IR 05000445/1987030

Insp Repts 50-445/87-30 & 50-446/87-22 on 871104-1201. Violations Noted.Major Areas Inspected:Applicant Actions on Previous Insp Findings,Followup on Items of Noncompliance/ Deviations & Electrical Corrective Action Program

ML20237D596
Person / Time
Site:	Comanche Peak
Issue date:	12/16/1987
From:	Livermore H, Wagner P NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20237D587	List: IR 05000445/1987030 ML20237D585 ML20237D591
References
50-445-87-30, 50-446-87-22, NUDOCS 8712240063
Download: ML20237D596 (15)

Text

-- -_ - - ____ - ______ - ____-_-_______-________ _

l

,

APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report: 50-445/87-30 Permits: CPPR-126 50-446/87-22 CPPR-127 Dockets: 50-445 Category: A2 50-446

.

Construction Permit Expiration Dates:

Unit 1: August 1, 1988 Unit 2: Extension request submitte Applicant: TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: November 4 through December 1, 1987 Inspected by: h.O- %M '1/15/ 6 7 P. C. Wagner, Iteactor Inspector Date Reviewed by: /?'5 0) m 5 krf /?/N/87 H. H. Livermore, Lead Senior Dat'e Inspector 8712240063 871226 PDR ADDCK 05000445 PD3

.. _ _ - _ _ _ _ _ _ _ - _ _ - _

r______

.

.

'

Inspection Summary:

Inspection Conducted: November 4 through December 1, 1987 (Report 50-445/87-30; 50-446/87-22)

Areas Inspected: Nonroutine, unannounced inspection of applicant actions on previous inspection findings, follow-up on items of noncompliance / deviations, electrical corrective action program, and general plant areas (tours).

Results: Within the 4 areas inspected, two violations (failure to control modifications, paragraph 7 and failure to control drawings, paragraph 7) were identified. These two violations are similar to earlier identified violations 445/8711-V-02 and 445/8607-V-2 In addition to the meeting to discuss the problems mentioned above, the NRC inspectors held two discussions with applicant personnel to ,

discuss NRC concerns over changes to the electrica3 erection i specification. Those concerns which were not resolved are being followed as five open item .

. _ - _ _ _ . . . _ _ _ _ . . _ _ - - _ - -

'

> i

';

,

$,f

. .

/ #

'

i ,

/,'

'

DETAILS

, Persons Contacted ,

-

• R. P. Baker, Engineering Assurance (EA) Regulatory 'Ch.np?.iance l

i Manager, TU Electric

• R. D. Best, Nuclear Operations Inspection Report Item Coordinator, TU Electric

• D. N. Bize, Regulatory Compliance, TU Electric

• J. Conly, Lead Licensing Engineer, Stone & Webster Engineering Corporation (SWEC)

• C. G. Creamer, Instrumentation & Control Engineering Manager, ,:

TU Electric ' '

<

• R. D. Delano, Licensing Engineer, TU Electric

• P. E. Halstead, Manager, Quality Control (QC), TU Electric \^

L. Heatherly, EA Regulatory Compliance Engineer, ^

• i TU Electric

• D. A. Hodge, CPRT Interface, TU Electric

'

i g ' ' ) t'

• R. T. Jenkins, Manager, Mechanical Engineering, TU Electric ( ik 1 ""

• J. J. Kelley, Manager, Plant Operations, TU. Electric

'

• J. J. LaMarca, Electrical Engineering Manager, TU Electric

.

,

• O. W. Lowe, Director of Engineering, TU Electric

• D. M. McAfee, Manager, Quality Assurance (QA), TU Electric )

• D. E. Noss, QA Issue Intorface Coordinator, TU Electric j

• D. M. Reynerson, Director of Construction, TU Electric  ;

• M. J. Riggs, Plant Evaluation Manager, TU Electric;3 > /1

• A. B. Scott, Vice President, Nuclear Operations, TU Electric l

• C. E. Scott, Manager, Startup, TU Electric

• J. Smith, Plant Operations Staff, TU Electric ,.s'g

• J. Streeter, Director, QA, TU Electric ,s

• C. Terry, Unit 1 Project Manager, TU Ele:tric j

• T. Tyler, Director, Projects, TU Elect 7.ic j The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the December 1, 1987, exit intervie . Applicant Action on Previous Inspection Findings (927011

