ML20148T155

Rev 4 to Wire & Cable Program Rept

ML20148T155
Person / Time
Site:	Rancho Seco
Issue date:	12/31/1987
From:	Gough E, Sandra Talley, Vinquist J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
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ML20148T123	List: ML20148T155
References
NUDOCS 8802030216
Download: ML20148T155 (142)

Text

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Enclosure To GCA 88-001 WIRE AND CABLE PP.0 GRAM REPORT i

i RANCHO SECO NUCLEAR GENERATING STATION SACRAMENTO MUNICIPAL UTILITY DISTRICT SACRAMENTO REVISION 4 NOVEMBER / DECEMBER 1987 PREPARED BY:

APPROVED:

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( N\\.f2LU W I, a

t, uAMC00RDI<A7 MA GER OF QUAUTY DEPARTMENT S. R. Talley

. V. Vinquist f* * ?***Ss M

CRT5 PROGRAM MANAGER HAkAGER OF NUCLEAR ENGINEERING E. J. Gough G. V. Cranston i

-1

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Enclosure To GCA 88-001 WIRE AND CABLE PROGRAM REPORT

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

Since 1975 about 9,000 cables have been added whfie a few have been deleted.

In connon with all large modern power plants in the United States, Rancho Seco tracks its raceway and cable data in a computerized program run on a main frame computer.

The current program has an acronym of CRTS (Cable Raceway Tracking System) and performs some checks and calculations as well as recording and reporting data. CRTS has been in place since July of 1980.

The original cable population of 14,000 was installed by Bechtel Power Corporation (BPC).

BPC was both designer and constructor.

Until the CRTS program was put in place in 1980, the cable and raceway was tracked by a BPC Program EE-553. This program has been used for over 20 nuclear power plants.

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

In 1985 questions arose concerning the degree of design control exercised following spurious actuations reported in LER 85-16.

In 1986 questions arose concerning the degree of ccntrol exercised during the installation process and the validity of "as-built" information in the CRTS data base following issuance of LER 86-10.

Employee allegations regarding overfilled cable trays and incomplete data in CRTS, added to the level of concern.

The July Wire and Cable Program Report contained 56 CRTS Action Items, including entries for 16 Non-Conformance Reports (NCRs] and 12 Occurrence Description Reports (00Rs]. The August Report was reformatted and lists 00Rs and NCRs separately from the CRTS Action Item List (Attachment (1)].

CRIS Action Iteus 1 through 22 remain the same, Item 23 of the July Report is now listed under NCR S-5270 in the CRTS NCR List, Iteus 24 and 25 of the July Report have been combined and are now Item 23.

00Rs and NCRs listed as Items 26 through 52 of the July Report are now listed by the appropriate ODR or NCR number in either the CRTS ODR List (Attachment (2)] or the CRTS NCR List (Attachment (3)] as appropriate.

CRTS Action Items 53 through 56 of the July Report now appear as CRTS Action Items 24 through 27 respectively.

The August Report added Item 28.

The September / October Report added Items 29 and 30.

-2

Enclosure To GCA 88-001 WIRE AND CABLE PROGRAM REPORT (Continued)

Identified problems and questions are listed in the CRTS Action Item List L Attachment (1)), the CRTS ODR List [ Attachment (2)], and the CRTS NCR List [ Attachment (3)], with appropriate references.

The separate ODR and NCR lists have been expanded and now provide descriptions of the occurrences or nonconformances, direct causes, corrective actions and reference to the CRTS Action Item Commentaries

[ Attachment (4)), where appropriate.

2.2 INITIAL ACTIONS Initial action taken by SHUD, in mid-1986, was to hire a contractor

[Impell - Task 271] to provide computer applications and electrical engineering expertise required to resolve CRTS database discrepancies and verify that the CRTS database correctly reflected the plant "as-built" configuration.

This task was essentially an engineering review and checking process aided by microcomputer programs written to sort CRTS data and to print data lists as requested by the engineers.

Checks were made of raceway overfills, violations of separation criteria, intermixing of instrument cables with power and control cable and other discrepancies as listed in the Action Plan.

Although a number of discrepancies were "bookkeeping" problems, generated by the enhancement, a significant number could, potentially, have been of real concern.

Identified discrepancies are documented in reports from the SMUD contractor [IMPELL) to SMUD and their dispositions described in Item 2 of the CRTS Action Item List and supported by calculations in SHUD files.

Late in 1986 a decision was made to signal trace a significant sample of the approximately 2400 safety cables installed from 1975 through 1986 and compare the "as-built" condition with plant documents and the CRTS data base to establish a level of confidence in the reliability of the data base.

The signal tracing has found sufficient number of major defects in both Lot 1 (397 cables) and Lot 4 (78 cables) to require 1007, inspection of each lot.

In late June,1987 sampling was complete in Lots 2, 3 and 4.

However, in July,1987 a decision was made to sample Lot 2 to the "one-defect" level, increasing the size of Lot 2 by 35 cables.

Circuit tracing was completed on December 8,1987 with a total of 617 cables either traced visually or by signal tracing.

During the final checking and revision of the Sample Plan [ Appendix (1)J cables deleted from the plant Laf ter the populations were established) were deleted, from each lot, as follows:

Lot 1, Lot 2 Lot 3 Lot 4 Was 422 1702 190 78 Is 397 1462 176 78

-3

Enclosure To GCA 88-001 WIRE AND CABLE PROGRAM REPORT (Continued) e l

Additionally, in Lot 2, 76 Class 2 [ Appendix "R"] cables and 3 Class 1 [ Appendix "R"] cables were found to be pre-commercial operation vintage.

Three [3] of the 76 were included in the Lot 2 inspection

[

total of 91.

Deleting 79 pre-commercial cables reduces the Lot 2 total to 1383.

Three more cables were traced in Lot 2 in December 3

and were found to be correct [no defects].

Final inspection totals l

l and statistical inferences are given in Table 1 of the commentary to r

j CRTS Action Item 28.

Simply stated, the intent was to estabitsh 95 percent confidence that the true percentage of discrepant circuits [ major defects] in the l

sampled population is no greater than 5 percent.

Inspection totals j

are in fact higher for Lots 2 and 3 than are required to establish i

this confidence level. See commentary to CRTS Action Item 28.

L 1

j 2.3 ACTION PLAN

{

SMUD has provided a document [ Appendix (2)] to the NRC which describes a five part Action Plan to consolidate the various activities of the Nuclear Engineering Department, which deal with the cable and raceway questions, l

l Although the scope of the plan is complete, the details and the individual actions require additional definition to enable a reviewer L

to easily determine the acceptability of the resolution of each item (i.e., question or issue raised).

The Wire ano Cable Program Report i

is intended to replace the Action Plan and to provide additional i

definition and schedule information on a monthly basis, i

2.4 CRTS ACTION ITEM LIST AND COMMENTARY j

This report provides a listing of thirty CRTS action items i

[ Attachment (1)] with a detailed commentary on each [ Attachment i

4 (4)].

Tnis list is intended to serve as a record of all questions t

raised and of all known problems, other than ODRs and NCRs.

For each I

item the list includes an item number, description, source, status

]

and schedule for resolution, if appropriate.

1 j

A comentary will be provided on each item covering chronology, generic implications, causes and corrective actions as appropriate.

l 4

This report contains all comentaries and final inspection totals j

[see the cor.snentary to CRTS Action Item 28),

j l

To understand the significance of each.itea it is necessary to j

read the attendant conaentary.

The major concerns are sununarized in

[

Section 3.

-4

(

i l

I I

w

Enclosure To GCA 88-001 WIRE AND CABLE PROGRAM REPORT (Continued) 2.5 CRTS RELATED 00RS AND NCRS CRTS related DDRs and NCRs are now listed separately LAttachments 2 and 3] with der 'iptions, causes, corrective actions and reference to the CRTS Actict. Iteu Commentaries, where appropriate.

3.

MAJOR CONCERNS ISSUES CONCERNS Procedures The level of control exercised on cable installa tion.

Sampling Plan Accuracy of CRTS data on cable locations.

Data Base Completeness Qaission of cables from data base.

Raceway Fill Control of cable tray fill Lweight and ampacity questions).

Design Control Mixing of instrument cables Lwith power &

controlj in design process.

CRTS Discrepancies Control and entry of data f ato CRTS.

Fecords Control of documents of record.

Miscellaneous Problems Completeness of licensee action in resolving probl ems.

Root Causes Identification and correction of all identified root causes.

Status of each issue is, in summary, as follows:

3.1 PROCEDURES Procedures in place during the original construction period are addressed in Item 7 of the CRTS Action Item List.

Procedures in place from 1975 through 198f, are addressed in the con.1entary to CRTS Action Item 25.

3.2 SAMPLING PLAN This issue is fully addressed in the conmentary to Item 1 of the CRTS Acticn Item List.

-5 a

Enclosure To GCA 88-001 WIRE AND CABLE PROGRAM REPORT (Continued) 3.3 DATABASE COMPLETENESS The "completeness" issue of the CRTS data, centers on the data concerning the telephone and security cables.

This issue, although l

real, has no significant safety implications.

The issue also l

includes questions concerning the verification of CRTS software.

Items 10,11,12,13 and 14 of the CRTS Action Item List cover the completeness issue.

3.4 RACEWAY FILL l

The cable tray fill and weight questions have been reviewed.

Percentage fill and weights for all cable trays have been checked.

Although soue relatively minor questions remain to be answered, no significant problems have been found. Changes are planned to USAR t

which will reconcile differences between the USAR and Nuclear Engineering Procedures and will clarify design limits.

Enhancements planned to the CRTS sof tware will, when in place, automatically prevent fill and weight limits from being exceeded.

Thesa questions are addressed in Items 2 LpartialJ. 6 and 00R 86-125.

3.5 DESIGN CONTROL The design control issue is more complex than the raceway fill issue, but problems are limited to a relatively small number of instrument cables which mix with power and control cables and violate design c ri teria.

No evidence has been found of a programmatic failure following a reviw of the original 14,000 cable population.

Checking a

of the 9000 cables added after commercial operation continues, but is not expected to change the outcome of the evaluation.

The question of a possible generic design problem in the original 14,000 cable population is addressed in Item 5 of the CRTS Action Item List.

Other specific mix questions are addressed in Items 2 Lpartial), 9 and by ODR 87-307 and NCRs S-6523, S-6561, S-6562, S-6503, S-6564 S-6565 and S-6566.

3.6 CRTS DISCREPANCIES j

The large number of CRTS discrepancies, listed by the SHUD contractor (ImpellJ in Task 271, is another complex question.

Although the large number is initially disquieting, upon examination none have any safety significance as detailed in the commentary on CRTS Action Item 2.

One example of this is the total of 703 reported mixes of Class 1 with Clast. 2 or 3 cables. Almost all the 763 cables are in the r

original cable population which permitted mixing and none violated safety criteria. All of the 1967 Class 1 discrepancies and some Class 2/3 discrepancies have been carefully analyzed, with j

oocuuentation, without finding any significant concerns.

The reason J

-6 d

Enclosure To GCA 88-001 l

UIRE AND CABLE PROGRAM REPORT (Continued) j for this, detailed in the commentary, is that the Impell review process itself generated the discrepancy lists which then had to be addressed.

One benefit of the CRTS discrepancy process is that the I

total population of 23,000 cables and related raceways has been l

scrutinized closely and results provide additional confidence in the l

lack of significant safety concerns in the cable population.

Tnis r

issue is addressed in Item 2 of the CRTS Action Item List.

i i

i 3.7 RECORDS i

Record control at Rancho Seco is a simpler issue.

The customary

}

industry documents of record for installed cable and raceway are the e

signed installation cards.

The computer tracking system is used as a convenient source of data while the verification record is the installation card.

At Rancho Seco the originals of th9 installation

[

l cards for the initial 14,000 cables and 13,000 raceways have not yet been found, although facsimile record copies do exist.

As discussed in the commentary to CRTS Action Item 3, we find that records for the

[

l original cables and raceways are apparently complete, although the clerical task of checking each cable and raceway card is not i

compl ete.

Card records for the cables and raceways installed af ter commercial operation are mostly complete. Missing cards are l

j identified on NCRs for disposition, j

i 3.8 MISCELLANEOUS PROBLEMS l

{

Tnis issue deals with the completeness of SHUD actions in identifying i

and resolving all cable and raceway problems.

Together, the CRTS Action Item List (Attachment (1)], CRTS ODR List LAttachment (2)],

CRTS NCR List LAttachment (3)) and the CRTS Action Item Commentary i

LAttachment (4)] is the vehicle which records all questions and j

problems. All identified items with safety significance will be i

resolved before restart.

All identified items with no safety j

significance will be resolved before the end of the Cycle 8 outage.

I i

All items in the CRTS Action Item List will be reviewed for generic r

i implications before resolution. When a concern has been identified, the basic steps taken by SHUD are:

t

1) Take immediate action to prevent repetition.

[

l I

2)

Identify the direct cause and take corrective action.

[

3)

Investigate and toentify the root cause, and if required, f

l Supplement the corrective action.

l i

7 i

l i

i

_,,,.-_,n,,_,-..,._

--,_n_

WIRE AND CABLE PROGRAM REPORT (Continued) 3.9 ROOT CAUSES Where applicable, root causes have been established for each item in the CRTS Action Item List.

The Incident Invet,tigation/ Reviews Group LIIRG) established root causes for significant issues identified l

during the investigation of problems encountered in the 9,000 cables installed 1975 tnrough 1986.

This issue is addressed in Itea 15 of the CRTS Action Item List.

4.

APPENDICES 1.

Sampling Plan for Cable Raceway Tracking System Database (Impell Task 271 SMUD calculation No. Z-ZZZ-E0694, Revision 4, dated December 14, 1987).

2.

Rancho Seco Wire and Cable Program Description and Action Plan (District submictal dated April 3,1987 JEW 87-478).

3.

Justification for the Exclusion of the Original Rancho Seco Cable l

Population from the CRTS Sampling Program (District subuittal dated July 24,1987. GCA 87-338).

I I

4.

Prior Use of 95/95 Acceptance Criteria in Nuclear Power Plant i

Sampling Applications Involving Safety-Class Components and Technical Basis for Rancho Seco Sampling Plan (included in District submittal

[

dated August 18,1987, GCA 67-400).

1 P

I 5.

Cable Discrepancies / Root Cause Investigations of the Cable issues (District submittal dated November 9,1987 DTS87-103).

6.

Construction Inspection Data Reports EC-13, dated October 16, 1978 and EC-46, Rev.1, dated February 22,1980 (included in District submittal dated December 4,1987. GCA 87-780).

l 5.

ATTACfNENTS 4

1.

CRTS Action Item List (5 pages) 2.

CRTS 00R List (4 pages) l 3.

CRTS NCR List (9 pages) 4.

CRTS Action Iten Comentary (115 pages) j l

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Enclosure To GCA 88-001 3

Page 1 i

CRTS ACTION ITEM C0ffiENTARY ITEM NO. 1 l

DESCRIPTION Demonstrate that the CRTS recorded cable locations match

~

"as-built."

COMMENTARY I

1 ChRON0LO,GY i

Employee allegations and statements as early as 1983 indicated possible

{

deficiencies in the CRTS data with the possibility of both missing and inaccurate information. SHUD Nuclear Engineering Department LNEDj I

actions were pulled together into a single Action Plan in January,1987.

[

SMUD IIRG assumed responsibility for the root cause analysis of the CRTS problems and related LERs in April 1987.

In July 1986, NED authorized a contractor LImpell] to institute a review i

1 and evaluation of the CRTS program which would identify data discrepancies, evaluate and document their significance, and report to SMUD.

Approximately 43,000 manhours have been expended on this effort through 1987, and work will continue through the Cycle 8 Outage, j

j Completion of this effort is item 2 of Oe CRTS Action Item List.

t j

In early December 1966 NED made a decision to signal trace a sample of L

safety-related cables installed from 1975 through 1986.

This program is detailed in the Sample Plan LAppendix (1)).

The plan is designed to statistically insure that the overall quality level achieves at least a

[

951 coopliance with a 95% confidence level. A decision was also made not to signal trace a sample of the original 14,000 cables on the basis that j

4 the original designer / constructor Sechtel Power Corporation LBPC) had exercised an acceptable level of control.

The supporting rationale for i

tnis decision is referenced in Item 7.

By late June 1987, tne finding of ten major defects in Lot 1 initiated a complete inspection of all 39? cables.

Cable tracing was completed on December 8,1967 witn 152 completely cnecked and 245 inspected in the i

t rerouted portions.

Two additional major defects were identified as l

described in NCR S-o884, bringing the total number of Lot I defects to l

twelve. During the final checking and revision of the Sample Plan LAppendix (1)] cables deleted from the plant (af ter the populations were establishedj were deleted, from each lot, as follows:

Lot 1 Lot 2 Lot 3 Lot 4 l

l Was 422 1702 190 78 Is 397 14b2 176 78 l

I l

j j

Enclosure To GCA 88-001 ittachment 4 Page 2 IIEH NO. 1 CONTINU10_

Additionally, in Lot 2, 76 Class 2 (Appendix "R") cables and 3 Class 1 (Appendix "R"] cables were found to be pre-comercial operation vintage.

Three (3) of the 76 were included in the Lot 2 inspection total of 91.

Deleteing 79 pre-comercial cables reduces the lot 2 total to 1383.

Three more cables were traced in Lot 2 in December and were found to be correct (no defects).

Final inspection totals and statistical inferences are given in Table 1 of the comentary to CRTS Action Item 28.

Sampling of Lots 2, 3 and 4 is complete.

Appendix 1 (SHUD Calculation Z-ZZZ-E0694] has been revised to remove deleted cables and also to remove 79 pre-1975 vintage Appendix "R" cables from Lot 2. The revised (and final) totals for inspection are given in the comentary to CRTS Action Item 28.

Population Lot 4 consists of a group of 78 cables which were all sigr.sl traced.

This was done because the signal tracing uncovered seven Appendix "R" cables which were documented as rerouted from Fire Area 36 to Fire Area 31, when this had not been done, as described in LER 87-13.

I These cables were part of the group of 20 cables installed under one ECN.

This group includes the seven cables found with incorrect routes in LER 86-10. All cables in this group (28] have now been traced with the fourteen cables described having incorrectly recorded routes.

The direct and root causes of LER 86-10 and 87-13 bave been addressed by the SHUD

!!RG.

See the Itec 4 commentary.

Gf3ERIC IMPLICATIONS Hith the completion of the Sampling Plan activity SHUD has established a 95% confidence that the CRTS database is 95% accurate with respect to the location of the 2034 safe shutdown / safety-related cables installed from t

1975 through 1986.

This is viewed by SHUD as acceptable and comparable with industry norms as described in the comentary to CRTS Action Item 28.

The SHUD evaluation of the level of control exercised in installing the i

original 14,000 cables indicates a level of confidence at least equal to the 95/95 target for the 9000.

See Item 7 of the CRTS Action Item List.

New procedures and planned CRTS enhancements will be adequate to control the validity of CRTS "as-built" data.

The "completeness" issue concerning CRTS data is a separate question and is addressed in Items 10, 11,12,13 and 14 of the CRTS Action Item List.

i

+

Enclosure To GCA 88-001 attachment 4 Page 3..

ITEM NO. 1_

C0HIlhulD_.

CMSES The root cause of the problems related to the CRTS and its use is that neither Nuclear Engineering management nor the CRTS Supervisor were adequately involved in the CRTS.

Root Cause evaluations are referenced in the commentary to CRTS Action Item 4.

Corrective actions are described in the commentary to CRTS Action Item 29 and are reviewed against Root Causes in the commentary to CRTS Action Item 30.

Fron the sampling plan results the "as-built" record appears adequate.

CORRECTIVE ACTIONS The current process mandates that the installation of safety cables i

(Class 1 and Appendix "R") is witnessed by the QC inspector; this corrects a major deficiency in rest practice. A new procedure. NEAP 4127 "CableandRacewayTrackingSystem"wasissuedinJune,1987andcontrols the methods by wn ch changes are made to the CRTS database and the issuance and processing of all installation cards. Corrective actions have bee,i reviewed against the IIRG root cause evaluations (See the commentary to CRTS Action Item 30),

i I

i i

i I

Enclosure To GCA 88-001 itiachment j Pne 4 ITEM NO. 2 DESCRIPTION Resolve all CRTS database discrepancies.

COMMENTARY CHRON0LQG1

[

Since July 1986, a SHUD contractor (Impell) has been performing a review and evaluation of the CRTS data for the total population of 23,000 cables. This review has been conducted under control of the Impell QA Program and all results have been documented and submitted to SHUD for acceptance.

Progress reports have been issued, the most current of which is Report No.

25 dated October 9, 1987. The large number of discrepancies reported is not a ense for concern. Many are not real discrepancies, but are i

"bookkeeping" corrections. Still others cre caused by incorrectly

(

applying current criteria to cables which were installed to older criteria. These "discrepancies" are therefore incorrectly reported, and no discrepancy ar.tually exists.

As explained in the Action Plan, SHUD will have reviewed, evaluated and made disposition, with documentation, all Class 1 and Appendix "R" i

discrepancies prior to restart. Class 2 and Class 3 discrepancies will be dispositioned in the same manner after restart, but before the end of the l

Cycle 8 outage, g GERIC IMPLICATIONS Each discrepancy has to be evaluated separately. The evaluations may be summarized as follows.

Note that the Action Plan totals have, in some cases, changed as indicated:

Class 1. Ihm 1.0 - Intprmixing of Class 1/2/3 Cables (Tot &LIO)

None of the 763 discrepancies are valid.

The total brsaks down as r

follows:

669 Are part of the 14,000 original cables and are correctly installed.

This is because the original criteria allowed I

mixing, provided that no Class 2/3 cables "bridged" redundant Class I separation groups, i

82 Are either deleted or are routed in "special" raceways so that i

no mixing occurs.

12 Here installed post-1975 but under the original plant criteria.

All may be grouped with the 669.

