View source for GO2-82-958, Responds to NRC Re Violations & Deviations Noted in IE Insp Rept 50-397/82-21.Corrective Actions:Electrical Separation Project Engineering Directives Reviewed to Identify Cables Affected by 6-inch Separation Requirements

{{Adams
| number = ML20070K937
| issue date = 12/02/1982
| title = Responds to NRC Re Violations & Deviations Noted in IE Insp Rept 50-397/82-21.Corrective Actions:Electrical Separation Project Engineering Directives Reviewed to Identify Cables Affected by 6-inch Separation Requirements
| author name = Carlisle C
| author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM
| addressee name = Sternberg D
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION V)
| docket = 05000397
| license number = 
| contact person = 
| document report number = GO2-82-958, NUDOCS 8212300318
| title reference date = 10-25-1982
| package number = ML20070K903
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 15
}}

=Text=
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P.O. Box 968 3000 GeorgeWashingtonWay                           509)372-5000 Docket No. 50-397                       Richland, Washington 99352 pfC -6 77 I: 39 December 2, 1982 G02-82-958                                                    pgD/IPly Mr. D. M. Sternberg
             -Chief, Reactor Projects Branch No. 1 U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

==Subject:==
NUCLEAR PROJECT NO. 2 NRC INSPECTION 82 NOTICE OF VIOLATION

==Reference:==
Letter J. L. Crews to R. G. Matlock, dated October 27, 1982.
Washington Public Power Supply System hereby replies to the Notice of Violation and the Notice of Deviation transmitted as Appendix A and Appendix B, respectively, via the referenced letter. Our reply pursu-ant to the provisions of Section 2.201 of the NRC's " Rules of Practice" Part 2 Title 10 Code of Federal Regulations, consists of this letter and Attachments 1, 2, and 3. Attachment I contains our response to the Notice of Violation. Attachment 2 contains our response to the Notice of Deviation. Attachment 3 contains additional information perti-nent to resolving the general issue of electrical separation which goes beyond the specifics identified in Attachments 1 and 2.
If you have any questions or desire further information, please contact          1 Doug Timmins at (509) 377-2501, extension 2942.
l Ise Deputy Program Director, WNP-2 RTJ/kd cc:   W.S. Chin, BPA - Site A. Forrest, Burns and Roe - HAPO N.D. Lewis, NRC J. Plunkett, NUS Corp.
R.E. Snaith, Burns and Roe - NY A. Toth, NRC Resident Inspector (917Q)
Document Control Desk, NRC WNP-2 Files (917B)                                                         i l
l 8212300318 821223 PDR ADOcK 05000 0
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STATE OF WASHINGTON         )
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COUNTY OF BENTON            )
CHARLES S. CARLISLE, Being first duly sworn, deposes and says: That he is acting for the WNP-2 Program Director of the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the permit holder herein; that he is authorized to submit the fore-going on behalf of said permit holder; that he has read the foregoing and attachments listed therein and knows the contents thereof; and believes the same to be true to the best of his knowledge.
DATED:        LQpjfs y .Q                               ,          1982 0K C. S.' CAR [ISl.E On this day personally appeared before me C. S. Carlisle to me known to be the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and purposes therein mentioned.
GIVEN under my hand and seal this        )           day of k r , M , 1982.
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ATTACHMENT 1 WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT N0. 2 DOCKET NO. 50-397 LICENSE N0. CPPR-93 RESPONSE TO INSPECTION REPORT 82-21 NOTICE OF VIOLATION The following are Supply System responses to the violations identified in Appendix A of the reference letter. For purposes of clarity, each violation is repeated followed by our response.
A. 10 CFR 50, Appendix B, Criterion V, as addressed in paragraph 17.1.1.2 of the FSAR (Quality Assurance Program) states in part: " Activities affect-ing quality shall be prescribed by documented instructions, procedures, or drawings ... (which)... include appropriate quantitative or qualita-tive acceptance criteria for determining that important activities have been satisfactorily accomplished." FSAR, Amendnent 23, stated in Section 8.3.1.4.3.7 "Where control devices of redundant systems are mounted in the same panel, physical separation (six inches), barriers, or isolation devices are provided."
