ML18033A606

Rev 1 to TVA Employee Concerns Special Program Subcategory Rept 30400, Cables & Conduit, Consisting of Vol 3, Operations Category

ML18033A606
Person / Time
Site:	Browns Ferry
Issue date:	09/11/1987
From:	Elliot W TENNESSEE VALLEY AUTHORITY
To:
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References
30400, 30400-V03-R01, 30400-V3-R1, NUDOCS 8902150406
Download: ML18033A606 (88)

Text

EMPLOYEE CONCERNS SPECIAL PROG VOLUME3 OPERATIONS CATEGORY SUBCATEGORY REPORT 30400 CABLES AJG) CONDUIT UPDATED TVA NUCLEAR.POWER

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory REPORT NUMBER:

30400 REVISION NUMBER:

1 TITLE:

Cables and Conduit PAGE 1 OF 30 REASON FOR REVISION:

(1)

Reformat to conform with revision 4 of ECTG Program Manual and incorporation of SRP comments and inclusion of final corrective action plans.

PREPARATION PREPARED BY:

W. T.

E liott C.

W. Touchstone, Eric G. Shewbridge SIGNATURE (NOTE:

Evaluators listed in Attachment I REVIEWS I

r~g DATE SIGNATURE DATE SIGNATURE DA CONCURRENCES CEG-H:

9'..g'7 SIGNATURE DATE SRP:

SIGNATU APPROVED ECSP M

AGE

/AT(

=SRP Secretary signature denotes SRP concurrence are in files.

5570T

II

Preface, Glossary, and List of Acronyms for ECTG Subcategory Reports

.HISTORY OF REVISION REV NUMBER PAGES REVISED REASON FOR CURRENT REVISION 3

To clarify that one or more attachments will help the reader find where a particular concern is evaluated

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30~00 FRONT MATTER REV:

3 PAGE i OF viii Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (TVA).

The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by, TVA's Manager of Nuclear Power to evaluate and report on those Office of'uclear Power (ONP) employee concerns filed before February 1, 1986.

Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).

The ECSP addressed over 5800 employee concerns.

Each of the concerns was a

formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate.

The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the

NRC, and the general public.

The results of these investigations are communicated by four levels of ECSP reports:

element, subcategory,

category, and final.

Element reports, the lowest teporting level, will be published only for those concerns directly affecting the restart of Sequoyah Nuclear Plant's reactor unit 2.

An element consists of one or more closely related issues.

An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns.

For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself.

Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.

Subcategory reports summarize the evaluation of a number of elements.

However, the subcategory report does more than collect element level evaluations.

The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.

This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for under'ying causes not fully apparent at the element level.

To make the subcategory reports easier to understand, three items have been placed at the front of each report:

a preface, a glossary of t'e terminology unique to ECSP reports, and a 1'ist of acronyms.

Additionally, at the end of each subcategory report will be a Subcategory Summary Table that includes the concern numbers; identifies other subcategories that share a concern; designates nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.

Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.

'JIVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 FRONT. MATTER REV:

2 PAGE ii OF viii 0

The subcategories are themselves summarized in a series of eight cIathgo'ry reports.

Each category report; reviews the major findlings and chil'ectiv'e significance of'he subcategor.y reports ~in'on'e 6f the, following.adea0:

'anagement and personnel relations industrial safety construction material control operations quality assurance/quality control

welding, engineering A soparato roport on amployaa concerns dealing with specific conte'ntione of intimidation,, harassment, and wrongdoing will be released by the TVA Offide of the In,spector General.

Just as tho subcatagory r aports'ntegrate t'.he information collecte'd ett 'th element level, the category reports integrate the information assembled in, all the subcategory reports within the.category, addressing, particularly the underlying causes of those problems, that run across more than One subcategory.

A final rcport will intograto and assess the information collected'y, all of the lower level report;s prepared for the

ECSP, iincluding the In'specter General's report.

For moro dotail on t:ha mothods by which ECTG employee concerns wer'e evaluated and report;ed, consult the Tennessee Valley Authority Employee Concerns Task Group Prog,ram Manual.

The Manual spells out the program's objectives,

scope, organization, and r asponisibilitiIes.

It also 'specifies the procedures that were followed in the investigat;ion, reporting,'nd closeout of the issues raised by employee concerns.,

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 FRONT MATTER REV:

2 PAGE iii OF viii ECSP GLOSSARY OF REPORT TERMS" classification -of evaluated issues the evaluation of an.issue leads to one of the following determinations:

Class A:

Issue cannot be verified as'actual Class B:

Issue is factually accurate, but what is described is not a

problem (i.e., not a condition requiring corrective action)

Class C:

Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D:

Issue is factual and presents a problem for which corrective action has

been, or is being, taken as a result of an evaluation Class E:

A problem, requiring corrective action, which was not i'dentified by an employee

concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.

collective si nificance an analysis which determines the importance and consequences of the findinfs in a particular ECSP report by putting those findings in the proper perspective.

concern (nee "employee concernm")

corrective action stops taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.

criterion lur al:

critoria a basis for defining a performance,

behavior, or quality which ONP imposes on itself (see also "requirement").

element or element re ort an optional level of ECSP report, below the subcategory level, that deals with one or more issues.

em lo ee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

3O'4OP FRONT MATTER RE'V 2

PAGE.iv OP viii evaluator(s) the individual(s) assigned the responsibility to assess a specific grouping of employee

concerns,

~findin's includes both statements of tact and the judgments made about those facts during the evaluation procesa; negIative findings require corrective action.

issue a poten,tial problem, as interpreted by the ECTG during the evaluation

process, raised in one. or miore conder'ns.'-form (see msmplLoyee concern"')

evaluation

.'judgment or decision may be.based.

root cause the underlying reason for a probl'em

=Terms essential to the program but which require det;ailed definitioh hlav6 b'een defined in the ECTG Procedure Manual (e.gen generic specific, nuclear safety-related, unreviewed safety-significant question).

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 FRONT MATTER REV:

2 PAGE v OF viii Acronyms AI AISC ANS ANSI ASME ASTM AWS BFN BLN CAQ CAR CATD CCTS CEG-H CFR CI CMTR COC DCR DNC Administrative Instruction American Institute of Steel'onstruction As Low As Reasonably Achievable American Nuclear Society American National Standards Institute American Society oi Mechanical Engineers American Society for Testing and Materials American Welding Society Brogans Ferry Nuclear Plant Bellefonte Nuclear Plant Condition Adverse to Quality Corrective Action Report Corrective Action Tracking Document Corporate Commitment Tracking System Category Evaluation Group Head Code oi Federal Regulations Concerned Individual Certified Material Test Report Certificate of Conformance/Compl'iance Design Change Request Division of Nuclear Construction (see also NU CON)

TVA EMPLO'YEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400.

FRONT MATTER REV:

2 PAGE vi OF viii DNE DNQA DNT DOE DPO Division of nuclear Engineering, Division of 5luclear Quality Assurance Division of,Nuclear Training'epartment of Energy Division Personnel Office&

DR Discrepancy Report or Devi'ation Rkpo'rt'CN ECP ECP-SR ECSP

'ECTG EEOC EMRT EN DES ERT FCR FSAR FY GET HCI Engineering Change Notice Employee Concerns. Program Employee Concerns Program-S ite Reiiresentative Employee Concerns Special Program Employee Concerns Task Group Equal Employment Opportunity Commission Environmental Qualification

.Emergency Medical Response Team Engineering:Design Employee

Response

Team or Emergency

Response

Team Field Change Request Final Safety Analysis Report Fiscal Y'ear General Employee Tr sining Haz:ard Control Instruction HVAC INPO IRN Heating, Ventilating, Air Conditioning Installation Instruction Institute of Nuclear Power Operations Inspection Rejection Notice il

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 FRONT MATTER REV:

2 PAGE vii OF viii L/R MMX MI MSPB MT NCR NDE NPP NPS NQAM NRC NSB NSRS NU CON NUMARC OSHA ONP OWCP QA QAP QC Labor Relations Staff Modifications and Additions Instruction Maintenance Instruction Merit Systems Protection Board Magnetic Particle Testing Nonconforming Condition Report Nondestructive Examination Nuclear Performance Plan Non-plant Specific or Nuclear Procedures System Nuclear Quality Assurance Manual Nuclear Regulatory Commission Nuclear Services Branch Nuclear Safety Review Staff Division of Nuclear Construction (obsolete abbreviation, see DNC)

Nuclear Utility Management and Resources Committee Occupational Safety and Health Administration (or Act)

Office of Nuclear Power Office of Workers Compensation Program Personal History Record Liquid Penetrant

Testing, Quality Assurance Quality Assur ance Procedures Quality Control QCI Quality Control Instruction

TEA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30i400 FRONT MATTER ','REV:

2

,PAGE viii OF viii QCP QTC RIF Quality Control Procedure, Quality Technology Compang Reduction in Force RT SQN SZ SOP SRP SWEC TAS T6L TVA TVTLC UT VT WBECSP WBN WR Radiographic Testing, Sequoyah Nuclear Plant Surveillance Instruction Standard Operating Procedure'enior Review Pane'tone and Webster Engineering Corporation Technical Assistance Staff Trades and Labor Tennessee Valley Authority'ennessee Valley Trades anid Labor Council Vltrasonic Testing Vi.ual Testing Watts Bar Employee Concern',

Spec'lan Program Watts Bar Nuclear Plant Work,Request or Work Rules' Workplans

Revision 1

CABLES. AND CONDUIT Subcategory Report 30400 Executive Summary I.

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SUMMARY

OF ISSUES The Cables and Conduit Subcategory is comprised of seven employee concerns that raised six issues about electrical hardware deficiencies and problems with the procedures for aspects of plant construction dealing with cable and conduit.

Five of the six issues were substantiated at one or more nuclear sites and required corrective action as a result of an employee concerns evaluation.

The two most significant issues substantiated and requiring corrective action dealt

.with the poor condition of electrical manholes at all nuclear sites and ONP noncompliance with the electrical aspects of construction specifications.

Other issues substantiated and requiring corrective action included:

(a) use of improperly qualified RTV coating, (b) improper use of steel fish tape in breaching electrical penetrations, and (c) the presence of loose conduit for a particular

.cable tray.

II.

SUMMARY

OF FINDINGS I

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Several conditions were found to exist in violation of design, construction, or operating requirements.

Each of these conditions, called specific deficiencies, requires corrective measures:

1.

Numerous deficiencies regarding the design and maintenance of electrical manholes were identified at all sites.

A common problem with cables submerged in -standing water was found which may cause "water treeing" of the cables.

This condition involves the build-up of microscopic voids between the insulation and conductor and may result in insulation degradation and shorts.

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l 2.

At Watts Bar Nuclear Plant (WBN), Sequoyah Nuclear Plant (SQN),

and Browns Ferry Nuclear Plant (BFN), there had been a lack of compliance with construction specification requirements for minimum cable bend radius.

3.

At WBN and

SQN, some deficiencies were identified in the content of procedures dealing with breaching.

Quality controls on the breaching of electrical penetrations at WBN were inadequate to'nsure that approved procedures and practices were followed.

4.

At SQN, an isolated case was found where room temperature vulcanizer (RTV) coating of questionable quality had been applied to a junction box.

Corrective Action Tracking Documents (CATDs) were submitted to the I Rl various plants'ine managers on these deficiencies as they were found.

Page 1'of 4

Revision 1

III.

SUMMARY

OF COLLECTIVE SIGNIFICANCE I RI This evaluati.on has revealed significant negative. finding in two areas:

technical adequacy'nd management effectiveness.

The two most significant technica'L adequacy issues dealt with the poor condition of electrical manholes at all nuclear sites and OMP's noncompliance with construction specification requi'rements for minimum cable bend radius, With respect to the manhole issue, it was determined that nonloaded, energized voltage cable submerged beneath standing water may be subject to insulation degradation This was identified as a potontially:

safety-related problem for all TVA nuclear sites.

Tho second technicel, adequacy iss<ie of exceeding minimum:cable bend, radius has the potentihl to invalidate the environmental qualification certification of installed safety-related cable.

Problems in thei areai os management effectivoness need to be addres. ed as part of the ongoing overhaul of'NP's prpcuduqes, and management systems.

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SUMMARY

OF'OOT CAUSE After the element evaluation,s had been; conducted, an independent review and analysis of the element findings wes ~performed,to search for symptoms of the root causes of. deficie'ncies.

These symptoms were:

(a) lack of material control for consumables (RTV),, (b) inadequate;work; controls (review and implementation of'onstruction specifications),

(c) inadequate configuration control (,installation,not equal to design specificat,ions),

(d) inadequate work control. (electrical penetration breaching),

(e) inadequate work control.(penegragion breaching devices),

(f) inadequate i'nitial design control, and (g) inadequate work controls

'(housekeeping).

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A collecti,ve assessment of the root, causes for these symptoms and the I

element-level findings led to the following subcategory-level root I

causes for deficiencies at all sites:

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,(a)

Various procedure

problems, including,inadequate procedural

content, personnel error in using procedures, and lack, of, adequate processe.

to ensure that commitments are reflected in procedures.

(All sites)

(b)

(c)

Judgement errors concerning water drainage were made by engineers and their supervisors with respect to liniti'al,design of electrical manholes.

(.All sites)

(d)

Acceptance criteria are inadequate to ensure satisfactory initial design of elect r i cal, manways. 'All;sites)

Inadequate processes for recognizing adverse trends in t'he,condi,tion of electri,cal manholes and theref'ore no actions are taken to preclude recurrence of problems.

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Revision 1

V.

SUMMARY

OF CORRECTIVE ACTION Corrective Action At The Element Level 1.

SQN committed to correct manhole sump pump deficiencies and determine adequacy of all Class 1E/CSSC medium and low voltage power cables routed through manholes before unit 2 restart.

Additionally, SQN committed to completing the following after unit 1 start-up:

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A.

Evaluate all Class 1E/CSSC cables and splices for fitness of'uty.

B.

Determine root cause of manhole flooding.

C.

Determine corrective action to prevent recurrence.

The above corrective action will,also be initiated for WBN,

BFN, and BLN as indicated in the corporate response to. the issue of "water IR1 treeing" of submerged cable in manholes.

I At WBN, a workplan completed all items identified in an NSRS report with the exception of AI-2.15 revised.

AI-2.15 will be revised to include instructions identifying temporary cables installed in cable trays.

At BFN, procedures will be written to perform regular inspections of manhole sump pumps.

General cleanup items will be accomplished on maintenance requests.

Cables in manhole T will be replaced in cable trays per ECN P0287.

A DCR will be issued to add a permanent sump pump in manhole T.

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2.

With regard to implementation of upper-tier documents, WBN has revised procedures (MAI-4, HAI-5) to include performance and documentation of bend radius inspections.

The ECTG Construction CEG is tracking deficiencies associated with exceeding maximum pull tension (MPT), side wall pressure (SWP),

and minimum bend radius at SQN, via CATD 10900-NPS-01.

At BFN, site controls will be established to identify and track upper-tier source documents/requirements and ensure their distribution and implementation at the appropriate levels'CRs were generated to address cable bend radius and pull tension violations which may have occurred due to inadequate procedures.