1 J

Enclosure To GCA 88-001 i

.__.EAge 5 __

j ITEM NQ J CONTINUED __

Class 1 Item 2.0 - Overfilled Trays (Power and Control) Total _31 The 38 cable trays were reviewed to determine their fill at the time of commercial operation and their current ft11, with the results given below.

The 38 were checked for both ampacity derating and also for weight.

EE-553 CRTS EE-553 CRTS 10/14/75 11/7/87 10/14/75 11/7/87 Trav 1 Fill 1 Fill Trav

% Fill 1 Fill L43AZ3 44 37 M41F1 36 39 L44AK1 45 44 M41G1 34 36

)

L44AU1 41 38 M41H4 36 32 L44BF1 36 35 M41H3 42 39 j

L44BM2 17 39 M41P1 34 36 i

L44BN2 34 42 M41X1 39 39 L44BY3 47 39 M41Y1 39 39

}

L44CF1 45 44 M41Z1 31 37 1

L44P1 39 35 M43V10 47 36 L44P2 39 40 M43V11 34 34 L44V36 49 39 M44AU1 39 36 1

M398A7 40 39 M44AY1 34 36 M40AM2 36 39 M44AY4 49 44

)

M40A02 37 38 M44V10 61 53 M41AA) 30 33 M44V11 36 40 1

M41AD1 34 37 M44V70 38 36 4

M41AE1 32 34 M4581 48 40 j

M41AF) 32 34 M45V10 38 35 q

M41801 35 31 M45V8 48 31 An issue raised by the Resident NRC Inspector concerned the documentation 1

of ampacity and weight checks.

The specific question was, "Did SMUD perform 10CFR50.59 reviews of overfilled trays?" The review process for the original 14,000 cables and the later 9,000 added cables was as follows:

1 Orlainal Installation Power and control cable trays filled in excess of 40% were checked to i

verify that the cable loading was not in excess of 50 povnds per linear i

foot.

Instrumentation cable trays filled in excess of 60% were checked to l

verify that the cable loading was not in excess of 50 pounds per ilnear foot.

Instrumentation cable tray fill between 40% and 60% was accepted 4

j based upon a generic calculation.

In addition, ampacity checks were made on all power and control cable trays filled in excess of 40%. No j

documentation of the design checking has been found in Bechtel or SMUD

]

files.

Retention of such documentation was not a conmon practice. As detailed later in this commentary, all fills and weights have now been checked and documented.

}

j i

t

i l

Enclosure To GCA 68-001 i

Page e ITEM NO. 2 CONTINUED I

Cables Installed Af ter Commercial Operation Power and control cable trays filled in excess of 40% were oispositioned as described for the original installation, the cable loading was verified to be less than 50 pounds per linear foot, and the ampacity was checked.

The results were not documented by calculation, and no formal reviews were perforued to verify that weight limits were met.

Instrueentation cable trays filled in excess of 50% were checked to verify that the cable loading was not in excess of 50 pounds per linear foot.

Instrumentation I

cable tray fill between 40% and 50% was accepted based upon a generic calculation.

The results of the instrumentation cable tray weight checks l

were also not documented, and no formal 50.59 reviews were performed.

l Results I

l By July 1,1987, all cable trays and conduits had been reviewed for fill and for weight problems. Percent fill is a feature of the CRTS program.

Weight calculations were performed by a separate program run on a PC using l

i data "dumped" from the main computer.

Results are as follows:

l

(

l Instrument Tray Fill _s i

l The USAR limit is 40% versus the Nucisar Engineering design criteria which l

l has a 501 fill limit for instrument cable trays. All trays have been I

checked for weight, regardless of fill level. No trays were found to

[

l exceed the USAR limit of 50 pounds per linear foot.

Visual checks are

[

i being perfornied for "heaped" or "nounded" conditions indicating possible i

I problems during a design basis earthquake.

At this time, no significant problems have been found.

The USAR fill limit will be changed, (see CRTS i

Action item 17).

Power and Control Tray Fills t

Tne USAR limit is 40%. All trays have been checked for weight, regardless of fill level. One Class 2 cable tray is overweight by 1.10 lbs, assuming that the cables in the tray un the entire length of the tray.

However.

l because cables enter and les.J the cable tray along the length of the a

tray, in no case is the cable tray support loading in excess of 50 pounds per linear foot.

la order to resolve the apparent overweight and to allow future cable additions to the tray without naving to revise calculations justifying tne adequar,y of the caDie tray, the cable tray will be made into two cable trays by ECN R-2015, issued on Octooer 2,1987.

No other l

trays have been found with "real" fills in excess of 50 pounds per linear foot. A few additional "false" fills have been found, which are in the process of correction.

"False" fills occur when long tray sections include all cables in the weight calculations and exceed 50 pounds per linear foot, even if scue of the cables only run a short distance in l

t

Enclosure i

To GCA 88-001 i

Page 7 i

ITEM NO. 2 CONTINUED

[

l j

I the raceway section, whereas the weight borne between supports does not exceed 50 pounds per linear foot..Docuuentation is provided by Impell under Task 334.

Ampacity checks have been made on all power and control cable trays with fills in excess of 40%. No ampacity problems have been found.

Sunnary of Overfilled Tray Review No significant problems have been found to date. Final checks are

[

required to check special conditions to verify that their impact is mintual:

l i

Weight contribution from telephone / security cables.

Weight contributions from fire wrapping and cable tray covers.

1 i

The final cable tray checking, to be performed prior to restart, was performed on Decemoer 28, 1987. Only one cable tray exceeds the 50 pounds per linear foot limit (X44RF1) and this tray is acceptable, since it is at l

grade elevation and is supported Dy concrete pads, t

I Causes of Overfilled Trays No significant problems have been found, and there appears to have been a I

reasonable degree of conservatism in the original design.

Nevertheless, the lack of documented reviews in the period 1976 to 1986 is an omission l

I in the design process which should not have occurred.

The direct cause j

was a lack of procedural guidance.

Enhancements planned for the CRTS i

SOf tware will, in the future, automatically block cable aoditions which i

j exceed fill and weignt limitations, j

Class 1 Item 3.0 - Overfilled Conouits (Power / Control) (Total is 108, Was 107)

All 108 are either incorrectly recorded fills, because the "as.huilt" l

conduit is larger than recorded, or are acceptable for other reasons (very l

short length).

Quite obviously, conduits cannot easily be overfilled, unlike trays, and all 108 have documented dispositions indicating a l

complete lack of either fill or ampacity problems, i

I Class 1 Item 4.0 - Overfilled Condatts (Instrunents) (Total is 14, Was 13)

{

l i

All 14 are dispositioned as false fills or similar. No ampacity problems I

exist with instrument cables.

Class 1. Item S.0 - Raceway Connections (Total is 293, Was 200)

Tne CRTS program established "linkages" or "nodes" to check that i

l connecting raceways in caole vias aid, in fact, connect. When noces were i

l missed by designers making the drawing changes, each missed node generated a discrepancy report for each cable using tne via. All missing noces htye l

been cnecked and the "bookkeeping" errors corrected.

Enclosure l

To GCA 88-001 1

Page 8 l

ITEM NO. 2 l

CONTINUED l

[

l Class 1. Item 6.0 - Duplicated Numbers (Total is 2 Was 35) 1 These are two "bookkeeping" errors, both of whicn have been dispositioned as having no significance.

l l

Class 1, Item 7.0 - Document Discrepancies (Total is 555, Was Sbli f

i l

The 555 are a miscellany of minor data discrepancies dealing with entries q

covering equipment numbers, raceway numbers, caDie codes, cable data (conductor size / number) and others. All have been checked and the data l

1 corrected as needed. No data questions remain open.

(

Class 1, Item 8.0 - Tagging / Identification Discrepancy (Total is 0. Was 7) l The original seven items are now reported in the Item 5.0 totals.

i t

Class 1, Item 9.0 - Missing / Unsigned Construction Cards (Total is 174, Was 4

53) 1)

I j

The total of 174 missing / unsigned Class 1 cards is made up [Ref. Impell j

Calculation 271-101-107) as follows:

[

t i

hCR #

1. of cards problem Status i

5-/533 41 Class 1 raceway cards w/o sig

~Open 1

S-6549 26 Class 1 pull cards w/o sig Work Request w/Elec Maint j

3 1

i S-6547 15 Class 1 term cards w/o sig Closed 1

11-27-87 j

S-6459 59 Class 1 raceway cards w/o sig Open 28 Resolved in calc 271-101-107 Closeo l

04-15-87 5

Terminations included in error N/A i

)

in calculation 271-101-107 l

t t

Total UT I

i The 125 open itens are milestoned for complettor prior to Restart.

Tne i

nicrofilming process (, described on page 11 of Attachment 4) is largely I

complete with aDout 8000 cards lef t to microfilm. The work nas, so far, l

found approximately 100 cards which are missing signatures.

Of these.

thirteen L13; are Class 1 and are listed on an NCR for disposition prior i

i to restart.

l i

i i

i l

i Enclosure To GCA 88-001 l

l Page_9 _

t ITEM NO. 2 CONTINUED-4 i

.I The following Non-Class I discrepancies have all been dispositioned j

without finding any safety problems.

Mon-Class 1. Item 1.0 -_ Intermixing of Power / Control /Instrustat Cables i

2 (Total is 400 Was 125)_

The USAR wording requires separation of instrument cables from power and i

i control cables for RPS and ESFAS. USAR does not clearly address mixing for other systems and does not address or define what constitutes j

l instrument, control, and power cables.

t a

i SMUD Nuclear Engineering Procedures (NEP's, Criteria and Guides) also did t

i not clearly define instrument, control, and power cables. However, I

various types of signals (analog, digital) were discussed, and digital 1

]

signal cables permitted to mix with control cables.

}

The NEP's have been revised to define the separation required between instrument and power and/or control cables and to define the instrument t

circuits requiring separation. Details are given in the commentary in l

i CRTS Action Item 9.

J i

j The 400 reported Non-Class 1 mixes have been dispositioned as follows:

l l

367 Accepted as meeting NEP's.

1 i

i 16 To be rerouted.

17 Nhich require drawing changes to clarify service level, i

j 400 Total J

t

)

The original design process used twisted shleIded pair (TSF) or coax /trian l

cables for all circuits considered as instrumentation.

This has led to some confusion, since no cable service levels are established th CRTS. A future CRTS enhancement will identify service levels for all cables.

i i

Mon-Class L Item 2.0 - Overfilled Trays (Power and Control) (Tott]_h i

153 Was 131) 3 i

All trays have been checked for weight. Only one tray exceeded the l

50 pounds per linear foot USAR limit, as discussed previously. Ampacity checks have been made on all cable trays with fills over 40%. No ampacity 1

problems have been found, j

j Non-Class 1. Item 3.0 - Overfilled Trays _(Instrument) (Total is 18. Was 191 All trays have been checked for weight. None exceed the 50 pounds per l

linear foot US4R limit.

[

i l

Enclosure To GCA 88-001 Page 10 ITEM NQJ CONTINUIR.

Non-C111s 1. Item 4.0_ Overfilled CondulLEQ1tr_And_ControlLLIQ11Lil 644. HAL6311 All 644 are either incorrectly recorded, because the "as-built" conduit is larger than recorded in CRTS, or are acceptable for other reasons. No ampacity problems exist.

Etiolution of Minor CRTS DAla Discitgancies A number of minor Non-Class 1 data discrepancies exist as reported in Impe11 Status Report 9, dated January 12, 1987.

These are summarized below.

None have any safety significance.

These data discrepancies will be resolved after restart but not later than the Cycle 8 scheduled outage.

Non-Clas1_1 1.0 Overfilled Conduits (Instrument / Telephone) 151 2.0 Raceway Connections 1390 3.0 Duplicated Numbers 33 4.0 Document Discrepancy 15'J4 5.0 Tagging / Identification Discrepancy 130 6.0 Hissing / Unsigned Construction Cards

.__92 Subtotal 3390 Sicurity 7.0 Raceway Connections 177 8.0 Duplicated Numbers 29 9.0 Documentation Discrepancy 276 10.0 Tagging /!dentification Discrepancy 4

11.0 Hissing / Unsigned Construction Cards

__88 Total 3964 Cluies_of D1screpintita The enhanceM nt of the CRTS software penerated the list of discrepancies.

The direct cause of the discrepancies was the database conversion and errors entered into the database in the 1980 to 1982 timeframe. The root cause of the CRTS problems has been dttermined by the IIRG.

The level of control exercised is addressed in Item 4 of the CRTS Action Item List.

CORRICTIVE ACTIONS Hajor (safety-related) discrepancies will be reviewed and dispositioned, with documentation, prior to restart. Hinor (non-safety-related) discrepancies will be reviewed and dispositioned, with documentation, prior to the end of the Cycle 8 outage.

Disposition of each discrepancy will include verification that plant design documents, the CRTS database and the "as-built" plant configuration are all in agreement.

ko k M 001 Page 11 ITEM NO. 3 DESCRIPTION Define SHUD cocument of record controlling cable location.

COMMT.NTARY CHRONOLOGY In a January 7,1987 meeting, the Region V Electrical Inspector LMr. Anoy Honj asked where caole pull cards are now kept and what will be done with cable pull cards in the future. To answer the question concerning SMUD a

future actions required defining the SMUD document of record for cable locations. Answers to the two original questions nnd the additional definitions are as follows:

1.

NRC Question:

Where are cable pull cards now kept (January, 1967j?

District Response: The cable pull cards, together with equipment and q

raceway installation cards, were kept in either locked metal card files in an office area of the "Bechtel Butiding " which is a temporary on site construction of fice, or in boxes in trailers used as temporary offices, 2.

NRC Question:

knat will be done with cable pull cards in the future ( Af ter January,1987)?

District Response: The cable and raceway installation cards are now being kept in a "vault" in the "Bechtel Builoing." Tne record documents are a mixture of original cards and facsimiles when the originals cannot be found.

The vault is a secure, locked room with cement walls and a Halon fire protection system.

At tnis time, records are being checked to see how many cards are uissing.

When original cards are not found, f acsiniles froa the construction records will be substituted to create a complete recoro.

A cuplicate record is being created on microfila.

As of December 31, 1987 approxiuately

]

29,000 cards have been microffimed and returned to the Becntel Building vault. Inis process will continue until a couplete duplicate ret.ord is established.

l l

s F0 closure 7 TdGCAfp(01 Attichment 4 Page 12

'7 m

ITEM NO. 3 CONTINUEu 1

?

Additional Informeil0D 1.

INSTALLATION VERIFICATION RECORQS_EQR INSTALLED CABLE ANJLk CEHAY

't i

The present Installation Verification Records for installeOcable and raceway are the "pull cards," "termination, cards," and "raceway installation" cards, respectively. As of Hovember 30, 1987, 183 Class 1 cable pull cards (originals or facsimiles) have not yet been located.

Full details of missing cards (all lypes) are given in Section 4 of this commentary.

2.

ENGINEERING RECORDS FOR DESIGNED CABLE AND RACEWAY, These records I.re the input documents to the CRTS program.

They are designated as "forms" and are engineering drawings by SMUD definition s Originally, new forms were issued for changes. As of June 15, 1987, 5

all new cable and raceway input documents have been handled as Drawing Change Notices. Originals of input documents e s being marked to show changes instead of issuing new forms. '(keference memo EEGS87-005, frota E. J. Gough to the Electrical EnginPhrivJ staff, s

dated May 1, 1987)

CRTS input drawings / forms are as follows':

E-1008 Raceway Input Document E-1010 Scheme Cabin Input Document E-1026 Raceway Code Input Cocument E-1027 Cable Code Input Document E-1028 Electrical Equipment Input Doctment 5

I 3.

CRTS PROGRAM AND DATA BASE The function of the CRTS program and database is twofold:

a.

An engineering design tool which is insed by the design group to perform design checks and calculations. Currently, the CRTS program checks for:

Raceway continuity Percentage fill Mixing of redundant separation channels Verifies raceway service levels for compatibility The CRTS is being enhanced to perform:

Height calculations i

l Checks on mixing of instrument cables with power and control cables

Enclosure To GCA 88-001 i

(' 3 s

s s Pace 13 1

IIEH NO. 3 i

CONTINUED b.

A convenient data source which is used for engineering design information.

Typical uses of the CRTS generated information are; Identification of cable routes T

' Calculation of totals of combustible materials (8tu totals)

\\

Height calculations for cable tray sections

s c.

Installation Status.

GENERIC ItLPJ,ICATIONS Plant cables provide many diverse functions.

The cables of safety systems iirovide both power supply and control functions, as well as important indications to operators.

The control and separation of redundant safety

' ' groSps of cables and of all cables required for safe shutdown are important safety factors. The existence of reliable and accurate records concerning the location of the cables is essential to plant safety.

With the completion of the Action Plan, SHUD will have established a record file of insta.11ation cards (originals and facsimlies) and a duplicate microfilm record.

SHUD will also have confirmed that the CRTS database is accurate to an acceptable confidence level.

E Hith ad?quate maintenance of both records and CRTS data, the necessary level af control will exist.

Diffic Ities in tracing records indicate a need for greater management interest in record storage and an increased awareness on the part of SHUD ypiclyees of the importance of records, i.

10 ERECTIVE ACTIONS Replacement Cards:

The detailed procedure for the replacement of missing G{TS cards was provided in Revision 1 to NEAP 4127, issued effective December 14, 1987.

Current Process: A new procedure (NEAP 4127) was issued in June, 1987.

This procedure is considered adequate to ensure that all cards are returned to CRTS.

4.

LQLALj!UMBEFLOF HISSIf!G_CA_@S The following are details of missing cards as of November 30, 1987:

Enclosure To GCA 88 001 Paae 14 i

ITEM NO. 3 CONTINUED L

Cable Raceway Tracking System (CRTS)

. ANALYSIS OF 2,480 MISSING CABLE CONSTRUCTION CAROS November 30, 1987 t

Nuclear (1)

Nucicar(2)

Both(3)

(4)

.0ceration Engineering DRDtS.

Pre _ECN Total Missing Cards 1184 - 48%

1057 - 43%

51 - 2%

188 -

7%

' Pull' Cards 181 - 7%

239 - 10%

23 - 1%

14 - 0.4%

'From' Termination Cards 488 - 20%

230 _ 9%

14 -0.5%

23 -

1%

'To' Termination Cards 453 - 18%

278 - 11%

14 -0.5%

23 -

1%

_' Delete'_ Cards 62 - 3%

310 - 13%

0-0%

128 - 5%

i Total Cables in Data Base (CRTS Revision Level 1608) 22,826

\\

Total Cables Having Hissing Cards 1,472 Fraction of Cables Having Missing Cards 6.45%

l Total Hissing ' Pull' Cards 457 -

18%

• i Total Missing ' Termination' Cards 1523 _ 61%

l Total Hissing 500 - 20%

i

_______________' Delete'_ Cards l

Total Missing Cable Cards 2,480 - 100%

[

I (1) Nuclear Operations (NO) initiated ECN.

l (2) Nuclear Engineering (NE) initiated ECN.

(3) N0/NE jointly initiated ECN.

(4) Proposed cables entered 1976-1980, no ECN.

l Hissing Class 1 ' Pull' Cards 183 (7% of all missing cards)

{

Enclosure To GCA 88-001 Page 15 ITEM NO. 4 DESCRIPTION Document the level of control exercised by SHUD in installing cable 1975-86.

CHRONOLOGY Questions concerning the completeness of CRTS data, missing installation cards, and conflicting procedures have been raised beginning in 1983.

The existence in 1978 of Quality Control Instruction QCI 107, which required the destruction of installation cards, raised questions concerning records.

Employee allegations and statements to the SHUD Ombudsman also tended to indicate some possible problems in controlling the installation process.

LER 86-10 identified seven Appendix "R" cables which should have been relocated but were not.

The SHUD IIRG has completed their investigations and forwarded a summary of their Root Cause Reports in DTS87-103 dated November 9, 1987.

CRTS ACTIOS DESCRIPTION FORECAST 11 8 23 Determination of tne cause of the redundant Complete

\\ cabling in same fire area (LER 86-10) and the determination of the cause of redundant instrument cables routed through same

}

fire area (LER 87-13).

25 Document a thorough engineering Complete evaluation of the procedures and specifications used to install cable in the period 1975-1986.

26 Description of the events and LER 85-16 Complete circumstances leading to the LER 86-10 Complete misrouting of cable described in LER 87-13 Complete LER's.

LER 87-26 Complete 27 Description of the events e.nd Complets circumstances leading to the discrepancies discovered between the "as-built" cable routes and the routes recorded in CRTS.

Refer to Appendix 5 for a summary of the Root cause investigations.

Enclosure To GCA 88-001 Page 16 ITEM NO. 5 DESCRIPTION Demonstrate that no Bechtel generic design problem existed.

COMMENTARY CHRON0 LOGY Hith the discovery of a misrouted RCS pressure transmitter instrument cable as being a possible cause of the August and December 1985 spurious closures of the Decay Heat System (OHS) valve HV-20002 (LER 85-16), and the further identification that the misrouting of the instrument circuit occurred during the original design of the plant, investigation of the original cable population was begun for any evidence of a generic design problem.

GENERIC IMPLICATIONS Ine original Rancho Seco cable population consisted of nearly 14,000 cables, routed in 13,000 raceways.

The original Rancho Seco EE-553 circuit and raceway schedules were reviewed for any evidence of a generic

[

design problem in the original cable population.

Since the present CRTS database has been reviewed for raceway fills and weights, channel separation and channel "bridging," and would have identified any such problems in the original cable population, only intermixing of power, control, and instrumentation cables was examined in the original cable W

population.

The EE-553 raceny schedules were reviewed for any indication of a generic problem concerning power / control / instrumentation intermixing.

Approximately 3260 pages were manually reviewed, representing approximately 13,000 raceways. Approximately 10 cases of Class 1 intermixing were identified and approximately 60 cases of Non-Class 1 inte'? mixing were identified (Table 1), with no evidence of a generic intermixing problem.