Contrary to the abnve requirement, approved construction specifications used to install safety related Class lE electrical cables since January 1979, have not specified acceptance criteria for separation of redundant Class lE cables. For example, as a result of the absence of acceptance criteria in specifications for installation, on September 2,1982 the Emergency Reactor Shutdown Panel H22-P100 contained cables IP7AF-0004-C-Div-1, IM7A-0094-C-Div-1, and other Class lE Division 1 cables which were not provided six inch physical separation, barriers, or isolation devices from cables 2M8BA-0284-C-Div-2, 2C002-0101-C-Div-2 and other redundant Division 2 Class lE cables. " Connection Wiring Diagram Local Instrument Rack" (DWG E538, Rev. 8, sheet 40), and other construc-tion guidance provided to and implemented by the installation contractor did not specify separation requirements of redundant safety related Class lE circuits within this panel.
This is a Severity Level IV violation.
Supply System Response The need for the required 6" separation for the subject cables was pre-viously identified by Burns and Roe in the course of their electrical separation task activities and was provided via Project Engineering Directive (PED) 218-E-2439 in December 1979. This PED, among others, was unique to specific cables, and as such, the 6" requirement had not been generically incorporated into the contract specification.

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Attachment 1-
            '.Page _2 Subsequently, Burns and Roe issued PED 218-E-4837. in May 1982, which provided the 6" separation requirement for all intruder (redundant Class-lE and prime) cables within equipment. This PED was incorporated into the contract specification in July 1982. Considering the above, Burns and Roe was knowledgeable of the requirement and had issued appropriate direction to the contractor.
It should be understood that Burns and Roe, in the performance of their electrical separation task activities, identifies the cables and equip-
                                                         ~
ment affected by this requirement and issues the necessary, specific      -
direction to the Contractor via PED, not through drawings or by relying on the generic, contract specification requirement.
Corrective Action Taken The installing Contractor is performing a review of ninety-six (%)
electrical separation PEDS issued _ to date by Burns and Roe to identify other cables and equipment affected by the 6" separation requirements.
Documentation is being reviewed to verify the 6" separation criteria was adhered to.- Where compliance status is in question, a field inspection will be conducted to verify the physical configuration. The acceptable configuration will be documented or the cables and/or equipment shall be modified accordingly.
Action To F'eclude Recurrence The installing Contractor will retrain the personnel involved with issuing routing and termination instructions to ensure the 6" separation requirement is understood and properly executed based on PED direction.
Date of Full Compliance The review of electrical separation PEDS by the installing Contractor has been completed. A report documenting the results of the PED review and the verification of field compliance is being compiled by the installing Contractor and is scheduled to be issued the week of December 6,1982.
Contractor training is scheduled to be complete by December 3, 1982.

               ' l c-4ttachment i r' age 3 B.     .10 CFR 50,~ Appendix B, Criterion III, as addressed in FSAR section 17.1.1.3 DesignLControl .(Burns and Roe) states in part: l' Measures shall
                            . be established to assure that applicable regulatory requirements...are correctly translated into-specifications, drawings, procedures, and instructions." Criterion VI, " Document Control," states in part:
                              " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes.thereto,
          .,                  which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."
The Burns and Roe " Quality Assurance Plan for Washington Public Power Supply System, Nuclear Project 2" (Second Edition, Rev. 0) states in Chapter III Sections 3.1 and 4.1:
                                    "A project criteria document is prepared for the WNP-2 Project.
This document, prepared by a criteria development team, identifies applicable regulatory requirements, design ~ bases, codes, and stan-dards to be. translated into drawings, specifications, procedures, and instructions during the design process."
                                     "The' detailed design effort proceeds in accordance with the approved project criteria document and the applicable initial system descrip-t ion . "
Contrary to the above, on September 1,1982, the Design Engin m review-ing Design Drawings to insure implementation of electrical separation criteria in Design Documents and Engineering Directives, was working to criteria defined in an out-of-date and uncontrolled copy of FSAR Chapter 8.3 (Amendment 23) rather than the project criteria document. The uncon-trolled copy differed in the description of separation criteria from that submitted to the NRC as FSAR, Chapter 8.3 (%endment 23).
Additionally, the Burns and Roe Engineering Criteria Document, required by the Quality Assurance Plan, was found to be in conflict with FSAR Chapter 8.3 (Amendnent 23) in that ' fire stops' were defined as ' isola-tion devices' in Section D, Paragraph 3.6.1.14 of the criteria document, although this was not reflected in FSAR (Amendnent 23) Section 8.3.1.4.1.12 " Isolation Device".