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3.

Regarding breaching

issues, WBN issued a deficiency report against plant procedures not requiring proper breaching tools.

Affected procedures were revised and training provided for personnel involved with breaching of electrical penetrations and fire barriers.

4..

At SQN, junction box 3190 was recoated with RTV 3140 on a work request.

Page 3 of 4

Revisi.on l Regarding the lack of corporate control over design and constru0ti'on'tandards and maintenance activities, DNE has initiated the Specification Improvement.Program (SEP),

which will provide ONIP with generic mestee specifications to cover construction, modifications and additions, and maintenance of TVA's nuclear plants.

The TVA corporate organization disagreed with the ii'inding that there is a lack of corporate and plant control over the use of consumables.

The response indicated that the loss of material traceability,for RTV coating on one junction box appeared to be an isolated case and'no'ction was found to be necessary since corporate and plant programs were adequate for controlling consumables.

This response was accepted.

However, this issue is being escalated to the Operations Category Report since the implementation of the corporate program for control of consumables

.is questionable based on negati,ve findings in other Operations Subcategory Reports.

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Page 4 of 4 II

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PAGE 2

OF 30 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction The seven concerns that comprise the Cables and Conduit Subcategory are.characterized by electrical hardware deficiencies and problems with procedures related to electrical aspects of plant construction and modifications.

1.2 Descri tion of'ssues The concerns were stated as perceived by concerned individuals (CIs) and were combined into four higher-order groups of related concerns called elements.

In this section of the report, each element is presented with a brief overview of its issues.

1.2.1 Element 304.01 - Procedure Problems Issue 304.01 Office of Nuclear Power (ONP)

Non-Compliance With Construction Specifications IN-85-112 -001 This is a broad based concern regarding ONP's compliance with construction specifications when making modifications and additions at Watts Bar Nuclear Plant

'(WBN).

The CI gives an example of a

new cable being pulled with no maximum pull tension or minimum bend radius specified.

Because this particular example is given, this concern was characterized to deal only with problems related to ONP's compliance with electrical aspects of construction specifications.

Issue 304.01-2

- Improperly Qualified Coating Applied to Junction Boxes:

TAK-86-005 In this concern from Sequoyah Nuclear Plant (SQN),

the CI thought that the Room Temperature Vulcanizer (RTV) coating applied to junction boxes under a Special Maintenance Instruction (SMI) may not have been properly qualified and may have been improperly applied to all junction boxes.

1.2.2 Element 304.02 - Electrical Penetrations Breached Issue 304.02 Use of Improper Tools to Breach Electrical Penetrations:

IN-85-207-002

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit;,

REPORT NlllMBER:

30400 REVISION NUMBER:

1 PAGE 3

OF 30 O

The CI repo'rted that steel fi:sh tape was used in lieu of the required, wooden or fiberglaiss rods to breach penetratioin seal's at MBN.

Issue

'304.02 Cable Pulled Through Previously Sealed Penetrations IN-85-862-002 A CI stated that ONP personnel at MBN ha!d pulled cabl~e through penetratiions after Division of Nuclear Construction (DNC) Quality Control (QC) personnel

'hadl signed off sealing of the penetration.

1.2.3 Eleraent 304,.03 - Cable Probleras in Manholes Issue 304.03 Poor, Disorganized Cond,ition of Elec'trical Manh! o les IN-85-!345-001 QCP-10 '5-8-13 One CI stated that electrical manholes at MBN are disorganized with!, cables having, 'been:spliced andi not properly laced down.

A CI also expres.ed concern about the condi,tion of electrical tmanholes at Bellefonte Nuclear Plant (BLN).

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I Ol 1.2.4 Eletnent 304 '4 - Loose Conduit Problem I,ssue 304.04 Loose Conduit. in MBN unit 1 Diesel Buildiing IN-85-465-002 A CI alleged that a conduit wa,s loose where it entered the cable tray in the MBN uni.t 1 Die:sel Building.

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TVA, EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 REPORT TYPE:

Subcategory I

TITLE:

Cables and Conduit REVISION NUMBER:

1 PAGE 4

OF 30 2.0 EVALUATION PROCESS 2.1 General Methodolo The evaluation of this subcategory was conducted according to the Evaluat.ion Plan for the Employee. Concerns, Task Group (ECTG) and the Evaluation Plan for the Operation Group.

The concern case files were reviewed.

Source documents were researched and interviews conducted in order to identify the requirements and criteria which applied to the issues raised by the concerns.

The issues were evaluated against the identified requirements and criteria to determine findings.

A col'lective significance analysis was conducted; causes were indicated for negative findings; and corrective action for the negative findings was initiated or determined to have already been initiated.

2.2 S ecific Methodolo Applicable sections from the following baseline documents were reviewed:

TVA NQAM and Topical Report; TVA General Construction.

Specifications; ANSI N18.7; National Electric Code,;

BFN QA Manual, Appendix B; Electrical Design Standard DS-E-13.5.1; BLN Design Criteria N4-SO-D788.

Numerous lower-tier implementing procedures such as Maintenance Instructions (MIs), Modification and Addition Instructions (MAIs), Administrative Instructions (AIs), and Standard Practices were also reviewed.

Information relevant to the issues was also obtained from memorandums, deficiency reports, Nuclear Safety Review Staff (NSRS) investigation reports and other ECTG reports.

The evaluators conducted informal interviews with cognizant personnel either to verify document-based findings or to provide nondocument-based evaluation input.

Interviews were conducted with cognizant personnel in the Division of Nuclear Construction (DNC),

the Division of Nuclear Engineer,ing (DNE),

MBN Preoperational

Testing, SQN Electrical Maintenance, and with an evaluator in the Employee Concerns Special Program's Construction Category Evaluation Group.

Inspections of selected electrical manholes at

SQN, BFN and BLN were also performed.

TVA EMPLOYEE CONCERNS SPECIhL PROGRAM'EPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PhGE 5

OF 30

3. 0 FINDINGS Generic appli.cability statements are included only for concerns which are classified a.

being potentially safety-related or safety-significant as denoted on attachment h.

3.1 Element - 304;01 - Procedure Problems Issue 304.01-1 ONP Non-Complianice W11th Corsstruction Specificationis:

WBN The concern regarding lack of ONP~ compliance with construction specifications was substantiated

~with 1i.espe<'.t

'to 'minimum bend radius for new cables as given by the example in the concern.

However,

-no safety-related defic,iencies were identified It was determined that ONP instructions for iristalling and ~inspecting cable termin'ations had not contained the inspection requirements for bend radius referenced in Construction Specification G-38, "Installing Insulated Cable Rated up 'to 15,000 Volts.,"

Before the current evaluation, however line management had already initiated corrective acti. on.

NCR W'-290-P had -been

issued, stating that, bend radius inspecti,on,s had not been accomplished on all cables terminated using M6AIs 4 and 5 because these procedures had not contained the inspection requirement.

The Engineering Report for the.NCR had recommended that the following actions be taken:

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io a.

MAI-4 and MEdiI-5 be, revised to include procedures for inspection of cable and conductor bend radius acceptability and provisions be made for. documenting'hese i'nspections.

b.

All Clas:

lE cable terminated, using M&AI-4 and MAI-5 be inspected for minimum bend'ra'dius acceptability and documentation be prov.ided for'erifying this acceptance.

c.

Any Class 1E cable not meetin'g the'equirements for minimum bend rad.ius in Electrical Design S'tandard 'DS-E12.1.5 be reworked.

At the time of thi.s report' writing, the revisions to MRAI-4 and MUI-5 had been accomplished.

No: safety-related deficiencies were identified during the evaluation by the Operations CEG.

However, the adequate closure of the NCR may identify safety-related i.sues.

ESCP, Construction

CEG, issued CATD 10900-WBN-Ol to WBN to determine the status of the remaining open items in the engineering report.

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PAGE 6

OF 30

~SN IRl The issue regarding lack of ONP compliance with construction specifications was validated for SQN by ECSP Construction CEG Report C010900-SQN.

This evaluation (304.01')

concurs with the findings and conclusions of that report.

The construction report identifi,ed the root cause to be an inadequate upper-tier document (G-38, for

,pulling cable) which resulted in inadequate site procedures.

The reason for the inadequacies was failure to recognize a need to monitor maximum pull tension (MPT) and side wall'earing pressure (SWP),

and failure to adhere to manufacturer's mini'mum bend radius (MBR), limits.

The ECSP Construction CEG issued CATD-10900-NPS-01 to track the deficiency of exceeding,

SWP, MPT, and MBR.

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BFN IR1 I

The concern regarding lack of ONP compliance with construction specifications in areas relating to electrical cable was substantiated at BFN, and safety-related issues were identified.

was determined that General Construction Specification G-4's requirements for maximum cable strain and for strain at a cable bend had never been fully implemented in BFN modifications procedures or electrical maintenance procedures.

On January 15,

1986, General Construction Specification G-4 had been superseded at BFN by General Construction Specification G-38 which contained more restrictive requirements than G-4.

Applicable implementing instructions still had not been

upgraded, however and CATD 30401-BFN-03 was issued concerning this deficiency.

The new general construction specification initially had been made applicable only to modifications work but later had been determined by DNE to be applicable to all related work.

A stopwork order had been issued in June, 19&6 by the BFN site director for cable pulling activities.

This order had remained in effect until the. M&AI for cable pulling had been revised to incorporate the detailed requirements in G-38 for cable pull tension and bend radius.

The MLAI had been revised and approved in September 1986 and a

memorandum had been sent to all Electrical Section Supervisors requiring that the installation of all CSSC cables be done using the MSd,i.

Two other instructions dealing with cable pulling, a

modifications instruction and an electrical maintenance instruction, had not yet been upgraded to the requirements of G-38 as of this evaluation.

CATD 30401-BFN-02 was sent to BFN to address this deficiency.

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1%A EMPLOYEE CONCERNS SPlECIAL PROGRAÃ REPORT NIJMBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REVISION NUMBER:

1 PAGE 7

OF 30 It was also determined that the requirements of Appendix B to 'th&

Construction Quality Assurance Manual have not been fully implemented in modifications or eletrical maintenance instruct;ions.

There was no doctumen5ed~evidence that the modifications and electrical ma,intenance instructions had b4en verified to be equal to, or bet,ter than, the procedures i.n th6 Construction Quality Assurance

Manual, Appendiit B.

CATD-30401-BFN-01 was issued to BFN Line Management concerns,ng'his'eficiency.

A review of the NQAM and BFN Site Director Standard Practicie 2.4 showed t;hat there has been an inadequate program at BFN t.o incorporate des:ign output documents and changes to upper-ti4r documents into.Lower-tier documents.

Currently, revisions 6o general spiecifications are sent, only to the Modifications s6ctiott for incorporating int;o applicable implementi,ng procedures.

There is no provision to notify other sections

uch as Maintenance, Traini,ng',

Fire,'Protection and Performance Testing theist may be affected by changes to general specifications,.

Also, Standard Practice 2.4 cioes not address standard drawi,ngs; therefore, no plant section is being officially informed of either the exist:ence of standard drawings or of their revisions.

CATD 30401-BFN-04 as sent to BFN concerning this defic,iency BLN The concern regarding lack of ONP compliance with construction specifications iin areas relating to electrical cable was evalu'ated

'or generic appli'cabi.lity to BLN.

The concern was not substantiateid at BLlM and'o safety-related issues were identified.

It was determined that BLN ONP personnel have not installed any electrical cable on any perm'anent plant equipment.

Instead, DNC has handled all electrical cable installation assoc,iated wraith modificatilons and additions, even for systems already transferred.

to.ONP.

This has been done:in accordance with the NQAM, which designates

'DNE'and DNC'ith, the responsibili,ty for design,, procurement, and, construct'iov'i activities applicable to modifications and -addiitions before a plant is licensed.

Conclusion This issue was found to be.factual, at WBN, however, the deficiencies wete identified and corrective 'action was initiated by the plant before an employee concern evaluat.ion.

The is.ue was also factual at SQN and BFN; safety-related deficiencies were identified by employee concerns evaluations a'nd'cotrdctive action was required.

The issue was not substantiated't'.

BLN.'

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables and Conduit J

REVISION NUMBER:

1 PAGE 8

OF 30 Issue 304.01 Improperly Qualified Coating, Applied to Junction Boxes

~SN The concern regarding the misapplication of RTV at SQN was substantiated, a potentially safety-related issue was identified.

It was determined that the terminal blocks in junction box 3190, coated under the SMI identified in the concern, is required by the Environmental Qualification (EQ) binder to be coated with QA-RTV 3140.

A review of the MR which had covered the work for junction box 3190 revealed that there had been inadequate material traceability regarding the RTV used in the work.

The inadequate material traceability had been found subsequent to the work, and the RTV.used to coat junction box 3190 had been marked "No QA."

Therefore, the qualification of the terminal block coating was questionable.

CATD 30401-SQN-Ol was issued concerning this deficiency, A review of three other work requests for coating a total of 23 terminal blocks with RTV 3140 showed proper material traceability.

Also, an NSRS investigation had been conducted to address the material traceability practices of the Electrical Maintenance Toolroom.

All corrective. actions in response to the NSRS report were completed by the time of the current evaluation and were determined to be adequate.

. Conclusion The issue of improperly qualified RTV coating was. found to be factual and corrective action was required.

This issue is considered potentially safety-related.

Generic A licabilit This issue was evaluated as the site of concern (SQN) and was determined to be isolated to the specific installation specified in the concern, therefore, evaluations were not conducted at any other sites.

TBl EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables and Conduit, REVXSION NUMBER:

1 PAGE 9

OF 30 0

3.2 Element 304.02 Electrical Penetdatlioi>>s Breached Issue 304.02-1

- Use of improper hoofs 'to breach electrical penetrations:

The i. sue regardling use of steel fish tape to breach penetr>>I!tiIon

'eals was evaluated specifically at MBN ar>>d generically for iSQN.

i The evaluat'.ion at these two plants showed'th'at there is no upper-tier document forbidding th6 use

~of steel fish tape.

It was determined that use of steel fish, tape,to breach electrical penetrations is a matter left to the judgment of the variouS plants" line managers.

At MBN this practice is forb'idden in all instances, but at SQN the use of steel fis'h t.ape is accept;able for "breaching',

cable tray penetrations,.

Each t!1>>int's requi~rements are written i~n its own M&AI.

WBN IR1 The concern regarding use of steel fish tape to breach elect'.rical penetration seals was found to have been sub~stantiated for btBN'hrough a previous evaluation cbnducted by N'SRS.

The NSRS tl'epbrtl, I-85-702-MBN, had determined that fish tape

~had apparently

.been used for breaching congested penetrationsi This practice had been kn

~

violation of the ONP M&AI-14 which permitted use of wooden or fiberglass probes.

However, no instances of cable damage resulting'rom the use of fish tape had blee6 fbunld.

NSRS had concluded that management contro3.s on the breaching process had been inadequate to ensure that approved procedures and practices were being followed.

In its report the NSRS had made the fdllowi'ng'ecommendat;ions with regard to ~improving man'agement control'ovet

'th>>>>

breaching process:

a.