It should be noted that of the 10 Class I cable intermixes, that 8 no longer exist in the plant.

The remaining 2 cables provide tachometer indication signals to local panels of the Bruce GH Diesels (Reference Drawings E204 sheet 65 and E334 Sheets 1, 4 and 51 and have no safety features actuation or reactor protection function.

The Class 2 Appendix "R" cables listed in Table I have been reviewed. On the basis of this review, the Class 2 control cables 1H2C327I, 1H202280 and 1H202290 are the only Appendix "R" circuits.

These cables are routed in a four-foot-long, Non-Class 1 instrumentation tray X45V20 to test panel H3TP.

Enclosure To GCA 88-001 Page 17 ITEM NO. 5 CONTINUED The distance [4 feet) and the shielding on the low level instrumentation cables indicate no unacceptable cross-couplig [ noise) is possible to the control cables.

The converse is also true and the Class 2 shielded instrument circuits will not see unacceptable noise levels.

Therefore, the above cables can remain as routed and no corrective action is a

required.

The remaining Non-Class I cables will be reviewed by the end of the Cycle 8 outage.

CAQS15 Both the FSAR and USAR require separate cable tray, conduit, and penetration systems for 600-volt power and control cables and for instrumentation cables. The cable scheme numbering system used at Rancho Seco requires a "1" in the first location of the cable scheme number to designate Rancho Seco Unit 1.

A digit in the se.ond location of the cable scheme number designates a power cable; a letter in the second location of the cable scheme number designates either a control cable or an instrumentatioh cable. Hithout a method to differentiate the scheme cable number of a control cable from that of an instrumentation cable, intermixing may have occurred.

\\

CORRECTIVE ACTION 2

Upon the consolidation of SHUD efforts to resolve Rancho Seco wire and cable problems (Action Plan, JEH-478, April 3, 1987), Bechtel was asked to review the 1975 cable and raceway schedules for any evidence of a widespread problem concerning the intermixing of power, control, and instrumentation cables.

The intermixing of instrumentation cables in power and control raceways was identified by examining the 1975 EE-553 raceway schedules for any shielded cabics in power and control raceways.

In order to identify the power and contr,.,1 cables intermixed with instrumentation cables in instrumentation raceways, the 1975 EE-553 raceway schedule was examined for non-shielded cables in instrumentation raceways.

The results are given in Table 1.

d In order to prevent any further occurrences of power, control, and 3

instrumentation intermixing, SHUD has directed, by memo, that an additional column be added to the "1010" drawings and OCNs to indicate the service level of the cable being added.

For each added cable, the new column will indicate either "P", "C", or "I"

for power, control or instrumentation service, providing the physical designer with the necessary information to properly route newly added cable.

[ Reference memo EEGS87-005, from E. J. Gough to the Electrical Engineering staff.

l dated May 4, 1987.] Additional service level designators are under consideration and include "T" (Telephone),

"S" [ Security] and "IE" l

[ Instrumentation - Exempt - may mix with P and/or C cables).

Enclosure To GCA 88-001

___Eage 18 JTEM NO. 5 CONTINQLQ_

Table 1 Oriainal Cable Pooulation Power / Control / Instrumentation Iatermixing Class 1 Intermixing Power Cable in Instrumentation Raceway None Control Cable in Instrumentation Raceway 1HIA131D

• 1H1A131E

• 1H181390

• 1H18139E

• Instrumentation Cable in Power and Control Raceway 1G10886CS S

1G1088605 1RIC260AA

• 1RIC260AB

• 1RIC260BA

• 1RIL26088

• Non-Class 1_Irtermixina Power Cable in Initr_yttentition Raceway 112E07A 112GSIGC 112SDPS6A

• 112E11D 112GSIGF 112SDPS1B

• 112E11E 112GSIGG 112SDPS2B

• 112E09CN 112J11EA 112SDPS3B

• 112E09C0 112SDPSIA

• 112SDPS4B

• r 112E0901

• 112SDPS2A

• 112SDPS58 112F15Z 112SDPS3A

• 112SDPS6B

• 112GSIGA

• 112SDPS4A

• 11202308 112GSIGB

• 112SDPS5A

• 113C109A

• Cable deleted, no longer installed in plant

Enclosure To GCA 88-001 Page 19 1TEH NO. 5 CONTINUEQ_

Table 1 (cont.)

Control Cable in Instrumentation Racew3y 1A3A26503 II28360CA 1H2C327I 1A38470A1 II28360T 1H202028

• 1A38470A2 II28365CA IH20224I 1A38470A4 II28365X IH20228D 1A3P20082 II2G996D 1H202290 1A3P20086 II2N150LF 1H2E203B

• 1A3X5208 1A3X520H Instrumentation Cable in Power and Control Raceway II2G201 II2R3018 1R2I4608 II2G202 112R520AB 1R2PBTPA II2G203 II2R520AF 1R2T250A II2G204 II2R520AJ II2G417 i

II2R532AB

• Cable deleted, no longer installed in plant

Enclosure To GCA 82-001 t

i Page 20 s

ITEM NO. 6 i

DESCRIPTION Resolve overfill / overweight questions; including USAR and 50.59.

COMMENTARY I

CHRONOLOGY In February 1986, 00R 86-125 was prepared as a result of an investigation following allegations of raceway overfilling.

The 00R examined instrument l

cable tray overfilling, because instrument trays are filled to a higher level than power and control trays, and determined that for the cable tray with the highest fill, that the cable loading did not exceed 50 pounds per linear foot.

In addition, it was verified that the actual cable tray loading was used in the fire hazard analysis and also that the cable tray heat derating was acceptable with respect to the cable ampacity. As a i

result of the above investigation, 38 Class 1 overfilled trays and 150 Non-Class I overfilled trays were identified and subsequently reviewed for overweight, as described in the commentary to CRTS Action Item 2.

t 00R 87-204 was initiated in February 1987 as a result of concerns that cable trays with fills less than 40% might, in certain unique circumstances, exceed the cable loading of 50 pounds per linear foot.

LER i

87-24 was also initiated to determine the reportability of the identified problem.

GENERIC IMPLICATION 3 t

The Rancho Seco USAR limits the fill of redundant cable trays to 40%, so I

as not to exceed the cable loading of 50 pounds per linear foot used in the cable tray support design. Cable trays do exist whose fill exceeds 40% and were dispositioned during the original design process.

Power and control cable trays filled in excess of 40% were checked to verify that i

the cable loading was not in excess of 50 pounds per linear foot.

In addition, an ampacity check was performed.

Instrumentation cable trays e

filled in excess of 60% were checked to verify that the cable loading was not in excess of 50 pounds per linear foot. Cable tray fill between 40%

and 60% was accepted based upon a generic calculation. Although the above calculations were performed during the original design process, the I

calculations have not been found.

j i

To GCA 68-001 Page d ITEll N0. 6 CONTIWUED Power and control cable trays filleo in excess of 40% after comercial operation were dispositioneo as cescriced for tne original instaliation.

For instrumentation cable trays filled in excess of 50%, the cable loading was verified not to exceed 50 pounds per linear foot.

The results of the we1 nt cnecks perfonaed af ter cort.iercial operation were not accumented, 9

and no fonnal 50.53 reviews were perfonned.

As of May 1987, all cable trays e. ave oeen reviewed for fill and n.eignt problems, with only one Class e power ana control caule troy requiring physical uodification as oescribed in the cor.nentary to CkTS Action Item 2.

Tne USAR limit is 40% for power' and control tray fills.

All trays have oeen cnecked for weight (regaroless of fill level).

Only one tray has been round with an "apparent" fill in excess of 50 pounds per linear foot requiring physical i udification.

"False" fills nave been found where a long tray section includes all cables in the weight calculations (and exceea 50 lbs), whereas the weight borne between supports doec not exceed 00 los.

Ampacity checks have been made on all power and control cable trays with fills in excess of 467.

No ampacity problems have been found.

Tne USAR limit is 40% for instrument tray fills ana is at variance with the huclear Engineering criteria which has a 505 fill liuit for instrument cable trays.

All trays have been checked for weight (regardless of fill level). No instrumentation trays were found to exceed the USAR limit of 50 pounds per linear foot.

Visual check; are being performed for "heaped" or "nounded" conditions indicating possible problems during a design basis M

earthquake.

At tilis time, no significant problems have ocen found.

The USAR woroing will be revised, Lsce coimientat/ to CRTS Action Itam 17), and toe fill limits will oe cefineo in the NEP's.

In sumary, no significant prooiens nave been founo to date.

Final checks on weignt contributions f rou telephone / security caules and weight contributions f ron) fire wrapping are required to verify that their inpact is uiniaal.

m

Frank J. Miraglia, Jr. GCA 88-001 JAf; 2 : l'.53 oc w/atch:

General Manager flS 41 Chief Executive Officer, Nuclear MS 209 (2)*

Executive Assistant MS 209 Director, Nuclear Quality MS 271 tlandger, Nuclear Training MS 296 Manager, fluclear Liceitsing MS 286 Hanager, liuclear Engineering MS 208-6 Public Infortisation MS 204 Mdnager, Maintenance its 264 ilanager, Operations MS ?SS llanoger, Nuclear Cheuistry liS 244 Ndnager, Plant Perfonaance its 258 IIRG MS 298 NAC (6)

MS 209 Fourth Floor Files MS 43 Licensing Files kS 266 PRC Files MS 286 klC Files ks 224 1

NOV/lk00 Files MS 286

• 1 w/ enclosure + 1 w/o enc 103ure

\\

t

Enclosure To GCA 66-001 Attachuent 4 Page 22 ITER IJ0. 6 CONTIliUED CAUSES As evidenced by tne discovery of only one "apparent" problem concerning overfilled cable trays, the original 40% fill limit was a very conservative requirement in the original plant design.

However, tne aosence of documented 50.59 reviews for those cable trays whose fill was exceeded Lpost-commercial operation) is a cause for concern.

The direct cause of botn overfill and overweignt conditions lacking the documentation validating their acceptability was a lack of procedural guidance.

CORRECTIVE ACTI0l1 Immediate corrective action nos been to review all cable tray weights regardless of fill level Lsee corrr.1entary on CRTS Action Item 2).

Additionallj, for new design work Ladoed cables], all power and control trays which exceed 40% fill are c;1ecked for weight and ampacity; all instrument trays whose fill exceeds 50% fill are checked for weight.

tJEAP 4127 requires all DCris wnich generate error reports Le.g. caule tray fills above 40t3 to be referred back to IJE0 for review and documented analysis, in addition, tne 50.b5 review concern will be resolved tnrough the idCR process, with a forecast cxpletion date of January 6,1986.

Until the CRTS sof tware is enhanced to proviue automatic "blocking" of g

cable acuitions to specific raceways, tnose trays which require "blocking" dre Controlled by a list of Controlled trays issueu in an ERPT ano referenced in lludifications Procedure / Inspection Stdndard 11P/IS 307 and Electrical Design Criteria E51U4.2 LReference EEGS 88-Ou2 dated January 6, 1968;.

Issues to oe resolved post-restart, out Octore the end of the Cycle 8 outage art. as follows:

Resolve the concern of security ano connunication cables LClass 2 and 3; on raceway fill and weignt.

Resolve tne concern of firewropped cooles on raceway fill and weignt.

Resolve toe concern of coiled cables, not connected to equipment, on raceway weight.

Resolve tne concern of cable troy cover, on cable troy weight.

Enclosure To GCA 88-001 Page 23 ITEM NO. 7 QESCRIPTION Justification for not sampling the original cable population.

COMMENTARY CHRONOLOGY L

As a result of employee allegations as far back as 1983, and with the June 1986 identification of seven misrouted Appendix "R" cables, a decision was made in December 1986 to signal trace a sample of safety-related cables installed after commercial operation in 1975.

The original cable population of 14,000 cables was excluded from the sampling plan because the design, installation and inspection of the original cable population by Bechtel Power Corporation, Rancho Seco A & E and Constructor was governed by a quality program sufficient to control the physical design and installation of the original cable population.

SUMMARY

Justification for excluding the original cable population was presented by SHUD during the June 1987 NRC inspection visit in the form of a report.

The report, titled "Justification for Not Sampling The Original Rancho See,o Cable Populatio,n," was formally transmitted by GCA 87-338, dated i

July 24, 1987.

The report osmonstrates that Bechtel had in place and used a rigorous quality program sufficient to control the physical design of 3

the original cable population.

In contrast to those cables installed after commercial operation, the original cable population was installed while the plant was in a construction mode, under a uniformly consistent set of rules and procedures.

The procedures did not vary during the design, installation, and inspection of the original cable population, and as shown, in Appendix 3, these procedures were rigorously followed by a relatively stable and well-trained workforce.

The justification for not sampling the original cable population was transmitted by GCA 87-338, dated July 24, 1987, and is Appendix 3 to the Hire and Cable Program t

Report.

L i

.~

Enclosure To GCA 88-001 Paae 24 ITEM NO. 8 l

l DESCRIPTION Resolve all known physical problems.

f COMMENTARY CHRONOLOGY I

l Physical problems related to the Rancho Seco cable and raceway

[

installation have been identified by LERs 85-16, 86-10, 87-13, 87-24 and 87-26.

In addition, Impell, under Task 271, has identified, with documentation submitted to SMUD, additional CRTS database discrepancies, although not all are physical problems (See comentary to CRTS Action Item L

2).

The identified physical problems are of the following types:

Overfilled /0verweiaht Cable Trays (LER 87-24),

i Refer to comentaries to CRTS Action Items 2 and 6 for discussion.

Intermixina of Power / Control / Instrumentation Cables (LER 85-16 and 87-26)

Refer to commentaries to CRTS Action Items 2, 5 and 9 for discussion.

\\

Lack of Confiauration Control (LER 86-10 and 8'l-131 i

t 3

Refer to commentaries to CRTS Action Items 1, 4 and 23 for discussion.

l L RhJ f Redundant Class 1 Channel Seoaration l

No identified problems of this type have been found to date.

l Lack of Class 1/Non-Class 1 Separation i

As described in the comentary to CRTS Action Item 2, none of the 763 l

intermixes of Class 1, 2, and 3 cables are valid discrepancies.

The cables were either installed under the original plant criteria, which allowed mixing, or are deleted or routed in "special" raceways so l

that no mixing occurs, f

CAUSIS Refer to comentary to CRTS Action Item 15, i

l

b N k" $ -001 Page 26 ITEll NO. 8 CONTINULT CORKECTIVE ACTIONS Tne following currective actions nave been ta(en to resolve known Rancho Seco cable and raceway physical problems, and to prevent their recurrence:

Overfilled /0verweight Cable Trays Innediate corrective action taken as a result of ODR 86-125 and LER 67-24 was tne review of all cable tray weights, regardless of fill level.

As a result of the cable tray weight review, one Class 2 power and control esble tray was found to De overweight. ECN R-2015 will ue issued in October to divide the tray into two trays to resolve the apparent overweight.

Corrective action to prevent recurrence has been the revision of procedure HEAP 4127, "Cable Raceway Tracking System," to require that data cantained in DCNs to CRTS-related drawings be "error free" when input to the oroposed CRTS database. Should an error report indicate an overfill condition, toen the DCN is returned to the originator for resol u ti on.

In addition, the USAR will be revised to reconcile discrepancies in fill liuits for instrumentation cable trays to be consistent with'NEP 5204.22, LSee cormtentary to CRTS Action Item 17).

1 Intermixing of Power / Control / Instrumentation Caoles Irnoediate corrective action taken as a result of the identification of an SFAS instrument caDie routed through power and control edceways in LER 85-16 was tne review of tne CRTS database for further interuixing tsee comentary to CRTS Action Iteas 2 and 9J.

ds Well as tne exaHination of tne original Cable population for a generic intermixing proviem tsee comentar/ to CRTS Action Item 5;.

The intermixing identified by LER 85-10 has been corrected b/ ECNs R-u45s and R-1295.

Furtner interuixing nas ocen identified by CRTS dotsbase reviews, as icentified in LER 67-20, and by caole signal tracing as identified by 0DRs 67-oV4 and 67-723 and are corrected by ECNs R-1765 and R-1/86.

Sixteen Non-Class 1 intermixes t equiring relocation were toentifieo oy Iopell as aucumenteo D/ CPRs CPk-Obil, 010, 865, 638, 640, u22, 642, and C0ks C0h-SU4 and 742 contained in lopell Calculation No. 271 -101 -109, Rev. 6.

Tne hon-Class 1 intaruixes wili ce documented by NCR and will oe resolved prior to tne end vf tne cycic U outage.

Corrective action to prevent recurrence of power / control / instrumentation cable interaixing nas been the revision of Design Guides NtPH *>204.12 "Cable Systeu

~

Design, General," and hEPM 5204.43, "Instrunentation Systens

$hmloing ano Grounaing and Surge Protection," to clearly define tne

Enclusure To GCA 88-001 Page 26 1TEll NO. 8 C0t4TIi4ULD l

i physical separation requirements for power, control, and instrumentation circuits and to provide definitions of the cable service levels LSee coumentary to CRTS Action Item 9).

In addition, the USAR will be revised to remove any ambiguity as to the dppliCaoility of intermix 1ng restrictions to RPS and SFAS in USAR section 8.2.2.11.H tsee comentary to CRTS Action Itern 17).

Lack of Configuration Control Itaaediate corrective action taken, as a result of the identification of the cable inisroutes in LER 86-10, was to initiate the Rancho Seco cable sampling to establish a level of confidence in the cable installation. The LER 86-10 cable misroutes were corcected by ECN R-0705, whicn is construction complete.

The additional cablo nisroutes identified during the cable sampling activities and docuuented by LER 87-13 were rerouted by work request.

Corrective action taken to prevent the recurrence of cable misroutings has oeen to revise the Modification Procedure / Inspection Standard HP/IS 307, "Cable Installation," to require the use of design drawings 4of the latest revision when installing cable, and the requirement that tne cable routing inforaation on the E-1010 series drawing match that on tne applicable cable installation g'

card.

Witnessing requirements for caolo pulls have also been clarified in llP/IS 307 to require that caole installation verification shall consist of witnessing the installation of the caole.

Lack of Class 1/Non-Llass i Separ ation No corrective action necessary, as nsne of the 703 intermixes of Class 1, 2 ano 3 cooles or e valid uiscrepancies.

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Enclosure To GCA 88-001 Attachmant 4 Pa.ge 27 LTEM NO. 9 atifflp.tj_On Resolve power / control / instrument cable mixing concerns.

Com_mentarY ChLQAQ109y LER 85-16 Rev. O was the first documented evidence that instrument cables had been miFed With power and/or control cables at Rancho Seco.

Since i

this discovery, additional "mixing" has been found and details are provided in the commentaries to CRTS Action Items 2 (partial) and 5.

l Geric Implicat1001 The concern is the avoidance of unacceptable noise levels caused by cross-coupling between adjacent conductors in instrument circuits.

The level of,1oise is a concern for analog circuits and seine digital circuits.

Na concern attaches to cable insulation levels since all power, control, and iristrumer.t cables have 600 volt insulation ratings and additional protection in the form of a protective outer jacket.

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The ability of a circuit to tolerate noise is a function of the coulpment connected to it.

The type of equi,ynent and the provision of noise i

3 "filtering" components both play a part.

The original desigt, approach at Rancho Seco was typical of plants of similar vintage.

The raceway design for the original 14,000 cables provided two service levels for 600 volt class cables (NEPH 5103 Section 5.4.5.11 (1.b) 480 Volt (and below) power, DC and control and (1.c) instrumentation. No explicit definitions existed for either power, control, or instrument circuits.

Service levels were indicated for raceways as follows:

For Class 1 power and control raceway, the raceway designator begins with either the letter L. H, P or H for Channel A, B, C, or 0, respectively.

For Non-Class 1 power and control raceway, the raceway designator begins with the numeral 7.

For Class 1 instrumentation raceway, the raceway designator begins with either the letter A, B, C or 0 for Channel A, 8, C or D, respectively.

Foc Hon-Class 1 instrumentation raceway, the raceway designator begins with the letter X.

Enclosure To GCA 88-001 Page 28 JJEH N0. 9 CONTINUE 0-Conduit is differentiated from cable tray by having all digits after the first letter or number; cable tray is identified by having both letters and numbers after the first letter or number raceway designator.

For example:

L27AFI - Channel A Power and Control Cable Tray 4

M47223 - Channel B Power and Control Conduit 7278A1 - Non-Class 1 Power and Control Cable Tray 732007 - Non-Class 1 Power and Control Conduit A32AB2 - Channel A Instrumentation Cable Tray 2

044301 - Channel 0 Instrumentation Conduit X44A03 - Non. Class 1 Instrumentation Cable Tray j

X56032 - Non-Class 1 Instrumentation Conduit Scheme cable numbers did not indicate the service level (P. C or I] for cables; however, a standard practice was used which identified all 600 3

volt shielded cables (twisted shielded pairs, coax, triax, etc.) as instrument cables, This practice allowed 1Atitude to the designers in classifying circuits as "instrument" when the circuits were shielded.

For example, with this approach, low amperage (0.5 amp) 120 Volt power S

supplies could be installed using shielded, twisted pair cable and run with signal cat)les. When a field component (e.g., flow transmitter) was provided with only one entry (conduit hub) this was an obvious practical approach, meeting the equipment supplier's intent.

For safety circuits, an unacceptable noise level is a plant safety issue.

For this reason, the USAR wording requires sep5 ration of instrument cable from power and control cables for RPS and SFAS, while not explicitly addressing other systems, In practice, the design intent has always been to maintain the same separation for all systems.

Design Guides written in 1984 and later have attempted to provide more explicit direction with the result that the design intent for the original 14,000 cables and cables installed later has become blurred.

Cuni The direct cause for each identified problem (CRTS Action Items 2 (partial), and 5) will be addressed in each individual commentary.

Not all identified problems are, upon examination, real problems. A major cause of both real and incorrectly identified "mix" problems is an inadequate definition of design intent in both USAR and design documents.