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Attacnment 1 Page -4 The Project Criteria Document,'Section 0, also included on page 0-24z a Tabl_e IV titled " Divisional Compatability." The NRC took ' exception to tnis -table in'a letter from R.L. Tedesco to R.L. Ferguson, dated May 4, 1981 which instructed the licensee to " revise both Table IV...and your tray / cable marking codes to be consistent with your final cable separa-tion criteria." Contrary to the commitments made by _the Washington Public Power Supply System in their response letter of June 18, 1981 (G02-81-146) trom G.D. Bouchey to R.L. Tedesco, Table IV denoted no separation requirements between any C1 ass 1E system and any Non-Class,1E System.
This is a Severity Level IV violation.
Suoply System Response As described in the Notice of Violation, the Burns and Roe Engineering Criteria Document was not updated to the electrical separation criteria being used by the electrical design engineers. The critria in use was the Burns and Roe proposed Amendment 23 to FSAR Section 8.3.      On
,                             September 22, 1982, Burns and Roe revised the Engineering Criteria Docu-ment to reflect FSAR Amendment 23 (Project Criteria Advance Change WNP-2-Elec-3).
Interviews conducted by the Supply System Electrical Separation Task i
Force with Burns and Roe electrical engineers and designers, in c.njunc-tion with a review of training records and issued PEDS, confirmed that the proposed Amendment 23 document was, in f rct, the criteria being used.
In addition, Burns and Roe, baseo on their oi n investigation, came to the same conclusion and document _ed a similar sta.ement to the Supply System (BRWP-R0-82-284).
An independent review was performed of the proposed Burns and Roe Amend-ment 23 document against the approved FSAR Amendment 23, Section 8.3.
The review was performed by the Electrical Separation ~ Task Force. The conclusions of the review, recognizing that there are some text differ-ences, were that no substantive technical differences exist and the text changes were made for editorial clarification. Relative to the fire stop
,                            specifics, also identitied by the Task Force, Burns and Roe had not been using fire stops as an electrical isolation device, but only as a device taken credit for in analyses which minim 1zes fire propagation.
I Based on the findings of the Electrical Separation Task Force, briefly l                            described above, it is our conclusion that the appropriate separation criteria (FSAR Amendment 23, Section 8.3) was being implemented by Burns and Roe. Si.milarly, the criteria of Supply System letter G02-81-146 was being implemented, not Table IV, page 0-24z, of the previously outdated-Engineering Criteria Document.
i

Attachment 1 Page.5                                                                        ,
                     . Corrective Actions Taken.
The Burns and Roe Engineering Criteria Document.was revised. The.
importance of updating the Engineering Critaria Document in a timely manner has been reemphasized to the Burns and Roe personnel responsible for design control.
The Supply System conductea an audit of Burns and Roe's use of the Engineering Criteria Document for all disciplines in September 1982. Two findings were documentea (QFR 2 of 6 and 3 of 6) which -identified generic problems with the use and updating of the criteria. The corrective actions for these findings will assure and verity Burns and Roe's appropriate use of' the Engineering Criteria-Document.
Action To Preclude Recurrence Burns and Roe has retrained the design engineers in the use of the Engineering Criteria Document. Records of these training sessions are avail able.
Date of Full Canpliance The Engineering Criteria Document was revised September 22, 1982.
Training sessions were canpleted November 22, 1982.

P.
ATTACHMENT 2 WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT NO. 2                                                 l DOCKET N0.-50-397 LICENSE NO. CPPR-93 RESPONSE TO INSPECTION REPORT 82-21.
NOTICE OF DEVIATION
                                        .s.
The following are Supply System responses to the violations identified in Appendix B of the. reference letter. For purposes of clarity,'each deviation is repeated followed by our response.
A. Washington Public Power Supply System letter of. June 18, 1981 (G02-81-146), from G.D. Bouchey to R.L. Tedesco concerning cable'separa-tion criteria at WNP-2, states that associated circuits shall be uniquely identified as such or as. Class 1E, from Class 1E equipment up to and including an isolation device.
Contrary to the above, on August 31, 1982, it was determined that the Non-Class 1E power cables AM7A-9130, AM7A-9131, and AM7A-9132 and trans-former TR-7A-C and other circuits which were associated with Class lE Division 1 circuits by both lack of electrical isolation and lack of physical separation were not identified as associated circuits or as                              .
Class lE circuits. Moreover, the Washington Nuclear Project No. 2 cable identification scheme, although providing identification .for " Prime" cables (cables which at some point lack electrical isolation from Class 1E sources) or."9000 series - dual compatibility" cables (cables which at some point lack physical separation from Class IE -sources),'does not uniquely identify that portion of these circuits that is associated with Class lE division- - As a result, associated circuits which require separation and insi llation in accordance with the requirements for Class lE systems, cannot be identified so that control of activities affecting these circuits is maintained in accordance with 10CFR50 Appendix B requirements.