Review the breaching proced'ures and either revise the procedu'res to permit adlditional tools to be used or confirm the existing ones to be adequate,.

b.

Instruct the crafts on the use of the established procedures.'.

Require the breaching proce'ss 'to'e observed by the QC inspectors and signed off accordingly In response!

to t.hese recommendaltidns, MBN~ line management had i

committed t.o revising the instrt>>ct'.ioi>>s ~as'appropriate and to trainling the crafts.

However, line manlageme~nt had not agreed that a

QC inspector should be requiredl td observe breaching.

The responsei also had noted t,hat WBN-DR-85-268 ~had been w~ritten to document the past use of fish tape.

CATD 30'402-MBN-'02'wa's written for MBN t,o

'rovide status of these correct'ive actions..

0

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables

.and Conduit REVISION NUMBER:

1 PAGE 10 OF 30 During the current evaluation a procedural discrepancy was noted.

It was found that the DNC procedure for breaching, references applicable ONP instructions;

however, the body of the procedure does not state specifically that the ONP instructions are to be used.

CATD 30402-WBN-01 was issued for WBN addressed this discrepancy.

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The concern regarding use of steel fish tape to breach electrical penetrations at WBN as evaluated for generic applicability to SQN.

The concern was not substantiated because the applicable

.SQN M&I allows for the use of a steel fish tape for breaching cable tray penetrations.

For breaching of conduit seals,

however, the MMI requires use of a nonconductive probe.

Site Electrical Modifications Section personnel were found to 'prefer use of a nonmetallic probe to breach all penetrations and seals where possible.

It was determined that a steel fish tape is used only where space restrictions prohibit the use of longer, unflexible probe.

During the evaluation it was noted that MGAI-4, "Control, Power, and Signal Cables," did not reference MSAI-13, "Electrical Pressure

Seal, Fire Stop Barrier, and Flame Retardant Cable Coating,"

and did not show any responsibility for the craft to be aware of the requirements of M&I-13.

CATD 30402-SQN-01 was issued concerning this discrepancy.

Conclusion The issue was found to be factual at WBN and corrective action was required as the result of an NSRS evaluation.

The is'sue was also found to be factual at SQN but not a problem since SQN site procedures allow this practice.

However, a problem was noted at SQN in that M&AT-4 did not reference MGAI-13 and corrective action was required.

Generic A licabilit The results of evaluations at WBN and SQN identified no upper-tier documents prohibiting the use of steel fish tape.

Further, no evidence of damage due to the use of steel fish tape was found.

Although, WBN had revised procedures to prohibit the use of steel fish tape, no safety-related issues were identified which would warrant other site evaluations.

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PAGE 11 OF 30 o!

Issue 304.ID2 Cable pulled thrOugh previously sealed pen~tr'ation's WBN The conc:em that WBN ONP personnel pull cable through penetkatiorLs previously sealed by DNC was not substantiated,.

It was found that there are procedures which preclude ONP from using existing conduit and cable trays during modification and maintenance activities.

The applicable ONP MAI for breaching was found to provi;de requirements that 'breached penetration seals be replaced in accordance with'esign requirements.

Therefore, the activit,ies identified are'llowable by exlisting plant procedures and dlo not constitute a

problem.

Conclusion While the;issue of pulling cable through previously sealed penetrat,ions is factual, this is not a problem and requires'no'orrective action.

Generic

~A olicabil~it Since the condition described by the concern was found not t'.o be 'a problem at, WBN, further site evaluations were not necessary.,

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I 3.3 Element 304.03 Cable Problems in Manholes Issue 304.03-1

- Poor, IDisorgan,ized Condition of Electrical Manholes In the evaluation of electrical manholes at each of TVA's four'uclear

sites, a

common problem was found with standing water in 'thk manholes.

In was determined that'the non-loaded, energized, level V

voltage cables eubmerged beneath this standi'ng water may be

'subject'o a condition known as "water-'treeing."

This condition involves the buildup of microscopic voids between the insulation and'onductor and may result in insulatiion degradation

.and shortls.

Thil issue was identified as a poten'tieill'y s'af6ty'-related

'problem fear ~all TVA nuclear sites.

CATD 30400-NPS-01

and, CATD 3040'3-NPS-01'r.re i.sued to the l.'VA corporate organi,zation concerning this matter..

The concern that, electrical manholes at WBN are in a disorganized state had been substant:iated in al NkRS itive'stigation report, (IN-85-945- 001).

The NSRS eval'uat;or had observed general debris in I

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REVISION NUMBER:

1 PAGE 12 OP 30 manholes and cable trays, missing cable tray covers, and cables routed outside of trays.

Recommendations noted below made by NSRS had been agreed to by line management and had been placed on the outstanding work item 1'ist (OWIL, item number 0-299-M-5515) for tracking.

l.

All manholes and handholes will be cleaned, missing cable tray covers reinstalled.

and any cables outside the trays shall be identified in accordance with ONP procedures if it is a

temporary cable or reinstalled in the tray if it is a permanent cable.

Temporary cables not being used will be removed.

2.

Maintenance requests shall be issued to repair any defective equipment

(,e.g.,

sump pumps) in the manholes.

3.

Permanent manhole and handhole covers will be installed.

Signs shall be installed indicating that entry must be authorized by a workplan or maintenance request and a confined space permit if applicable.

Revise MAI-3 to include instructions and an attachment to record all cable tray covers removed for cable installation activities with second party verification that the cover was reinstalled at the end of the cable 'activity.

5.

Rev.ise AI-8.5, AI-8.8, and AI-9.2 to include the requirements of'I-1.8, "Plant Housekeeping" in all workplans and maintenance requests'.

Revise MAI-3 and AI-2.15 to include instructions identifying temporary cables installed in cable trays.

The current evaluation determined that all corrective actions have been completed with the exception of revision of Administrative Instruction (AI) 2.15.

CATD 30403-WBN-Ol was issued to WBN for tracking this item.

~SN The concern that electrical manholes at WBN are in a disorganized state was evaluated for generic applicability to SQN.

The concern was substantiated.

at

SQN, and potential safety-related issues were identified.

T'FA EMPLOYEE CONCERNS

',SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit, REPORT NUMBER:

30400 REVISION NUMBER:

1 P'AGE 13 OF 30 e

Videspread problems were found With excesSive water lying in electrical manholes and cable sumps.

Two manhole covers were found'o be below the surrounding grale, thus allowing drainage of water into the manholes.

Several sump!

pumps wet'e found inoperable, and the discharge piping from one sump pump had been disconnected.~

Sump pump controls and junction boxels Were foufld to have been loCated below sump level, and to have been flooded>>

Also, several manholes needed to be cleaned and to have debris removed.

The c.ableal ih all'anho]Les inspected were coated with mud'nd dirt.

There was a lack of procedures governing housekeepi'ng'n'd prevetitiVe maintenance practiices on electrical manholeS and~ th~eir, associated sump pumps.i CATD'.

30403-',SQN-01, 02and 03 were sent to SQN concerning 'this

'ssue BFN The-.concern t1hat electriical manlholes't'BN are in a disorganized state was evaluated for generic applicability to BFN.

The concern was substantiated, and potential safety-related issues were identi.fied.

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I Documents we'e reviewed to determi'ne'th'e requirements for cable insta]I.lation in manhole..

Seveh of the eleven electrical manhole's identified on BFN drawings were iflsphcted>>

Tuchis sample was ~belie~ved to be adeqviate because iit indicated Sev'eral recurring problems'n'd the need for better maintenance of all the manholes.

Man'holes C,

D,,

E, F,

G, H,

and I were inspected.

Manholes J

and N (Dewatering and Hypochlorit;e Build:ing)- were not inspected 0

.Housekeeping and prevent;ive maintenance practices on elect,ri'cal manholes and three of their associ'ated

'sump putnps (manholes E,

F ancl G) were found to be inadequate.

Manholes inspected during the evaluation were littered with c4rdbo6rd

hoaxes, rags, arid rotten scaffc>ld boards.

Numerous cables were routed outside of trays in manhole T,

and cable tray barri6rs'fld 'covers for separating 480-V and 4-kV cables were mi.sing in'ma'nhOle's F,

G and H.

In addition, manhole T c.ont,ained no provisions for.

a sump pump and had a corroded junction box terminal block.

Ih manhole H, an exposed energized~

plug was found lying on a metal cable tray and had presented a

severe elec.tr.ical

. afety hazard.

The unauthorized plug and wire were cut off and a light;ing c,ircuit wire was taped to eliminate the immed i,at e haz at d.

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-it is locateci in a

low area and the manhole cover is lower than the surrounding.

asphalt, According to drawing 10N319-1,RA',

'the cover should be above grade.

Three of six sump pumps checked were not operable, and their respective manholes were )oar'tiall'y flooded.

MR 740057 was initiated to repair F. and 1F sumio pumi)s; the sump pump i.n manho]l.e G

worked after the reset buttori was pressed.

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REVISION NUMBER:

1 PAGE 14 OP 30 During the course of the evaluation, other deficiencies were found which related to the concern being substantiated.

First, it was determined that Electrical Maintenance Instruction (EMI)-58.1 dealing with CSSC cable installation allows for unrestricted routing of temporary cables outside of'rays.

This.was thought to be a

contributing factor in the excessive number of cables found lying outside of trays in one manhole.

Second, very few taped splices found in manholes E, F, H,

and T were found to have a legible tag to identify their. respective cable

numbers, and most taped splices had no tag.

Finally, the manholes inspected were not well-labeled.

CATD's 30403-BFN-01, 02, and 03 were issued to BFN, concerning the above deficiencies.

BLN The concern that electrical manholes at MBN are in a disorganized state was evaluated for generic applicability to BLN.

A second concern specific to BLN regarding the condition of'anholes in the electrical cable trench to the Intake Pumping Station (IPS) was also evaluated.

From inspections and personnel interviews, it was determined that there are widespread, continuing problems with water accumulation in cable pull manholes.

Therefore, these concerns were substantiated, and safety-related issues were identified.

Areas inspected included manhole number 2A2 (roadway, east of Reactor Building number 2) and the cable tunnel beneath the 500-KV switchyard.

Other manholes were sealed with a bolted steel top over which a heavy concrete mis'sile shield was installed and therefore, entry was not attempted.

In the areas inspected, dirt and mud were found on cables,

trays, walls, and floors, and debris had accumulated in sump pump basins which could contribute to sump pump failures.

Additionally, water lines were observed indicating previous flooded conditions and possible sump pump failures.

At the time of inspection, the areas were found dry with neat and orderly cable trays, and operable sump pumps.

Construction engineers and managers were aware of water having been present in many manholes, often for prolonged periods.

Furthermore, they expressed confidence that many sealed manholes presently contain standing water but were not confident about the reliability of electrical manhole sump pumps.

TVA EMPLOYEE CONCERNS SPECIAL PROGPM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PAGl? 15 OF 30 4I There was no preventive maintenance or periodic hou: ekeeping program for electrical manholes and associated sump pumps as described by Design C'riteria N4-50-D788'.

These criteria'efine requirements to ensure C'lass 1E electrical cables are installed adequately 'to provide acceptable leve'ls of operating reliability.

The Design Criteria requires that all equipment necessary for plant safe shutdown in a f]Looded condition be located within waterproof structures, except the ielectrical cables installed in underground conduit banks between t'e D/G Building and the Intake Pumpihg Station.

In Section 5, it further requires that each manhole,'andhole or cab]l.e pull point be accessible -f'r periodic visual inspection.

CATD 30403-BLN-01 was issued to BLN concerning these deficiencies.

.Conclusion The i.ssu,e of poor, disorganized conditi.on of'lectri.ca'1 manhol'es'wa's found to be factual at WBN. SQN, BFN, and BLN and corrective acti. on was required.

The deficiencies identified are considered potentially safety-related.

3.4 Element 304.04 - Loose Conduit Pr blem Issue 304.04-1 Loose Conduit in, WBN,Unit I Diepel Building WBN The concern that.conduit is loose where it enters a particu]lar cable tray in the WBN Diesel Building was found to have been substan'tiated through a previous evaluat-ion conducted by NSRS.

The conclusion of the NSRS report

( I-85-227-WBN) had 'been that a unistrut-type clamp had been missing from one end of the conduit in question.

The'ecommendation of the, report had been to add a clamp to the "free end of the conduit.

In response to the report's recommendation,',

construe,tion personnel had reinspected the conduit and had issued NCR 6324 to initiate the reinstallation and reinspection of th4 missing clamp.

The current evaluation identiflted no safety-'related issue and determined that no further corrective actions were neces,sary for this concern.

It was determined that other issues

'elated to conduit ahd cable trays are being addressed in the Construction CEG Report C019200.

Con'elusion This

.issue was found to be factual and corrective action was required as a resu'lt of an employee concern evaluation,.

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 I

REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REVISION NUMBER:

1 PAGE 16 OF 30 A collective assessment of the element level findings (section 3.0) led to the identification of three subcategory level findings.

These three findings have potential impact at all sites and should therefore be addressed at the corporate level.

The findings were determined to reflect adversely on management effectiveness and dealt with electrical

manholes, use of consumables, and use of Design and Construction Standards as follows:

Generic A licabilit I

I This issue was determined to be specific to WBN and was resolved I

before the ECTG evaluation, no other site evaluations were necessary.

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4.0 COLLECTIVE SIGNIFICANCE I

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a.

There is a lack of corporate control over design and maintenance activities associated with water in electrical manholes at all sites.

b.

There is a lack oi corporate and plant control over the use of consumables at SQN.

c.

There is a lack of corporate control over design/construction standards and requirements'and their use at

WBN, SQN, and BFN.

Electrical Manholes With regard to the first finding, line management at all sites had failed to recognize electrical manhole problems.

One common problem was that of standing water in manholes which could result in "water-treeing" of electrical cables.

'At all sites there was a lack of housekeeping, and preventive maintenance procedures for electrical manholes.

Additionally, manhole covers. were found installed below grade resulting in water inleakage and sump pump control boxes were being flooded because of their location below sump level.

Use of Consumables For the second fin'ding, there had been an instance of inadequate traceability of the RTV used for coating safety-related junction boxes which require "quality assurance" rated RTV.

Other examples in the Operation Category of materials that were inadequately controlled include teflon type (subcategory 30900),

Raychem heat shrink insulation (Subcategory'0200),

door hardware (Subcategory 30600),

Kerotest valves (Subcategory 30100),

containment paint (Subcategory 30100),

and cleaning solvents (Subcategory 31300),

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER".30400 REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REVISION NUMBFR:

PAGE 1.7 OF 30

~Desi n/Constr.ection,ttendatds For the third finding it was determined that ONP instructions fear

'nstalling and inspeicting cable terminations had not.contained the

~

inspection requirements for bend radiu:s as found in Constructi.on'pecification G-38.

However, MBN li.ne management:

had ali.eady initiated corrective action to address bend radius inspections before the 6udreht evaluation.

Inadequate site procedures at SQN vere determined tb be 4

result of the failure of G-38 t;o r'ecognize

.a need to monitor maxim6m )ull tension (MPT) and side wall pressure, (SMP),

and failure of G-38 to

'equire adherence to manufactur.er's minimum bend radius limits.