' (Closed) Open Item (445/8706-0-04): Follow-up on [

recommendations related to heat shrinkable insulation to sleeves. The Results Report for Issue Specific AUcion I Plan (ISAP) I.a.1, " Heat Shrinkable Cable Insulation f i Sleeve," made certain recommendations for supp?.emental j actions related to these sleeve The NRC inspector has d

\~

commenced an inspection of the program being iti.plemented  !

in response to those recommendations; eee par 4 graph 4, t r belo Since a program has been implen'.ented, the open j item to ensure NRC review of the actions to implement the recommendations can be close l l

l

,

a-

,

3, y- \ ,3 3,

9 ,

,,

g,. , j )  ;

j c (, -

. ,

v

?

,,,' 1

>

, [l ',

q< ( ,

,

,

'

\

fl',

'! 'j* '( ,ef c

.

.

'

o  : .

!

l ( 4J ,',,

i j g,, y i} , p

'

,

s, ,, i ') i ,

- _ ,

/ .r', ( \ 'y y ; { ya

, (Klosed: ladsolk..d; Item ( 4 *.5'/ 871B L U-ll) : Undocumented f

'r i cam,c/ ccdd inst.atied L.n ertrgow:y diesel generator (EDG)

1 3 ,coytsbl parel. Fo%A-up ty the Wu: g inspector disclosed

(J;\' j , the,t no pocamentatiori exigted to herify the acceptability 3 tr of these chpacirops; A: Mpcing Gas held on December 1,

t, 1987, to digcuss thii V tnttionj see paragraph 7, below, i

} '

'

llor the re'duits/ of thr>' meeting. ' This item has been t ,

i f

'

F'

elevd ef tM a vio?Atidniand the inresolved item is ' '

>

'

> A

</ consi&erqd to be closed!

^.  ;

,

l

' ! t q- \ r y , Follow-up r ( - ^/iolationsptoriatic as y 927 02 *) ,

eJ l / o f }b i

' (fliosed) Uniath GM, f 615-D-10): -

Failuim ef'ERC inspectors

,I tp '. identify' a lorna metnting stud' c jam nut < and additional

< eledtrical relays dn a, diesel: generator control' pane By i /fepier dated May lit 1987, the :;pplicant stated that the loose

'

~ jam nut mas not within the scope of the ERC inspect. ion being

conduct;ad.for the rp.ectrical equ'.prannt populd.tiO4 of i ISAP VII.c and thatit N W ERC inspec; ors we:.e able to determine

tb acceptability of the relays by using a design change .

- '.

audorization (DCA) in addit.on to the drawir.y used by the NRC

-' dnspectors. By letter dig d october 5, 1987, the NRC found f

P f the applicant's posi{. ion tW be acongt4ble and althdrew the

'

a

'

r deviatio j

,' >

\' ,

On November 18, 1987, the NRC .anspector verified that an

. ' outu ef-scope observation (1065) ' lad been written to document the lcoge jam nut and that noncqnformance report (NCR)

CM-87-560-X was dispordti'oned on August 7,1987, to rework the jaq nut by' cleaning the mounting,stu6 threads and reinstalling

,

thdnu The inspector.th n vetcdtie6'that the jam nut had

,/, been rewo,rkod gnd est properly installe ,; , ~

I

., ;

' ' ' , '31ect=-lh15 jrhrbctive Acti'on Program ( CAP); Activities 1- (n ]

HeatShrinkabi['/ableInsulationSleeven / ISIS) (510'2D, e >

\ , i In orde't to ; provide t e required elect $rikil insulation, a

) sleeve oftbnat shri N ablel material i's.placed over>an

/. electrica.!/condtactcp prlor to cinnectlag 4ha.t condWtcr to

! anctiher. Af ter the cordd.: tors are cofaected, the inm lating i ,

sleevh is I.noved to covdi the connection while overlapping the

'l

't' conductors. Whea the material is heated by a hot air blcu r, ^

'

it shrinks tN stne size of the conductors. In nuclear facility

'

cpplic'ationst, a special type of sleeve l'h med which it.corporates both insulating and sealing qualides;.'the

,

,,

sealing is accomplished by the presence of an asheciva on the

! interior surface of the. sleeve. . When properlf irstalled,

,

i ,

';

I

/ ' thn? HSIS prov$de notl only the'necessary elecvica ', s

^ '

," (~ Jasulation but Mso the en rironmental seal

~

'

to 'mtain' the

// -

'7 qualification 's,W t're cableg 'i O( .