This is a deviation.
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Attachment 2 Page 2 Supply System Response Within certain plant areas, due to raceway availability, it is necessary to route Non-Class 1E cables with Class lE cables in Class 1E raceways.
FSAR Amendment 23 provides analysis by category for Non-Class 1E cables that receive power from Class lE sources (prime) and/or that are physi-cally routed with Class lE cables in Class lE raceways (Associated'by Proximity). The section of a Non-Class 1E cable which routes directly with Class 1E cables is termed " Associated by Proximity" and is uniquely identified by " Note 5" in the WNP-2 computerized cable schedule. In the field unique identification is provided for these cables in a Class lE raceway by the "A" or "B" cable number prefix; Class lE cable numbers are prefixed by 1 through 7. In addition, prime cables and cable sections defined as " Associated by Proximity" are identified by color-coded markers per FSAR Tables 8.3-25 and 8.3-26. Thus, cables " Associated by Proximity" are uniquely identified in Class 12 raceways. These cable sections are specified to be installed to the same installation para-meters as Class lE cables, but may not have Class lE documentation to verify the installation.                            -
As allowed by Item A.3 of Attachment I to the {{letter dated|date=June 18, 1981|text=June 18, 1981 letter}} (G02-81-146) , analysis has been provided to show that Class lE cables are not degraded below an acceptable level when cables " Associated by Proxim-ity" have continuing sections in Non-Class lE raceways, equipment, or enclosures. The continuing cable / wire sections (termed Non-Class lE) are treated as Non-Clast, lE (non-associated) and as such require no further adherance to Class lE separation or identification within these raceways, equipment, or enclosures. However, Non-Class lE open trays with power circuits are separated from all Class 1E raceways with the same physical separation requirements as that required between redundant Class lE race-ways.
Note that circuit 3 defined as prime are not treated strictly as Non-Class lE circuits and do require application of unique identification and separation criteria as specified in the FSAR Section 8.3.1.4.
In addition, the "9000" series cable identification is not used to solely denote a cable " Associated by Proximity". The color-coded markers and A/B cable number prefix in Class 1E raceways are the correct identifica-tion means.
Corrective Steps Taken In order to provide improved clarification of the electrical separation criteria, an Electrical Separation Practices document has been written and is to be issued shortly.
Results Achieved - Clarification via new document.
Corrective Action Complete - December, 1982.
1

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Attachment-2 Page 3 B. Washington Public Power Supply System letter of. June 18, 1981, (G02-81-146), from G.D. Bouchey to R.L. Tedesco concerning cable separa-tion criteria at WNP-2 states that associated circuits shall remain with, or be physically separated the same as, those Class lE circuits with which they are associated, from Class lE equipment up to and including an isolation device. The accepted industry standard, Regulatory Guide 1.75, Revision 0, dated February 1974, states that Non-Class 1E circuits should be separated from associated circuits and Class 1E circuits by the mini-mum separation' requirements for redundant Class lE circuits. If non-Class lE circuits do not comply with these requirements the Non-Class 1E
;                  circuits should be treated as associated circuits.
Contrary to the above, on August 31, 1982 it was determined that associ-ated power circuits AM7A-9130 and AM7A-9131 were directly connected to Non-Class 1E transformer TR-7A-C and other Non-Class 1E electrical circuits. Physical separation and electrical isolation of these associ-
,_                 ated circuits was not provided the.same as those Class lE with which they were associated.
This is a deviation.
Supply System Response Regulatory Guide 1.75, Revision 0, does not apply to WNP-2; however, the intent of that guide is addressed by an alternate means as described in FSAR Section 8.3.1.4. Specifically, as discussed in our response to Notice of Deviation, Item A, that section of a Non-Class lE cable routed in a Class lE raceway is termed " Associated by Proximity". It remains with and is physically separated the same as the Class 1E cables with
;                  which it is routed. Based on analysis, the continuing section of that Non-Class lE cable external to the Class lE raceway is termed and treated i                  as Non-Class lE. This situation applies to cables AM7A-9130 and AM7A-9131.
Corrective Steps Taken Refer to previous response.
Results Achieved i
Refer to previous -esponse.
Corrective Action Complete Refer to previous response.
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Attachment'2 Page 4 C.   - FSAR Amendment 23,- Figure 8.3-29a defines ~3 feet' as the minimum horizon-tal separation require"ent between any two redundant' divisions in open tray, or where just one raceway is enclosed.
