ML20210B610

Advises That Region V Completed Review of Util 870403 Wire & Cable Program Description & Action Plan.Encl Identifies Concerns That Need to Be Addressed in Upgrading Plan

ML20210B610
Person / Time
Site:	Rancho Seco
Issue date:	05/01/1987
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Andognini C SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
TAC-65195, NUDOCS 8705050363
Download: ML20210B610 (4)

Text

gn 1:4 9'o,, _ UNITED STATES

[, g NUCLEAR REGULATORY COMMISSION r; j REGION V

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,o g 1450 MARIA LANE. SUITE 210 WALNUT CREEK, CALIFORNIA 94596 9*****

NAY 1 1987 Mr. Carl Andognini Chief Executive Officer Sacramento Municipal Utilities District P. O. Box 15830 Sacramento, California 95813

Dear Mr. Andognini:

Region V has completed a review of the Wire and Cable Program Description and Action Plan (CRTS) provided on April 3,1987 with a request for prompt comments or redirection.

Based on this review we believe that the scope, background, details, proposed action and schedule are not sufficiently defined to allow us to conclude that SMUD is acceptably resolving the discrepancies identified in this area. The enclosure to this letter identifies several specific concerns which Region V has identified in its review. These concerns need to be addressed in upgrading the Cable Program Action Plan.

The detailed nature of these concerns suggests that SMUD has attempted to solve the cable routing problem without clearly defining the fundamental problems, analyzing their root causes, and developing an integrated, consistent approach to its resolution.

In recognition of the potential magnitude and the importance of this issue I urge that the comments be considered and the plan resubmitted at the earliest date possible. Both the Region and NRR are eager to reach closure on the resolution plan but the impetus must come from SMUD---and quickly.

inc ely, John B. Martin Regional Administrator cc: T. Murley J. Taylor DESIGNATZD HIGI!LtL Cett1fied By_

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CONCERNS REGARDING SMUD CRTS ACTION ~ PLAN DATED MARCH 31, 1987

1. The problems evidenced by the reported and alleged conditions and the large number of CRTS discrepancies warrant a formal and complete root cause evaluation by SMUD prior to restart. It is not apparent how an adequate corrective action plan could be developed without such an analysis.

Section 4.4 of the plan tabulates a very large number of CRTS " Data Base Problems." The very large number suggests that either the CRTS data base is very flawed, or the cabling itself at Rancho Seco has not been properly installed, or both. Region V is concerned that the plan does not address the implications of either alternative. This relates to the need for a root cause investigation as well as an item by item disposition of the discrepancies. LER 86-10 partially comits to such an evaluation at an

, unspecified time for the seven misrouted cables identified there..and LER 87-13 states that the root cause for that event is "the same" as for LER 86-10 without elaboration.

2. Section 3.0 of the plan is incomplete and lacks many of the known details of cable routing problems. Specifically, the plan does not mention that in late 1983 the NRC learned that the CRTS could be missing many pull card inputs (discussed in Inspection Reports 83-37 and 84-26 and a SMUD followup audit) because two different methods of implementing the CRTS records existed. In addition, the existence of Licensee Event Reports 87-13 (relating to seven additional misrouted cables) and LER 87-26 (relating to thirty six additional intermixed power / control and-istrumentation cables) is not mentioned.

SMUD reporting of the problems of the CRTS has been tangential and ,

fragmented. The misrouting of seven cables reported in LER 86-10 was i originally identified to the NRC as a potential record falsification issue by !

an alleger, as was the existence of a large number of CRTS discrepancies in  !

1983 and again in 1986. M each case SMUD's official disclosure to the NRC (where it existed), was im.omplete until specific followup inspection was performed by Region V. For example, LER 86-10 described seven erroneously routed cables as "an isolated failure in design configuration control." LER 85-16 Revision 1 described two instances of intermixing of power and instrument cables without any explanation except that " adherence to these

[ construction specifications and inspection documents] should prevent recurrence."

3. Section 5.0 of the plan states that documentation of the level of control excercised by SMUD (1975-1986) in installing cable as well as identification of lessons to be learned from the level of control exercised will be completed sometime after plant restart. These commitments are unacceptable. The level of control exercised by SMUD (1975-1986) should be readily determinable, and determination of the lessons learned is an essential element in the root cause analysis discussed above.

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4. Section 4.2.1 of the plan uses the terms " major defect," " minor defect,"

and " insignificant defect" without clear definition. The only discussion apparent was for " major defects" on page 10 of Reference 4. This states that a major defect exists only if a discrepancy exists between the CRTS database and the as-built routing, and, in addition, a-design criteria was violated, and the defect has not been "dispositioned" by a CRTS Problem Report or a CRTS Conversion Problem Report. This dispositioning process is also undefined.

. 5. Section 4.4 of the plan states that only CRTS discrepancies with safety implications will be addressed prior to restart. Region V assumes that the CRTS has become an essential part of SMUD's quality records system in that it provides some of the objective evidence of proper cable routing. Given this, it is not clear how the safety implications of a discrepancy can be identified without " addressing" it. That is, all discrepancies should be addressed to determine if they have safety implications. Region V believes that an itemized description and schedule for cornction of each CRTS discrepancy is an essential part of a complete plan. Each apparently nonconforming condition should be dispositioned in accordance with the

! quality assurance. program prior.to restart.

6. Section 4.2.7 of the plan discusses the rationale for not including a sample of work done during plant construction. The rationale seems to be that the work done under a different tracking program, EE 553, was

controlled by Bechtel procedures, which are presumed to have been acequate. This rationale is confusing

The sample lots chosen by SMUD are not limited to CRTS pro after plant licensing (gram work, from the period but include all EE 1975 until July,553 1980).program Thuswork the done j

samples chosen do not reflect clearly only CRTS records, but a mixture.

Moreover, it is Region V's understanding, based on Inspection Report i 83-77, that Bechtel procedures were used for most of the CRTS work until l i

at least 1983. Given these understandings, the following sample <

populations seem justified: work done by Bechtel using EE 553, work done j by Bechtel using CRTS, work done by SMUD using EE 553, and work done by j SMUD using CRTS.

1 j 7. Neither the sampling plan, the action plan, nor the LERs submitted clarify

{ what " questionable pull card signatures" are, and why they fann some of

the sample population lots. At various meetings and inspections in the l last six months, SMUD personnel have implied that a single individual was

} responsible for all of the cable routing errors related to LERs 86-10 and 87-13. This view is inconsistent with the procedures provided to Region V and represented as the governing procedures for cable routing. A clear explanation of the cable routing requirements which pertained to each of

the populations discussed in paragraph 7 above, as well as any other appropriate populations, is needed to evaluate where responsibility for any errors properly lies. It is not apparent that SMUD has yet done such an evaluation. This concern is thus closely related to that of the need i for a root cause investigation.

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8. Section 4.3 of the plan entitled " Resolution of Concerns Regarding The

Completeness of the CRTS Data Base" states that a review of various quality concerns will be made, but no commitment date is specified for completion of this review. As discussed above, this review should be completed for safety-related and important-to-safety cable work as part of the root cause determination prior to restart. The nature of the questions in Section 4.3 also suggests that SMUD personnel are aware of more extensive problems with cable quality than have yet been disclosed.

This is a related concern.

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