-

9 i ( ~

,

' i p) , , %

a p -

,o V l . ,1

'

'

{ 4

-

g o- 7;

< .I\,

t .y g, m

~

,i s .

~

'

5 l i

I

'

.,, + i l The NRC documchted deficiencies in the installat1on and QC

inspection of ki$15 in NUREG-0797, Supplement As a result of the NRC findings,'the applicant implemented ISAP I.a.l., ISAP I. <,

The major NRC inupection activities related .to this ISAP are documented in' Inspection Reports (irs) 50-445/86-31, 50-446/86-25 and $0-445/87-06, 50-446/87-05. The NRC

'

'l found the ISAP'to have been acceptably conducted with no implementation violations or deviations being identifie .(The violations of requirements identified in-IR 50-445/86-04; 50-446/S6-03 w'ere for vendor installed l HSIS.) The NRC inspector was following the corrective action recommendations contained in the Results Report for ISAP I.a.1, dated December 30, 1986, as Open Item 445/8706-0-04, see, paragraph'2,'abov These recommendations were:' .

"5.9.1 Document Review of Sleeve Installations A review of QC documentation should be performed for all installations of heat-shrinkable insulation i sleeves in Class 1E circuits in Unit 1, Unit 2, and l Common to determine whether 1) there is conclusive y documented evidence that these sleeves have been installe? where required and inspected, and 2) there wcs adequate QC involvement in the. installation of v

both thu sleeves and the underlying electrical connections. Where the document review indicates inconclusi've evidence of QC involvement, further corrective action should be determined on a case:by-case basi l

"5.9.2 Reinspection of Installations in Harsh Environments A reinspection of all heat-shrinkable insulation sleeve installations in Class 1E circuits in harsh environments in Unit 1, Unit 2, and Common should be performed to ansess the adequacy of the sleeve installations to perform their intended functio Results of these reinspection should then be assessed to determine whether any additional action is required'for installations in mild environments." Specific Technical Issue Report (STIR)

l

'

In response to the recommendations of ISAP I.a.1, Stone and Webster Engineering Corporation (SWEC) produced STIR-CPRT-E-003, " Heat Shrinkable Sleeve Installations."

The STIR provided a program to assure that all'HSIS and electrical splices located in Class lE systems were

,

.

. . . . . . . . .

, _ _ - _ -

.  !

' j l

correctly installed and documente The proposed program {

contained two tasks: documentation review and visual hardware evaluation. The scope of the program included l

the following eight general categories of HSIS t f installation:

l (1) Bunker Ramo electrical penetration assemblies (EPAs)

l (2) Electrical conductor seal assemblies (ECSAs) {

(3) Low voltage cable reduction splices j (4) Device pigtail extension splices 1 (5) Conax EPA pigtail splice  ;

'

(6) Balance of plant splices (7) 6.9kv motor terminations  !

(8) 480v motor terminations, excluding motor operated valves (MOVs)

The installations included in categories 1 through 4 were excluded from the proposed program because of the following:

(1) The Bunker Ramo EPAs are all being replace (NRC inspection found these activities to be acceptable as documented in IR 50-445/87-03; 50-446/87-03 and 50-445/87-07; 50-446/87-06.) j (2) The ECSAs were installed in accordance with construction operations traveler (NRC inspection of ECSA installation activities is contained in IR 50-445/87-23; 50-446/87-17.)

(3) Low voltage, cable reduction splices will be included in the documentation reviews and field evaluations covered by Procedure CPE-FVM-EE-02 (NRC inspection of reduction splices was included in the ISAP I.a.2 and I.a.3 inspections.)