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Enclosure To GCA 68-001 Attach 1ent 4 Page 29 ITEM NO. 9 ColdT INUED~

A description of tne events and circumstatices leading to the discrepancies identified in LER 87-26 has been prepared by IING LSee t

Appendix 5;.

Corrective Actions - Physical Rework Tne physical reworking of caoles occause of raix probleas is identified in the following:

Hanholes.

Underground raannoles are concrete structures, below grade, wnich serve to provide convenient pulling areas for cables run in undergrcund duct. Hanholes are used to "carshal" i.e. redirect cable.

Mix probleus in manholes were investigated by a SMUD contractor Limpell J under Task 346.

Non-conforuances were recorded in NCR S-6999 for manholes MH006, MH046, MH047, MH048, and MH049.

The non-conformances were analyzed and the results recorded in Engineering Report ERPT-0293.

Tne mixing in MH046, MH047, FH040, and NH049 was identified as mixing of Class I utgital inputs to the Class 2 IDADS multiplexers and was accepted since noise filtering is adequate to limit noise to acceptacle levels.

3 Rework was required in mannole 000 and is scheduled for completion prior

• j to the heat-up milestone LJanuary 18, 1968).

A minluun separation of tnree (~$) inches is established between power / control cables and instrument caoles.

Installation specification IS-E-6304.8 Addendum 2 was issued on Septemaer 18, 1967 to impose the 3" minimum separation in raa n hol e s.

LER 65-16.

Seven cables required relocation.

NCRs S-5203 and S-5906 were i ssued.

Et,ds R-04W and R-1295 detail the work.

LER 67-20..

T ent/-eight caales required relocation.

NCRs 5-0bol.

5-05c2, 5-650), 5-6504, 5-65o5, ano S-65c0 were issued.

ECH R-1765 ana ECh k-1?cc detail the work.

ELN R-1765 was issued on July 23,1957 and es coupleted witn a closure date of Octuuer 28, 1967.

ECN R-17ec was issued on June 29, 1537, and is complete with a closure date of evenaer 24, 1987 CRTS UataDase Discrepancies LCRIS Action Itea 2)

Sixteen Non-Class I pwer, control, and instrumentation interaixes reqairing relocation were taentified b/ Iupell as docuuented

• >y CPAs CP R 4bi l v10, 669, 033, 04v, 022, 6i2, and CONS C0h-bus and 74 contained in lupfil Calculatton 40. //1 -l vl-lu9, Rev. v.

The Non-ulass 1 inter.aises will De docunented oy.'<tR and resui <ed prior to the enu of the Cfcie b outage.

Enclosure To GCA 68-001 Page 30 ITEM 140. 9 CONTINUED Corrective Actions - Changes to USAR and Design Process CRT5 Dataoase Since July isB7, the cable input accuuents (Form E-1010] have been required to carry a designation "P" LPower), "C" LControl J, or "1" linstrumentation) to indicate service level and assist in routing the ceble in raceways of tne proper service level.

Additional service level designators are under constocration and include "T" iTeiephonej, "5" LSecurityj and "!E" LInstrument-Exempt may mix with P and/or C caolesj.

A CRTS sof tware enhancement is planned (CRTS Action Item 10) whicn will:

Aoo a field for cable service level LP, C, I, etc.)

• Add a program feature to check cable service level against raceway service level.

Revisions to Oesign Documents Tne physical separation requirements for power, control and instrument circuits have been defined as follows:

Separate conduits, ducts, penetrations, and cable trays should be provided for the following types of circuits:

(1 ) hadiu"i vol tage (ti.'skV) ci rcui ts.

(2) Medium voltage (4.16kV) circuits.

(3) Low voltsgo power (460V) circuits f rom 460V swi tchgear, wi tn unintained spacing in trays.

(4)

Low voltage power (460V and belo ), control, and annunciator winaow input ciresits, and selected shielce.) instruuent circuits approvea by tne Electrical and I 4 C Supervising En,ineers.

(5)

Instrument circuits requiring separate routing.

In vertically stacAed trays, cable trays snvuld be a ranged in the order given above wi tn toe mediun voltage cables in the hignest position in tne stack.

Control cables toy be pulled wi th ivw voltage power cables, except when their respctive conoactur sizes dif fer too greatly, a

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Enclosure To GCA 68-001 Attactunent 4 Page 31 ITEM NO. 9 LONTINUED The instrument circuits requiring separate routing are the folicwing:

(1 ) All signal circuits from process instruisents such as tneroocouples, RTDs, transraitters, neutron flux detectors, acceleroueters, level eieraents, radiation wonitors, etc.

(2) All signal input circuits to computer and Anatec nultiplexers, except for selected circuits whicn the Electrical and I & C Supervising Engineers specifically approve in writing for routing through power and control raceways.

(3) All low energy level circuits (analog or digital), interfacing between instrument cabinets, and signal output circuits from instrument cabinets which control the plant equipraent or device.

(4) All circuits requiring coaxial, twinaxial, triaxial, and fiberoptic caDies.

(Class 1 ex-core detector c6bles such as I

those for source range and power range ion chamber circuits l

raust be run in dedicated rigid steel conduits.)

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(5) All low level anc higher level analog circuits as addressed in Electrical Design Guide NEPH 5204.43, sections 5.5.4 & 5.5.5.

(6) All signal circuits to panel raounted instruments tnat are part of a process instrument loop and shown on instruraent loop diagrams.

(7) All otner circuits designated by the Instrument anc Control Gruup as instrument circuits.

Revisions to the following Engineering Design Documents were completed in uuly IW7.

Tnese revisions are ceing applied to all new caole work.

hF.PH 5204.22 Design Guide - Cable System Design, General hEPri NU4.4J Design Gulce - Instrudefit3T, ion Systeni Saleiding and Grounding anu Surge Prot.:ction hvisions to USAR bee comentary to CRTS Action Itea 17.

Enclosura To GCA 88-001 Page 32 ITEH NO. 10 Descriotion Demonstrate completeness of CRTS, including software verification and validation [V & V).

j COMMENTARY CHRONOLOGY l

General background and initial actions concerning the CRTS program are t

described in CRTS Action Item 1 (as-built verification) and 2 (data discrepancies).

The completeness question has two issues:

1.

Installed But Unrecorded Cables: Hhether the CRTS data base includes all cables installed in the CRTS listed raceways.

2.

Deoendable CRTS Procram:

Whether the CRTS software is complete, reliable, and error free.

Generic Imolications i

1.

Installed But Unrecorded Cables l

Cables of two specific systems have been identified as having i

incomplete cable records:

Security System - CRTS Action Item 11; approximately 180 cables of a total population of 2000 not in CRTS.

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Communication System - CRTS Action Item 13; approximately 450 cables, of a total population of 1500, not in CRTS. (Refer to referenced Action Items for additional detail.)

1 The possibility has also been raised as to whether procedures l

existed which permitted cables (other than security / communication) to be installed without entries being made in the CRTS database.

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j The procedure question has been investigated by !!RG. An IIRG report has been issued (Reference DTS87-103 dated Nov, 9, 1987) l l

which indicates no evidence that other cables (than the security / communication cables identified) were installed without j

the CRTS database being updated.

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generic impliction for other systems.

Security and comunication cables are installed only in non-safety-related raceway, which lesser.s the level of concern.

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Enclosure To GCA 88-001 Paae 33 ITEM NO. 10

. CONTINUED Concerns with installed but unrecorded cables exist related to raceway weight, raceway fill, and to the quantity of combustible material in open cable trays.

However, the quantities are small and without significant safety impact.

2.

Decendable CRTS Program The CRTS software program was written by Control Data Corporation (CDC] for SHUD.

The program was run from 1980 through 1986 on a CDC mainframe computer in Kansas City.

Tne program is currently run on a CDC Cyber 180-830 computer installed at the Rancho Seco jobsite.

Maintenance and enhancement is provided by COC.

The CRTS data is downloaded to a network of four personal computers for ease of handling by CRTS personnel.

The CRTS software program is not a verified program meeting Nuclear Quality Standards. However, subroutines written for and executed on the PC network are verified under a contractor (Impe11] Q.A. progr&m.

The CRTS sof tware program inventories cable and raceway data and performs design checks. The CRTS database is also a source of data for other calculations (e.g. combustible loadings of cable insulation] and a source of information on cable router..

The dependability of the CRTS software is therefore of safety significance to the plant, and the sof tware requires verification to the requirements of the SHUD Quality Program.

The design documents issued for construction have included both the input documents as well as the CRTS generated installation cards.

This process provides verification of the cable routo, since any difference between design intent (input document] and CRTS record (output cards] is readily apparent.

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Enclosure To GCA 88-001 Page 34 ITEM NO.10 CONTINUED The original sof tware program used LEE 553) is a Bechtel Program which has been consistently maintained, enhanced, and verified by its owner.

The CRTS sof tware was written by CDC for SMUD, but received no verification beyond that accorded to commercial software.

The current sof tware has forty-five modules, some of which show evidence of problems ("bugs").

The database is not impacted, but reports generated from the data contain errors.

Corrective Actions 1.

Innediate Actions - Pre Rest. art At tne end of September 1987 forty-one software bugs have been identified. Four personnel have been added L1 Programmer and 3 Engineers - 2 on V4Y and 1 on data discrepanciesj.

All software bugs will be tracked, through resolution, on a database established for that purpose.

All problems which impact restart conaitments have been identified and corrected.

2.

Future Actions - Post Restart SHUD Information Management Services LIMS) is preparing a schedule and budget for the provision of upgraded Lenhanced]

CRTS sof tware, including verification and validation.

Part of this process is making a decision to either:

0 Enhance and verify the existing CRTS sof tware or 4

0 Purchase new sof tware - with verification.

The schedule will show the upgraced sof tware verified and in place before tne end of tne Cycle 8 Outage.

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Enclosure To GCA 88-001

_ Page 35 ITEM NO. 10 CONTINUED i

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A listing of future CRTS enhancements has been provided by the CRTS group as follows:

Software Enhancement List These enhancements are in a format for policy decision-making. Once given initial approval, then the enhancements must be translated into software specification format, then given final approval before software enhancement implementation.

"Needed." Sorted by CRTS Staff Recommended Priority l

N1. Add a new type of CRTS report, for all report options that gives the "proposed" database only, j

Type 3 is recommended for this option, to complement TYPE = 1 "as-built" database only, and TYPE - 2 "as-built and proposed," now in use.

i N2.

Revise raceway fill logic :o be consistent with NEPs and to have complete software control over overfill disallowances, and implement use of "justification j

codes" for overfill situations.

Precedence of "deleting" cables prior to "insertion" of other cables must be enforced to keep fills below NEP limits.

"Sparing" cable logic is to be revised so as not to inflate the overfill calculation if an existing included cable is merely having its scheme i

designation changed.

(Presently, the computer tracks both "old" and "new" names and counts both in fill calculation, which unnecessarily inflates the result.)

F N3. Add a new feature for cable weights for "tray" raceways, to keep fills within USAR limits; "justification codes" for overweight situations.

New software has to handle "split" trays, where a j

partition separates a tray into "instrumentation" j

and "power / control" sections -- unit weight for such occurrences has to be combined to meet the USAR 50 pound per linear foot limit.

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Enclosure To GCA 88-001 Page 36 ITEM NO.10 CONTINUED N4.

Provide a utility feature to search the entire CRTS database for every violation of its current cable-raceway-cqaipment design logic, at CRTS operator initiation.

This should be incorporated imediately af ter the two items above.

Thereafter, as each now logic feature is done, the utility feature should be revised to incorporate each new logic feature.

N5.

Revision to Quality Class 1, 2, and 3 intermixing input screening.

Class 1 screening is adequate.

Non-Class I screening needs revising to make use of "justification codes" for presently acceptable configurations that may violate newer, non-applicable requirements.

N6.

Revision to service level intermixing input screening to disallow power / control / instrumentation cable intermixing in same raceways.

Use of "justification codes" for violations of updated logic.

N7.

"Reserved" element tracking, i.e., organizing the cable numbers, raceway numbers, and equipment designations reserved by designers so that when ECN/DCN packages get to the CRTS staff, there are no conflicts among the various packages.

The reserved element tracking will become an adjunct database to the existing "proposed" and "as-built" CRTS databases now used by CRTS software.

[As a productivity measure, this is being implemented at the microcomputer level presently.J N8. Appropriate, limited read-only access to CRTS database via computer terminal placement within Design City [ Trailer 2J and among Modifications

[ Construction] personnel.

This would free time now used to answer many questions by CRTS staffers, to do other necessary CRTS work.

Designers and constructors could interrogate the CRTS database on their own.

N9.

Add the capability to generate a "repull" card wnen an exi. ting, installed cable is rerouted, in order to dif ferentiate between new installation of cable and revision to an existing Cable's route.

Enclosure I

To GCA 88-001 Page 37 ITEM NO. 10 CONTINUED i

"Desired." Sorted by CRTS Staff Recommended Priority I

0.1 Additional cable and racewe.y enh acements to assist construction personnel -- new database fields: type of service, cable jacket, conduc'or diameter [versus 1

"overall" diameter), bending rat:us, pulling

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tension, sidewall pressure, unit weight, etc.

D.2 10 CFR 50 Appendix "R" supplementary information, i.e., fire protection features, such as fire area in which CRTS element resides, Appendix "R" wraps on i

raceways, whether a given cable is related to e

1 safe-shutdown considerations, whether a cable is associated with "spurious operations equipment." etc.

0.3 Change of CRTS database principle from "position" orientation to "complete history audit trail" I

orientation.

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Enclosure To GCA 88-001 Page 38 ITEM NO. 1.1 l

DESCRIPIl08 Show to what extent security cables are documented in CRTS.

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COMMENTARY CHRONOLOGY f

00R 87-409, dated April 9, 1987, reports that 630 telephone and security system cables are installed in the plant with incomplete documentation.

Approximately 180 cables of a total population of 2000 security cables are not in CRTS.

i All security cables are recorded in one of three data bases:

l.

EE-553 (KL) l 2.

CRTS 3.

PC Data Base t

All security cables are in Non-Class I raceway.

GENERIC IMPLICATIONS The concern with the incomplete documentation of the plant security cables is due to potential impacts upon cable tray weight, fill, and i

combustible content, as well as separation and mix concerns.

However, i

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

Resolution of this problem will be completed by the end of the Cycle 8 outage.

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CAUSES j

The cause of the incorplete security cable documentation has not yet i

been determined.

i COMECIlvt ACT1045 i

f The immediate action to prevent further undocumented security cable l

additions to the plant has been to require all design work to be

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reviewed by the Nuclear Engineering Department. Additional actions may i

be taken later af ter further investigation of causes, i

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7 Enclosure To GCA 88-001 Page 39 ITEM NO. 12 i

DESCRIPTION Complete security cable documentation.

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COMMENTARY i

To be performed prior to the end of the Cycle 8 outage.

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Enclosure To GCA 88-001 l

Attachment _4 Paae 40 ITEM NO. 13 Descriotion Show to what extent coprJnication Cables are documented in CRTS.

l Comentarv I

Chronology 00R 87-409, dated April 9, 1987, reports that 630 telephone and security system cables are installed in the plant with incomplete documentation.

The comunication cables include those from the following systems:

i PA - Public Address (Dedicated Conduit]

l SP - Sound Powered (Dedicated Conduit)

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c CBX-Computer Based (Non-Safety Tray and Conduit) i Exchange [ROLM) 5 CBX cables include circuits for VHS radio and microwave link.

Communication cables are shown on series 700 drawings and ECNs.

Generic Imolicationi The concern with the incomplete documentation of the plant comunication 7

cables is due to potential impacts upon cable tray weight, fill and combustible content, as well as separation and r.;ix concerns. However, since the comunication cables are in either dedicated conduit or in

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Non-Class I raceways, there is no significant impact upon safety i

cables.

Resolution of this problem will be completed by the end of the j

l Cycle 8 outage.

Causes S

The cause of the incomplete comunication cable documentation has not yet been determined. A potential cause is that since the communication cables were installed by the Electrical Maintenance Department, i

conflictin procedures may have led to incomplete communication cable i

documentat on.

Corrective Actions l

l The imediate action taken to prevent further undocumented comunication L

cable additions to the plant has been to require all design work to be i

reviewed by the Nuclear Engineering Department. Additional actions may i

be taken later after furthe-investigation of causes.

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Enclosure To GCA 88-001 Page 41 ITEM NO. 14 1

DESCRIPTION Complete communication cable documentation.

COMMENTARY To be performed prior to the end of the Cycle 8 outage.

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Enclosure To GCA 88-001

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Page 42 ITEM NO. 15 1

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DESCRIPTION formal and complete root cause evaluation of all cable problems.

COMMENTARY ThoroughRootCauseevaluationshavebeenperformedforthemajorcable

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problems.

Reports summarizing these investigations and providing the causes have been previously transmitted (DTS87-103, dated November 9, i

1987] under separate cover to the NRC, l

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Enclosure To GCA 88-001 Page 43 ITEM NO. 16 DESCRIPfION Define major / minor / insignificant defects.

COMMENTARY 4

CHRONOLOGY The Sample Plan (Appendix (1)), prepared by Impell under SHUD Task 271, provides in Figures 9.1, 9.2 and 9.3 a flowchart methodology to classify the types of defects discovered by the circuit tracing walkdowns into major, minor or insignificant defects.

The NRC requested, in the May 6, 1987 meeting between the District and the NRC, that the District provide formal, written definitions of the types of defects.

t Major, minor, and insignificant defect definitions were given verbally to NRR during a site visit June 15 through 18, 1987.

Definitions (see 1

below) will be included in the next revision of the Sampling Plan.

The 1

following was explained to NRR.

The word "defect" is used in the Samplinn Plan to describe a cable route which is checked and found to differ from the CRTS recorded route.

i Defects are classified as either "major," "minor," or "insignificant."

l The classification is determined by reference to a set of decision

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diagrams included as Figures 9.1, 9.2 and 9.3 in the Sample Plan (Appendix (1)).

For the convenience of reviewers, the following definitions will also be included:

l Haior Defect l

A major defect is a cable route which differs from the CRTS recorded i

route and the difference constitutes a violation of the plant safety or design criteria. Corrective action is required, j

Minor Defect A minor defect is a cable route which differs from the CRTS recorded route and the difference does not constitute a violation of the plant l

safety or design criteria.

The corrective tction is to correct the engineering record with no chi.nge to plant configuration.

Insianificant Defect l

An insignificant defect is a cable route which differs from the CRTS

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recorded route only to the extent that typographical errors exist in the recorded data.

The corrective action is to correct the errant data, i

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Enclosure To GCA 88-001 Page 44 ITEM NO. 17 l

r DESCRIPTION Revise USAR COMMENTARY f

r CHRONOLOGY L

The investigations into the direct cause of a number of CRTS problems has identified the need to revise and clarify the wording used in Sections 5 and 8 of the USAR in a number of areas, as follows:

1.

Section 5.1. 2.1.8.C.1. (b) (Cable Trav and Bus Duct Suports) i t

The criteria for cable tray supports limits the loading imposed on the i

tray to 50 pounds per linear foot.

In fact, the 50 pounds per linear foot is a minimum figure, and supports have been designed which accept higher pounds per linear foot values. This change is made for clarification:

Existing Text "1.

(b) Cable tray loading of 50 pounds per linear foot is used throughout regardless of tray width or anticipated weight of wire and cable.

In no case does actual weight of wire, cable and tray exceed this figure,"

I Revised Text j

"1.

(b) A standard cable tray live loading of 50 pounds per linear h

foot is used throughout regardless of tray width or anticipated weight of wire and cable.

Some cable tray supports are designed fcir loads which exceed 50 pounds per I

linear foot.

In no case does the actual weight exceed the l

design limit."

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2.

Section 8.2.2.11.H t

This section provides criteria for the separation of redundant cables of

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safety circuits, but is unclear because it mixes general criteria for all j

safety circuits with specific criteria for RPS and ESFAS circuits, and does not clearly indicate what is general criteria and its applicability.

This change is made for clarification:

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The separation of redundant cables of the reactor protection system and safety features actuation system circuits is accomplished by spatial separation in accordance with the following criteria:"

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i Page 45 l

ITEM NO. 17

_ CONTINUED Revised Text "H.

The separation of redundant cables of safety systems is I

accomplished by spatial separation in accordance with the l

criteria given in this section.

Specific criteria applicable only to Reactor Protection System (RPS] and Engineered Safety Features Actuation System (ESFAS) cables is included."

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Section 8.2.2.11.H.1 As a result of NCR S-6594 and LER 87-26, the District has performed a Safety t

Analysis, 50.59 log No. 1020, which requires the following change to the USAR

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text

• i Existing Text "1.

Separate cable tray conduit and penetration systems are......."

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... Class I instrumentation circuits are routed in rigid metal h

conduits as explained in (2) below."

l Revised Text l

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Separate raceway (cable tray, conduit and penetration) systems are i

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... Class I instrumentation circuits are routed in metal raceway as i

explained in (2) below."

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Section 8.2.2.ll.H.2 j

As a result of NCR S-6594 and LER 87-26, the District has performed a Safety i

Analysis, 50.59 log No. 1020, which requires the following change to the llSAR f

text, because the Babcock & Hilcox design interface criteria for RPS and ESFAS i

cables requires separate "rateway" and does not specifically require separate j

"conduit."

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l Existing Text i

i "2.

Reactor protection system and safety features actuation system instrumentation each have their channels routed in separate conduits and are physically separated from each other throughout the plant."

i Revised Text "2.

Reactor protection system and safety features actuation system instrumentation each have their channels routed in separate raceways and are physically separated from each other throughout the plant."

l 4

7 Enclosure To GCA 88-001 Page 46

[

ITEM NO. 17

.10NTINUED 5.

Section 8.2.2.11.H.5 t

As a result of NCR S-6562 and LER 87-26, and per the Safety Analysis, 50.59 log No. 1002, the USAR will be changed as follows:

Existino Text I

"5.

Power and control circuits are not mixed with instrumentation circuits in any raceway for any system."

i i

Revised Text "5.