5.0 ROOT CAUSE~PRELIMINARY ANALYSIS Sections 3.0 and 4.0 discussed the specific findi,ngs for each of'he element evaluations of this subcategory and their collect.ive significance.

This section, presents the results of an independeht

'revie'w and analysis done on these specific element-level. findings to ident'ify the most frequently occurring and videspread root; causes at the subcategory level.

Patterns of recurring findings called symptoms werj'e derived from the elements.

These symptom's Were tested for root j:ause<,

and the rorot causes for all elements were then analyzed collectively to identify which occurred most frequently and at the. most sites.

Detiails i

of the symptoms and root causes derived for each element are presented in

.Attachment D,

"Summary of Symptoms and Root Causes."

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0 A review and analysis of t'.hese sympt'orna>

and 'root causes taken collectively points to the, following, four significant root causes:

(a)

Various prdcedure

problems, including inadequate procedural'co'ntent',

personnel error in using proced'ures,'nd lack of adequate pr'oc'esses'o ensure that corm'itments are 'reflected in.procedures.

(All sites)

(b)

Inadequate processes for recogn'izi.ng'dverse trends in the condit,ion

.of electrical manholes, and therefore t'here 'are no actions taken to pr'eclude rec'urrence of problems'.

'(All 'sites)

(c)

Judgment errors concern:ing vated 'draina~ge were made by engirtee&s and their supervisor's with respect to 'initi'al'de'sign of electrical manhole s.

(All s ites )

IR1 (d)

Acceptance criteria are inadequht6 t6 e'nsure satisfactory initial'esign of electrical manways.

(All sites)

These four subcategory level root.. causes hre supp'ort,',ed'y various findings at all TVA nuc'.Lear plants as d,iscussed below.

O

TVA ENPLOYEE CONCERNS SPECIAL PROGRAN REPORT NUMBER:

30400 REPORT, TYPE:

Subcategory TITLE:

Cables and Conduit REVISION NUMBER:

1 PAGE 18 OF 30 Procedure Problems At SQN, the lack of material control for RTV was determined to be parti, ally a result of insufficient training for personnel in the use of procedures.

At BFN, a lack of controls to ensure commitments are reflected in procedures contributed i.n part to inadequate review and implementation of construction specifications and inadequate configuration control regarding cable pulling and installation.

At SQN,

BFN, and BLN, there are inadequate controls to ensure housekeeping commitments are reflected in electrical manhole preventive maintenance procedures.

At SQN, a procedure (MEAI-4) was found to be incomplete by not providing,adequate

.reference to a related procedure.

Finally regarding procedures, personnel error was responsible in part for lack of material control (RTV) at

SQN, and improper breaching methods at MBN.

IR1 Inade uate Reco nition of Adverse Trends

'For

SQN, BFN, and BLN, there had been inadequate processes to recognize a

need for work controls regarding preventive maintenance and housekeeping of electrical manholes.

The results of this were recurring conditions of flooding, scattered debri's, and improperly secured cables.

Errors in Jud ment At SQN, manhole covers had been located below grade and sump pump control boxes were located below sump level, thus resulting in flooding of these areas.

At BFN, a manhole had no provisions for a sump pump.

Inade uate Acce tance Criteria At SQN,

BFN, and BLN, inadequate acceptance criteria in the initial design process resulted in inadequate design controls for electrical manways.

Corrective Action Tracking Documents (CATDs) were not issued specifically on these subcategory-level root causes.

It was believed that corrective actions being taken already by line management as part of the commitments made in the Nuclear Performance Plan were helping to address these root causes.

However, line management was expected to use the subcategory-level root cause information as an aid in preparing corrective action responses to subcategory-level CATDs that would preclude recurrence of the deficiency noted.

The ECTG's process for judging the adequacy of line corrective action, responses to subcategory-level CATDs included a determinat'ion"of how well the applicable root causes were addressed by the response.

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TVA EMPLOYEF. CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REVISION NUMBER:

1 i,PAGE 19 OF 30 The significant root causes for all subcateg'ories in the operations~

category provided part of the input for determining programmatic 'arieas of weakness at the category level and t]he associated causes.

In the, operations category report, these progrtammat]ic'weaknesses and associat'ed'auses are presented along with a diacdssionl of how they are being,

'orrected through implementation of thel N&clead Performance Plan and other corrective, action progr.ams.

'. 0 CORRECTIVE ACTION 6.1 S~ecific Deficient!ies and Findi d

a the Element Level 6.1.1 Element 304e01 Procedures Probleriss SQN CATD 30401-SQN-01 was sent to SQN line management recommending. requalc<xee'~in a~~f"55Xling For tert'locks in junction:boa;P'L9()!.e:(QNPXfjtg diRnagement rb stat ing, *, p,~.)g:t'g~,",']t pe (-QlsdtI "JB 3190 was.z'ic~>$ ked with,+V~3 )W,,equest B200741."

P-ar.'i'0 Liv~~~~~

i',nal dpogda]d (MR) avvaca~~~~armww BFN The following, CATDs weire issued to BFN line management:

0 30401-BFN-0!L (Rl)

Site instructions have not been verified as being equal to or better than Construction QA Manual, procedures.

30401-BFN-02 (Rl) - Cable installation procedures not, in accordance with G-4 or G-38 prior to June 18, 1986.

30401-BFN-03 (Rl)

-, Inadequate implementation of design output. documerits, i.e.,

G-specs.

30401-BFN-04 (Rl) - Lack of corporate program to ensure implementation of design output document;,

listed in NQAM.'

TVA EMPLOYEE. CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PAGE 20 OF 30 The BFN line response states as follows:

30401-BFN-01 (R1)

"The Design Baseline and Verification Program will confirm that safety related systems and components are reconciled to their design basis.

This vill bo accomplished through the following actions:

c.

Issuance of unitized Configuration Control Drawings (CCDs) as replacements for the as-built drawings a.

Review of the documented commitments/requirements and licensing basis followed by a compilation of the design criteria into controlled documents b.

Malkdown of the systems for functional requirements d.

Comparison of the design drawings with the verified as-built data e.

Evaluation of the systems for conformance with the design basis and documented in System Evaluation Reports (Systers) f.

Reissuance of the CCDs as the verified single drawings of record "In addition, the transitional design change control process has been implemented to maintain the configuration which the DBVP will regain.

The transitional design change control process will be compatible with the permanent design change control process to be operational by December 1987.

Both processes rely on the verified CCDs as the controlling documents for design, modifications, operations, and maintenance.

"The Specifications Improvement Program will also support maintaining the configuration of the plant.

SIP will confirm that implementing documents contain necessary information to assure that the design basis is in accordance with the documents issued by the DBVP.

The Master Specifications will be issued the first quarter of 1988.

The Engineering Requirements Specifications issued, date is being developed."

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TFA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables and Conduit, IKVISION NUMBER:

1 PAi GP 21 OP 30 4l 30401-BFh1-02

( Rl )

"DNE to Resolve Significant. Cond,ition Reports SCRBFNEEB8716, RO and SCRBIFNEEB8634, RO."

NOTE:

SCRBF'NEEB8716 identifies 1".hat cable pulling tension'ay hiave been viol.atoned since G-4 requirements were never fully implea>ented into modifications or

,'aintenance procedures before June 26, 1986l SCRBFNEI.B8634 identifies that manufacturer'S limit,at:ions on cable bend radius may have been viols,ted.

This CATD wi.ll be resolved via r&solut'.los of these SCRs.

30401-BFh1-03 (Rl }

1.

"Procedures section to submi.t a revision to SDSP-2.4 t;o requi.re all G-Spec revisions to be sent to all affected

'ecti.ons, and that Procedures;section to assist in 'th6 determination of affected sections.

2.

Procedures section to review all G-Specs to de'termi'ne'hich ones state that they are applIicable to BFN and provide a list of them to Document Control.

Document Control to ensure that the latest revision of each has been addressed by SDSP-2.4 f'r source document impleme ntat ion.

3.

Design output document.

applicable to BFh1 should be identified and controlled as a result of CAIR 85-001, item:

5 and 7 and ONP Standard 4.4.10.

QA is requesti,ng a plan and schedule for action on items 5 and 7.'.

Procedures siection to revise SDSP'-24 to address'mplementation of each type de;sigh output. document identified as a result of OhlP Standard 4.4.10."

30401-BFN-04 (Rl) 1.

"An NQAH, Part I, Sectiion 2.2 (ID-QAP-2.8), revision request was,sent to the Chief, Quality Systems

Branch, on February 26, 1987. It was Written Iin response to CATD-30401-BIFN-06,, which was recalled and replaced by',

this CATD-30401-BFN-04 Rev.

1.

The revision request mentions CAR 85-001.

QA is requesting a plan and schedule for action on items 5 and 7 of t:he CAR.

2.

DNQA revise NQAM as requested above,.

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PAGE 22 OF 30 3.

BFN implement NQAM revision.

CAR 85-001 items 5 and 7 are required for startup and scheduled for completion in May 1988."

6.1.2 Element 304.02-Electrical Penetrations Breached WBN

-p

.n 30405-WBN-01 is:

'"SOP'.42'.i;s bo be'delMOd+MCATB BI900'-

- 1.

DNC d do breaching.-as

.thsia~is func~n gator b

difica DNC makes requests &r breach~

~WB I~O ara e~ "i'll~

aanhcat

'%40p4%4 es not ions.

raph The WBN line response for 30402-WBN-02 is:

Two CATDs were issued to WBN line management.

CATD 30402-WBN-Ol identified a deficiency in SOP-42, the DNC procedure. for breaching.

CATD 30402-WBN-02 requested the status of actions taken in response to recommendations made by NSRS in a

revious evaluatio e for "WBN Instruction Change 85-878 was issued against MAI-14 Revision 5 on 12/17/85 which stated t at a fish tape shall not be used to breach an electrical en ation and that a

wooden or fiberglass rod can be su titute or the wooden nose tool.

This instruction chan e was perma tly added under revision 6 of MAI-14 date 2/25/86.

W - 268 was written against plant procedur P~aus th y did not prohibit the use of fish tape

~

c 'lectrical penetrations which could pos i

'a installed cables.

The immediate and i~

orr i

e action taken for this DR was the issuance

@8~+5-875.

B-DR-85-268 was closed by pQA on 12/31/Sp'..ei/bate the above restr ictions on the use~'o

-Rh tQ s

hen breaching electrical penetrations &hi rGbr e

and documented per WBN-QCI-1-.11-1 Revisionogn Q for the Nuclear Services Branch craft and crag.fWoemanXPn lved in breaching of penetrations.

/

r

. The ccrrective act/on inkipt in response to I-85-702-WBN is complete.

IC-85-878 was incorpo'rate5 into'AI-14 Revision 6 on 02-25-86.

. Training was conducted n 01-09-86 and 01-13-86 on breaching of fire barriers 4n a

ordance with MAI-14.

DR-85-268 was completed on 12-31-Z5 to restrict the use of fish tape.

No further action required."

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NtBfBER:

30400 REPORT TYPE:

Subcategory TITLE:

Cables and Condluit REVISION NUMBER:

1 PAGE 23 OF 30 6.1 CATD 30402-SQN-Ol was sent to SQN line imanagement noting that M&AI-4ME4-ea1~efary~ Mi&I-13 and did not show an/

respoeisjlbi3..it!( fcrr-.Qe g:ra]'t to be Fvare Zi~M

'rrts of 'NJcI 13;..:.f~QN 1ine.:.min jg@ijflr~r~e>pl9!~ting:

-'.~4 v,Irr:t; i,r:" f 'r"'gi.

"M&AI-'4 was reviaeci'oa08-13-86, o 'in rpor te the refe ehce to M6dil-13."

\\

.3 Element:304.03

- Cable Pro'blemsMn, KPn55TFS I Rl, NPS In CATD 30403-NPS-Ol which was,sent to DNE-Electrical, TVA corporate management vas requires'ted tb evaluate the potential; for "water-treeing" to occur on cables in electrical'anholes submerged in;standing water.

Tlhe corrective action response isr "TVA will take corr:ective action for this CATD in two phases,.

For the first phase the following actions vi'll occur:

L.

Sump pump deficiencies wi,ll be corrected in, all Class lE CSSC manhioles and handholes except those used for cabling to the additional Diesel Generator Bui.ldings.

This will, include sump pump power suplplies,,

controls, and piping, and will lbe accomplished using applicable maintenance iristructions (If the above cannot be accomplished prior to restart of SQN unit 2 it shall be acceptable to use temporary means to ensure tlhe water level is rrraintained below the cables within the manhole/hand'hole).

2, Existing high potential and/or megger test results for all Class 1E/CSSC medium and low voltage pawer cables routed throu:gh the manholes and.handholes vill be obtained.

I'f lt;est results are npt available tests will be performedl in accordance to applicable site procedures, or instructions.

These tes'C results will be evaluated t,o determi.ne if the cables are adequate for their application.,

Any found to lbe inadequate will be replaced.

The second phase of the evaluation will include the following:

1..

TVA will evaluate all Class 1E/CSSC cables and spli.ces in all manhajles/handholes

'for fitness of duty relative to past and future,subreergerance with respect to manufacturers test data.

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PAGE 24 OF 30 2.

TVA will investigate and determine the root cause of known MH/HH flooding.

This investigation will include as a minimum identification of and deficiencies in the following:

3.

TVA will determine corrective action to prevent recurrence which may include the addition of water level alarms and the incorporation of an upgraded Preventive Maintenance Program."

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a.

Sump, sump

pump, and piping design and installation.

I b.

Reliable, automatic operation of sump pumps with controls and power connection protected from flooding.

I c.

Water-tightness of covers and gaskets.

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d.

Location of covers above grade.

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Internal sealing to prevent excessive leakage.

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WBN line management was requested by way of CATD 30403-WBN-Ol to provide. the status on remaining corrective action associated with a previous NSRS investigation of rical manholes.

The WBN line response i

.'m "Wothplm i

b-1 which wodtelQ<@K geljigi'notified b Emplayee ;dence.rL 5 8+36.-@.g~";

mm4"tsn iew with ei1 items',coqplfte.'except'~he e ectri

~a' ce secti n has t '

not yet rev>sed iQ-2.15.

T eCVx son

~

z s,t~o include instructionif. id 'm es ihstalled in cable trays.

At c revision to AI-2.15 workp)yn AS515.-1"will be closed and sent to the vault."

~SN

. CATDs 30403-SQN-01, 02, and 03 were sent to SQN line management in Electrical Maintenance and DNE noting that CSSC cables have been submerged in water with potentially adverse effects.

The acceptable response received.from Electrical Maintenance personnel at SQN was as follows:

TVA EMPLOYEE CONCERNS SPECIAL PROG1ULN REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

1 PAGE 25 OP 30 "Electrical Maintenance wil'1 assign an engineer to (a) identify manholes to be PM'ed, (b) prioritize manhole

list, CSSC first, (c) develop a

PM to address

problems, and (d) schedule and perform PM's (and initiate corrective actions as necessary)."'on~Term "Electrical Maintenance will aiccelerate the completion date of the portion of their assignment concerning level II Class 1E cables.

