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4 COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP I '. a . 4
Title:
Agreement Between Drawings and Field Terminations Revision No. 4 Reflects Comments Description On Plan Prepared and Recommended by:
Review Team fM
[]
Leader Date Approved by:
Senior Review Team (h, ml Date # !2 4[f(,,,
8610080441 861003 PDR FOIA PDR GARDE 86-272
Rsvicion: 4 Pags 1 of 8' ISAP I.a.4 Agreement Between Drawings and Field. Terminations 4
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1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Page J-29)
"...the TRT selected 380 cables, involving 1600 individual terminations, and inspected them in detail with respect to drawing i
requirements. This inspection revealed that six cables (five of j which are safety-related) were not terminated in accordance with current drawings. These six cables are:
f - E0139880 in panel CPI-ECPRCB-14*
j - E0110040 in panel CP1-ECPRTC-16,
- E0118262 in panel CP1-ECPRTC-16,
- NK139853 in panel CP1-ECPRCB-02 (non-safety),
- EG104796 in panel CP1-ECPRTC-27, and
- EG021856 in panel CPX-ECPRCV-Ol'" .
2.0 ACTION IDENTIFIED BY NRC (NUREG-0797, Supplement Number 7, Item l
Number 6 (c), Page J-31)
- "TUEC shall accomplish the following actions prior to fuel load:
Reinspect all safety-related and associated terminations in the control room and in the termination cabinets in the cable spreading room to verify that their locations are in accordance with all current design documents. ' Should the results of this reinspection
- reveal an unacceptable level of nonconformance to design documents, the scope of this reinspection effort shall be expanded to include all safety-related and associated terminations at Comanche Peak Steam Electric Station (CPSES)."
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3.0 BACKGROUND
j The specific cables identified above have been re-inspected and the "as-built" configurations reviewed by TUGC0 l Engineering. The engineering review has considered design ,
, changes and temporary modifications author 3 zed prior to the 1 TRT identification. )
- The TRT notified TUEC that the panel identified as CP1-ECPRCB-14 should be CP1-ECPRCB-04.
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Rsvision: 4 Paga 2 of 8 ISAP I.a.4 (Cont'd)
3.0 BACKGROUND
(Cont'd)
The results of this review are as follows:
One cable (E0139880) was terminated correctly, but the color-code table on the drawing had not been correctly reflected in the conductor termination details. This drawing was corrected, and other similar drawings were checked to ensure that this condition does not exist elsewhere.
One cable (E0110040) was found to be properly connected in accordance with the document revision in effect.at the time the termination was made. However, a subsequent drawing revision changed the color code of the conductor for no apparent reason. This drawing error was detected and corrected prior to the September 18, 1984, letter from the NRC to TUGCO.
One cable (E0118262) contained a drafting error at the time of the TRT inspection, (two green conductors shown). The cable was functionally correct as landed. The drawing error has been corrected.
One cable (EG104796), a two conductor cable, was found to have wires interchanged on the terminal points. This connection has no polarity requirement. Thus, the interchange of wires had no' affect on the operability of the circuit. The physical terminations have been corrected to match the drawing.
One cable (EG021856) was found to be a designated " spare" per a properly issued design change document (DCA 19948, Revision 1). However, the interconnection drawing for one end of the cable still showed the cable to be terminated which indicates that the review and drawing update cycle was incomplete at that time. The cable has been deleted from the current revision of the interconnection drawing.
One cable (NK139853), a non-safety cable, the orange and yellow / orange pair of conductors had been designated as spare, but left terminated. However, the vendor-side conductors had )
been removed from the terminal blocks. The subject conductors have also been removed from the terminal blocks. l.!
In summary, i
E6139880 Drawing error - correctly terminated j E9110040 Drawing error * - correctly terminated i E6118262 Drawing error - correctly terminated
- Corrected prior to September 18, 1984.
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'. R vision: 4 Pag 2 3 of 8 ISAP.I.a.4 (Cont'd)
3.0 BACKGROUND
(Cont'd)
EG104796 Interchanged conductors - functionally correct EG021856_ Incomplete Design Change Authorization -
cable not required NK139853 (non-safety) spare conductors terminated -
functionally correct.
In the course of normal practices, afteg construction has been completed and the equipment is in the startup cycle, a wiring check is done per Prerequisite Test Instruction XCP-EE-8. Any design. changes required as a result of this testing are controlled and requested in accordance with the Startup Procedure for Design Requests (CP-SAP-14). Additionally, the change may be implemented as a temporary modification which is controlled by CP-SAP-13, Startup Procedure For Temporary Modifications.
4.0 CPRT ACTION PLAN 4.1 Scope and Methodolagy The objective of this action plan is to assure that the safety-related and associated cable terminations in the control room and cable spreading room are in accordance with current design documents.
The following task will be implemented to achieve this objective:
Inspection of terminations 4.1.1 Inspection Program An inspection program employing random sampling will be initiated which will enable a determination to be made with reasonable assurance of whether the essential Class IE conductors in the control room and cable spreading room which interface with the Alternate Shutdown Panel are terminated in accordance with the applicable drawings.