(4) The STIR committed to expand the scope of CPE-FVM-EE-022 to include documentation reviews and field evaluations for the splice (Device pigtail extension splices were the subject of Violation 445/8518-V-01. The applicant's July 9, 1987, response to this violation stated that the scope of corrective action report (CAR) 063 would be expanded to identify any deviations from the requirements for these types of splices. NRC inspection of some replacement activity related to these splices was documented in IR 50-445/87-23; 50-446/87-17.)

Additional information on the remaining categories is presented below for completeness and to provide continuit !

- _ _ _ . _ _ _ _ _ _

- - - _ _ _

..

l

. I

'

(5) NRC' inspection of the Conax EPA pigtail connections to field cables was documented in irs 50-445/87-03;_

50-446/87-03 and 50-445/87-07; 50-446/87-0 i (6) The STIR defines the balance of plant splices to be '

"all additional lE splices / heat-shrink locations not included in other specific groups." These include inline cable splices and cable jacket repai (7) There have been no NRC inspections of these splice j i

'

(8) The STIR excludes MOVs because the " valve operators are supplied from the manufacturer with internal termination strips." While the NRC inspector found this reasoning to be incomplete, he was aware that a complete walkdown of MOVs was being conducted which would identify any HSIS installations, see IR 50-445/87-16; 50-446/87-13, paragraph NRC inspection activities will concentrate on '

.

categories 6, 7 and c. Field Verification Method (FVM) j The NRC inspector reviewed the FVM written to implement ,

'

the above STIR. The FVM, CPE-FVM-EE-064, " Instruction to Acquire Data for' Heat Shrinkable Sleeve Installations,"

was written by SWEC and approved by the applicant to implement the program proposed by STIR-CPRT-E-00 Revision 0 of this FVM was approved on May 19, 198 This procedure required: (1) a review of QC documents for !

all installations of HSIS in Class lE circuits in Unit 1, i Unit 2, and Common areas, and (2) a visual hardware evaluation for all outer sleeves for Class lE HSIS installed in~ harsh environment area The procedure included a check sheet for the steps involved in completing these requirements and acceptance criteria for both documentation reviews and visual hardware evaluation ;

d. Implementation of FVM I The NRC inspector discussed the implementation of CPE-FVM-EE-064 with the SWEC Team Leader on November 19, 1987. The inspector was informed that the FVM had been reissued as Revision 1 on October 19, 1987, and that Interim Change Notice (ICN) 01 had been issued to Revision 1 on November 10, 1987. During discussions of the changes involved in the revision and ICN, the Team Leader stated that HSIS locations are determined by the existence of documentation of its installation. The inspector observed, however, that undocumented locations

_ _ - _

_ _ _ __

. . . l

.

l

'

8' )

l

would be least likely to have received an installation QC inspection and these would also not be inspected as part ,

of this CAP. The NRC inspector reviewed Revision 1 and i ICN-01 to the FVM and observed that a footnote had been added to Section 2, " Documentation Review," of the FVM data sheet which states that if no IR exists for the installation of HSIS, the remainder of the data sheet should be considered N/A. The ICN added Attachment D to the FVM which lists the drawings applicable to terminations in the cable spreading rooms. All of the cables listed on the drawings are excluded from the scope of the FVM. The inspector also disagreed with this change because the acceptability of possible HSIS installed along the cable route and/or at its other end had not been addressed. The inspector discussed these concerns with applicant personnel on November 20, 198 The NRC inspector was informed on December 1, 1987, that a deficiency report (C87-4741) had been written and that the FVM would be revised. Future NRC inspection, as part of the ongoing inspection of this portion of the electrical CAP will be require . Electrical Erection Specification Review and Meeting (51051)

The NRC inspector's review of Revision 3 to the Electrical Erection Specification (ES-100) was documented in IR 50-445/87-23; 50-446/87-17. As a result of that review, a meeting with involved applicant engineering personnel was requested so that clarification of some items could be obtained. The items discussed at the meeting held on November 6, 1987, were: Design Change Authorizations (DCAs)

The NRC inspector noted that a number of the DCAs which were still open against Revision 3 were more than a year ol The NRC inspector questioned why these DCAs weren't ;

'

incorporated into the specification when it was revise Applicant personnel stated that Revision 4 of ES-100 was targeted to be issued by mid-November and that Revision 4 would incorporate all open DCA The NRC inspector learned of an additional 32 DCAs issued against Revision 3 on November 5, 1987, see item f belo The inspector had only reviewed one of these DCAs prior to the meeting. The review of the remaining 31 DCAs is discussed later in this paragraph. As of November 5, 1987, there were 71 DCAs open against Revision ,

_ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _

_ _

..

