deficiencies were due to inadequate shop and inspector controls in place at the vendor's manufacturing facility during the time of fabrication of the CPSES Solid State Safeguard System (SSSS) Load Sequences.

Inspections are being performed on the internal wiring of the Solid State Safeguards System Load Sequencers for proper workmanship based on inspection criteria recommended by the vendor and the electrical installation specification (Reference 4.2).

3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution n) of this issue.

This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report SDAR CP-87-49, in letter number TXX-88021, dated January 11, 1988, from TV Electric to the NRC.

3.1 Corrective Action The inspection of the internal wiring of the Solid State Safeguard System (SSSS) Load Sequencers for proper workmanship based on inspection criteria recommenced by the vendor (Reference 4.1) and the electrical installation specification (Reference 4.2) is being performed.

3.2 Preventive Action Preventive action has been implemented by the vendor (Reference 4.1).

4.0 References 4.1 Vitro Laboratories' Mannfteturi,.9 Process Standards for Crimping and Lugging MPS-136, dated September 1, 1983 f)

V 4.2 CPSES Specification, Electrical Installation, Class Non-Safety, 2323-ES-100, Revision 4, dated November 5, 1987 I, II and B11-1