We will tar ~ the completion of the development and performance f'deduces g's to August 31, 1987."

The acceptable response re i

lfgo personnel at SQN

.was as follows:

euQ la i "X.

Correct sump pun i Ifc 'inn<

iiricluding poiveg supply, control,q t dl a.ge piping) in all Class, 1E/CSSC manhol

.s 4

'Hfb )

xcept MH 41 (MH '41 is'or the additi i>QQ gva generator.)

iQiq II.

Obtain the h'i potelkal and megger test results for -all Clas QMQSB+a um and low voltage power cables rout d M~u@

h MH/HHs. If the test results are nba Avail

e, perform the tests in accordance wgQj'Ml-1' Evaluate the test results to determ'nQzW the,l ss 1E/CSSC cables are'E, adequate

~as~

p ication.

Write work requests

,to repla e,~dey e cables "

"Note: I~fL':Iare required, before unit 2

restar Eva uate&11 C

a

s. 1E/CSSC cables and splices f'r fit ejQrgpf~

e'lative to past and future su ma",QncR~it i respect to manufacturer's test data.

IV.

'E%gate a

determine the root cause of,MH/HH floodi~~ Th i,nvestigation should identify~ any def iciencieWin the following:

~.!

A.

Sump, sump pump and piping design and instal~lation.

B.

',Reliable, automatic operation of sump pumps with con,trois and power connection protected from iflood:ing.

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM I

REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER'0400 ISION NUMBER:

1 OF 30 V ~

I C.

Water-tightness o

c5 a

kets.

I D.

, Location of cov ve d

E.

Internal sea n t p

excessive inleakage.

Determine oqg~i t'

'to prevent recurrence.

The addi o~+ wate 1

el alarms should be conside

+W~e co e tive action should also consid Weffec f an accelerated Preventive Maint n~

p evi y submitted and approved by ECTG Ray%

30 3

QN 03-Rl.

J st,FX:.jca CAP 304.03 SQN 03 is as follows:

0+

edi v

tage cables that are energized and N~ly 1 d d are subject to,electro-chemical eeing.'ce water will be removed by sump pumps f

2 restart, any cables failures will be

~N"Wan~a theref'ore accommodated by single failure

"~ crite>i t

Items III, IV, and V have an estimated corn etion of after Ul restart."

BFN CATDs 30403-BFN-01, 02, and 03 were sent to Maintenance,

DNE, and Modifications personnel at BFN to document the numerous deficiencies associated with electrical manholes.

CATD 30403-BFN-02 to DNE noted problems in one manhole with.

respect to (a) missing, cable tray barriers and covers, and (b) numerous cables being routed outside of cable trays.

For the same

manhole, CATD 30403-BFN-03 to BFN Modifications addressed (a) the need for a sump pump and (b) the presence of a corroded junction box terminal block.

CATD 30403-BFN-01 to BFN Maintenance identified the lack of a formal manhole maintenance program as well as problems with manhole cleanliness, with manhole labeling, and with the electrical maintenance instruction for CSSC cable installation.

The corrective action response from BFN management is as follows:

30403-BFN-01 "MRs will be written to correct the housekeeping problems identified as follows:

(a) Item 1 - General cleanup; (b) Item:5 - Tape bare ends of cable (3/c 7/19) in MHT; (c) Item'7 - Replace broken splice connector in MHE; (d) Label manholes legibly - Item 9.

This can be tracked by assignment No.

6018; expected completion date 3/30/87.

TVA EEiiPLOYEE CONCERNS SPECIAL PROGRAM REPORT'YPE:

Subcategory TITLE:

Cables and Condui't REPORT NUNBERr

30400 REVISION NmtBER:

PAGE 27 OF 30

~:

Items 2

6 4 - EMSIL will be written to check AH sump pumps and issue BF-ill to perforate inspection r,egularly.

See assignment No. 6019.

Expected completion date

'/30/87.

3.

Item 3 - Regular check of sump ptrmp vill prevent fl,ooding."

304i03-BFl!f-02 "On workplan 8491 and ECN P0287 there were Cablea pirll'ed i.nto manhole T and abandloned.

Also on 'the same vorkjpla'n And'CN, cables vere pi~lied into manhole T 'that were to be temporary cab]Les but are now in place as permanent cabl'esl.

These cables were routed, outside the cable trays and'herefore not properly installed.

Corrective action for cables being routed outside the cabl.e trays in, manhole T vill be to create enough slack in the cables so that the cables can be put back in the trays.'o accomplish thi.s, two ribs must be cut. out of the bottom of.

the t'rays which wil.l create the necessary slack.

Then 'the cables are to be pl.aced in the cable trays and tied down neatly.

This modiification will be done per ECN P0287, The additional scope for ECN PO'287 and schedule for design wil'1 be dIetermined by October 1, 1987.

Al,so at that time, the cable trays'iLll in manhole T wiill be evaluated.

This wodk is not required for unit two cycle five restart.

Ãietal barriers and covers which were not installed in the trays shown for manholes F

G, H,

and J to separate 480V and 4-KV cables are not. required at this tirae because the 4-KV bus tie ]Line cables have been abandonedThese cables were abandoned because they failed el.ectrica]L tests and will nest be used i.n the future.

New 4-KV bus tie line cables are presently installed. in a temporary overhead configuratibn.'hould they ever, be put in ca'ble trays again, they will be in trays by themselves or. have adequate metal barriers and covers for separation,"

30403-BFN-03 "Temporary corrective maintenance has been initiated by Electrical Techn:ical Section.

Also, assignment 6019 has been issued to Lyle Knox and Rod Howell (ETS) to issue a

ACR tcj add a permanent sump pump i,n manhole "T" and to replace the term strip with a water-proof splice."

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER'0400 REVISION NUMBER:

1 PAGE 28 OF 30 BLN CATD 30403-BLN-01 was issued to BLN line management noting the lack of a preventive maintenance or periodic inspection program for electrical manholes as described in Criteria Document N4-50-D788.

The BLN line response is as follows:

"The subject CATD and related concern findings has boon reviewed within the BLN site organizations, and we agree that the electrical manholes contain water, mud, debri's, and inoperable sump pumps.

BL'N will add as a part, of their preventive maintenance program a periodic inspection requirement.

This will be completed by FY -1988.

Additionally, in discussion, with DNE, an NCR (NCR 5154, RO) has been formulated for a design re-evaluation delineating the problems associated with water accumulation 'inside the electrical manholes, sump pump failures, pump electrical outlet location, etc.

This item will be entered into TKOI for tracking through final corrective action."

6.1.4 Element 304.04 - Loose Corduit Problems IR1 No further corrective action was required for this element.

Corrective action identified'y a previous evaluation had already been accomplished at the time of the current uvaluat.ion.

CATDs 30400-NPS-01, 02, and 03 were sent to TVA corporate management to address the three subcategory-level findings of this subcategory, as presented in section 4.0 of this report.

It appears that Lwo of the subcategory-level negative findings are consistent with problems previously identified by TVA and already being addressed through implementation of the Nuclear Performance Plan.

These two negative findings deal with procedures problems and with precluding recurrence of problems through trending and root cause analysis.

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I The corporate response to CATD-30400-NPS-01, which identified lack of control over design and maintenance activities associated with water in electrical manholes, states:

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"DNE has initiated the Specification Improvement Program (SIP),

which will provide ONP with generic m'aster specifications to cover construction, modifications and additions, and maintenance of TVA's IR1 nuclear plants.

The main scope of SIP (67 master specifications) will be complete by Dec.

1987, but will be added to as user noeds are identified.

LEB will assure compliance with SIP.

The I

implementation of the master specs will prevent recurrence of the problems with water in electrical manholes at all sites."

I

TVA EME?LOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:-

Cables and Conduit REPORT NUMBER:

30400 REVISION NUMBER:

PAGE 29 OF 30 4

~

'he TVA Corporate respo'nse to CATD-36400-NPS~02, which dealsi withi lack.of control of consumables, stlaths as follows".

"We have, concluded, based upon the information provi,ded in ECSP Report Number.30400, that this appears to be an isolated case.

In fact, tlhis report states thalt in a r,'evie9 of 23 terminal blocks with RTV 3140 all shoved proper material traceabiliitV.

The report makes no mention of traceabi.lity problems vithi any other consumables; We do not agree iwith the statement that there is a "lack of corporate and plantico'ntrol'ver the use of'onsumable,s."

NQAM Part XII', Sectio'n 2.3 and Sequoyah Standar'd Practice SQA 45, Revlision 26i, Paragraph 13.0 and 25.0 'clalarly

'escribe tlhe steps to be taken iini controlling consumables fromi a corporat;e and, plant level, relspectively!

iTherefore, except for'ppropriatie training of'he iindividuals involved in this

instance, no further action iis idehmed necessary at this t.ime."

The above rosiponse was accepted'ecause it was based on, a si'ngle

'solated incident of material traceabil'ity presented in this subcategory.

The response showed 'that 'an adequate program i.s defined for corporate control of consumables.

However the 'adequacy of the implementation'of the corporate program is still questiona~ble based on the numerous examples from oth'er Operaticns subcategory

~

reports presented in Section 4.0 Where 'there was a lack of Control over QA Level fl items.

Becaus'le tlheae 'examples fall outside the scope of this subcategory

report, howev'er the question of implementation of the corporatei QA Level II program is not being i

pursued further in this report.'t is 'being escalated to the Operation Category report for further consid'eration.

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The response to CATD-30400-NPS-03 'conce'ming'he lack Of control over design and constructiori standards and requirements and their u:se at the nuclear sites state.:

"DNE has initiated the Specification Improvement Program '(SIP)',

whlich will prov:ide ONP with generic 'master specifications to ciover constructiion, modifications and addi'tions',

and -maintenancle bf TVA's nuclear plants The main scope of,SIP (67 master specific:ations) will be complete by Dec.

1987, but vill be added to as user needs are identified.

i DNiE has taken the positlioih tlhak installed cables are acceptablei ahd the ongoing'valuation by each plant si,te will provide documentatioin to'upport, the, adequacy iof'i installed cables.

EEB will lasslurie compliance with SIP."

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:

Subcategory TITLE:

Cables and Conduit REPORT NUMBER'0400 REVISION NUMBER:

1 PAGE 30 OF 30 7.0 ATTACHMENTS Attachment A Subcategory Summary Table Attachment B Listing of Concerns By Issue Attachment C - Checklist for Root Cause Analysis Attachment D

Summary of Symptoms and Root Causes Attachment E - Graph of Symptoms Versus Root Cause Attachment F - Bar Charts of Symptoms Attachment G - Bar Charts of Root Causes Attachment H - Corrective Action Tracking Documents (CATDs)

Attachment I - List of Evaluators by Element/Plant

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30400 Revis'ion 1

ATTACHMENT A Subcategory Summary Table

REFEREtlCE ECPS132J-ECPS132C FREQUEIICY REQUEST OWP - ISSS " RIIN CATEGORYI OP PLANT OPER.

SUPPORT TENNESSEE VALLEY AUTHORITY OFFICE OF tlUCLEAR POWER EI1PLOYEE COtlCERtl PROGRAN SYSTEN (ECPS)

Et1PLOYEE CQtlCERtl ItlFORNATIOtl BY CATEGORY/SUBCATEGORY SUBCA 1 EGORY a 30ti PROCEDURE PROBLENS I

PAGE 1

RUN TINE 13 t 36 t RUN DATE " 04~2si~i 5

H SVB R PLT CONCERN WUNBER CAT CAT D LOC Iti 112-00101 OP 304i01 ti HBW TRAApn 1

REPORT APPL 2

SAF RFLATED BF BL SQ HB 1

Y Y

Y Y

HISTORICAL 'QtlCERtl REPORT OR IGItl QTC CONCERN DESCRIPTIOW TVA NUCLEAR POHER DEPARTNEtiT IS tlOT t tnbst r ~tt t st an t nbna

~ sr e s.sr ass s nsst. vnstnr r'svwassv a

s ~ tsvvunutstss a

rsa

~ ts uutsv t nuv s ION SPECIF.ICATIOIIS WHEN NAKING NODIF ICATIOtlS AWD ADDITIOtiS.

EG WD NAXIN VN PULL TFIISIOII IS SPECIFIED HHEII tlU CLEAR POIIER DEPARTNEtlT PULLS A tlEH C hnl F dWA M'IIITMUM BEIID Phl)TUS TS hl SO WOT SPECIFIED REF.

SECTII CAT OI SVBCAT 3s

~sscnou assai 3.1 304.01-1 IN -85"207-00201 I >VIE/

IN 85 'i65 OOZ01 T500tll OP 30si02 W HBti 1

tl tt Y

Y I-85-70Z-HBtl 2 tth WA SR SR OP 30404 N HBii I

N ii ii Y

I-85-227-HBti 2 tlA WA WA SR QTC QTC CRAFTS ARE USING STEEL FISH TAPE IN LIEU OF I'IBERGLASS OR HOOD RODS TO B

REACH PEIIETRATIOtl SEALS THIS t1AY C AUSE DAI'1AGE TO EXISTItiG CABLES IN TH c

labcAf'HED bcNcrbArr tl ~ s Tur c nb APT r CE OF USING STEEL FISH TAPES VIOLATE S

PROCFDVRE NAT-14 AiiD COiiST.

NIGiiT.

(KNOHtl) NENQ OF APPROX.

JULY 198~i.

CONSTR.

DEPT.

CONCERN.

ADDITIOttAL I tlFQRNdTTAtl TN FTI E HTTHHEI D hllF TO COtlFIDEtlTIALITY.

NO FOLLOHUP REQUIR t n r at ~

CONDUIT IS LOOSE WHERE IT ENTERS CAB LE TRAY DIESEL BUILDIWGt VtlIT Sl s ROON'2B-8 1ST ELEV.

(ENTER ROON AWD 20 'PAM DOOR NchP CCTITIIG) ~

THTS LI AS REPORTED TIIO HEEKS AGO BUT IS STI LL UNCORRECIFD ~

3.2 304.02-1 g.4 304.04-1 IN 862-00201 OP 3040Z ti WOti 1

W W

ti Y

T50226 2 tiA tlA ttA SR QTC tIUC POWER PERSONNEL PULLED CABLE THR.

QUGH PEtIFTRATIQtlS AFTER QC CIVII CQW STRUCTIOII SIGNED OFF SEALIWG OF PEIIE TRATION.

TsHI S OCCVRRFD Iil AUXILIARY REACTOR AWD CONTROL BUILDINGS.

U iiITS 1

8 Z.

IIVC PQilER DEPT.

CQtlCFRti.

CI DECLINED TO PROVIDE ADDITIONAL IWFORNATIOW.

3.2 J0~4 ~ v2 c

I htll FRIIS hRF GR()VPFh BY FTRST 3 nlrt TS nr. SVnrhTcrnPY WVMnro

REFERE.

- ECPS132J-ECPS132C FREQUEtlCY REQUEST OHP - ISSS RMM CATEGORYi OP PLAtlT OPER.