.

The NRC inspector will review Revision 4 after it is issue b. Cable Raceway Supports The NRC inspector had closed open Item 446/8606-0-08 relating to temporary supports for a cable tray in IR 50-445/87-07; 50-446/87-06, based on the observations of work in progress. In an attempt to clarify temporary support requirements,. Revision 3 incorporated a requirement that the general foreman verify that the raceway is " adequately supported for cable pulling" prior to any cable pulls. The NRC inspector questioned the guidance to be used to ensure " adequate support" and how permanent supports are provide Applicant personnel stated that the general foremen must rely on their experience and expertise to determine adequac Also, the document that provided for the

installation of a temporary support (usually a DCA) is controlled by the paper flow group (PFG); the PFG does '

not close a support package until final engineering and QC approva During a subsequent meeting on December 1, 1987, the inspector was informed that DCA 61927 would clarify the

" adequate support" requirements. The NRC inspector found these responses to be acceptabl ;

c. Taped Electrical Joints A new Appendix I was added to Revision 3 which provides a method to insulate and seal electrical connections with wrappings of electrical tape over an adhesive coatin ,

i In response to the NRC inspector's inquiry on the qualification of this arrangement, applicant personnel stated that a testing program was underwa This is an open item pending review of documentation that verifies that the connections insulated as described in Appendix I to 3S-100 are environmentally qualified (445/8730-0-01; 446/8722-o-01),

d. preinsulated Environmental Seal (PIES) Splices The inconsistency in heat sealing requirements between the craft and QC procedures, which was discussed in IR 50-445/87-13; 50-446/87-10, was resolved in Revision 3 by directing that PIES splices were not to be heat sealed unless specifically directed by engineering to heat sea The NRC inspector questioned how environmental ,

'

qualification had been verified for non-scaled splices

_ _ - _ _ - _ _ _

- - _-__ __

4 .

^

.

'

installed in harsh environments. Applicant personnel stated that DCA 61927 would be issued to Revision 4 which will require heat sealing unless directed by engineering to the contrar The NRC inspector will review Revision 4 when issued, and any associated, unincorporated DCAs, as part of the routine NRC inspection progra e. Cable Pulling Lubricant  !

The restriction on the use of a cable pulling lubricant i (Yellow-77) on Anaconda brand electrical cable was clarified in Revision 3 by adding a restriction which prohibits installing Anaconda cable in a raceway in which Yellow-77 had been used on other installed cables. This ,

clarification resolved the inspector's concern of contact l with Yellow-77 by Anaconda cable, but did not address the I restriction on the use of Yellow-77 on only the Anaconda provided cable (i.e., why was only Anaconda cable ;

affected?). Applicant personnel stated that Anaconda cable (which was only used on Unit 2) had not been analyzed with Yellow-77, while other manufacturers had analyzed their cables with Yellow-7 Since facility directions contained in a February 4, 1981, memorandum (CPPA-8423) requiring: (1) Yellow-77 to be viped from cables as they exit a conduit and (2) prohibiting its use inside the Containment Building, i may not have been incorporated into the appropriate '

procedures, and because of questions raised on the combustible possibility of the lubricant in a dry state, further NRC review will be required to determine the acceptability of Yellow-7 This is an open item pending NRC resolution of the acceptability of Yellow-77 (445/8730-0-02; 446/8722-0-02).

f. Electrical Cable Pulling Aids During follow up on November 5, 1987, of the metal fish tape which the NRC inspector observed in a conduit and reported in IR 50-445/87-23; 50-446/87-17, the inspector became aware of DCA 58763. This DCA to Revision 3 of ES-100 provided guidance which was being interpreted by craft personnel to require the abandonment of pulling lines in conduits. Applicant personnel committed to revise the DCA wording when it is incorporated into Revision 4 to clarify that the pulling lines should be removed, if practica _ _ - _ _ _ _ _ _ _ _

'

. . . , ,

,,

*

This is an open item pending.NRC review of the acceptability of abandoning pulling lines in conduits, including conduit sleeves embedded in walls or floors (445/8730-0-03; 446/8722-0-03).