Power and Control circuits are not mixed with instrumentation circuits in any raceway for any system unless an engineering analysis for acceptability is performed."

6.

Section 8.2.2.11.H.9 r

Per the disposition of LER 87-24, the following change to the USAR has been committed to because both weight and ampacity considerations are different for power and control cables versus instrument cables.

The follow!ng text change to USAR Section 8.2.2.11.H.9 is planned to provide clarification and agreement with NEP 5204.22:

Existina Text i

t "9.

The maximum percentage fill in redundant trays is 40 percent and

(

wherever possible, it is kept at a bruch lower value."

j Revised Text "9.

The maximum fill in trays is limited to prevent exceeding the cable ampacity rating in accordance with IPCEA No. P-46-426 and ICEA No.

P-54-440, and the designed weight of cable on the tray supports."

[

\\

Cable tray fill limitations are typically imposed because of the following:

j 0

All cable trays - Load bearing capacity of tray and supports O

Power cable trays - Ampacity ratings of cables l

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1

Enclosure To GCA 88-001 Page 47 ITEM NO. 17

. CONTINUED l

The current status of these items at Rancho Seco are as follows:

Load Bearing Cacacity of Cable Trays

[

All tray weights (without regard to percent fill) have been checked against the 50 pound per linear foot USAR limit and were again checked on i

December 28, 1987 with results as described in the commentary to CRTS

}

Action Item 2.

An enhancement is planned to the CRTS software to t

calculate cable tray weights for all future design changes, without regard to fill level.

j Ameacity Ratino of Cable 1 The ampacities for 600 volt 900C power and control cables routed through randomly filled cable trays are based on either the number of conductors (IPCEA No. P-46-426] or percent fill per ICEA No. P-54-440, L

typically 40% of a 4" tray.

[

Scheduled USAR Revision i

These changes are scheduled for inclusion in the next annual update of the l

USAR in July 1988.

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t Enclosure To GCA 88-001 6t.tachment 4 Page 48 ITEM NO. 18 DESCRIPTION Issue NEAP 4127.

I 1

COMMENTARY i

CHRONOLOGY i

j The identification of concerns regarding CRTS completeness and missing

^

CRTS cards, followed by the further identification of cable installation problems associated with LERs 85-16 and 86-10. led to the overall review i

of Rancho Seco cable installation procedures and practices as described in l

the Action Plan and this report.

Initial direct cause determination, confirmed by the preliminary root cause evaluations, has identified that the lack of a formal procedure, by which proposed changes to the CRTS database are made, and describing and controlling the issuance and return of cable and raceway construction cards, was a contributing factor in cable and raceway installation and documentation problems.

It should be

)

noted that no specific cabling problem appears to have been directly associated with or caused by the CRTS computer program itself, but that t

problemt arose through not formalizing the procedure by which cable i

additions, modifications, and deletions are made to the plant, and l

I controlled and inventoried by the cable and raceway construction cards and j

y the CRTS database, i

s

)

GENERIC IMPLICATIONS i

i Lack of a formal procedure to control changes to the CRTS database and l

hence control cable and raceway additions, modifications, and deletions to i

the plant, was a factor in the following types of cable problems at Rancho

)

Seco:

i Cable Tray Overfills and Overweiahts Prior to June 1987, formal procedures for the engineering review and l

acceptance of overfilled cable trays did not exist.

Rancho Seco I

cable tray supports are designed to support, as a minimum, a cable loading of 50 pounds per linear foot.

The USAR specifies a cable i

i tray fill limit of 407. so that the cable tray support design of I

50 pounds per linear foot is r.ot exceeded.

In the past, undocumented

(

engineering reviews were made when cable additions to cable trays exceeded the cable tray fill limit. Neither the informal checks nor

[

]

the supervisory approvals were procedura11 zed, and no documentation is available to show that such reviews have been made, j

j j

i i

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i

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Enclosure To GCA 88-001

__B ge 49 L

ITEM NO. 18 i

_ CONTINUE 0_

i Presently, NEAP 4127 "Cable and Raceway Tracking System" prevents the issuance of DCNs to CRTS-related drawings (E-1008,1010.1026, 1027 and 1028] unless an error-free report can be produced when the i

data is entered into the proposed database.

If a design error is detected, then the DCN is returned to the originating engineer for resolution. Once an error-free report is produced, the DCN is then l

submitted to the Electrical Supervising Engineer for approval.

Should the CRTS errar report indicate an overfilled cable tray, the DCN is returned for the engineering review and evaluation of the cable tray's included cables to verify that the cable tray support design basis cable loading has not been exceeded.

l CRTS Comoleteness The "completeness" issue is discussed in the comentaries to CRTS

[

Action Items 1, 2, 3 and 10. Concerns relate to whether or not CRTS recorded cable locations match "as-built," the resolution of CRTS f

database discrepancies, cables not recorded in the CRTS database and L

missing CRTS cards.

[

The formalization of CRTS procedures in NEAP 4127 provides the

{

definitions and responsibilities sufficient to control future cable and raceway additions, modifications, and deletions to the plant.

j NEAP 4127 formalizes the flow of DCNs to the CRTS-related drawings, 7

as well as the flow of the CRTS generated cable and raceway installation cards to ensure the retention of completed cards to i

ensure CRTS cable and raceway locations match the "as-built" and to ensure that CRTS data is entered without errors.

By procedure,

[

error reports are run on data to be entered into the proposed data-i base and again, once construction is complete, during the final processing of completed cards, in order to ensure that the proposed data, as well as the "as-built" data, is error-free and reflects the actual plant configuration.

CAUSES i

i l

A sumary of the overall root cause evaluations is contained in Appendix l

5.

p i

j CORRECTIVE ACTION l

\\

Corrective action has been to issue NEAP 4127 "Cable and Raceway Tracking

[

System," on June 15, 1987, to control changes to the CRTS database and

~

control cable and raceway modifications to the plant, j

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Enclosure To GCA 88-001 l

i Pace 50 j

ITEM NO. 10 r

i DESCRIPTION Provide bases for acceptability of a 95/95 level of assurance regarding cable routing.

i l

COMMENTARY CHRONOLOGY I

The basis for 95/95 is given in the Sampling Plan (Appendix (1)). Cable i

sampling started in February 1987 and was completed on October 26. 1987, t

Following a meeting with SMUD on May 6, 1987, and a subsequent telephone conference call on May 11, 1987, the NRC requested additional information.

1 i

j SMUD RESPONSE The additional information requested has been provided in an a;,pendix to i

the comentary to CRTS Action Item 19 of the July Hire and Cablo Program Report, GCA 87-400, dated August 18, 1987, and therefore will no longer be included with this comentary, but will be referred to as Appendix 4 to this submittal of the Hire and Cable Program Report. Following issuance of the SER supplement and final acceptance of the Sampilng Plan, the l

supporting documentation will be tr.alntained in NED files for audit or i

re-inspection. Appendix 4 will be forwarded to NRR (in final form with i

inspections complete) with the monthly Hire and Cable Program Report. The j

appendix has been prepared by a SMUD consultant (Impell) and:

1.

Provides information on established precedents.

i 1

1 2.

Provides additional information on the technical basis for the Samoling Plan and provides a comparison between the Rancho Seco I

Sartpling Plan and Military Standard 1050 and related plans.

I 4

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Enclosure To GCA 88-001 1

Page 51 ITEM NO. 20 DESCRIPJ10R Resolve NRC concerns about possible blasing of sample, j

COMMENTARY CHRONOLOGY i

Section 9.1 (3)

Evaluation Process, of the Rancho Seco Sampling Plan (Appendix (1)) contains the following statement:

"If a deviation does exist between the CRTS database routing and the "as-built" routing, the results are first checked against existing CPRs or CONS to determine if the deviation has already been dispositioned.

If this problem has been dispositioned by a CPR or CON, no defect for that i

lot exists."

i i

The question was raised, by Mr. Faust Rosa, at the May 6, 1987 meeting as i

to whether the dispositioning of deviations, by CPR or CON, introduced a bias into the sampling.

SHUD RESPONSE i

The response to the concern is provided in this commentary.

The process described in Section 9.1 (3) is essentially only a correction of minor bookkeeping errors, none of which impacted the cable route. Only seven J

cables had deviations which were dispositioned as described. All are detailed herein and none had deviations which affected the route. No bias I

was introduced into the sampling by Section 9.1 (3).

This commentary will be added to the Sanple Plan in the next revision.

i i

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Enclosure To GCA 88-001 Page 52 l

JTEM NO. 20 CONTINUED TABLE 1 i

t f

List of Circuit Tracing Halkdown Cables with CONS or CPRs l

t The following list of cables are part of the CRTS circuit tracing sample cables and have CRTS problems identified as CONS (*) or CPRs(**).

l t

11g3 C@

dork Recuest Number CON or CPR Desianation l

1 IG1Q886AR 108063 CON-0118 CPR-0053 i

2 1M1A137 C 127745 CON-0001 1

3 1 PIA 06 0 126992 CON-1018 l

4 1RIC26088 128755 CPR-0365 I

5 1RIC469CL 127708 CPR-0031 6

1R21R2H C 127006 CPR-0534 CPR-0672 7

1118314 A 127022 CPR-0866

• Conversion error reports (C0111 were generated for equipment, i

raceway, and cable problems identified from the June 1980 corrputer conversion error reports prepared by SHUD's contractor Control Data Corporation, when Bechtel Power Corporation's EE-553 database was converted to the present CRTS database.

• • C.RTS Problem Reports (CPRs) were generated for equipment, raceway, and ca.ble eroblems identified _after tne June 1980 conversion.

t i

The following describes the problems and reFolutions stated on the associated

[

CONS /CPRs and their impact on the circuit tracing walkdown effort.

l I

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f Enclosure To GCA 88-001 i

Attachment _a Page 53

+

i ITEM NO. 20

_ CONTINUED-j l

i i

Table 1 (continued) i i

ITEM 1 t

1

(

Cable: 1GlQ886AR on CON-0118 and CPR-0053 j

t i

Problems:

CON-0118 states that the CRTS raceway vias do not l

match Bechtel's EE-553 cable routing.

CPR-0053 states that the construction card's first i

and last vias ("red") do not match CRTS first and

}

last vias ("white").

l l

i i

Resolutions:

CON-0118 -- Junction box numbers were removed from CRTS vias and were confirmed by walkdown.

l 6

CPR-0053 -- Inspection verified the cable is painted with "red."

OCO has been issued to correct CRTS.

l i

1 Halkdown Impact:

None on cable routing.

1 i

ITEM 2 i

Cable:

1HIA137 C on CON-0001

[

Problem:

CON-0001 states that CATS vias show cable tray L43V36 connecting to L398NS, but CRTS raceway i

conntettons do not show them connecting.

t

)

Resolution:

CON-000) -- CRTS Revision Level 1372, 02/16/87, raceway connections show tray L43V36 connecting to L39BN5.

l Halkdown Impact:

None on cable routing.

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Enclosure To GCA 88-001 Page__54 ITEM NO. 10 4

_ CONTINUED Table 1 (continued)

{

t ITEM 3 i

Cable:

IPIA06 0 on CON-1018 I

Problem:

CON-1018 states that "from" termination of cable j

does not match equipment I.D. schedules.

[

Resolution:

CON-1018 - "From" termination is a section of a I

panel. Panel is listed in equipment I.D.

j schedule.

i l

Halkdown Impact:

None on cable routing, i

l ITEM 4 f'

\\

f Cable:

1RIC260BB on CPR-0865 i

Problem:

CPR-0865 states that CRTS shows the cable has a j

deleted status and removal of the cable is not l

verified.

[

Resolution:

CPR-0865 -- Inspection verified the cable is f

j being spared and has been retagged to I

IB1PA0101.

i Walkdown Impact:

Cable is deleted.

New sample cable selected, f

ITEM 5 i

I Cable:

1RIC469Ct. on CPR-0031 Problem:

CPR-0031 states that the pull card is not signed i

i by QC.

Resolution:

NCR was issued, and when dispositioned, the pull 1

card will be signed by QC after inspection.

s l

Halkdown Impact:

None on cable routing.

l 1

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f 4

Enclosure l

To GCA 88-001 f

f Page 55 a

j ITEM NO 20 CONTINUED-j Table 1 (continued)

I ITEM 6 i

Cable:

1R2!R2H C on CPR-0534 and CPR-0672 i

Problems:

CPR-0534 states that the cable is routed in t

j Class 2 overfilled tray.

CPR-0672 states that the construction card has i

not been received and that the number of l

l conductors does not match design drawings.

4 f

Resolutions:

CPR-0534 -- Cables in overfilled tray were l

{

analyzed.

i CPR-0672 -- Resolution of Non-Class 1 problem on

[

unsigned construction cards is not completed.

j Walkdown Impact:

None on cable routing.

}

l l

ITEM.7 i

Cable:

1110314 A on CPR-0866 Problem:

CPR-0865 states that CRTS shows the cable has a deleted status and removal of the cable is not verified.

Resolution:

Inspection was performed and confirmed that the

[

table does not exist.

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Halkdown Iepact:

Cable is deleted. New sample cable is selected.

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,-,n,-,

-v,

Enclosure l

Vo GCA 88-001 4

i i

.. Page 56 l

ITEH_NO. 21 i

6 I

)

DESCRIPTION Provide NRC with location of cable pull cards.

1 i

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CCNMENTARY

}

Refer to commentary to CRTS Action Item 3.

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I a

i Enclosure I

To GCA 88-001

--_.Page 57 1

t ITEM No. 22 f

j C15CRIPTIOS Provide NRC with future plans for Cable pull Cards, CCWENTARY j

i Refer to comentary to CRTS Action Item 3.

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Enclosure i

To GCA 88-001 j

attachment 4 f

Page 58 ITEM NO. 23 i

DISCRIPll0!i Redundant cabling in the same fire area (LER 86-10 and 87-13),

f CCMENTARY CHRON0'QGY i

Refer to Root Cause Investigation 86-10.

l f

GBERIC IMPLICATIONS L

LERs 86-10 and 87-13 identified significant concerns with Rancho Seco cable configuration control.

LER 86-10 identified seven safety-related instrumentation cables in Fire Area 17 that were not rerouted into i

fire-wrapped conduit as required by CRTS. LER 87-13 identified seven safety related instrumentation cables that were not moved from Fire Area L

i 36 to Fire Area 31 as required by CRTS.

In both cases, the cable i

j rerouting was to have been performed under ECN A-4942, and in fact the

(

subject cables were correctly routed per the original issue of ECN i

t i

A-4942. However, the routing of the cables was revised several times j

after the initial issue of ECN A-4942, and the failure to subsequent 1v I

reroute the cables resulted in LERs 86-10 and 87-13.

In addition to the t

safe shutdown / Appendix "R" concerns that arose as a result of the I

incorrectly routed cables, additional concerns identified by preliminary i

root cause investigations include that of adequate control of CRTS cable

[

l and raceway installation cards (See commentary to CRTS Action Items 3 and 1

18) and the failure of the Electrical QC inspectors to verify proper j

location and routing of the subject cables (Notice of Violation 50-312/87-21/-01).

I CAUSES I

3 l

l Refer to the sumary of the Root Cause Investigation 86-10 (Appendix (5))

for the root cause findings.

}

l CORRECTIVE ACTIQS$

1 l

In response to LER 86-10 Rancho Seco began an inspection program of safety-related cables to estabitsh a level of confidence in the cable locations, as well as the CRTS database.

Based on the analysis of the I

i misrouted cables in LER 86-10, and the lack of identified cable routing j

l problems in the original plant cable population, the decision was made to l

sample only those safety-related cables installed after commercial I

l operation in 1975 (justification provided in commentary to CRTS Action l

i i

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d

e Enclosure I

To GCA 88-001 t

l Page 59 t

ITEM NO. 23 i

CONTINUED i

i Item 7).

As described in the Sampling Plan (Appendix (1)], the l

post-comercial operation safety-related cables have been divided into I

four sample populations and the objective has been to demonstrate with a 95% level of confidence that at least 95% of the sampled population is correctly installed in the plant per CRTS. Cable inspection, as part of

{

the Sampling Plan, identified the seven additional cable misroutes L

described in LER 87-13, and prompted the 1001 inspection of the Lot 4 sample population, which is complete with no additional major defects.

j r

Additional cable misroutes were identified as described in 00Rs87-604 and 4

87-723, and have required the 1001 inspection of the Lot 1 sample

[

i population, completed on December 8,1987.

Cable rerouting for those l

misrouted cables identified by LER 86-10 was performed by ECN R-0765 and is construction complete. Cable rerouting for those misrouted cables i

identified by LER 87-13 was performed by work request 126636 and is also i

J compl e te. Hisrouted cables identified by 00Rs87-604 and 87-723 will be l

corrected by ECNs R-1785 and R-1786, issued on July 23, 1987 and June 26, 4

l 1987 respectively. Construction completion for R-1785 was on October 28, 1

1 1987 and closure for R-1786 was on November 23, 1967. Additional i

corrective action nas been to include in the Modification i

Procedure / Inspection Standard HP/IS 307, "Cable Installation,"

I requirements to ensure that when installing cable, that the design documents are tne latest revision, and that the cable routing information I

on tne E-1010 series drawing matches that on the applicable cable installation card. Further requirements have been included in MP/IS 307 i

by Procedure Cnange Notice, in order to clarify the requirements for l

l witnessing cable pulls, as follows:

[

1 "Verify the cable is installed in the raceway specified by the I

d applicable E-1010 series drawing. Verification shall consist of

(

witnessing the installation of the cable."

i

)

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Enclosure t

To GCA 88-001

[

[

At_tachment 4

]

_Page 60

[

i

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ITEM NO. 24

~

i ELSCRIPTION Provide description of the installation procedures and practices used at Rancho Seco for the original cable population of 14,000

{

cables.

j t

]

COMMENTARY l

Refer to the comentary to CRTS Action Item No. 7.

(

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Enclosure To GCA 88-001

..... Page 61 _

ITEM NO. 25 DESIBIfl10!i Document a thorough engineering evaluation of the procedures and specifications used to install cable in the period 1975-1986.

COMimIAar CHRONOLOGY This CRTS Action Item stems from a lack of independent inspection for the i

installation of approximately 1100 safety cables in the period i

1983-1985.

This is identified in a draft Notice of Violation, included by NRC Region V, in a letter to SHUD dated July 30, 1987

Subject:

NRC Inspection Report.

The concern which exists is that the lack of independent inspection could i

have resulted in not detecting damage to cable during installation.

This engineering evaluation addresses the approximately 9000 cables installed 1975-1986 and covers two areas:

1)

Adequacy of cable installation procedures and specifications used 1975-1986, 2)

Evidence of cable damage experienced 1975-1986.

The NRC Notice of Violation identifies a SHUD letter dated September 23, 1976 which stated that the Rancho Seco QA program complied with the l

guidance given in RASH NO. 1284.

This document in turn invokes IEEE 4

Standard 336-1971 (ANSI N45.2.4-1972).

IEEE 336-1971 requires in Section i

2.3 "Procedures and Instructions" that "Installation, inspection, and l

test procedures and work instructions shall be prepared and documented for those activities falling within the scope of this standard." Cable installation is covered in Section 4.

This evaluation is made against the 1976 SHUD comitment.

G MERIC IMPLICATIQRS Approximately 14,000 cables were included in the original construction cable installation.

Both the NRC and SHUD evaluations (NRC inspection 1

report 50-312/87-21 Section 2.A.(1) and CRTS Action Item 7) accept the adequacy of quality control in the original construction, j

i The 9000 cables installed 1975-1986 may be sumarized by year as follows.

The Class 1 cable totals given are approximate and derive from Appendix 1 to the Wire and Cable Program Report.

The Class 2/3 cable totals are ratioed from the Class 1 totals.

I

Enclosure To GCA 88-001 Page 62 11 B l0 u25 CONTINUED _.

Approximat LCable Distribution by_ lear YEAR CABLES CLASS 1 NON-CLASS 1 IECN closEtl IRSIALLEQ CaaLES_.

CABLES (3.425 X Class 1]

?

225 51 174 1975 66 15 51 1976 4

1 3

3 1977 53 12 41 1978 101 23 78 1979 53 12 41 1980 598 135 463 1981 0

0 0

1982 0

0 0

1983 3638 822 2816 1984 828 187 641 1985 3315 749 2566 1986 119 27*

92 d

9000 2034 6966 Includes 25 cables whose ECNs were closed in 1987.

? - Year not 1

confirmed.

The period 1983, 1984, 1985 saw 1758 Class 1 cables installed or over 86%

of the total installed 1975 through 1986. A detailed evaluation has been made (year by year) of:

Installation specifications Installation procedures Inspection procedures i

This evaluation has determined that no Rancho Seco cable installation specifications as such, existed during the years 1975 through 1981.

However, the required cable installation attributes were addressed by inspection requirements contained in Construction Inspection Data Reports (CIDRs) included with each work request package. Copies of CIDRs for 1978 and 1980 are included as Appendix 6 of this report.

From 1982 onward, installation specifications existed and were adequate.

Details are as follows:

i

I t

Enclosure t

1 To GCA 88-001 l

I Page 63 f

1 ITEM NO. 25 i

CONTINUED i

f j

ADE00ACY OF CABLE INSTALLATION PROCIERES AND SPECIFICATIONS _USED 1975-1916 I

YEAR 1975

[

Installation Specifications:

None Installation Procedures:

EM-145 Rev. O Inspection Procedures:

QCI 107 Rev. O, 1, 2, 3 Industry Guides / Standards:

None I

Regulatory Standards:

None Comeliance 11$

N0 l

Cable Installation Specifications Issued?

X

{

Material Handling Addressed?

X Cable Tensile Strength Addressed?

X Cable Sidewall Pressure Limitations Addressed?

X Cable Pulling Calculations Addressed?

X l

Installation Tension Measurements Addressed?

X Cab e Lubricants Addressed?

X Cable Bending Limitations Addressed?

X l

Installation Procedures Issued?

X Inspection Procedures Issued?