SUPPORT S

H SUB R PLT COtlCERN NUMBER CAT CAT D LOC 1

REPORT APPL 2

SAF RELATED BF BL SQ IIB HISTORICAL REPORT CONCERN ORIGIN CONCERN DESCRIPTION TEHtlE VAI LEY AUTHORITY OFFICE OF NUCLEAR POIIER EMPLOYEE COIICERtl PROGRAM SYSTEM (ECPS)

EMPLOYEE COWCERtl ItlFORMATIOtl 'BY CATEGORY/SUBCATEGORY SUBCAlEGORYi 304 CABLE PROBLEM IN MAWHOLES I

RUtl TIME 13i36 RUtl DATE - 04/24.

REF.

SECT CAT SUBCAT 566 TlCAl/<+'-

IN 945" 00101 OP 30403 H

WBW T50100 1

Y Y

Y Y

2 SR SR SR SR I-85-362"HBW QTC ELECTRICAL MAtlHOLES ARE IN A VERY DI SORGAHIZED STATE.

CABLES ARE LAYING OUT OF TRAYS HITH SEVERAL FEET OF S

LACK DUE TO CABLES BEItlG SPLICED Atl D NOT LACED DOIIN PROPERLY.

EXAMPLES MAY BE FOUtlD IN THE MANHOLE tlEXT TO THE" FAB" SHOP OR MAtlHOLES Itl FROtlT OF HE TURBINE BUILDING AHD AUX. BUI

'DIHG ENTRANCE.

CI HAS NO ADDITIOIIA L INFORMATION.

NO FOLLOH UP REQUIRE D.

3.3 304.03-1 QCP10

~ 35-8-13 Ol OP 30403 N

BLH 1

Y Y

Y Y

2 SR SR SR SR TAK-86-005 01 OP 30cj01 H

SQH 1

H H

Y W

2 tlA WA SR NA 7

CONCERNS FOR CA'IEGORY OP SUBCATEGORY 306 OECP RTV APPLIED TO JUNCTION BOXES OW SMI 360-.0 MAY NOT HAVE BEEN PROPERLY APPLIED ON ALL JUNCTION BOXES.

RTV USED WAS HOT QA LEVEL AND HAS EXCEED ED IT'S StIELF LIFE.

EMPLOYEE STATED THAT SHELF LIFE WAS HOT A CONCERN A

S HE HAS VERIFIED THAT THE RTV It( QU ESTION HILL IH FACT SET UP PROPERLY.

3.1 304.01-2 OECP CI EXPRESSED CONCERN ABOUT CONDITION 3-3 OF MAtlHOLES IN ELECTRICAL CABLE TRE 304 03 NCH TO IPS.

COtlCERtlS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY tlUMBER.

~ I 0

0

30400 Revision 1

Attachment B

Listing of Concerns by Issues The Cables and Conduit Subcategory (30400) is comprised of seven concerns grouped into four elements addressing a total of six issues.

Element 304.01 - Procedure Problems Issue 304.01-1 Issue 304.01-2 Improperly qualified coating, applied to junction boxes.

(TAK-86-005)

ONP non-compliance with construction specifications.

(IN-85-112-001)

I I

I I Rl I

I I

'Element 304.02 - Electrical Penetrations Breached

'Issue 304.02-1

,Issue 304.02-2

'Element 304.03 - Cable Problems in Manholes Use of improper tools to breach electrical penetrations.

(IN-85-207-002)

Cable pulled through previously sealed penetrations.

(IN-85-862-002)

I I

I I Rl I

l I

I I

'Issue 304.03-1 Poor, disorganized condition of electrical manholes.

(IN-85-945-001 and QCP 10.35-8-13)

Element 304.04 - Loose Conduit Problems I Rl Issue 304.04-1 Loose conduit in the

.MBN unit 1 Diesel Building.

(IN-85-465-002)

4I

Attachment C

Checklist for Root Cause Analysis 30400 Revision 1

1.

Procedure lacks specifics to perform task.

2.

Personnel lack sufficient training in the applicability/use of procedure.

3.

Lack of understanding regulatory requirements or commitments.

4.

Lack of adequate

system, process, or administrative controls to ensure commitments are reflected in procedures or processes.

5.

Inadequate communication within functional group.

6.

Inadequate communication between functional groups.

7.

Management Assumed Risk.

8.

Procedures incomplete or failed to incorporate all technical requirements.

9.

Error in judgment by qualified individual.

10.

Unqualified individual performing the task.

ll.

Insufficient time to perform task.

12.

Inadequate prerequisites defined to ensure satisfactory completion of task.

13.

Personnel performed task knowingly in violation of procedure/process.

14.

Personnel error in following procedures.

15.

Failed to identify root cause of previous deficiencies.

16.

Failed to take appropriate action to preclude reoccurrence.

17.

Inadequate process to detect adverse trends.

18.

Inadequate acceptance criteria defined to ensure satisfactory task completion.

19.

Management attentiveness to trends.

20.

Lack of accessibility to documentation.

21.

Inadequate controls for review of results to ensure compliance with commitments.

22, Timeliness of changes to commitments or changes to licensing/regulatory requirements.

23.

Isolated incident.

24.

Random error.

25.

Other - i.e.,

equipment related failure.

0 Cl II

30400 Revision 1

ATTACHMENT D Page 1 of 2 Summary of Symptoms and Root Causes, Element 304.01, Problems in Followin Procedures Related to Electrical As ects of Plant Construction For Element 304.01, there was the potential for negative findings at the category level exhibited by the following symptoms:

(a) lack of material control for consumables (RTV), (b) inadequate work controls (review and implementation of construction specifications),

and (c) inadequate

, configuration control (installation is not equal to design specifications).

The first symptom was identified for SQN, and the second and'hird symptoms appeared for BFN.

As these symptoms were tested for root cause, the appropriate root causes and applicable plant sites were as follows:

a.

Personnel lack sufficient training in the applicability or use of procedures (SQN) b.

Lack of understanding regulatory requirements or commitments (BFN) c.

Lack of adequate

system, process, or administrative controls to ensure commitments are reflected in procedures or processes (BYN) d.

Inadequate communication within functional group (DNC at BFN) e.

Inadequate communication between functional groups (DNC and ONP at BFN) f.

Unqualified individuals performing the task (i.e., individuals are performing the task who are unqualified to do the specific task of ensuring material traceab.ility due to their lack of training (SQN))

g.

Personnel error in following procedures (SQN) h.

Inadequate acceptance criteria defined to ensure satisfactory task completion.

(BFN)

Element 304.02, Electrical Penetrations Breached For Element 304.02',

there was the potential for negative findings at the category level exhibited by the following symptoms:,

(a) inadequate work control (penetration breaching),

and (b) inadequate work control (penetration breaching devices).

The first. symptom appeared in the evaluation for MBN, and the second symptom appeared in the evaluat'ion for SQN

~

As these symptoms were tested'or root cause, the appropriate root causes and applicable plant sites were as follows:

a.

Procedures incomplete or failed to incorporate all technical requirements (SQN) b.

Personnel error in following procedures (WBN) c.

Inadequate controls for review of results to ensure compliance with commitments (MB)')

30400 Revision 1

ATTACHMENT D Page 2 of 2 Element 304.03, Electri.cal Manholes For Element 304.03, there was the potentiial for negative fi.ndings at the category level exhibited

'by the f'ollowing symptoms:

(a) inadequate initial design control, and (b) inadequate work controls. (housekeeping).

These symptoms were identified for SQN,

BFN, add SLY.

As these symptoms were, tested for root cause, the appropri.ate root causes for each of, the three plant si'tes were judged to be as follows:

a.

Lack of adequate

system, process, or administrative,controls to elnsVre commitments are reflected

.in procedures or processes b.

Error in judgment by qualified individukl c.

Inadequate process to detect adverse'tr'ends d.

Inadequate acceptance criteria defined to ~ensure satisfactory task completion No symptoms for root cause analysis were identified in Element

30404, E'.oose

'onduit.

The analysis of the symptom and. root cau:es fair these elements is depicted graphically in Attachments E,

F, and G.

iAttachment E's' plot of each element's symptoms versus the root causes pointed out by the symptom.

Root cause numbers on the hcirizontal'xis correspond to ithe 25 items on thle "Checklist for Root Causes Analysis" found tn Attachment C. Attachment F

contains bar graphs showing the number of times each of the symptoms in the subcategory occurs for the 'various plants.

AttaChment'. G'ontains bar graphs showing the number of times each. root cause'ppears in the subcategory for the various plants.

0 IR1 I Rl From a study of Attachments E and F it cain be seen that inadequate wotk

.controls appear in four out of the subcategory's seven symptoms.

Inadequate

'ork controls were identified with respect to 'review and implementatibn of construction specifications, electrical penetration breaching practices,i ahd

'lectrical manhole housekeeping practices.

Al'soA'ttachmenits E and G show that there were four root causes. that occurred at each of the same thdeei plants:

(a) lack of adequate

. ystem,

process, or admi.ni,strative control's to

'nsure commitments are reflected in proceduresi or processes, (b) errot in judgment by qualified individual, (c) inadequate process to detect adverse'rends, and '(d) inadequate acceptance criteria defined tio ensure satilsfact6ry task completion.

These four root causes appeared more frequently overall than any other root cause,s, as shown in Attachiment G.

I'Rl Rl I Rl

30400 Revision 1

ATTACHMENT E SYMPTOMS VS ROOT CAUSES SUBCATEGORY 304 S~mtoras Sl YI MI pl TI Ol MI Sl Element 304.03 Element 304.02 B

B B

1. Lack of material control for consumables (RTV)

2. Inadequate work controls (review and implementation of construction specifications)

3. Inadequate configuration control (installation is not equal to design specifications)

4. Inadequate work control (penetration breaching)

5. Inadequate work control (penetration breaching devices)

6. Inadequate initial design control

7. Inadequate work controls (housekeeping)

I I

I I

I L

L I

B B

7I S

S I

L L

I B

B 6I S

S I

I Sl

'S I

I 4/

W I

I 3I B

B B

I Element 21 B

304

~ 01 I

1I S

S S

I I

1 2

3 4

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ROOT CAUSES KEY:

W

=

WBN S

=

SQN B -"BFN L

=

BL'N

~

OCCURRENCES VS SYMPTOMS

SUBCAT 304 tO U

blK Q00 VY vz VX EA xA vzz.n V~X/J YXXA I I'lJ YX/XJ 0

SYMPTOMS

OCCURRENCES VS ROOT CAUSES SUBCAT 304 TAYIS SAII HNSLAII~

1 2

2 i S

~

2

~

~ 1011121214141

~ 171 ~ I~ 202122222424

. ~

'I 2

2 4

S

~

7 4

~

10 I'I 12 IS Il 1S

'I~ 11

'I~ I~ 20 21 22 22 24 24 IIOOI CAMCS 2-0 I

2 2

4 4

~

7

~

~ 101112 ISIAISI~ 171 ~ I~ 202122222A24 IIOOI CAUSIS 0

0 I

2 S,S S

4 7

4

~ 1011121$ 'ISISI ~ I71 ~ I~ 202'I22222l24 IIOOI CAIISCS

C I

CA Cl I

UCCUZCADlY LAB VS BOOT CALLUSES SUBCAT 304 l I

~

~

I<] 0

~

~ Cl tg a ~ ~

ili jJJ0zhl K

Q 0

2 rd rw rA 0

1 1

2 3

4 5

6 7

8 9

1011 12131415161718192021 22232425 ROOT CAUSES

30400 Revision 1

CATD NUMBER ATTACHMENT H CORRECTIVE ACTION TRACKING DOCUMENTS (CATDs)

CORRECTIVE ACTION PLAN APPROVED 30400-NPS-001 30400-NPS-002 30400-NPS-003 30401-SQN-01 30401-BFN-Ol Rl 30401-BFN-02 Rl 30401-'BFN-03 Rl 30401-BFN-04 Rl YES YES YES YES YES YES YES YES 30402-MBN-01, 30402-WBN-02 YES YES 30402-SQN-01 30403-NPS-01 30403-WBN-01 YES YES YES 30403-SQN-01 30403-SQN-02 30403-SQN-03 30403-BFN-01 30403-BFN-02 30403-BFN-03 YES YES YES

'YES YES YES 30403-BLN-01 YES

ECSP Corrective Action Trackin~Document (CiITD)

ECTG C.3 Attachment A

Page 1 of 1

Revision 2

INITIATION ADDlicable ECSP Report I'lo.:

304IOO l.

2 ~

3.

5.

.6.

Immediate Corrective Action Required: ')

Y'es No Stop Work Recommended:

0 Yes

'Q No CATD No.

30/AOO-NPS-001

'4.

INITIATION DATE 02/06/87 RESPONSIBLE ORGANIZATION:

TVA~Caroorate "Q

Collec'tive S~inificance

,'Sections of Reoort 36400.

there, is, a,

lack of coroorate control over design, and maintenance activities associated with water in electri'cal manholes at all sites.,

C3 AT:ACHHENTS 7.

8.

9.

P..EPARKD BY:

NA..E G. Shewbridpe '~7 DATE:

APPROVAlt.:

EC:G P!I C~ II'IGR.,+~~'

~~

DATE: ~/P7~%>

CORRECTIVE 'ACTICN 10.

PROPOSED CORREC.IVc ACTION PLAN:

~ r~ C"~~/~/

11.

PROPOSED BY:

DIRECTOR/HGR:

12.

CONCUlRREINCE:

CEG-H:

(~l~('RP:

Q>7jg t~

ECTG PROGIIAM MGR: ~@%@

VERIFICATION AND CI OSEOUT Q ATTJ CHiHENTS, DATE:

DATE:

DATE DATE:

DATE:

DATE:

DATE:

13.

Approved cor:.ec ive actions haVe 'be6n 'verified as satisfactorily implemented.

3579T SIG WlATURE i.'ITLc

DATi,

ECSP Corrective Action Trackin Document (CATD)

ECTG C.3 Attachment A

Page 1 of 1 Revision 2

INITIATION A licable ECSP Re ort No.:

30400 1

~

2 ~

3.

5.

6.

Immediate Corrective Action Required:

0 Yes H

No Stop Work Recommended:

0 Yes H

No CATD No.

30400-NPS-002 4.

INITIATIONDATE 02/06/87 RESPONSIBLE ORGANIZATION:

TVA-Cor orate PROBLEM DESCRIPTION: H QR 0 NQR As noted in the Findin s and Collective Si nificance Sections of Re ort 30400 there is a lack of cor orate and lant control over the use of consummables.

Of articular interest is RTV. however other materials i.e.

Ra chem Teflon etc.

should be iven consideration in the CATD dis osition.

7; PREPARED BY; NAME E.

G Shewbrid e

G.

CONCURRENCE; CEG-H 9.

APPROVAL:

ECTG PROGRAM MGR.

0 ATTACHMENTS DATE:

DATE:

DATE:

CORRECTIVE ACTION'0.

PROPOSED CORRECTIVE ACTION PLAN:

Please zeier'o attachment 11.

PROPOSED BY:

DIRECTOR/ggR,q 12.

CONCURRENCE:

CEG-H:

SRP:

ECTG PROGRAM MGR:

ATTACHMENTS DATE: 5 DATE:

/c P7 DATE:

DATE:

DATE:

DATE:

DATE:

rc i= 7 VERIFICATION AND CLOSEOUT 13.