The NRC inspector was also informed that the. fish tape mentioned above had been removed.on November 5, 1987, in ,

, accordance with NCR 87-02197. The NRC inspector vetified that the fish tape was removed and that the cables were tywrapped during a facility tour on November 17, 198 The NRC inspector reviewed the 31 additional DCAs mentioned above and found the following.to be significant: DCA 52508, approved on October 28, 1987, contained 221 pages of clarifications to the' codes and standards which are applicable to electrical installation .

'

activities.. The DCA also clarifies separation requirements, cable pulling requirements and QC inspection requirement DCA 52565, approved on November 13, 1987, contained 56 pages of revised electrical' separation requirement Included in these' changes was the deletion of all separation requirements for lighting system conduit In addition,,the'DCA revised paragraph 1.5.1.4 of Appendix K to state " Cable.in protective wrap is considered as cable in conduit." The NRC inspector questioned the acceptability.of these two changes; however, since the changes are-included in Amendment 65'to the-FSAR, they will require further NRC review. This is an open item pending. completion of the NRC review (445/8730-0-04; 446/8722-0-04).

Additional changes affecting separation requirements within control and distribution panels were noted in DCAs 31439, Revision 1, and 61165, Revision , DCA 52998, approved on October 24, 1987, deleted the requirements related to the lighting circuits separation color coding because the lighting systems have all been downgraded to non-Class 1E. However, the DCA allows-the use of "any color jacketed lighting cable without having to color code it black" (black designates the cable as non-Class 1E). The inspector also noted that DCAs 56402 and 58724 affect the lighting circuits. The latter DCA now allows the use of electrical spring connectors (wire-nuts) on any lighting circui DCA 58226, approved on October 26, 1987, incorporated QC !

inspection attributes for the installation of cable tray side rail extensions. In response to the NRC inspector's

!

. _ . - . _ _ . _ _ _ _ _ _ _ _ _ _ _

.

'

.,

question of control of cable tray weight for support consideration, the applicant personnel stated that procedure ECS 5.01-15, " Validation and Maintenance of Cable Tray Loading," was issued on November 18, 198 The question of loading on the cable tray supports is being followed as part of-the inspection of the percent fill portion of the electrical CA DCA 61201, approved on October 26, 1987, revised the leak rate acceptance criteria for EPAs and deleted the requirement for evaluating the seal areas of EPAs installed in the isolation valve tanks. The inspector was informed in a meeting on December 1, 1987, that the deletion of these tanks as a pressure boundary had been incorporated in Amendment 38 to the FSAR. This is an open item pending NRC review of this FSAR change (445/8730-0-05; 446/8722-0-05).

No violations or deviations were identifie . Plant Tours At various times during this report period, the NRC inspector conducted inspections of the Unit 1 and 2 reactor, safeguards emergency diesel generator, auxiliary, and electrical / control buildings. These inspections were conducted to observed work in progress, equipment protection and storage, and general housekeeping activitie Specific observations are discussed below, Previous Observation Follow-up (51063)

(1) The splice connector end caps on conductors in Unit 1 cabinets TC-20 and CR-24 had not been removed as of December 1, 198 (2) The termination of cables repulled to Unit 2 cable spreading room cabinet 2CR-21 in response to violation 445/8604-V-02 had not been started as of November 30, 198 (3) The cable slump and fish tape problem in the auxiliary building had been corrected prior to November 17, 1987. See paragraph 5.f, abov Electrical Cable Rework (51063)

On November 17, 1987, the NRC inspector observed a number of Train A (orange colored jacket) electrical cables which had been pulled back and were being temporarily store The cables were individually coiled and hung in the Unit 2 lower electrical equipment room beside the

_ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _

,_ .- -- -

.