Contrary to the above, it was determined on September 1,1982 that the required 3 feet horizontal separation was not provided for redundant safety Division -1, Division 2, and Division 3, and redundant B0P Division A and Division B cables routed in non-watertight, interlocked armor on the floor of the southwest corner of the control room. (These conduits were not identified by other than- divisional markers.)
                  .This is a deviation.
Supply System Response FSAR Figure 8.3-29a applies to raceways in " General Plant Areas", not to underfloor raceways in the Main Control ~ Room periphery outside the PGCC.
The FSAR requires an update to include the specific separation requirc-ments for this area. However, separation criteria has been applied to this area by PED 218-E-4840 issued in May 1982. The FSAR will be revised to include words similar to the following:
Periphery of PGCC 1
A modular floor raceway system is not provided in this area. Cables in this area shall be routed in grounded flexible conduit with 3 feet horizontal separation maintained between redundant Class lE conduits. Where this distance cannot be maintained, one of the redundant conduits shall be rigid. The redundant conduits shall not touch. An approved fire rated material may be used to prevent the two conduits from touching.
These conduits are identified by metal tags which identify the cable number and division. Since these tags are not color coded, an-additional color-coded marker shall be attached near the metal tag to identify the conduit divisional assignment.
Corrective Steps Taken PED 218-E-4840 was issued in May 1982. FSAR Section 8.3.1.4 is to be revised to include the separation requirements for the periphery of the
.                 PGCC within the Main Control Room.                             In addition, the draft Electrical Separation Practices document does address this item and will reflect the proper criteria upon issue.
Results Achieved i                 Clarification of electrical separation criteria in the periphery of the PGCC.                                                                                                             !
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     .. ...                        o Attachment 2 Page 5 Corrective Action Complete The subject FSAR revision and the Electrical Separation Practices docu-ment will be issued in December 1982.
D.-  FSAR Amendment 23, Table 8.3-25 " Division markers for equipment, race-ways, and cables external to PGCC" states that Non-Class 1E B0P Division B shall be identified with gold marker background colors and black character colors.
Contrary to the above, it was determined on September 1, 1982 that in the cable spreading room, tray section 7252, labeled S-Div-B in accordance with Table 8.3-25 above, there were numerous cables identified with blue markers at approximately 5 foot intervals similar to PGCC Class 1E Division 2. FSAR Table 8.3-25 does not provide for such markers external to the PGCC. There appeared to be no divisional markers for these cables in accordance with FSAR requirements throughout the approximately 75 to 100 feet of routing within the cable spreading room.
This is a deviation.
Supply System Response As a part of the PGCC design, there has been a need to interconnect the Main Control Room Balance of Plant (B0P) fro'nt benchboards with the vertical boards located at the back of the room. However, the PGCC ducts provided do not allow such routing to be practicable. As an alternate, a network of dedicated raceways has been provided in the cable spreading room to route the interconnecting cables. The design of this raceway network and listing of the interconnecting cables which are routed in these raceways is documented on Burns and Roe drawing E766, sheets 8, 9 and 10.
Even though these raceways are physically located in the cable spreading room, they have been considered an extension to the PGCC floor ducts and are treated as an exception to the standard criteria. Hence, contractor direction per ECN No. 77, Revision 1,1978, required that these cables be identified in these raceways in accordance with the PGCC cable marking requirements even though they physically reside in the cable spreading room.
Since these cables and raceways will be exclusively used for the PGCC interconnecting cables and are not part of the General Plant raceway /
cable scheme, it is desirable that they retain identification tags per PGCC cable tag requirements. A statement of this exception will be included in a FSAR revision stipulating the cable and raceway identifica-tion requirements for these specific cables. In addition, the Electrical Separattar. Practices document will address this exception.

            ' Attachment 2 Page 6
                  .' Corrective Steps Taken ECN No. 77, Revision 1,-was issued in -February 1978 via letter WNP-2-FL-218-F-78-56. The FSAR and Electrical Separation Practices document will address this exceptior.
Results Achieved Clarification of eiectrical separation criteria with respect to the subject exception.                                                         J l
Corrective Action Complete                                                 l The subject FSAR revision and the Electrical Separation Practices document will be issued in December 1982.
E. FSAR Amendment 23, Table 8.3-25 " Division markers for equipment, raceways, and cables external to PGCC". states that Class lE Division 1 equipment shall be identified with labels of yellow background color and black characters; Class lE Division 2 equipment chall be identified with labels of orange background color and black characters, and Class lE Division 3 equipment shall be identifiea with labels of red background color and black characters.