Approved corrective actions have been verified as satisfactorily implemented.

3579T SIGNATURE TITLE DATE

~

I iCTG C.3 Attachment A

Page 1 of 1

Revision 2

ECSP Cor'rective Action Track rr Document (CllEU)

INITIATION l.

2.

3.

5.

6.

Applicable ECSP Report No.:

30400 Immediate Corrective Action Re)uit.ed:

0 Yes H

No StIop Work Recommended.:

0 ges 9

No, CATD No.

30400-NPS-003 a.

INITIATION DATE 02/06/87 RESPONSIBLE ORGANIZATION:

TVA-'Cor orate a

la lack of c~or >orate control over design and construction standards and rec?uirements and their use at the nuclear sites

.7..

8.

9.

PREPARED BT:

NAME E.

CONCURFENCE:

CEG-H APPRO'VAL:

ECTG PROGRAM G.

She@br id e

2~~ r MQR.

0 ATTACHMENTS DAT:

-,'8'i DATE:

E'- ~ - g"7 DATE:

CORREC-IEri AC IO 10.

PROPOSED CORRECTIVE ACTION PLAN:

11.

PROPOSiD BY.:

DIRECTOR/PGiH

'< S4a 22.

COMCURREllCE:

iCEU-H:

I ERR:

ECTG PROGRAM MGR:

DATE:

DATk:

DATE:

'DATE:

DATE".

DATi:

ATE:

227<<yC ~, '7Q Jl r I ED Cv (5S QU 13.

Appro:ed corrective actions have been verified as satisfactorilY implemented.

3579T SIGNATUPE TITLE DATE

ECSP Corrective Action Trackin Document

<CATO>

ECTG C.3 Attachment A

Page 3 of 1

Revision 2

INITIATION l.

2.

3.

5.

6.

Immediate Corrective.Action Required:

0 Yes El No Stop Work Recommended:

0 Yes H

No CATD No.

304.01-SON-Ol 4.

INITIATION'DATE 10-14-86 RESPONSIBLE ORGANIZATION:

0 erations PROBLEM DESCRIPTION: 0 QR S

NQR The roblem identified is mise lication of RTV'140 on 'unction box terminal blocks 7.

PREPARED BY:

"NAME T.

W. White 8.

CONCURRENCE:

CEG-H W.

R.

La er ren

9.

APPROVAL:

ECTG PROGRAM MGR.

0 ATTACHMENTS DATE:

10-14-86 ATE:

10-15-86 DATE:

CORRECTIVE ACTION 10.

PROPOSED CORRECTIVE ACTION PLAN:

Action Plan as ro osed.

t vour Co ective m.

'.?

ll.

PROPOSED ECTOR/HGQ +03 860926 804 12.

CONCGRRENC CEO-H:

.SRP:

I ECTG PROGRAM HGR:

0 ATTACHMENTS DATE:

9-29-86 DATE:

DATE:

DATE:

DATE:

DATE:

VERIFICATION AND CLOSEOUT 13.

Approved corrective actions have been verified as satisfactorily implemented.

2086T SIGNATURE TITLE DATE

ECSP Corrective hction Traction Docmaent

)Cliff rale r or

.L Revision 2

IXITIhTICN l.

2.

3.

S.

6.

h~i~licable ECSP R~ert lo.:

~Pdi ate CorrectilIe Lction RoQQired) 0 Yes WNO Stop York RIacc~ended:

0 Tea B

lMo U

&-~

RESPONSIBLE ORQilNIFLTIOW'te Director PROBLRR RRSCRIPTXOR: I~R II R

Rtte laetoeottoao haec,&apt heep eerified as being a~nal to orl Qtt r than the~rocedurea In th4 hffected aiIctions include:

Eletrical Wodifications Eec <fc81.

~g

~aa ibl~others.

7.

8.

9.

PREPhRED BT:

METE %~

emCVRRENCE:

CEIG-HQ~

hPPROVLL:

lECTG=PRl:lGRLH 5GR. >>

hTThCHKISTS DLTE:

~~+~~~'TE:~

lZ~~

~ DhTE:

CORRECTIVE hCTIdR PROimED RRECTIVE CTIdw Ram:

s ~e~~W~a~

e ll.

PROPOSED BT:

DIRECTOR/

12.

CONCURRENCE:

CEG-8:,'

SRP:

ECT'G PRDGRMf l5GR: Wc~~7-7~~WI-VERIFIChTICN hlfD CMSEOOT 0 h Th HEENTS DhTE DhT:

DOTE DhTE:

MTE:

DLTE:

DhTE:

13.

hpproved corrective actions hash beck v'erified is aatigfalcterilly

'iapleaented.

291ST SIGllthTURE TlYLE

ECSP Corrective hction Trackin Document CATD Attachment h Page 1 of 1 Rerision 2 - h INITIhTION 1.

2 4 3.

S.

h licable ECSP Re ort No.:

304-01-BFN Immediate Correctire hction Required 0

Yes

~No Stop Mork Reconanended:

0 Yes B

No CATD No. 30401-BFN-04 Rev.

1 4.

INITIATIONDATE 3/12/87 RESPONSIBLE ORGANIZATION:

DN h PROBLEM DESCRIPTION: LFQR 0 NQR N hM art 1

section 2.2 rovides a list of desi n out ut documents and re uires these documents to 3am im lemented b

Construction Procedures.

No cor orate ro ram exists to ensure that these doucments and revisions to them are im lemented b

the Nuclear Site Director.

7.

'PREPARED BY:

NAME

.Z.

8.

CONCURRENCE:

CEG-8 9.

APPROVAL:

ECTG PROGRAM KGR.

dTThCHMENTS ATE:

5- <t-87 DATE:

CORRECTIVE 'hCTION 10.

PROPOSED CORRECTIVE hCTION PLAN:

11.

PROPOSED BY:

DIRECTO 12.

CONCURRENCE:

CEG-8:

SRP:

ECTG PROGRAM HGR:

hTTACHMENTS DdTE:

DATE:

ZZ-DhTE:

DdTE:

DATE:

DhTE:

DdTE: :F-l~.>7 Ql VERIFIChTION AND CLOSEOUT 13.

hpprored correctire actions hare been,.rerified as satisfactorily baplemented.

2978T SIGNATURE TITLE DATE

ECSP Corrective Action Track~in Document liCATD)

ECTG C. 3 Attachment A

Pate 1 of 1

Revision 2

0-INITIATION l.

2.

3

~

5.

6.

hi~licable ECSP R~eiort No:,,

OP, 304.,02, Immedjatie Corrective hction Required:

p$

Yes 0

No sP Stop Mork Recommended:

0 Yes +

No CATD No ~

OP 30402

'MEiN 01 a

~

INITIATION DATE 10/27/B6 RESPONSIBLE ORGANIZhTION:

WBN Division of Nuclear Construction, PROBLEN DESCRIPTION:

C3 QR ~NQR SOP-42 states as its ~ue~ose>>

"to establish the method for all mech nical and electrical breachin~ and sealirg."

Section 3.0 "Reference~s list Nhl-14 and QNP Itachani cal P~ie

!cleave. Bee~in'rocedure (no instruction number 2rovidecQ.

Section 6.0 "Proc du're

" does not spec~iC that the referenced ON~P irocedur s 'ar to be 'used nor doe~

i,t outline the methods/materials used fo breaching~and seali~n,

~enetratsons.

~ATTACHMENTS CORRECTIVE ACTION 0

7.

PREPRRED BT:

NIgNE G.

D,a Ga dnnr DBTE:

ILO/27r'86 8.

coNOURRENcl'::

QEG-H EEH'

'c.

~~

DBTE: Qo-cv-gt 8,

BPPRQVnL:

ECTG PROGILIIN HOR

&.~~/dbg D

E: ~lo 2 84-10.

PROPOSED CORRECTIVE ACTION PLAN:

c 11.

12.

PROPOSED BY: gfRECTOP'WGQ i'"" r">.'

'ONCJRRKNCK:

CENCE-E~

SRP.

( W

//

EC G

?ROGR 8 NPR:

4 v

DATE.",

DATE."

DATE,",

DATE".

DATE,".

DATE

,. ', /. i 7 DAT ".".

ATTACNMKNTE VERIFICATION AND CLOSEOUT 13

~

Approved corrective actions have beien verif ed as satisfactorilIy'mplemented'.

2258T SIG?JATURE TITLE'ATE

ECSP Corrective Action Trackin Document (CATO}

ECTG C. 3 Attachment A

Page l of l,

Revision 2

INI. IhT ION 1.

2

~

3.

5.

6.

h o'.icable ECSP Re ort No:

OP 304.02 Immediate Corrective Act.ion Required: gf Yes 0

No St,op Mork Recommended:

0 Yes Q

No CATD No.

OP 30402-MBN-02 4.

INITIATION DATE 10/27/86 RESPONSIBLE ORGANIZATION:

MBN Hechanical maintenance.

PROBLEM DESCRIPTIOH: +QR 0

NQR Please orovide the status of cotrective actions '.nitiated in res onse

'to NSRS Reoor t I-85-702-MBN and the status/actions taken b

def icienc re or t MBN-DR-85-268.

( Re ference memorandum ft om M. T. Cottle to K. M. Mhitt, Januar 7

1986}

7.

PREPARED BY:

NA}iE G. D.'Gaz'dner U.

COHCURREHCE:

C"G-H '(C.

9.

APPROVAL:

EC "

PROGRAM NGR.

ATTACHHENTS DATE:

10/27/36 DhTL:

tO-t'r-Zt DATE:

cc 5 CORRECTIVE ACTION 10.

FROPOSEO CORREC VE hC IOH PLAN:

4 Ro 11.

PROPCSEO BY:

DIRECTOR/HGR r

12.

CONCURRENCE:

CEG-H:

EC " PROGRAH HGR:

VERIFICATION AVD CLOS".E'UT 0

ATTACHNEHTS DATE:

DATE

.'ATE:

DATE:

DATE:.

DATE:

13.

Approved corrective actions have been verified as satisfactorily implerne n t:ed.

2250T SIGNATURE TITLE DATE

Fa a 0 44 a a>>4/@44 a

r, Pago 1 of 1 Revision 2

INITI..TION l.

2 ~

3 ~

5.

6.

ECSP Corrective

=~ction Trocki~n Document J'CAT~Di hg> lieaole ECS~PRo oee No:

304.0B-BFN Immediate Corrective Action Req~uire4!

0 Yes No Stop cwork Recommended:

Q Ties JS No CRII) No. 3040:I-BFN-03 4

4 ZIFZZZBZZOII IIBZE 11/11/aa RESFONSZBLE ORQBNZEBI'ZON: Noliiilieatioea ~ BeoNea Fae IAI bo,r 7118 in manhole T near

'the Central Alarm Station has been fliooded and is severl corroded.

The box.Mas fnstalledi under 0

7.

8.

9.

incom~lete EcN P0286.

It certains cables

.'d'or cCTv G H and x.

the manhole needs a sumo~un The terminal strigshould be re laced Mith a waterproof'olice.

An FCR a ainst ECN P0286 could add a

smmn pm~mand remove the terminal st i 0 ATTZ!GHEE.4TS PREPARED BY:

NAHE Dv~iht B,.

Thorn~son ~3592)

DATE:

11/ll/86 APPROVAL:

ECTG PROGRAH HGR.,'

~&.'r DATE:

II IS-Fb CORRECTIVE ACTION PROPOSED CORRECTIVE ACTION PLAN-

'emi~orar~~rree;~v~~

ISSUED M Euax md~Hmm1MZL

~muxhaMM~auLm Cl ATTACHMENTS 11.

PROPOSED BY:

DSIRECTORQM~

12.

CONCURRENCE!

CEG-H:

SRP:

DATEi.

t DATE:

DATE:

DATE:

DATo:

ECTG PROGRAH HGR! '++~i~

DA1~

VERIFICATION AND CLOSEOUT 13.

Approved corrective actions have been veriL'fed as satisfactorily, implemented.

244.

SIGNATURE TITLE DATE kiev 3/ 5 3040IIZM.W.fiF/Fti gNFe/Io.

on Thr T,,ovroll; Sacnngs Flaw>>

i

.v.,

ECSP Cottective hctioa T ackin Docaeent

~ClID 1.

2 ~

3 ~

5.

6.

h licable ECSP Re ort No:

OP 30'.03 Immediate Corrective hction Requited:

0 Tes gl No Stop cwork Recaaaended:

0 Yes g

No ChTD No. 30i03-8LN-01 INITIhTION DhTE 11-3-86 RESPONSIbLE ORGdNIZhTION: Cone traction PROSLEN'ESCRIPTION: Q QR 0 NQR Cable 11 aanholes have vatet standin in bottoa.

No teventire aaintenance or riodic ins ction ro raa exists at bQ as deectibed b

Desi n Criteria Na-50-D788 section 5

ata ta h l.

7.

PREPdRED bT:

NhNE John H.

r 8.

CONCURRENCE:

CEG-H 9.

hPPROVdL:

ECTG PROGRhH HGR.

EP CORRECTIVE hCTION 10.

PROPOSED CORRECTIVE hCTION PLhN:

hTThCHHENTS DhTE:

11-3-86 a.

DhTE: II xq g DhTE:

/i-S<-tr 11.

PROPOSED ST:

01 RECTOR/

12.

CONCURRENCE:

CEG-H:

SRP:

ECTO PROGRhN MR:

hTTdC S

DhTE:

DhTE:

DhTE:

DhTE:

DhTE:

DhTE:

DhTE:

VERIFIChTION hND CllNCOQT 13.

hpptored cottective actions have been vetiiied as satisfactorily iRpl0$0nted o

XSSST SIIRLIURC TITLE

LTTJLCEKBtT,h 1.

Se'reral dozen cables hare been routed outside'he cable trays i'n aanhole T and there is inad4quata slack to get the ciblles 'in t5e trays.

k large number of clblks ar'e 6ou'ted through manhole If,4h it may, not be possible td gt N the cables in trays.

Except' aanh4t T, about the only ~cables tha't 4e oint of the drags 'ar>> apart

'ables

~ pall QLres, and ~ pmap poser cables..

Xn Mhole 8, a

couple of cables cross Lays on the insi'de edge, of the trky.'nd one cable is out of the MaIIs.'n mehole',

son>> of the 4-kf 'bus tie cables follw the to) e3igk od t'e's'bl>> tray.

2.

The drawings for aanholes Fl, 4, 0, 'and 0'how a metal barrier <<nd corer ia the trays

<<o segarfatl 480~V <<nd 4 kV cables'hhse'barriers and, covers are dot~ injstIL11ed. It is doubtful they could be installed.

aisd still &in4r:ain Sufficient bend radils on th4 4-kV cables.

The 4-kV'us tie linl cables are abandoned Ny'way, so the barriers may not be needed.

v

, ~

0 ~

~

~ ~pe

~ ~

0

Haaholes aced

.a general cleanup.

Sump pump routine checks are not adequate to"ensure continued opera'tion

~

lanhole C is collcctiag surface vatcr because the manhole is fn a lov aiea, and the cover is lover than the surrouading asphalt..