R2Vicien 4 Pag's 4 of 8 ISAP~I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
A sample inspection is considered to be a reasonable approach for the following reasons:
- 1) No programmatic deficiencies have been identified in this population to date.
- 2) The population is homogeneous with respect to the attribute of agreement with drawings.
4.1.1.1 Population Identification The first step in the sampling program will be to identify the popclation of all essential Class lE terminations in the control room end cable spreading room that are in circuits which interface with the Alternate Shutdown Panel in Unit 1. This population of " safe shutdown" terminations i will be taken from over 14,000 Class 1E terminations in these two rooms.
The " safe shutdown" terminations have been chosen as a sub-group of the population of all Class IE terminations due to their crucial role in plant safety. Since there.
are no product or process differences between this sub-group and the remainder of the Class 1E terminations, this approach will allow for an investigation, which focuses on safety, while still attaining an engineering assessment of the quality of the larger population.
4.1.1.2 Random Sampling
! The sampling plan will be designed in accordance with the guidelines of Appendix D, and will result in reasonable assurance that programmatic deficiencies do not exist in the l population.
This plan employs a 95/1 screen, which is significantly more conservative than the 95/5
- screen which is used in the majority of the ISAP's in which a sampling program is 1 employed. The decision to enforce this l higher standard (which increases sample sizes i by approximately a factor of five) was made by the Electrical Review Team Leader.
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' R vision: 4-Pega 5 of 8 ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Based on the preliminary determination of a population size of.3812, the minimum sample size according to Appendix D is 300 with a rejection number of zero (i.e., the critical .
region is one or more deficiencies found in the sample). If one (1) deficiency is found, a root cause evaluation of the deficiency will be performed, and a sample expansion in accordance with Appendix D will be undertaken.
If the number of deficiencies discovered in the original sample is two (2) or more, or a potential root cause is identified as programmatic, a 100% reinspection of all' essential and associated terminations in the Control Room and Cable Spreading Room of Unit I will be performed.
4.1.2 Use of Results Results of the actions under this Plan will be evaluated to establish root causes and to identify appropriate corrective action.
4.2 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope.
4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Assist the Review Team Leader in identifying the Class 1E terminations which interface with the Alternate Shutdown Panel.
4.2.1.2 Process NCRs, if any, generated as a result of this action plan.
4.2.1.3 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Review sample plan, NCRs and inspection reports, if any.
Rsvision: 4
- Paga 6 of 8 ISAP I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.2 Evaluate inspection results and specify additional inspections, if required.
4.2.2.3 Determine root cause, generic implications and safety significance.
4.2.2.4 Personnel (prior to October 18, 1985)
Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe, Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985)
Mr. J. J. Mallanda, Review Team Leader Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe, Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team 4.2.3.1 Inspect termination for compliance to
) acceptance criteria.
4.2.3.2 Personnel Mr. J. L. Hansel, Review Team Leader - QA/QC 4.2.4 Third-Party Adviser 4.2.4.1 Provide input to the Sampling Plan.
4.2.4.2 Personnel Dr. F. A. Webster, Statistics Adviser 4.3 Oualifications of Personnel Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear l Power Plants". CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and specifically trained to the CPRT Program Plan.
' :Rsvision 4-
- Pags 7 of 8 r
ISAP I.a.4 '
(Cont'd) !
i 4.0 CPRT ACTION PLAN (Cont'd)
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Third-party participants in the implementation of this action l plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.
Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT' Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K " Assurance of CPRT Program Quality", of the CPRT Program Plan.
4.4 Procedures 4.4.1 Instruction QI-001, " Procedure for Class 1E Cable.
" Terminations Inspection - CPRT Action Item I.a.4".
4.5 Acceptance Criteria 4.5.1 Inspections The acceptance criterion for the termination inspection is that either:
- The termination is physically in agreement with the drawing (a conductor of a larger size than that shown on the drawing is also
, acceptable), or
- The termination is not in agreement with the drawing but is functionally correct (e.g.,
connected to an electrically common point, wires reversed in circuits with no polarity requirements) 4.6 Decision Criteria 4.6.1 If any terminations are not acceptable per Section 4.1.2, the sample size will be increased, in accordance with Appendix D.or a 100% reinspection will be performed, as described in Section 4.1.1.2.
4.6.2 For cases where terminations are not in agreement with l the drawings, either the drawings or the terminations l will be corrected. I
V Revision: 4 Pago 8 of 8 ISAP.I.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.6.3 If the number of deviations in the original sample is two (2) or more, or a potential root cause is identified as programmatic, such that it is required to reinspect all " Safe Shutdown" terminations, then all Class 1E essential and associated terminations in the Unit 1 Control Room and Cable Spreading Room will be inspected.
4.6.4 If it is necessary to reinspect all Class 1E essential.
and associated terminations in the Unit 1 Control Room and Cable Spreading Room and more than 14 (0.1% of approximately 14,000 Class 1E essential terminations) defective terminations are found, then all Class IE essential and associated terminations-in Unit 1, Unit 2, and common will be reinspected.
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