X l

I j

YEAR 1976 l

l

)

Installation Specifications:

None Installation Procedures:

EM-163 Rev. 0 l

Inspection Procedures:

QCI 107 Rev. 3 j

Industry Guides / Standards:

IEEE 336-1971 l

Regulatory Standards:

Safety Guide 30 f

l i

i 1_.

Enc 1csure To GCA 88-001

__ fA2e 64.

IIEB_E(L_15

_COMI1EED_.

Cro11ance 1ES E0 Cable Installation Specifications Issued?

X Haterial Handling Addressed?

X (16) (See Coment)

Cable Tensile Strength Addressed?

X (11)

Cable Sidewall Pressure Limitations Addressed? X (11)

Cable Pulling Calculations Addressed?

X (11)

Installation Tension Heasurements Addressed?

X (11)

Cable Lubricants Addressed?

X (13)

Cable Bending Limitations Addressed?

X ( 4)

Installation Procedures Issued?

X Inspection Procedures Issued?

X Comment: The intent of IEEE 336 and Safety Guide 30 were met in the CIORs.

The # in parenthesis ( ) indicates the CTOR item as follows:

Inspection item Insptttien Requirement Method 4.

Bending radius shall be in accordance with Visual manufacturer's recomendations and necessary requirements.

11.

Pulling tension shall not exceed manufacturer's Visual recomendations.

13.

Excess lubricant shall be removed from cable Visual imediately af ter pulling.

16.

Purchase Order number, Manufacturer's Reel Verify number, DCN number, Work Request number, and Stock Code number shall be recorded on the cable pull card upon receiving cable from the warehouse, 15A!Ll911 Installation Specifications:

None Installation Procedures:

EM-163 Rev. O Inspection Procedures:

QCI 107 Rev. 3 Industry Guides / Standards:

IEEE 336-1971 IEEE 336-1977 IEEE 422-1977 Regulatory Standards:

Safety Guide 30 Compliance:

See 1976 Response

Enclosure f

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To GCA 88-001 l

j L

Page 65

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j YEAR 1978

[

Installation Specifications:

None f

i j

Installation Procedures:

EM-163 Rev. O, 2, 3

[

r i

Inspection Procedures:

OAP 29 Rev. 1 i

j QCI 107 Rev. 3, 4 t

Industry Guides / Standards:

IEEE 336-1977 IEEE 422-1977 j

l Regulatory Standards:

Safety Guide 30 f

1 i

j Compliance:

See 1976 Response f

l f

YEAR 1979 i

l Installation Specifications:

None 1

l Installation Procedures:

EM-163 Rev. 3

)

Inspection Procedures:

OAP 29 Rev. 1 l

j QCI 107 Rev. 4 l

i Industry Guides / Standards:

IEEE 336-1977 f

l IEEE 422-1977 l

Regulatory Standards:

Safety Guide 30 Compliance:

See 1976 Response

)

YEAR 1910 Installation Specifications:

None Installation Procedures:

EM-163 Rev. 3 j

i Inspection Procedures:

OAP 29 Rev. I s

OCI 107 Rev. 4 Industry Guides / Standards:

IEEE 336-1977 IEEE 336-1980 l

IEEE 422-1977 j

Regulatory Standards:

Safety Guide 30 Coepliance:

See 1976 Response I

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L Page 66 i

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L ITEM NO. 25 t

CONTINUED f

YEAR 1961

?

Installation Specifications:

None l

)

Installation Procedures:

EM-163 Rev. 3 inspection Procedures:

E!! EC 11 Rev. 0 i

E!! G-2 Rev. O i

j E!! G-4 Rev. O 1*

QAP 29 Rev. 1, 2, 3, 4 QCI 107 Rev. 4

(

l Industry Guides / Standards:

IEEE 336-1980 l

IEEE 422-1977 i

4 I

Regulatory Standards:

Safety Guide 30 I

Compliance:

See 1970 Response l

t

• Effective Date hot Known l

YEAR 1982 l

Installation Specifications:

CMP Rev. 0, 1, 2 l

I l

Installation Procedures:

CMP Rev. O, 1, 2 i

j EM-163 Rev. 3 l

Inspection Procecures:

E!! EC-11 Rev. O 1*

l E!! G-2 Rev. O J

E!! G-4 Rev. 0, l' I

QAP 29 Rev. 4 L

)

QCI 107 Rev. 4 I

[

Industry Guides /Standarcs:

IEEE 336-1980 i

IEEE 422-1977 l

Regulatory Standards:

Safety Guide 30 I

• Effective Date Not Known i

4 l

i i

i t

Enclosure To GCA 88-001 Page 67 ITEM NO. 25 CONTINUED Comoliance Y15 HQ Cable Installation Specifications Issued?

X Haterial Handling Addressed?

X Cable Tensile Strength Addressed?

X Cable Sidewall Pressure Limitations Addressed? X Cable Pulling Calculations Addressed?

X fnstallation Tension Measurements Addressed?

X Cable Lubricants Addressed?

X Cable Bending Limitations Addressed?

X Installation Procedures Issued?

X Inspection Procedures Issued?

X t

Comments:

Tne intent of IEEE 336, IEEE 422, and Safety Guide 30 were met.

YEAR 1983 Installatior, Specifications:

CHP Rev. 2, 3, 4, 5 Installation Procedurer,:

CHP Rev. 2, 3, 4, 5 EM-163 Rev. 3 Inspection Procedures:

EII EC-11 Rev. 1*,

2, 3 EII G-4 Rev. O 1*,

2

'l EII L 2 Rev. O, 1, 2 i

QAP 29 Rev. 4 QCI 107 Rev. 4 QCP 330 Rev. 2, 3, 4 Industry Guides / Standards:

IEEE 336-1980 IEEE 422-1977 Regulatory Standards:

Safety Guide 30 Compliance:

Set'1982 Response

• Effective Date Not Known 1

+

l 1

4

ho#Nk bh-001-Page 68 l

t ITEM NO. 2_5 l

CONTINUED e

t YEAR 1984 Installation Specifications:

CMP Rev. 5, 6 Idstallation Procedures:

CMP Rev. 5, 6 EM-163 Rev. 3, 4

[

i.

(

Inspection Procedures:

EII EC-11 Rev. 3, 4, 5, 6 i

EII G-2 Rev. 2, 3, 4, 5*

EII G-4 Rev. 2, 3 QAP 29 Rev. 4 3

QCI 107 Rev. 4 t

QCP 330 Rev. 4, 5 j

Industry Guides / Standards:

IEEE 336-1980 t,.y IEEE 422-1977 i

IEEE 690-1984 Regulatory Standards:.

Safety Guide 30

[

i Compliance:

See 1982 Response f

• Effective Date Not Known l

!A YEAR 1985 l $fl l

's#'

Installation Specifications:

CMP Rev. 6, 7, 8, 9, 10

(,

NEPM 5304.8C Rev. 0*

Installation Procedures:

CHP Rev. 6, 7, 8, 9, 10 EM-163 Rev. 4 NEP 63u7 Rev. O I

l Inspectica Procedures:

E!! EC-11 Rev. 6 Ei! G-2 Rev. 4, 5 L

EI! G-4 Rev. 3, 4 QAP 29 Rev. 4, 1 i

i QCI 107 Rev. 4, 5 l

QCP 330 Rev. 5 l

l Industry Guides / Standards:

IEEE 336-1980 IEEE 336-1085

[

i IEEE 422-1977 I

~

l IEEE 690-1984 6:.

Regulatory Standards:

Safety Guide 30 Vy Compliance:

See 1982 Response

• Effective Date Not Known i

I b

Enclosure To GCA 88-001 Pace 69 ITEM NO. 25 CONTINUED _

YEAR 1986 i

Installation Specifications:

NEPH 5304.8C 0*, 1, 2 Installation Procedures:

EM-163 Rev. 3. 4 MP/IS 307 Rev. O NEP 6307 Rev. O, 1 Inspection Procedures:

HP/IS 307 Rev. O NEP 6307 Rev. O 1 0AP 29 Rev. 1, 2 QCI 107 Rev. 5 QCP 330 Rev. 5 Industry Guides / Standards:

IEEE 336-1980 IEEE 422-1977 IEEE 422-1986 IEEE 690-1984 e

Regulatory Standards:

Safety Guide 30 Compliance:

See 1982 Response i

• Effective Date Not Known i

i YEAR 1987 u

Installation Specifications:

IS-E-5304.8 Rev. O NEPH 5304.8C Rev. 2, 3 Installation Procedures:

EM-163 Rev. 4 i

MP/IS 307 Rev. O Inspection Procedures:

MP/IS 307 Rev. 0 0AP 29 Rev. 2 h

j QCI 107 Rev. 5

ndustry Guides / Standards:

IEEE 336-1985 IEEE 422-1986 I

IEEE 690-1984 l

Regulatory Standards:

Safety Guide 30 1

L Compliance:

See 1982 Response a

-c..-- e-

---

n-

Enclosure To GCA 88-001 Page 70 ITEM NO. 25 CONTINUED CONCLUSIONS Of the 9000 cables installed 1975-1986, approximately 1080 [12.5%) were installed 1975 through 1981 without issued cable installation specifications, but with the required inspections covered by CIDRs.

The cables installed after 1981 were covered by installation specitications which were adequate to prevent cable damage.

Two conclusions are apparent:

1.

87.5 percent of cables installed 1975-86 were installed while adequate installation specifications and procedures existed.

12.5 percent were installed without installation specifications, but with the inspection attributes covered by CfDRs.

2.

The cables installed in the 1983, 84, 85 period were covered by

+

adequate installation specifications and procedures.

1 1

REFERENCES AND DOCUMENTATION The following is a list of the cable installation documents referenced in this commentary. Availability of copies at Rancho Seco is also indicated.

Cable installation related soecifications and orocedures CMP Construction Methods and ProceduresSection III Cable Installation Initial Release dated 06-04-82 Revision 1 dated 07-16-82 Revision 2 dated 07-29-82 Revision 3 dated 01-28-83 Revision 4 dated 04-06-83 Revision 5 dated 04-25-83 Revision 6 dated 11-16-84 Revision 7 dated 03-27-85 Revision 8 dated 05-08-85 Revision 9 dated 05-15-85 Revision 10 dated 08-26-85 Cancellation - dated unavailable Note:

Revisions 1, 2, 3, 5, 6, 8, and 9 were unavailable.

t i

l

Enclosure To GCA 88-001 Page 71 ITEM NO. 25

_ CONTINUED P

EII EC-11 Engineering and Inspection Instruction Manual - Cable Installation During Construction and Major Modification Revision 0 dated 08-12-81 Revision 1 dated unavailable Revision 2 dated 01-29-83 Revision 3 dated 04-30-83 Revision 4 dated 03-20-84 Revision 5 dated 06-28-84 Revision 6 dated 11-01-84 Cancellation date unavailable Note:

Revisions 0 through 5 were unavailable.

t EII G-2 Engineering and Inspection Instruction Manual - Site Construction Inspector (Generation Engineering Quality 1

Control)

Revision 0 dated 08-12-81 Revision 1 dated 01-29-83 Revision 2 dated 04-25-83 Revision 3 dated 03-28-84 Revision 4 dated 12-03-84 Revision 5 dated 01-07-85 Cancellation date unavailable Note:

Revisions 0 thraugh 4 were unavailable.

EII G-4 Engineering and Inspection Instruction Manual -

Process of Construction Inspection Reports Revision 0 dated 08-12-81 Revision 1 dated unavailable Revision 2 dated 04-25-83 Revision 3 dated 03-28-84 Revision 4 dated 11-25-85 Cancellation date unavailable i

Note:

Revisions 0 through 3 were unavailable.

EM-163 Electrical Maintenance - Installation of Permanent Plant Cables Revision 0 dated 11-19-75 i

Revision i dated never issued Revision 2 dated 05-31-78 Revision 3 dated 10-06-78

• Revision 3 dated 10-09-80 Revision 4 dated 09-21-84

• Error was made in assigning revision number.

I 1

i m

,-______.__.- -___-.._ _ - ___ ~ _ -. _ _ _... _ _ _. _ _ _. -_-

Enclosure To GCA 88-001 Paae 72 IIEM NO._25 CONTINUED IEEE 336 IEEE Standard Installation, and Testing Requirements For Instrumentation and Electrical Equipment During the Construction of Nuclear Power Generating Stations Initial issue 1971 Revised 1977 Revised 19801 Revised 19852 I

Title revised to:

IEEE Standard Installation, i

Inspection, and Testing Requirements for Class 1E Instrumentation and Electrical Equipment at Nuclear Power Generating Stations.

2 Title revised to:

IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities.

IEEE 422 IEEE Guide For The Design and Installation of Cable Systems in Power Generating Stations Initial issue 1977 Revised 1986 IEEE 690 IEEE Standard For The Design and Installation of Cable Systems for Class 1E Circuits in Nuclear Power Generating Stations Initial issue 1984 IS-E-5304.8 Installation Specification - Rancho Seco Nuclear i

Generating Station Installation Specification For Electrical Cable Installation and Termination i

i i

Initial issue dated 08-28-87 l

MP/IS 307 Modification Procedure / Inspection Standard i

Revision 0 dated 12-12-86 t

l NEP 6307 Nuclear Engineering Procedure - Cable Installation l

Initial issue dated 12-28-85 i

Revision 1 dated 10-17-86 l

Cancelled as of 12-12-86 i

I

Enclosure To GCA 88-001 Mtachment 4 Paae 73 LTEM NO. 25 CONTINUED NEPM 5304.8C Nuclear Engineering Procedure Manual - Electrical Cable Installation and Termination Initial issue dated unavailable Revision I dated 07-03-86 Revision 2 dated 11-06-86 Revision 3 dated 02-18-87 Cancelled as of 08-28-87 QAP-29 Construction Inspection Revision 1 dated 06-14-78 Revision 2 dated 02-10-81 Revision ' dated 05-18-81 Revision 4 dated 09-01-81

• Revision i dated 06-05-85

• Revision 2 dated 01-01-86 Cancelled 07-28-87

• Error was made in assigning revision number.

QCI 107 Quality Control Instruction - Installation Inspection of Electrical Cable, Hire, and Conduit Initial issued dated unavailable Revision I dated unavailable Revision 2 dated unavailable Revision 3 dated 09-30-75 Revision 4 dated 08-04-78 Revision 5 dated 03-12-85 Cancellation date not available Note:

Revisions 0 through 2 were unavailable.

QCP 330 Quality Control Procedure - Conduit and Cable Inspection Original dated 02-03-82 t

Revision 1 dated 03-15-82 Revision 2 dated 05-18-82

• Revision 3 dated 02-03-83 Revision 4 dated 04-20-83 Revision 5 dated 01-18-84 Cancelled as of 09-25-86

• Revision 3 changed title to Cable Installation Inspection Procedure.

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

I k

Enclosure To GCA 88-001 Atlachment 4 Page 74 LTEM MO. 25

. CONTINUED.

Evidence of Cable Damage Exoerienced 1975-1987 NCRs written during the period 1975-1987 were reviewed for evidence of Class I cable damage during or after cable insts11ation (see Table 11.

The review did not uncover a consistent pattern of cable damage during the installation process.

The results of the review are as follows:

Twenty-three NCRs were written for damage done during or after the cable installation process.

Eighteen of the twenty-three described damage that occurred, or most likely occurred, during the installation process (cable pulling and termination).

Eight of the eighteen described damage or potential damage that occurred while cable was being installed in raceway.

The eight NCRs involved a total of twenty-five cables, as shown on Table 2.

Only one NCR (NCR S-3178] described a cable that failed in service during the period 1975-1987.

The "B" phase of the 5 KV power cable feeding the "B" nuclear service raw water pump tripped on ground fault on May 18, 1983.

The cause was identified as follows:

"cable was damaged on initial installation." A temporary repr.ir of the cable was completed on June 21, 1983 and the cable was placed back in service.

ECN A-4905 was issued on February 16, 1984 to replace the entire cable, from the switchgear to the pump. During the replacement of the repaired cable on May 21, 1985, the minimum training radius and the maximum allowable sidewall pressure for the new cable was exceeded as documented on NCR S-4726.

The new cable was subsequently replaced in accordance with ECN R-0328.

Conclusions The evidence of NCRs written during the period 1975-1987 does not indicate a generic problem of cable damage during the cable installation process. Only twenty-five, out of approximately 2000 Class I cables installed, were identified as being damaged or potentially damaged during installation.

Damaged cables were either replaced or repaired.

References and Documentation Tables I and 2 are lists of the NCRs reviewed for this evaluation.

J s

Enclosure To CCA 88 001 w

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Enclosure To GCA 88-001 Page 79 -

ITEM NO. 26 DESCRIPTION Provide description of the events and circumstances leading to the misrouting of cable described in LERs 85-16, 86-10, 87-13 and 87-26.

COMMENTARY Refer to Root Cause investigations RC 85-24, RC 86-10 and RC 87-09 (Appendix 5].

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Enclosure To GCA 88-001 Page 80 ITEM NO. 27_

DESCRIPTION Providc. description of the events and circumstances leading to the discrepancies discovered between the "as-built" cable routes and the routes recorded in CRTS.

CCHMENTARY See Root Cause Report 87-03 Cable Raceway Tracking System.

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Enclosure To GCA 88-001 Page 81 ITEM NO. 28 Description Provide the bases for acceptability of a 95/95 level of assurance regarding cable routin

[ Compared with other accepted homogenous populations]g.

Comentary The basis for acceptability of a 95/95 level of assurance regarding cable routing rests on two arguments:

1)

Prior use nf 95/95 acceptance criteria in Nuclear Power Plant Sampling Applications.

2)

Application of 95/95 acceptance criteria to cable routings.

The response concerning prior acceptance of 95/95 is given in the response to CRTS Action Item 19 and is complete.

Final inspection results are given in Table 1 at the end of this comentary.

Application Of 95/95 Acceptance Criteria To Cable Routings The confidence level established by the 95/95 acceptance criteria is the conditional probability that the percentage of major defects in the total population is less than or equal to five percent.

Two populations [ Lots 1 and 4] have been given 1007, inspections.

The acceptance criteria is applied to Lots 2 and 3, both of which have been sampled with the following results:

Lot 2 Lot 3 Population Size:

1383 176 Sample Size:

91 51 Major Defects:

0 0

i Enclosure To GCA 88-001 Page 82

~

ITEM NO. 28 l

CONTINUED Statistical inferences using the Likelihood Density Function Method are:

t Lot 2 Lot 3

[

J Maximum liklihood i

estimate of the i

percentage of improperly routed i

i circuits in the I

population:

05 05 1

i

==

Conclusion:==

With 95.05 confidence, With 96.0% confidence, I

it can be asserted that it can be asserted that 97.0% or raore of the 95.5% or more of the j

circuits are properly circuits are properly i

routed.

routed, t

t

[ Note:

"Confidence" is the conditional probability that the population from which the sample was drawn contains no fewer than 'X' percent

[

acceptable items, given the evidence available from the sample.]

Statistical inferences using Acceptance Sampling Methodology are:

j Lot 2 Lot 3 l

Acceptance Number 1

0 l

I i

==

Conclusion:==

With 95.0% confidence, With 95.8% confidence, it can be asserted that it can be asserted that 95.05 of the circuits 94.9% of the circuits j

are properly routed.

are properly routed.

[

t (Note:

"Confidence" is the conditional probability of rejecting a lot l

containing 'X' percent discrepant items, given that a lot of that quality i

has been submitted.]

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Enclosure To GCA 88-001 Page 83 1

ITEM NO. 28' CONTINUE 3]

i The establishment of Lot 3 separately from Lot 2 was done in an attempt to 3

establish whether the cards with "questionable" signatures constituted a special class with a common problem. With 29.0 percent of Lot 3 inspected, this is clearly not the case, and the "questionable" signatures have no sif '.~ i ca :Ke.

Therefore, Lots 2 and 3 can be examined statistically by combining cae total and sampled populations.

This gives a population 1

LOT 2 + Lot 3 r

Population Size:

1559 a

r Sample Size:

142 i

\\

l This allows the examination of the statistical inferences for the combined lots.

These fir 9res are:

l Statistical inferences using the Likelihood Density Function Method are:

j Lot 2 + Lot 3

==

Conclusion:==

With 95.1% confidence, i

it can be asserted that 98.1% or more of the circuits are properly routed.

t l

[ Note:

"Confidence" is the conditional probability that the population from which the sample was drawn contains no fewer tnan 'X' percent acceptable items, given the evidence available from the sample.)

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Enclosure To CCA 88-001 Page 84 ITEM NO. 28 CONTINUED Statistical inferences using Acceptance Sampling Methodology are:

LFor an acceptance number of zero]

Lot 2 + Lot 3

==

Conclusion:==

With 95.1% confidence, it can be asserted that 98.0% of the circuits are properly routed.

[ Note:

"Confidence" is the conditional probability of rejecting a lot containing 'X' percent discrepant items, given that a lot of that quality has been submitted.]

A reliability level of 98% for the combined population of 1559 would indicate the possibility of 31 or fewer major defects.

This possibility has to be evaluated I

against the evidence produced by the inspections and other sources:

i 19 major defects were found; 7 in Lot 4 and 12 in Lot 1.

These defects fall into 3 incidents as follows:

1.

Seven [7] major defects in Lot 4 were all in one incident and are documented in LER 87-13.

The Seven cables were to have been moved by ECN A-4942 from Fire Area 36 to Fire Area 31, but were left in place.

Associated with this incident are the seven additional cables that were to have been rerouted into fire wrapped conduit in Fire Area 17.

The c. ables were identified by LER 86-10 prior to the start of the Sampling Program, and are not counted as major defects. The misrouted cables could have caused a loss of redundancy l

if a fire had occurred in either Fire Area 17 or 36.

The direct cause of the cable misrouting has been identified as persennel error.

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b Enclosure i

To GCA 88-001 Page 85 ITEM NO. 28 TONTINUED 2.

