IR 05000456/1986014
| ML20202E898 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/07/1986 |
| From: | Muffett J, Westberg R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20202E872 | List: |
| References | |
| 50-456-86-14, 50-457-86-12, NUDOCS 8604140069 | |
| Download: ML20202E898 (5) | |
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U.S. NUCLEAR REGULATORY C0FNISSION
REGION III
l Reports No. 50-456/86014(DRS);50-457/86012(DRS)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Connonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL l
Inspection Conducted: March 19 through April 2,1986
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s/9 86 Inspector:
R. A. Westberg Date Jc e
Approved By:
J. W. Muffett, Chie Plant Systems Section Date Inspection Summary Inspection on March 19 through April _2 1986_jReports No._5_0-45pfjf6014]DRjl x
No. 50-457/86012(DRS))
L Treas Inspected: Routine, announced inspection by one regional inspector of (
licensee action on previously identified items and safety evaluation report
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review and followup.
It was conducted in accordance with NRC Inspection Procedures No. 92701, No. 92702, and No. 92719.
Results: No violations or deviations were identified. Of five previously identified items reviewed, four were closed.
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ADOCK 05000456 PDR
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DETAILS 1.
Persons Contacted Comonwealth Edison Compa_ny_nC_ol
- P. L. Barnes, Regulatory Assurance Supervisor
- D. L. Cecchett, Regulatory Assurance Engineer
- J. F. Phelan, Project Field Engineering, Electrical Supervisor J.R.Wozniak,ProjectConstructionDepartment(PCD),FieldEngineer Electrical
- T. W. Ronkoske, PCD Field Engineer Electrical
- A. J. D' Antonio, Regulatory Assurance Engineer
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- G. E. Groth, Assistant Construction Superintendent (
- E. R. Netzel, Quality Assurance Supervisor l
D. L. Shamblin, Project Construction Superintendent j
J. A. Zych, Quality Assurance Engineer SargentandLundyEngineers(S&L1
- J. D. Regan, Electrical Project Engineer D. J. Raef, Project Leader Electrical J. Paprocka, Designer USNRC W. J. Kropp, Senior Resident Inspector
Other personnel were contacted as a matter of routine during the inspection.
- Indicates those attending the exit meeting on March 26, 1986.
2.
Licensee Action on Previous inspection Findings a.
(Closed) Violation (456/82006-02A): Safety-Related cable trays were found to be in physical contact with non safety-related cable trays at nodes 1696H-CIE and 17130-CIB; 11335B-CIE and 11335F-PIB; and
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cable ISX001 and 1689A-PIE.
Insufficient horizontal spacing was found between 213985-PZE and 21384T-P21B. The inspector verified '
that the current design drawings call for covers on cable trays 1713D-CIB, 11355B-CIE, 11335F-PIB, 21398S-P2E, and 21384T-P28. With covers installed, the spacing can be one inch metal to metal and comply with IEEE 384-1974. Separation of a safety-related cable in free-air in contact with a cable tray was found acceptable by NRR in the SSER letter dated February 25, 1986. Additionally the inspector visually verified that the trays were not in physical contact (metal to metal). All items reviewed were found acceptable.
b.
(Closed) Violation (456/82006-02B):
Insufficient separation was found between safety-related cable trays and non safety-related cable trays at nodes 21398T-C2E and 213840-C2B; and 12028C-CIE and 120860-CIB.
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The design drawings did not specify the required covers. The inspector verified that Drawing No. 20E-0-30528, Revision S now specifies a cover for tray 213844-C2B and Drawing No. 20E-0-3072C, Revision AD, specifies a cover for 120860-C18. All items reviewed were found acceptable.
c.
(Closed) Open Iten (456/82006-03):
Ten examples of areas where minimum separation was not maintained were found. The inspector verified that the design drawings show enclosed raceways for eight of the ten examples which makes their separation acceptable. The other two examples were analyzed by S&L and found acceptable. The inspector reviewed the following documents:
(1) Drawing 20E-0-3667, Revision AU; (2) Drawing)20E-0-3659, Revision AD; (3) Drawing 20E-0-3663, Revision AK; (4 Drawing 20E-0-3051B, Revision Y; (5) Drawing 20E-0-3021B,RevisionAH;(6) Drawing 20E-0-3021A,RevisionAE;(7)
Drawing 20E-0-3031A, Revision R; (8) Drawing 20E-0-3031B, Revision T; (9) Drawing 20E-1-3041C, Revisions;(10)CSCVNo.330. All items reviewed were found acceptable.
d.
(Closed) Violation (456/84044-06):
Inspection program contains insufficient electrical separation acceptance criteria to verify thct design requirements had been met (CAT Item Section IIB.I.B(1)).
The inspector reviewed L. K. Comstock (LKC) Procedure No. 4.3.5,
" Cable Pan Installation," Revision E, and No. 4.8.5, " Inspection of Class 1E Safety-Related Cable Plan Installations," Revision F.