The Burns and Roe WNP-2 Project Criteria Document states in paragraph 3.6.1.25 that " equipment associated with the RPS, NSSS, and ESS shall be identified so that two facts are physically apparent to the operating and maintenance personnel: First, that the equipment is part of the nuclear safeguards system; and second, the grouping (or division) of enforced segregation with which the equipment is associated."
Contrary to the above, on September 2, 1982 it was determined that HPCS instrument panel H22-P04 (ESS Division 3) was labeled with yellow background and black characters the identification scheme for redundant division 1; that RHR instrument panel H22-P021 (ESS Division 2) was labeled with yellow background and black characters the identification scheme for redundant division 1, that (main steam isolation valve-leak control system) MSIU-LCS instrument panel IR-74 (Division 2), and MSIU-LCS instrument rack IR-73 (Division 1) were labeled with black background and white characters a method not appearing in the FSAR identification scheme for either B0P or PGCC equipment.
This is a deviation.
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Attachment 2 Page 7 Supply System Response FSAR Amendment 23, Table 8.3-25 describes the application of divisional markers for equipmunt, raceways, and cables external to PGCC. In the context of divisional identification for the purposes .of electrical separation, equipment is defined as enclosures and open face racks con-taining electrical components. The components, e.g., valves, instru-ments, relays, etc., are not individually identified with divisional markers. The enclosures and racks are identified with divisional markers. For racks with more than one division, the divisional markers are placed on a termination b'ox.
The divisional markers are additional tags which delineate the divisional association of the equipment. For example, HPCS related equipment are tagged with a "DIV 3" marker in addition to the equipment identification number. The divisional marker follows the color scheme in FSAR Table 8.3-25. Note that individual components (mounted on or'in equipment) have component identification tags located next to them which are not electrical separation divisional markers. The component identification tags are not intended or required to follow the separation color scheme in the FSAR.
In an effort to provide the contractor with clear instructions involving the application of divisional markers and equipment identification tags, Burns and Roe issued Project Engineering Directive PED 218-E-3153 in April 1981.
The 218 Specification Section 16A Paragraphs 4.6.2, 4.6.3, and Section 50A Paragraph 3.5.4 address the tagging requirements which are consistent with the above discussion.
Nuclear safeguard systems and their components are identified by the individual component identification tags. The grouping (division) asso-clation is provided by the 6: visional markers.
The specific examples identified in the NRC Deviation E address the component identification tags, not the divisional markers.
Corrective Steps Taken The FSAR and the Electrical Separation Practices document will clarify the above discussion.
Results Achieved Clarification of divisional identification requirements.
Corrective Action Complete                                                  ;
The subject FSAR revision and the Electrical Separation Practices docu-ment will be issued in December 1982.
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s NUCLEAR PROJECT NO. ~2                                                         p                                                                              *''
w            , 00CKET' NO. 50-397                                                                                             e s
: LICENSE N0.: CPPR                                                                                      .A A        +-
RESPONSE TO INSPECTI,0fl RE(0RT 82-21 Several of the items dis $$ sed in AttacNgsnts 1 drq 2 are specific is nature                                                                                                                                      ''
and part of the general electrical 'separf.iofrissue being discussed by, the Supply System and theEC,- both Region V 'and Licensing. As all ar.e 2.cre, the                                                                                                                    ,
N Supply System established an Electrical 5eparation Task Force 1,n; September 1982 to revisit the-;:ritenia and its implementation in a manner;4to address thex NRC concerns and reso1Je the general \ issue. This -review, and associated find- ^
          'ings and corrective action, is ongoing 9nd scheduled for completion 'i!!;danuary
          > 198 3. The responses provided in Attachefnts 1 and 2 dddjress!the specifics, and_ in some cases where appropriate, the item in a genLric manne .. HoWever, those responses cannot address -the elegrical separdtioyissue in'its entirety due to the ongoing Task Force activitieme.g., implegefitation of.ith~e labeling                                                                                                                                        '
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It is our intent to have-ongoh'g dialogue with the NRy (RegionTVbon the find-ings of the Electrical Separat;30n Task Force and on corrective action as found                                                                                                                                 , ,
necess ary. As the Task Force review activities approaci completion, a means                                                                                                                        !               ';
to document the closure of the general issue shall be 'a]                                            , . . reed up\n.                                                                                                    4
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