Eleven [11] Major Defects were found to have been caused in a second I

incident in 1981 when a power and control tray was re-tagged as an instrument tray but without the eleven power and control cables being i

removed.

The direct cause appears to be failure by construction to pull back cable as required by design documents.

3.

One [1] Majoi Defect was caused in 1984 when a Class I conduit stopped short of a floor blockout, causing the cable installer to complete the last four feet of the route in a Non-Class 1 cable tray.

i Evidence - Other Than Inspections 1

An examination of all sources [such as LERs, 00Rs, NCRs] for major defects in

{

Populations 1, 2, 3, and 4 have found no major defects to add to the total of 19 found by the inspections other than the 7 major defects reported in LER 86-10 a

which are part of the same incident reported in LER 87-13 and discussed as part of incident #1.

-]

l The major defects found are therefore limited to the three incidents described.

This fact is strong evidence to suggest that there was no systematic breakdown in the design and/or installation process for cables but rather a limited nunber

[3] of specific incidents.

This is taken as an indication that the real number o

of major defects, which would be found by a 1001, inspection, is likely to be less than the statistically inferred totals.

a Correlation between earlier precedents [ established by NRC] for acceptance of f

i 95/95 sampling of safety related components [such as structural steel welds and

]

concrete expansion bolts) is viewed as follows, i

Given a possible discrepant (major defect] population of 31, the following must t

occur coincidentally to impact plant safety.

I 1)

A major defect or defects have to exist in safety related components.

c q

2)

The major defect or defects have to involve a loss of redundancy in safety system.

3)

An incident or accident has to cause a coincident failure in I

redundant safety systems.

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Enclosure To GCA 88-001 Page 86 ITEM NO. 28 CONTINUED The basis of the NRC acceptance of 95/95 sampling for structural steel weld inspections is assumed to be the low probability of coincident weld failure in supports of redundant systems.

The following must occur to cause a loss of redundancy:

1.

A defective weld must exist in the welded steel supporting a safety system.

2.

A defectiva weld must also exist in the welded steel supporting the redundant safety system.

3.

An incident or accident must cause stresses resulting in weld failures in welded supports for redundant safety systems.

4.

The failures must be sufficiently severe to impair safety function (in both sets of equipment) below an acceptable level.

The basis of the NRC acceptance of 95/95 sampling for concrete expansion bolts is assumed to be the low probability of coincident failures in redundant safety related equipment.

The following must occur to cause a loss of redundancy:

1.

Defects must exist in bolts holding down safety related equipment.

2.

Defects must also exist in bolts holding down redundant safety related equipment.

3.

An incident or accident must cause stresses resulting in bolt failures in both sets of equipment.

4.

The failures must be sufficiently severe to impair safety function

[in both sets of equipment] below an acceptable level.

For major defects in the cable routes of safety related cables the possibility of coincident failures in redundant safety systems is more complex.

The types of major defects ider.tified at Rancho Seco include:

A.

Redundant safety cables in the same fire area (14 cables in 1 incident].

B.

Lack of acceptable separation between Class 1 cables and Non-Class 1 cables [2 cables in 1 incident].

C.

Lack of acceptable separation between Class 1 instrument cables and Class 1 power / control cable [42 cables in 6 incidents).

Enclosure To GCA 88-001

~

Page 87 I

ITEM NO. 28 CONTINUED i

A, B, and C defects have been identified in the Rancho Seco cable populations and are consider 9d viable.

Possible scenarios which could impact plant safety l

are 3

1.

Major Defect A.

A fire causing a loss of redundancy.

j 2.

Major Defect B.

An electrical overcurrent condition in a Non-Class 1 cable combined with a single failure in an overcurrent device. This could cause a condition in which a cable failure could impact a Class 1 cable [ lacking adequate separation) resulting in a loss of safety function.

3 3.

Major Defect C.

An electrical transient in a power cable causing a i

spurious control or indication signal in an instrument cable [ lacking i

i adequate separation).

i l

Scenario 1 postulates a single major defect resulting in a loss of redundancy.

This would appear to indicate the need to reduce the possibility of major i

]

defects to a minimum.

However, for a single incident or accident to cause a loss of redundancy the following must occur:

I i

Major Defect A l

1.

Redundant safety cables must exist in the same fire area.

l 1

2.

A fire must be initiated.

l l

i 3.

The fire detection / prevention system must fail.

i i

4.

The fire must cause a loss of safety function in both IEEE 383 qualified (fire retardant) cables.

5.

Neither loss of safety function is to a "fail-safe" condition.

i Major Defect B l

1.

A lack of acceptable separation must exist between a Class 1 cable and a j

Non-Cl ass 1 cable.

l i

i 2.

A failure must occur in the Non-Class 1 circuit conductor or component.

j i

3.

A failure must occur in a Non-Class 1 circuit protective device.

I 1

4.

The ef fects of the two failures must be sufficiently severe to cause a i

failure in an adjacent Class 1 cable, i

Enclosure To GCA 88-001

}

Page 88 ITEM NO. 28 CONTINUED i

S.

The Class 1 failure is not to a "fail-safe" condition.

l 6.

A simultaneous failure must occur in a redundant Class 1 circuit.

Major Defect C 1.

A lack of separation must exist between a Class 1 instrument cable and a power or control cable.

l 2.

An electrical transient must occur in the power or control cable causing a "spike" (electromagnetic induction) in the instrument cable.

\\

3.

The magnitude of the induced "spike" in the Class 1 instrument cable must be sufficient to initiate a spurious action or indication in the instrument circuit.

4.

A simultaneous failure must occur in a redundant instrument circuit.

From the evidence and discussions provided it would appear that:

The number of major defects in Lot 2 and Lot 3 cable routes, that would be found by a 1001 inspection is likely to be less than thirty-one [31].

i l

The likelihood of major defects in cable routes causing a loss of t

t redundancy in safety systems is not higher than the likelihood for welds and concrete expansion bolts sampled to the same level.

Conclusion The confidence / reliability levels for Lot 2 and Lot 3 are as stated above.

To closely correlate the sample results from three diverse populations appeara imprac tical.

However, based on the logic presented in this commentary, the acceptance of 95/95 for sampling homogeneous populations is considered to be equally valid for cable routes as it is for weld inspections and inspections of r

concrete expansion bolts.

r i

L l

Enclosure To GCA 88-001 Page 69 ITEM NO. 28 CONTINUED Table 1 CRTS Circuit Tracing Results Description tot 1 Lot 2 Lot 3 Lot 4 Lot 2 + 3 Population Size 397 1383 176 78 1559 H

S Sample Size 245 152 91 51 78 142 Circuits Traced 245 152 91 51 78 142 Major Defects 11 1

0 0

7 0

Minor Defects 17 21 4

1 2

5 Insignificant or No Defects 217 130 87 50 69 137 Statistical Infer.

LDFH NA NA 95.0/97.0 96.0/95.5 NA 95.1/98.1 Statistical Infer.

ASH

• NA NA 95.0/95.0 95.8/94.9 NA 95.1/97.9 Total nuraber of circuits traced = 617 l

LActual total was 620 but 3 Lot 2 inspections were not credited)

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

DEFINITION OF LOTS Lot 1: Safety related and safe shutdown circuits with rerouted vias between comuercial operation and DececLer 22, 1986.

Lot 2: Safety related and safe shutdown circuits without rerouted vias between commercial operation and December 22, 1966.

Lot 3: Safety related and safe shutdown circuits without revised vias and questionable cable pull card signatures.

Lot 4:

Safety related and safe shutdown circuits with rerouted vias and questionable cable card signatures.

Enclosure To GCA 88-001 Page 90 ITEM NO. 29 DESCRIPTION Provide an itemized listing and description of changes in procedures and controls for cable design and installation which have been made in response to the identified cabit deficiencies.

COMMENTARY The changes in procedures and controls made in response to identified cable deficiencies are part of the corrective actions taken by SHUD.

To place the changes in context, each identified cable deficier.cy is discussed (when appropriate] relative to direct and root causes together with a description and detail of each corrective action.

For convenience in considering corrective actions, they are presented in six groups:

1.0 CRTS Procedures and Cable Design Interface.

2.0 CRTS Procedures and Cable Installation Interface.

3.0 CRTS and Engineering Design Problems.

4.0 CRTS and Data Discrepancies.

5.0 CRTS and Documents of Record.

6.0 CRTS and Software Problems.

1.0 CRTS PROCEDURES AND CABLE DESIGN INTERFACE Report Ref:

CRTS Action Items 1 and 2.

Problem:

Hissing and discrepant cRTS data.

Direct Cause:

The direct cause of problems in the CRTS cable design interface area was a lack of CRTS use procedures.

Root Cause:

The root cause of the CRTS problems is that neither Nuclear Engineering management nor the CRTS supervisor were adequately involved in the CRTS.

(Root Cause 87-03, Appendix 5.]

Corrective for a detailed review of corrective actions against Actions:

root cause evaluations, see CRTS Action Item 30.

Immediate Corrective Actions - Pre Restart 1.1 A procedure (NEAP 4127, Rev. O, "Cable and Raceway Tracking System") was issued on June 15, 1987 and controls the method by which proposed changes to the CRTS data base are submitted, approved and incorporated.

Enclosure To GCA 88-001 Paae 91 ITEM NO. 29 CONTINUED 1.2 As described in the commentary to CRTS Action Item 6, a NED instruction given on May 1, 1987, and effective on June 15, l

1987, requires all CRTS input documents / forms to be handled as l

Drawing Change Notices (Reference EEGS87-005, from E. J. Gough to the Electrical Engineering Staff, dated May 1, 1987).

This corrected a practice in which new forms were issued for all changes.

l Future Corrective Actions - Pre or Post Restart 1.3 A full time CRTS Administrator (contract employee) has been in place since April 2, 1986 and is responsible for implementation i

of NEAP 4127. A CRTS Coordinator (Section 4.7 of NEAP 4127]

l j

receives and inputs data. 5 MUD Personnel Department has been advertising for a CRTS Group Leader since June 22, 1987.

The j

Group Leader hired by SMUD will replace the CRTS Administrator

(

after a suitable overlap. The CRTS organization chart (Figure i

l (1)] is shown at the end of this section together with the j

organization chart for the NED Electrical section (Figure (2)].

l l

2.0 CRTS PROCEDURES AND CABLE INSTALLATION INTERFACE j

Report Ref:

CRTS Action Items 1, 2, 11, 13 and 23.

I Direct Cause:

The direct cause of problems in the CRTS/ cable installation interface was a lack of CRTS use procedures.

i 4

I Root Cause:

The root cause was a failure to have and/or use procedures for cable design, installation, l

inspection, and repulling.

(Root Cause 87-09, i

Appendix 5).

For a detailed review of corrective actions against root cause evaluations, see CRTS Action Item 30.

I Common CRTS problems with past installation practir.e and corrective actions are as follows:

1 i

l

2.1 Problem

Installation cards not returned to CRTS.

Corrective Action:

NEAP 4127 requires cards to be returned to the i

i CRTS Coordinator and held untti the ECN is closed.

The ECN cannot be closed until cards 1

are returned to CRTS and the data accepted by

[

the CRTS Coordinator, j

i i

i' i

a hoNkN-001 Attachm. ant 4 Page 92 ITEM NO. 29 CONTINUED

2.2 Problem

"As-Built" corrections not reported on cards returned to CRTS Coordinator.

Corrective Action:

NEAP 4127 requires Field Problem Reports to be generated if the design cannot be implemented as shown on the design drawings.

Only "installed length" dimensions can be noted on the CRTS card; the practice of allowing field engineers to solve design problems and then to note the "as built" changes on the CRTS card is not penui tted.

Each related MP/IS [ Modification Procedure / Installation Specification] has been revised to reflect the CRTS card handling procedures mandated by NEAP 4127.

The revision to the procedures were effective December 22, 1987.

2.3 Problem

MP/IS 307 did not clearly specify that the inspection of a cable routing is a "hold point" or define that verification of routing requires the installation to be witnessed.

Corrective Action:

PCN #4 [ dated 07-01-87) to MP/IS 307. Rev. O, makes the route inspection a "hold point" and requires the installation to be witnessed.

2.4 Problem

Rancho Seco has approximately 2500 Appendix R cables [2200 Class I and 300 Class 2/3) listed.

The list is a "living" document which is revised on a periodic basis as ECNs are closed.

The problem has been that no procedural requirement has existed to require QC inspection of Class 2 or 3 Appendix "R" cable routes.

Corrective Actions:

Innediate Corrective Actions -- Pro Restart 2.4.1 Since May 1,1987 the Quality Department has been reviewing all Work Requests against a list of 300 Class 2/3 cables. All Appendix R cables have their routes insnected and a "hold point" is indicated on the cable pull card.

Enclosure To GCA 88-001 Page 93 ITEM NO. 29 CONTINUED 2.4.2 As of October 1, 1987 the NED Electrical Engineering physical design group has been identifying all proposed Appendix "R" circuitry via fleid note on the E-1010 DCNs.

(Reference Memo EEGS87-040, dated September 21, 1987.]

2.4.3 NEAP 4119 (Nuclear Engineering Fire Protection Program Control) has been revised, effective November 11, 1987, to require identification of the Appendix R circuits on the CRTS cable input document (Form E-1010).

2.4.4 As part of the review of procedures associated with the resolution to CRTS Action Item 25, the Quality Assurance Procedures (QAPs) and the Modification Frocedures/ Inspection Instructions (HP/ISs] associated with cable installation and inspection will be revised to include the requirement to inspect the Class 2 and 3 Appendix R cables to the same requirements as for Class 1 cable installations.

The appropriate OAPs and HP/ISs will be revised prior to restart.

Future Corrective Actions -- Post RestaIl 2.4.5 CRTS software enhancemant to create a field in the electrical circuit schedule, as well as the cable cards, to indicate the service level of the cable ("P",

"C" or "I") and to identify the Appendix "R" cables ("R"] will be completed prior to the end of the Cycle 8 outage (see commentary to CRTS Action Item 10).

In addition, the L-1010 form will be revised to allow the above information to be input into the CRTS database.

2.5 Problem

Incomplete security cable and communication cable documentation in CRTS.

Corrective Action:

A scoping statement was added to Nuclear Engineering Procedure NEP 4109 "Configuration Control," that requires that all permanent changes to the physical or functional characteristics of Rancho Seco be reviewed and controlled by Nuclear Engineering via the ECH process.

This change appears in Revision 7 to NEP 4109, dated July 29, 1987.

Enclosure To GCA 88-001 Page 94 3

ITEM NO. 29 CONTINUED 3.0 CRTS AND ENGINEERING DESIGN PROB'. EMS 3.1 P0HER AND/0R CONTROL CABLE HIXING HITH INSTRUMENT CABLES Report Ref:

CRTS Action Items 9 and 17.

]

Direct Cause:

The direct causes are either:

1.

Construction error [00Rs87-109, 87-723,87-735, NCR S-5968) or 2.

Design error.

(NCRs S-5263 S-6523, S-6561, S-6562, S-6563 S-6564, S-6566, S-6999]

Root Cause:

Root cause of intermixing was the failure to have and/or use procedures for cable design, installation, inspection and repulling.

[ Root Cause 87-09, Appendix 5.]

For a detailed review of corrective actions egainst root cause evaluations, see CRTS Action Item 30.

Corrective Actions:

] mediate Corrective Actions -- Pre RestAtt 3.1.1 Issut NED clarification of the physical separation requirements for power, control and instrument (P. C and Il cables.

This clarification is included in the commentaries to CRTS Action Items 9 and 17 and covers changes to both NED Design Guides and USAR.

No revision is required to the installation specification fer cable (IS-E-5304.8) because separation of cables by service level (P, C or I] is defined in the design drawings and not in IS-E-5304.8.

3.1.2 Issue NED direction requiring the identification of all cables on CRTS input documents (Form 1010) as "P"

(Power),

"C" (Control) or "I" (Instrumentation). A memo (EEGS87-006) from E. J. Gough to the Electrical Engineering Staff, dated Hay 4, 1987, was issued directing the following:

Enclosure To GCA 88-001 6.ttarJ) ment 4 Page 95 ITEM NO. 29 CONTINUED,,'

1 "Effective immediately, each new cable scheme numbershallhaveitsserviceJovel(power, o

control and instrumentation (analog or digital)]

shown on E-1010s."

b

{,

3.1.3 Revise NEPH 5204.22 and NEPH 5204.4!>,to define required separation between power, control and instrument cables in raceways and manho M (PCNr issued on both, dated July 27, 1987).

Future Corrective Actions fBefore end of Cvele 8 outagel 3.1.4 CRTS software will be enhanc'ed to screen raceways for service level mixing (P ar.j!or C with Il and block proposed changes which violate Design Criteria. 3 3.2 CABLE TRAY TILL AND HEICHT CONCERT 3 i

Report Ref:

CRTS Action Items 6 and 8.

Direct Cause:

Inadequate procedural guidatice.

Root Cause:

The root cause of the overweight cable tray problem is the failure to ensure adequate implementation of USAR requirements.

[ Root Cause 87-05, Appendix 5)

I for detailed review of corrective actions against root cause evaluations, see CRTS Action Item 30.

l Corrective Actions:

1 L

Imediate Cerrective Actions -- Pre Restart i

3.2.1 All cable tray weights have been calculated regardless of percent fill.

This process was again repeated prior te restart, on December 28, 1987, as described in the comentary to CRTS Action Item 2.

1 i

3.2.2 NEAP 4127 is issued and governs the CRTS process.

l Step 5.2.4 requires proposed changes, which violato design liinits, to be returned to the originator, as follows:

i l

l

\\

1

s/

[

E 4.-

Enclosure To GCA 88-001 Page 96

(

)

ITEM NO. 29

_ CONTINUED--

"5.2.4 After entry, an error report is generated to ensure that the proposed changes are feasible and do not violate design limits.

If the report indicates design errors, the CRTS coordinator notifies the originator.

The originator resolves the problems and i

provides corrected DCNs to the CRTS coordinator."

i

]

The design limits imposed by the CRTS program are I

process controls at this time. CRTS staff are directed to return all DCNr to Engineering when the addition of cables to trays:

Increases power and control tray fills above 40%.

Increases instrument tray fills above 50%.

Th. power c.ad control trays are given a 50.59 review for weight and ampacity limits.

Instrument trays are reviewed for weight only. Checked cable trays which i

exceed limits are redesigned and resubmitted.

Checked cable trays which meet design limits are resubmitted to CRTS after the 50.59 review.

The weight and dimensional data for the approximately 450 f

cab.e codes will be validated against available manufacturers data or validated against a sample or model.

l 3.2.3 The lack of 50.59 reviews for design work done in 1975-1986 will be resolved through the NCR process with a forecast completion date of January 8, 1988.

l Future Corrective Actions fBefore and of Cvele 8 Outaael I

3.2.4 USAR wording will be revised and clarified as described in the commentary to CRTS Action Item 17.

l 4

l 3.2.5 Following completion of the completeness checks on CRTS content (CRTS Action Items 10, 11, 12, 13 and 14), the impact of any added cables will be l

l reviewed.

In addition, the impact of weight contrDutions from various sources such as cable tray 4

covers and protective fire wraps will be checked l

against design limits.

I l

l l

l l

t

{

t Enclosure To GCA 88-001 Page 97 ITEM NO 29

CONTINUED _

3.2.6 CRTS software will be enhanced to automatically block cable additions which exceed design limits.

In addition to calculating percentage fill, CRTS will calculate weight per cable tray section.

Design changes which exceed the minimum 50 pounds per linear foot limit will not be accepted without a 50.59 t

review.

4.0 CRTS AND DATA DISCREPANCIES i

Report Ref:

CRTS Action Item 2 Direct Cause:

Inadequate procedural guidance.

[

Root Cause:

Tha root cause of the problems related to the CRTS 4

and its use is that neither Nuclear Engineering management nor the CRTS Supervisor were adequately l

involved in the CRTS.

t Corrective Actions:

4 t

The large number of data discrepancies concerning the Rancho Seco l

Cable Raceway Tracking Syster originate frose a nus.ber of sources.

Many of these problems have occurred because of a lack of procedural guidance, such as the intermixing of power, control and instrumentation cables, the overfilling of raceways and the misrouting of cablei and are discussed elsewhere in this commentary, i

as well as in separate commentaries within this report.

It is Important to note that no physical cable problems nor CRTS data discrepancies have been caused by the CRTS program itself, but have i

all been caused by souret.s external to the CRTS program, and as described in Section 6.0, the software problems affect solely the ability to generate the variout CRTS reports and have not affected the accuracy of the CRTS database, nor has data been lost.

l An additional source of potential data discrepancies that must be j

examined would be the possibility of data discrepancies occurring during the inputting of data into the CRVS database. This question was raised with the CRTS staff and it has been determined that an j

insignificant number of data discrepancies can be attributed to this source, for the following reasons:

l l

1)

The CRTS software performs checking of input data.

Errant data such as non-existent cable codes or non-existent raceways (in i

cable routed cannot be entered since the self-checking l

mechanisms in the CRTC program would block such errors.

I l

Enclosure To GCA 88-001 Page 98 ITEH NO. 29 CONTINUED 2)

A hardcopy is made of all newly entered data and is checked by the CRTS staff to ensure that the data has been input correctly.

In addition, upon ECN closure, when the "proposed" data is changed to "as-built" data, the yellow DCNs to the CRTS related drawings are checked against the data base to verify the accuracy of the database.

3)

The Card Control Group, upon receipt of the CRTS generated cards, compares the data on the cards against the DCNs to the applicable CRTS-related drawings (E-1008 and E-1010) to ensure that the data was input correctly into the database.

Individually, each of the above three methods does not provide complete assurance against data input errors, however, together the three methods provide an interlocking mechanism to screen out data input errors to the CRTS database. Of the approximately 8000 total CRTS database discrepancies listed in the Action Plan [ Appendix (2)), approximately 2500 are document discrepancies. Of the 2500 document discrepancies, none are as a result of a mismatch between the CRTS-related drawings and the CR7S data base itself As a result of corrective acticns for other CRTS related problems, an increased emphasis has been placed on formalizing the methods by which the CRTS staff performs its work, as well as how the CRTS staff interfaces with the other plant groups, such as the Card Control Group ano the Records Information Center.