The procedures reference the three inch horizontal and 12 inch vertical separation criteria from the Braidwood FSAR. The inspector also reviewed S&L Project Instructions (PI) No. BB-59, " Documentation of Cable Separation Criteria Violations," Revision 1 and No. BB-77,
" Cable Tray Separation Walkdown Procedure" and found them in agreement with the separation criteria in the FSAR. The inspector reviewed the 61 apparent separation criteria violations from the CAT inspection with the following results:
(1) Seven were determined to meet the criteria; (2) Four were identified and dispositioned by S&L on their walkdown; (3) Three were dispositioned by S&L on the basis of a calculation; (4) Two were duplicates of tray nodes already on the list; (5) Four were determined to be acceptable based on the recent SSER on cable separation; (6) Ten were trivial, non safety-related cable in conduit over safety-related trays; and (7) 31 will be enclosed by a raceway cover as indicated by the design drawings.
The review of-these items determined that acceptable separation, and separation criteria now comply with design requirements.
(0 pen) Violation (456/82006-04) Cables in free air were routed e.
closer than the 12 inch limit allowed by procedure. The inspector reviewed this item but determined visually that some violations of the cable separation critieria still remain. Pending further review, this item remains open.
3.
Physical Identification a_nd__In_ dependence of Class 1E Cables and Non_-Class _
IE Cables
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o a.
Introduction The Braidwood Final Safety Analysis Report (FSAR) Section 8.3.1.4
" Physical Independence of Redundant Systems" established the separation requirements for the physical arrangement of cable trays.
With respect to safety and non safety-related cable trays, the Braidwood FSAR specifies an exception to the Regulatory Guide (RG) 1.75 required separation distances of five feet vertical and three feet horizontal and substitutes 12 inches vertical and three inches horizontal instead.
The Construction Appraisal Team (CAT) inspection used these reduced separation criteria as the basis for their inspection of cable trays and identified 61 instances that violated the criteria. These deficiencies were discussed with Sargent and Lundy (S&L) and licensee personnel who disclosed that in areas where less than the required separation exists, approved fire barriers such as cable tray covers would be installed. The CAT inspectors then selected seven out of the 61 identified deficiencies and reviewed the applicable design drawings with S&L personnel to determine whether fire barriers had been specified for these examples. The results of this review indicated that fire barriers were not specified in three of the seven examples.
(See Section 2.d of this report for the close-out of these items.)
Cable separation deficiencies have been previously noted by Region III inspections. As a result of these inspections, the CAT inspection, and differences in interpretation of the separation criteria between licensee and NRC personnel, the NRC Office of Nuclear Reactor Regulation was requested to evaluate the reduced separation criteria of Class 1E cables from non-Class IE Cables.
'The reduced physical separation was justified by the licensee by testing and analyzing various test configurations. The NRC staff reviewed the results of these tests and determined that the test program and the results were acceptable in the NRR SSER letter dated February 25, 1986.
Therefore the reduced rwaration criteria are acceptable.
The purpose of this inspection is to accomplish the following:
(1) Closeout the CAT items relative to cable tray separation.
(2) Select a new sample of cable trays for inspection and varify that the 12" vertical and three inch horizontal separation criteria is being observed.
(3) Closeout previous open items relative to cable tray separation, b.
Documents Reviewed
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(1) Sargent and Lundy Project Instruction (PI) No. PI-BB-59,
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" Documentation of Cable Separation Criteria Violations,"
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Revision 1.
(2) NO. PI-BB-77, " Cable Tray Separation Walkdown Procedure,"
Revision 0.
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L. K. Comstock (LKC) and Company Procedure No. 4.3.5, " Cable Pan Installation," Revision E.
(4) LKC Procedure No. 4.8.5, " Inspection of Class 1E Safety-Related Cable Pan Installation," Revision F.
c.
Inspection Results (1) The inspector reviewed the specific CAT items on separation criteria and verified that the licensee's inspection program now contains sufficient acceptance criteria for cable separation.
The inspector also reviewed the violations of separation f
criteria identified by the CAT inspection and verified that
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either they had been corrected or that no safety concerns existed.
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See Section 2d of this report for details.
f (2) The inspector selected a sample of 17 apparent violations of-the separation criteria for further review during a walkdown of the 439 foot elevation of the Unit I cable spreading rooms.
The review of this sample with S&L personnel showed that in all but one case, the violations had been previously identified and dispositioned by analysis or by covering the trays. The fact that cne violation was not identified was still acceptable since S&L had not performed their final walkdown of the cable trays in-this area. The other violations were identified by S&L during the engineering process.
d.
Conclusions The inspector's review of the licensee's program for cable separation indicated that it was consistent with the program described in the NRR SSER letter dated February 26, 1986 and the Braidwood FSAR.
4.
Exit Interview The inspector met with licensee representatives on March 26, 1986, and sumarized the purpose, scope and findings of the inspection. The inspector also discussed the likely infonnational content of the inspection. The inspector also discussed the likely infonnational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The inspector also met with licensee representatives on April 2,1986, to discuss the review of two additional previously identified items.
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