,

l 13 f

t l Train A, 6.9kv switchgear. The inspector observed no damage to the cables and found the storage to be acceptabl A review of the documentation associated with these cables showed that construction deficiency report (CDR)

87-10217-EC, dated September 25, 1987, documented that

" Conduit 24000361 has a polyethylene rope and rag lodged in the conduit." The inspector assumed the rag attached to the rope was for swabbing the conduit prior to a cable pull; this method of swabbing was required by procedur The CDR was subsequently transferred to NCR 87-00056 which was dispositioned on November 3, 1987. The disposition stated " Remove all the cables as well as the rope and rag. Make sure the conduit is free of all extraneous material. Then repull all the cables and any new scheduled cables not previously pulled." There was a listing of 47 affected cables attached to the NC I The NRC inspector will continue to observe the status of these cables, including continued proper temporary storage, as part of subsequent plant tour No violations or deviations were identifie . Significant Meetings (51053) I On December 1, 1987, I. Barnes and P. Wagner met with applicant personnel to obtain information on the capacitors the NRC inspector had discovered in the Unit 1 EDG control panels on September 23, 1987. See Unresolved Item 445/8718-U-11, paragraph l The NRC inspector had reviewed numerous plant documents to determine how, when, and where these capacitors had been installe From physical inspection of the wiring inside the EDG control panels and schematic diagram review, the inspector i determined that the capacitors had been installed in parallel  !

with the coil of time delay relay (TDR) TD4. The inspector could not ascertain what purpose this installation would ,

serve, nor did he discover any documentation which described I when or by whom the capacitors had been installe (Relay TD4 functions essentially in its DC circuit to provide alarm indication and has a time delay adjustable from 0.5 to 15 seconds.)

The NRC inspector also noted that there were two sets of schematic wiring diagrams for these EDG control panels; one set was the vendor provided set, the other was an applicant drawn set. The inspector determined that differences existed between the two sets of drawings during his review of the latest revisions and DCAs associated with the drawing _ _ _ _ - _ _ _ _ _ _ _ _ _ -

i

b -

[. *

! 14 Examples of these differences were most evident in the circuitry for solenoids 6A and 6B and relay contact numbers i

'

and arrangements (i.e., RX/1B and 10X) on drawings 09-500-76001, Sheet 3 and TNE-El-0067, Sheet 9 During the meeting on December 1, 1987, applicant personnel stated that: l The terminal lugs used to attach the capacitors, the wire used for this, and the wire identification markers were !

all the type which had been used by the vendor and that these were not available on site; The failure of the capacitors, as installed, would have no effect on the starting or stopping of the EDGs. The applicant personnel were also unable to determine the purpose of the capacitors and stated that a test would be '

performed with the capacitors removed and, if no ill effects were determined, a DCA would be issued for their permanent removal; and An inspection by applicant personnel of the remainder of the panel disclosed no other deviatic:is from the i equipment shown on the drawing j The NRC inspector asked how the differences he had observed 4 I

between'the two sets of schematic drawings for these panels, were to be resolved. The applicant personnel responded'that one set would be eliminated and that the drawings used during the inspection in c, above, were marked to indicate the !

i as-built configuration. The inspector also mentioned that he had not been informed of the number of the TNE drawing equivalent to vendor Drawing 09-500-76001, sheet 4 (which I shows the TD4 relay).

!

Since no documentation had been located to identify or verify the acceptability of these capacitors, the NRC inspector determined that the installation was in violation of Criterion III of Appendix B to 10 CFR Part 50 (445/8730-V-06).

The NRC inspector's review of the two sets of schematic diagram drawings for the EDG control circuitry, drawing 09-500-76001 which was the vendor provided schematic and drawing TNE-El-0067 which was the applicant generated schematic, both sets containing numerous pages, had disclosed that a number of differences existed between the two set Specific differences in the circuitry arrangements were noted between Drawing 09-500-76001, Sheet 3, Revision CP-2, approved on October 29, 1986 and Drawing TNE-El-0067, Sheet 96, Revision CP-1, approved on April 11, 1984. The NRC inspector, therefore, determined that the existence of incorrect drawings

- - - - - _ _ - _ -

- _ _ - _ _ - - _

.

.

e I

was a violation of Criterion V of Appendix B to 10 CFR Part 50 (445/8730-V-07).

l 8. Open Items open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in paragraph 5 (five items).

9. Exit Interview (30703)

An exit interview was conducted December 1, 1987, with the applicants representatives identified in paragraph 1 of this report. During this interview, the NRC inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings.

. .

___ _ _ _ _ _ _ _ . _ _ _ _

j