This is being done by a CRTS office procedure, as well as a fic. chart [Figu.e (3)] delineating the CRTS staff li.terfaces with the Card Control Group and the Records Information Center.

Farecast compietto, for l

proceduralizing the activitias of the CRTS ttaff is prior to the end of the Cycle 8 outage.

5.0 CRTS AND DOCUMENTS OF P.ECORD Report Ref:

CRTS Action Items 3 and 22.

Problem:

The documents of record (CRTS card 4] for cable and raceway installed at Rancho Seco are incomplete.

I CRTS input documents [ Form 1010, etc.) were not being i

controlled as Drawing Change Notices, l

Direct Cause:

Lack of CRTS use procedures.

l c

1

Enclosure To GCA 88-001 Page 99 L

ITEM NO. 29 CONTINUED Root Cause:

The roct cause of the problems related to the CRTS and its use is that neither Nuclear Engineering i

management nor the CRTS Supervisor were adequately involved in the CRTS.

Corrective Actions:

Corrective Actions for both Installation Verification Records and Engineering Design Records are as follows:

1 Installation Verification Records i

I l

The installation verification records for installed cable and raceway at Rancho Seco are the signed cable "pull cards" and "raceway installation" cards, respectively.

The original cards for the 14,000 cables and 13,000 raceways installed during the

{

construction of Rancho Seco have not been found.

Facsimile copies l

exist as attachments to the Construction Inspection Data Reports l

(CIDRs), and require sorting and filing to verify completeness.

This activity will be performed prior to the end of the Cycle 8 i

g outage.

j Presently, after the signed, completed CRTS generated cards are returned to the CRTS group, the cards are microfilmed by the Records Information Center, to be part of the permanent plant microfilm i

record. The cards are then returned to the CRTS group for storage 4

I in the Bechtel Building vault, which is a secure, locked room with i

cement walls and a Halon fire protection system.

l As described in the commentary to CRTS Action Item 3, not all CRTS 1

generated cards have been located. Corrective action is to generate i

replacement cards, to be checked against the design documents.

I Checked cards will be stamped "Replacement Card" and will then be signed by the checker. This activity will be completed for Class I 4

and Appendix "R" pull cards before re3 tart and for all other cards i

before the end of the Cycle 8 outage.

In addition, NEAP 4127 was 1ssued in June, 1987 and is considered adequate to control the CRTS generated cards in the future; see also Section 2.0 of this commentary.

t Engineerina Design Record NEAP 4127, "Cable and Raceway Tracking System," defines the t

CRTS-related drawings as follows:

l

\\

l E-1008 Shows raceway sections, including attributes and l

connections.

i l

l

Enclosure To GCA 88-001 Page 100 ITEM NO. 29 CONTINQLQ_

E-1010 Shows cables, including termination, cable code, conductors, and vias as applicable.

E-1026 Adds, deletes or modifies a raceway code.

E-1027 Adds, deletes or modifies a cable code.

E-1028 Adds, deletes or modifies an equipment number.

In January 1987, 00R 87-66 and NCR S-6278 document that the E-1010 drawings were not being processed in accordance with Nuclear Engineering Procedures. As corrective action, a memo [EEGS 87-005]

from E. J. Gough to the Electrical Engineering Staff, dated May 1, 1987, was issued to require that the CRTS-related drawings be issued and revised per NEP 4103 and NEP 4112, respectively.

6.0 CRTS AND SOFTWARE PROBLEMS Report Ref:

CRTS Action Item 10.

Problem:

The CRTS software has 41 identified bugs.

Direct Cause:

The direct cause of CRTS software bugs is the lack of verification of the CDC software.

Root Cause:

A root cause investigation is not required.

The direct cause is considered definitive.

Corrective Actions:

i immediate Actions -- Pre Restart Four personnel have been added to correct software problems. A computer data base has been established to track the forty-one identified bugs to resolution. All bugs which Impact restart commitments will be identified and corrected prior to restart.

Eyture -- Post Restart i

SHUD (IMS) is preparing a schedule and budget for providing upgraded CRTS sof tware, including verification.

The schedule will show the upgraded software verified and in place before the conclusion of the Cycle 8 outage, i

m----- -

i RANCCD $tCO WUCLEAR CthttAtlNG STAfl00 Enclosure CA8tt MCtWAY 1 RACK!WG SYSTEM (CRTS)

To GCA 88-001 ORCAWilAf!ON CHART

(

e 00VCLAS M. PALWER CRf8 ACMlut$itATOR SARBARA TouhGOUIST JtFF JotCEnt(W l

(CETS thGlWEtt OrtW)

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Alfxanett PARAS MICHAFL CutttY thGlktttikG AICE Ctt$ ELECitlCAL tt;thtta Ctt$ (40!kttt Ctf 3 Processing Cable Coje Verdse Work Bug Tracking Discrepancy flaing B W fla Testing Construction Liaison

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R0hALD WATSCW 3

CLint Caf$ Card Control Clerking Duties E

Ef fective Date: 09 23 87 Revision Cate:

09 29 87 Fir,ure 1 Ccomuter tite ctTS. cot

-101-(

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Enclosure To GCA 88-001

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Enclosure To GCA 88-001 Page 104 ITEH NO. 30 LESCRIPTION Review of corrective actions against root cause evaluations.

COMMENTARY A table summarizing direct and root causes is included at the end of this cornentary.

A detailed review of recomendations contained in each root cause is given in the conraentary.

ROOT CAUSE 86-10 kedundant cabling in the sarae fire area LLER 86-10).

SU! GARY I

The direct cause of the failure to reroute the cabl6s is personnel error.

Although the construction field engineer was aware of the routing revisions, l

ne did not initiate the field installation of the "C" revision of the cable i

routing.

j ine underlying cause is that the Card Control Group [CCG) did not follow Engineering and Inspection Instruction LEIIJ EC-10 "Processing of Installation 1'

Cards."

A contributing cause of this event was Quality Assurance's failure to perforn l

l adequate inspections of cable installations.

I The root cause is the failure of the Card Control Group cognizant engineer to impiceent adequate managerial controls.

He did not require the use of adequate and formal procedures for the processing of installation cards by the CCG.

[

Recommendations Corrective Actions 1.-4.

Issue a procedure (s) which CRIS card control is described in

7. 8.

estaolishes instructions for Attachment I to NEAP 4127. Rev. O.

3 4

]

16.

the processing of cable is a CRTS flowchart which i

17, installation cards, illustrates the process from ECN issue i

to the filing of the CRTS cards j

following ECN closure, p

I I

l 1

I

Enclosure To GCA 88-001 At%acloent 4 Page 105 ITEM NO. 30 CONTINUED i

Recocnendations Corrective Actions A more detailed card handling process is provided in a card flowchart included as part of CRTS Action Iten 29 connentary.

This flowchart illustrates the decision-making process used by the Card Control Group Lsee organization chart for CRTS also included with the Item 29 cocuentary) in handling cards.

l The Card Flowchart illustrates the work l

process in place at this time. A 4

written document, to proceduralize the process shown on the Card Flowchart, is being prepared as an Electrical Engineering Instruction [EE!]. The l

forecast issue date is January 18, 1968.

5.

After the procedure in Following issuance of the Card Control I

recowaendation number 1 is EEI, formal training will be conducted issued, train the Card for personnel who are either in the Control Group LCCG)

Card Control Group or who handle CRTS l

personnel on the procedure, cards in the interfacing groups LHodifications, Maintenance, Quality i

Control, etc.) This training will be conducted for new personnel entering these groups in an ongoing process.

Training will be conducted under the l

auspices of the Nuclear Engineering i,

Dept. [kED) with classroom training and l

l with records maintained in both NED f

1 files and by the huclear Training Group.

l 9.

Establish a ShuD signature SMUD Support Services-Records i

transcription policy.

Management Group [RMG) has established l

j policies and practices concerning i

records management.

These policies and practices are defined in a Rancho Seco i

Administration Manual (RSAP).

RSAP-0601 "Nuclear Records Management" i

does r.ot permit the transcription of signatures.

Section 5.2.9 "Replacing a i

Lost. Damaged or Contaminated Document" j

governs the process by which lost or camaged records are replaced.

[

f I

I I

t

Enclosure i

To GCA 68-001 Page 106 ITEM NO. 30 CONTINUED l

Recommendations Corrective Actions 9.

(Continued)

"Recreated" originals are allowed for information i, data) docuuents but r

contrni measures are imposed on other recortis which require assessments and l

evidence to support restored records.

[

RHG has no plans to establish a SHUD signature transcription policy.

i Transcribing signatures without compliance with RSAP-0601 would be a a

violaticn of SMUD administration policy.

t i

11.

Evaluate the cable inspection HP/IS-307 will be evaluated against the r

12-17, requirements as stated in findings of the CRTS Action Item 25.

HP/IS-307 to ensure that "Document a thorough engineering the following are adequately evaluation of the procedures and addressed:

specifications used to install cabie in tne period 1976 - 1986." The scheduled 4.

Cable pulls are 1% sue date for the revised itP/IS-307 inspected before the was December 11, 1987.

However, no i

cable is terminated as changes are required; HP/IS 307 is required by the USAR, acceptable "as-is."

b.

Cables are verified to l

be routed irt accordance

[

with the latest design l

orawings, e

c.

Clear guidelines exist i

for the inspection of I

pulled back and

[

repulled cable.

[

1 6.

Route the cables described in LER 86-10: Tne cable rerouting for LER 86-10 and LER 87-13 in cables identified in LER accordance with the 86-10 was perfomed under i

applicable design drawings ECh R-0765 and is tcompl eted).

construction complete.

LER 87-13: Tne cable rerouting for I

cables identifica in LER l

l 87-13 was perfomed under Work Request 128636 and is construction complete.

l l

l 1

i i

Enclosure To GCA 88-001 r

]

Page 107 ITEM NO. 30 CONTINUED L

ROOT CAUSE 67-03 Cable Raceway Tracking System.

f

SUMMARY

The root cause of the problems related to the CRTS ana its use is that neither Nuclear Engineering management nor the CRTS supervisor were adequately involved in the CRTS.

Recor:nendations Corrective Actions 1.

None, kEAP-4127 "Cable and Complete i

t Raceway Tracking System" was issued on June 15, 1987.

i 2.

Revise procedure NEP-4109 Procedure NEAP 4127. Revision 0 was i

"Configuration Control" to issued on June 15, 1987, and includes l

address the CRTS review of in Section 5.2 the procedure by wnich i

DCNs.

DCNs to the CRTS-related drawings

[E-1008. E-1010. E-1026. E-1027 and l

E-1028] are initiated, reviewed and approved.

Sections 5.2.2 thraugh 5.2.5 l

specifically address the CRTS review of the DCNs to the CRTS-related drawings, l

and no further procedural revision is l

J requi red, i

i 3.

Review and approve for use a An uncontrolled CRTS User's Guide is I

CRTS User's Guide, currently in use by the CRTS Card l

Control Group (CCG).

This document will be superseded by two guides.

o Card Control Group CRTS i

j User's Guide

[

o Design Group CRTS User's I

Guide l

Ine forcer will be the definitive document of the two, and will be used by CCG.

The latter will be used by engineers and designers performing physical design work.

Botn documents are scheduled for issue on January 18, L

f 1988.

[

t I

l 1

F l

[

Enclosure To GCA 88-001 Page 108 ITEH NO. 30

~ CONTINUED i

Recotnendations Corrective Actions 4.8 Verify and validate CRTS The corrective actions are described in I

sof tware, the cottaentary to CRTS Action Item 10.

j 5.9 Develop and implement a Tne commentary to CRTS Action Item 2 l

schedule to correct all contains the general commitment that:

known CRTS deficiencies.

l 1.

All safety-related i

discrepancies will be 1

dispositioned, with i

documentation, prior to i

resta rt.

2.

All non-safety-related discrepancies will be dispositioned, with documentation, prior to the end of the Cycle 8 outage.

[

i t

Attachments 1, 2 and 3 of the Wire and Cable Program Report provide an index l

to CRTS action items, CRTS 00Rs, and CRTS NCRs which track all discrepancies and their dispositions.

6.

Include the CRTS system in NEAP 4127 was issued on June 15, 1987.

I i

the Quality Assurance NEAPS are controlled by the Rancho Seco i

program.

Quality Assurance program.

This i teni

[

is complete.

7.

Establish the design basis A CRTS System Design Basis Document for the uses of tne CRTS will be written as part of the l

system.

NED/ Electrical Discipline program to L

furnish design basis documents defining the criteria for Land the scope and l

}

function ofj all electrical systems.

l J

l The CRTS System Design Basis Document is scheduled for issue prior to the eno i

j of the Cycle 8 outage.

l I

I I

1 I

a 1

Enclosure i

To GCA 88-001 i

Page 109 ITEM NO. 30 CONTINUED 1

ROOT CAUSE 87-05 2

Overweight cable trays LLER 87-24).

SUPEARY The direct cause of the overweight cable tray problem is inadequate procedural guidance.

The root cause of the overweight cable tray problem is the failure to ensure

[

adequate procedural implementation of USAR requirements.

Recomendations Corrective Actions 1.

Perform 10 CFR 50.59 Safety The 50.59 reviews will be performed via Arialysis Reviews for the the NCR process, with a forecast l

redundant (SFAS and RPS) completion date of January 8,1988.

Class IE cable trays that r

exceed the USAR fill limit of 401.

j 2.

Provide calculations to The corrective actions for overfilled verify the cable tray cable trays are contained in the i

loading for all overfilled comentaries to CRTS Action Items 6 and cable trays.

8.

An additional comitment to check j

all tray weights (regardless of fill levelj prior to restart is contained in j

the comentary to CRTS Action Iteo 2.

Tnis recheck was performed on i

December 28, 1987, as described in the j

i cocuentary to CRTS Action Item 2.

4.

Proceduralize the approval CRTS error reports indicating tray cycle required to exceed the overfill conditions cause the OCNs to i

l fill limits on cable trays, be returned to the originator for f

resolution.

This is described in the i

connentary to CRTS Action Item 8.

This i

review process is being proceduralized 4

j in an EEI LElectrical Engineering f

Instructionj scheduled for issue in

{

June 1%8.

f

(

I 5.

Resolve the discrepancy The USAR revision to provide t

Detween procedure NEP 5204.22 reconciliation between USAR Section l

and tne USAR.

8.2.2.ll H 9 and NEP 5204.22 is described in Section 6 of the l

j comentary to CRTS Action Iter.117.

(

i c

l l

Enclosure To GCA 68-001 l

Page 110 ITEM NO. 30 CONTINUED Recornendations Corrective Actions 6.

Evaluate adding a subroutine The connentary to CRTS Action Item 10 i

to the CRTS to calculate includes a list of software cable triy weights.

enhancements.

Enhancement N3 will provide a weight calculation for all r

cable trays regardless of fill level.

ROOT CAUSE 87-09 Unacceptable intermixing of power / control and instrumentation cables LLER 67-26).

SUMMARY

Cable Tray A28AA3 and A28AB3 j

j Direct Cause:

Construction error.

Underlying Cause:

Construction personnel failure to follow Procedure EC-10.

f I

Contributing Cause: Failute of QC to detect construction error.

i Cable Tray A28AN3 Direct Cause:

Design error, l

Contributing Cause: Lack of a comprehensive service level designator.

I

{

l Cable Tray A28AAl l

Direct Cause:

Either a design error or a construction error during 7

construction of the plant.

Contributing Cause: Lack of a comprenensive service level designator.

)

i i

Routing RPS/SFAS Cables in Tray Rather than Conduit l

Direct Cause:

Original design error, i

4 j

Underlying Cause:

Lack of training.

i f

1 t

i

~-- --. -_.

Enclosure s

To GCA 88-001 Attachm9nt 4 Page 111

[

! TEM NO. 30 CONTINUED Cables Associated with DHS X-Tie Flow Transmitters 1

i Direct Cause:

Design error.

l l

Underlying Cause:

Lack of training, Cables Associated with RCS Flow Transmitters i

f Direct Cause:

Original Design error.

L Underlying Cause:

Lack of training.

l i

I L

I ROOT CAUSE (Overall)

I i

Failure to have and/or use procedures for cable design, installation, inspection, and repulling.

l l

Recotnendations Corrective Actions

{

(1)

Revise electrical design The USAR text is being revised as procedures to include described in CRTS Action Item USAR requirements.

Cocynentary 17.

[

Corresponding revisions to Design l

Documents NEPH 5204.22 and NEPH 5204.43 were issued on October 5,1987.

Refer l

to CRTS Action Item CoGaentary 9 for 1

detail s.

i I

(2)

Require the witnessing of Complete.

PCN #4 (07-01-87) revised i

I cable pulls by electrical HP/IS 307.

See connentary to CRTS I

QC inspectors.

LCompleted)

Action Item 29 (Section 2.3),

j i

(3)

Evaluate the training given Supervisors attend numerous training j

to District supervisors to programs provided by SHUD to improve ensure that they are fully their management skills. Tnere is no cognizant of their areas fornal training or their specific areas of responsibilities, of responsibilities.

Inforaal training l

is provided by the supervisor's

[

t respective manager, j

(4)

Assure that all QC inspectors Complete.

l receive training on District l

procedures.

1, Completed) l l

l l

i l

i 4

l 2

~

..,-m

---

,.w-.

g

Enclosure To GCA 88-001 4

Attachrent 4 Page 112 1 TEM NO. 30 i

CONTINUED Recommendations Corrective Actions j

(6)

Provide a service level Since July 1987, cable input documents designator for all are marked "P" LPowerj, "C" (Control]

electrical cables, or "1" L!nstrumentation). Sof tware r

enhancements are also planned. See l

CRTS Action Item Commentaries 9 and 10 for details, j

(6)

Provide the necessary CRTS Refer to the cocuentary to CRTS Action l

software for the verification Item 10.

that intermixing conditions l

j i,

do not exist.

l (7)

Evaluate the necessity for 4 Per MP/IS 307, cable installation is i

CRTS generated repull card, performed using both the E-1010 series drawing and the CRTS generated card, i

Repulls are presently indicated on the i

E-1010 series drawing via field note.

4 The recomendation to generate a unique CRTS repull card will also be included i

in the list of CRTS enhancements in the commentary to CRTS Action Item 10.

(b)

Issue procedures for the use Complete.

NEAP 4127 was issued l

j of the CRTS.

LCompleted]

J u ne_15, 1987.

l i

i (9)

Establish the design basis See response *w RC 67-03 l

(11) for tne uses of the CRTS recocoendation 7.

l (15) system LRC 67-03, recocnenaation 7].

i (10)

Revise / issue procedures for See response to RC 86-10 cable installation to reconnendation il.c f

1 address the pull back and rerouting of cable in revised

?

routings.

LRC 86-10, recomendation ll.c) l

]

(12)

Evaluate the training given New engincers attend an orientation and j

to entry level engineers to indoctrination course where specific assure that they receive Licensing Basis Documents [LB0] and l

training on their assigned pertinent job relatea references are i

functions.

discussed.

System training is also r

provided and is geared to the job l

responsibilities of the individual

]i empl oyee.

l

\\

l i

i

Enclosure i

To GCA 88-001 j

Attach ent 4 Page 113 ITEM NO. 30 f

CONTINUED i

Reconnendations Corrective Actions i

l (14)

Issue a procedure for the See response to RC 86-10 processing of installation recomendation 1.

~

cards. LRC 86-10, recomendation 1J.

)

(16)

Ensuro that all engineers, All engineers are trained (with including contractors, documentation] by reading selected NED i

receive training on USAR and project administrative procedures requirements for their as assigned by the NED Training job function.

Coordinator.

Additionally, selected j

i SMUD and contract personnel are trained j

j to Rancho Seco LBDs as applicable to 10_CFR_50.59 reviews, t

ROOT CAUSE 07-02 f

f Pulled cables stored in safety-related breaker cubicles (LER 87-16J.

i

SUMMARY

i l

The direct cause of the coiled cables being lef t in all the cabinets, other than A405 and A409, was a planning error:

the cable terminations should have been scheduled to occur imediately following the cable pull, but were not.

Tne direct cause of the coiled cables being lef t in cabinets A405 and A409 was 3

j a design error; the effects of the coiled spare cables on the seismic analysis

]

were not considered.

}

Tne Root Cause of cables being lef t coiled and unrastrained in safety-related breaker cubicle cabinets was inadequate procedures for the installation of I

a electrical caoles.

[

Recormndations Corrective Actions 1.

Evaluate the pulling of cables See response to RC 86-10 Reconnendation into and the coiling of cables 11.

LFor reconnendations 1, 2. 3, 4 in existing plant equipment, and 5.]

i Based on the findings of the i

evaluation, revise Procedure LM 167 and the connitnents

)

l made in LER 87-10.

Update j

]

LLR 87-10 as appropriate.

j L

t i

i 4

~i i

j i

Enclosure To GCA 88-001 Page 114 ITEM NO. 30

__ CONTINUED Recommenda tions Corre0tive Actions 2.

Revise EH.187 "Control of Electrical Plant Modifications" to either:

1) provice guidelines for the cable configuration where the cable has been pulled into existing plant equip.1ent and cable termination will not be accomplished immediately af ter the cable pull or 2) prohibit the pulling i

into and coiling of l

cable in existing plant equi pment.

3.

Provide guidelines in the M.nintenance and Modification j

Deparusent procedures concerning what types of j

equipment or what equipment may have cables pulled into and coiled when termination is not seneduled to occur irrmdi ately.

j 4.

Revise MP/IS 307, "Cable i

Installation," and EH.163, a

"Installation of Permanent Plant Cables," to describe the process by which cables are declared to be spares.

5.

Revise Procedure AP.44, "Plant hodifications - ECN l

Implementation," to include tne coordination of work between Construction and Flectrical Maintenance personnel for electrical modifications.

i i

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