Lccordiag to the draving, lON19-1 RA, the cover should. be above gradeo 6.

Some of the sump pumps electrical supply cord plugs contain a

circuit iatcrrupting dcrice that is causing nuisance trips.

This tripping vas observed ia sLanholes E aad Q.

~ e The ends of most spare and abaadoaed cables hare.not beea taped pcr modifications and additions instruction (lthI)-13 or 5hZ-44.

Numerous abandoaed 4-kV bus.tie cables are not taped.

In manhole T, one 3-pair Number 19 hMQ cable has the outcr 5ackct removed, vith one pair cut aad the bare ends of the vire exposed.

Electrical Naintenance Instruction (EKI)-58.1, step 8.14 allovs temporary cables to be placed outside of trays. It has no limitation as to thc. aumbcr of cables or location.

This may.have caused the excessive aumber of cables outside of trays in manhole T.

In maahole E, the bottom tray on the aorth side has a broken splice connector.

One section of the tray is hanging dovn as a result.

ltost splices observed used-Raychcm sleeves, vhich is suitable-for the vet environment, especially the never looking, splices.-

h fcv older splices utilixc tape.

Over 50 splices vere obscrvcd.

Raychcm vas used oa 17 of 18 4-kV splices in manhole E.

Tape vas, observed on 3 small splices in manhole E.

Tvo Raychem and onc t:aped splice vere observed in maaholc F.

Three taped splices veri observed in manhole H.

Raychcm vas on about 30 splices in manhole T.

Raychcm vas not required in the original construction according, to G-4 and SF-17.

KQ-13 and EKI-58 have required Raychcm in recent years.

9.

Very fcv of the taped splices have~ legible tag identifying the cable number.

Host have no tag.

5anholes are not ve11 labe11e Come are har:

dravings are not to scale and measurements are aot shovn from acarby structures..

The security strap across the top of the covers often covers the labelling that docs exist.

Manhole T is incorrectly labelled NH N.'444T

f e

~

ya ot ~

~

"%CSP Cozrectiv>>

Aetio Ttaek~in Docmaent C4IQ C 0 httachnent I Page 1 of 1 R>>rieioa 2

INITIhTION 1.

20 3

5 4

iggicablt>>

ECSP R~>>et No:

SiOa.03-hFN Ifsaedhate rerr eot hre Ratios ifedoited:

Ch Yes g No Stop hfork Reooaneaded:

22 Yjfs P No, CAID hfo. 30A03-BPN-02 6,

INITIATION'i)ATE '.ll/11/86 RESPOhiSIBLE ORGANIIATIDhf

. rovnfs Perfrr DNP e

. tat:aa::

t ~~to

~R'rM~

~uC SEE 'hTThCHNE'NT h

~f

+7 lo e.

9 dTTdCE93lTS PREPARED BY:

NAhAE Dvi ht B

~o~nson~350~2 DATE:

11/11/86 CONCURRENCE:

CEG-H g~Ã

~ '+K ATE:; e;64k APPROVAL:

ECIG PROGRfIB ÃGR.

c' efW DATE: ~tl~

CORRECTIVE hCTION 10a PROPOSH)

CORRECTS. hCTION PM:

~S~~<~~~~

0-hTThCHEEVS 11.

PROPOSED M':

DIRECTOR/ G+,,

T>3

', F>~S 8"S'7 MTE:

12.

CONCURRENCE:

CEG-8:

l.Q

~ 'TE:

SRP

~

~d MTE DhTE:

QJP

~

MTE:

ECTG PRDGBlM 5GR: ~~QQ~~

MTE:

VERIFIChTION hÃD CLOSEOQT f~ ~T-Bpprored eforreo'fhjre aatioes Bare Deca retiriedas satisY,aotorill fmplaaeai tmi.

2444T o~

SIQMhTUJX ZXT?X I ~

t

\\

oe ~

~ e ~

vV4V

%t ~ 4 httachient h

Page 1 of 1 Revision 2

ECSP Corrective =

dction Trackfn Document NITIhTION

~

L.

2 ~

3.

5.

6.

~ A licable ECSP Re or't No:

304.03 BFN Iaanediate Corrective Action Requirgt:

0 Tea Ho Stop Vork Recoaeended:

0 Tes gf 'Ho CATD Ho. 3ei03-BFN-01 i.

IHITIATIOHDATE 11/11/86 RESPONSIBLE ORGAHIZATIO Braes Ferr Naintenance PROBLEH DESCRIPTIOH:

QR R 4 c ~- -8'7 SEE hTThCHNENT

~ Q)

?.

PREPARED BY:

HASE thai ht B.Th son 3592 8.'ONCURRENCE:

CEG-8 gH 9.

APPROVhL:

ECTG PROGRAM MR.

hTThCHHEXTS DATE:

11/ll/86 DATE:

CORRECTIVE hCTION.

10.

PROPOSED CORRECTIVE ACTION PLAN:

1.

3/c 819) in MHT (c) Item

- Re lace broken s lice connector in MHE; La e man o es egi y -

tern T is can be tracked b

assignment No. 6018; expected completion date 3 30 87.

2. Items 6

4 EMSIL vi e vrftten to c eck MH sump s and issue BF-to per orm inspection regularly.

See assi ment No. 6019.

pecte comp etion te 4 3

3. Item 3 - Regular check o

sump pump ~ill prevent floodin.

0 hTThCHMEITS 11.

PROPOSED BY:

DIRECTOR/

G 12 ~

CONCURRENCE:

CEG-8:

SRP:

ECTG PROGRAM MR:

57OL4 S7 DATE:

DATE:

DhTE:

DATE:

DATE:

DATE:

DATE:

8 l -'51 VERIFICATIOX hND'LOSEOUT 13.

Approved corrective, actions have been 'verified aa satistactorily iapgeeeated.

TITLE

ElCTG C.3 Attachment h

Page 1 of 1 Revi,sion 2

ECSP Corrective Aetio Trackin~Docuawnt

+CATD)

INITIATION E~>licel>1e ECSP~Re oet No,:

304-03-!SttN Rl 1.

2.

3.

5.

6.

Immediate Corrective Action Required:

0 Yes IR No Stop cwork Recommended:

C)

Ted S

Nb CATD No.+~3 3L~e-S~N-03 4.

INITIATIONDATE 12/04/ '6 RESPONSIBLE ORGANIZATION:

Dielis ion of Nuclear E~nineerin PROBLEM DESCRIPTION: 8 QR G NQR Electrical manholes vere found to contain submergedl cables or evidence that cables had been su-mared.

Nanholes in~sected and intiervievs indicate that CSS cables have been submer~ed.

The resultant adverse affects tel t ese cables need to be evaluated.

I~"

g/pe//

7 ~

8.

9.

ID ETTECIINENTS PREPIRED IIY:

IIENE Tto H>e

. Hctt DETE: ~2>>Ol 88 CONCURRENCE:

CEG-H 1,

c'.

DATE".

I t..~ -'

EPPROVEL:

ECTO PROGREN IIGR.~~Z DETE:

Z-CORRECTIVE ACTION 10.

PROPOSED CORRECTIVE ACTION PLAN:

~~~PC= '~(~ 1FAi~d'Al/'OE~

~7>7R~~RAA 1)~c'

~~5 7olo o o &

c'7.

7 D C.

~e~u'~~~+so a roiof tl'o c

50 g 0/0iD I +

0'7e~ /

~t

~l i*

Q>>~~2 P

0 CcPSS 4'/5 oh.

ge 5, i~ 8.'c.',

3-3o-1 A.

n W.h gg 0 h

.'AC 11.

12.

PROPOSED BT:

DIRECTOR/NGg:

DATE:

CONCURREN>CE:

CEG-H: ~ ~i~~~ 'It-DbTE SRP:

DATE:

DATE:

//

DATE:

~ DATE:

ECTO PIEOGRlll llGR,; 2~~~@ ~

DETE:

'/-i+-'//<

VERIFICATION AND CLOSEOUT 13; Approved corrective ac,tions havei been verified as satisfactorily implemented.,

2S4ST SIGNATURE'ITLE 0

ECTG C.3 Attachment A

Page 1 of 1 Revision 2

ECSP Corrective Action Trackin Document (CATD>

INITIATION A licable ECSP Re ort No:

304.03 S

N Rl l.

2.

3 ~

5.

6.

Immediate.Corrective Action Required:

0 Yes Cf No Stop Mork Recommended:

0 Yes 0

No

'CATD No.

30403 S

N 02 4.

INITIATION DATE 10-20-86 RESPONSIBLE'RGANIZATION S

N PROBLEM DESCRIPTION: Q QR 0 NQR Electrical manholes vere found to contain submer ed cables or evidence that cables had been submer ed.

Manholes ins ected,and interviews indicated that CSSC cables have been submer ed.

7.

PREPARED BY:

NAME Paul h

ard 8.

CONCURRENCE:

CEG-H 9.

APPROVAL:.

ECTG PROGRAM MGR.,

0 ATTACHMENTS DATE:

10-20-&6 DATE:

.u.

DATE' CORRECTIVE ACTION 10.

PROPOSED CORRECTIVE ACTION PLAN; S

N ro osed a

reventative maintenance ro ram for the electrical manholes that v '

ade uate.

0 OaP gK p C

J (ggk

~o

/r~'.:

/

~

~C'" >

/7

'0 ATTACHMENTS

'03 861007 803 ECTG PROGRAM MGR: /

11.

PROPOSED BY:

TOR/gG+

12.

CONCURRENCE:

CEG-H:

SRP:

DATE:

DATE:

DATE:

DATE:

DATE:

DATE'ATE:

10>>14-86

-Zc" VERIFICATION AND CLOSEOUT 13.

Approved corrective actions have been verified as satisfactorily implemented.

SIGNATURE TITLE DATE

ECSP Corrective Action Trackin Document (CATD)

ECTG C.3 Attachment A

Page 1 of 1

Revision 2

INITIATION Teleport No.:

OP 304.03 1.

2.

3.

5.

6.

Immediate Corrective Action Regui'red:

Y'es g

No

'top Work Recommended; 0

Yes'@ 'O CATD No.

30403-WBN-Ol

'4.

INITIATION DATE 11-24-;86,

.RESPONSIBLE ORGANIZATION 'BN'Mode ic'ati ns PROBLEM DESCRIPTION:

(3'QR QR Please'~r'ovide the status and schedule for incom~lete correctiv'e kctlions a~reed to in response to NSRS,~re>ort I-85-362-WBN; WBN,'correct'ive actions Were identified b~,

memo random from R.

C. Miles to E.

R. Ennis,(T14 851121 800).,

7.

PREPARED BY:

NAME G.

D. Gardner CONCURRENCE:

C EG-Ha~~~

APPROVAL:

ECTG PROGk'AH MGR.

ATTACHMENTS DATE: ~'I-XL DATE: ~R-'l-~

DAT,E:

/ -c7-2F,'7 CORRECTIVE ACTION 10.

PROPOSED CORRECTIVE ACTION PLAN:

P.:Ic, bt<-.;

'It 0

0 ATTACHMENTS 11.

PROPOSED BY:

D:~!'.CTOR/'HGR:

(Q 12.

COGCOPREMCE:

CEG-M: ~+A2Rt.

? 2Tt,

/

AIPA SRP:

ECTG PRDGRRM MGR:

DATE:

DATE:

DATE:

DATE:

DATE:

DATE:

DATE:

+~8~

/~5',~z",

,/T g7,,

VERIFICATION AND CLOSEOUT

13. Approved corrective act;ions hav'e bee'n ~terified as satisfactorily implemented.

ECTG C.3 Attachment A

Page 1 of 1 Revision 2

ECSP Corrective Action Trackin Document

{CATD1 INITIATION A

licable ECSP Re ort No:

304.03 S

N Rl l.

2.

3.

5.

6.

Immediate Corrective Action Required:

0 Yes H

No Stop Work Recommended:

0 Yes 8

No CATD No.

30403 S

N 01 4.

INITIATION DATE 10-20-86 RESPONSIBLE ORGANIZATION:

S N

PROBLEM DESCRIPTION: H QR 0 NQR Electrical manholes were found to contain submer ed cables or evidence that cables had been submer ed.

Manholes ins ected and interviews indicated that CSSC cables have 'been submer ed.

7.

PREPARED BY:

NAME Paul S

ard 8.

CONCURRENCE:

CEG-H +.c.

9.

APPROVAL:

ECTG PROGRAM MGR.

CORRECTIVE ACTION

'ATTACHMENTS DATE 10-20-86 DATE: 'zu-w6 DATE: $

10.

PROPOSED CORRECTIVE ACTION PLAt):

6 Y 8"Fg".~8/,/J iO4iW'//

A~a. 3

~~6 //29 o~'c Qt

'.G~

a.S 4R 8 I

~

L.3 0 ATTACHMENTS 11.

PROPOSED BY:

DIREC

/

-R:

12.

CONCURRENCE:

CEG-H:

. ~::+.: -" ~ i-.~ZP{.

~ -

c - r'~

SRP:

/

ECTG PROGRAM'GR:

DATE:

DATE:

DATE:

DATE:

DATE:

DATE:

DATE:

-M-l-k

/ G'7 VERIFICATION AND CLOSEOUT 13.

Approved corr'ective actions have been verified as satisfactorily implemented.

SIGNATURE TITLE DATE

4 KCTG C.3 httachment h,

Page 1 of 1,.......

Revision 2

KCSP Corrective drtion Tract~in Doc(usenr.

(CATD) 0'(

~ LON h~~licable ECSP Be~ort No.:

OP 304.03 l.

Immediate Corrective hction Requi,red:,'l,'es,

,0

, No 2.

Stop Mort Recommended:

Dl Yes 35'Ho CATD Ho.

30403 HPS-01

~

4" ~

XNZTI4TION (DhTE ll 24 86 5.

RESPONSIBLE ORGANZZhTZON:

Divisioni o N c 'ear En ine'erin -El.ec'trical 6.

PROBLEM DESCRIPTION: g QR 0 NQR ProbkeOs geee.identified with'stand(a vater in electrics:L nanholes at all sir.as.

Blthou h this v~ith ra ard to 'vates-treein 'r insulation on level V volta e

cables.

CATD 30403-+SN-01

@as vrit!tee fior iDHE to address this issue

~at E

N hovever~bscause this issue is eneric~a ries onse should be a~ada a

i(cable for all sites ATTACHMENTS 7.

PREPhRED BT:

NAME G.

Da Garden DhTK

'11-24-86 B.

CONCURRENCE:

CEG-

'u~

.'dru~~

DBTE:

9.

APPROVAL:

KCTG PROIQLlM MGR.'

'MW wG.

DATE.

I RREC IVE hCTION 10.

PROPOSED CORRECTIVE ACTION PII.AN:

III I

Cl ATThiCHMENTS ll. PROPOSED BY:

DIRECTOR/M+:

0(

Wt

(

DATE:

O,L, SRP:

DATE:

a DATE:

DATE:

DATE:

1 ECTG -PROGRAM MGR:,

<~Q~Z

~g DATE:

nC~><<g.my ia'4 g l

< k'> P'~'B~"~lq ~nq~~~

VERTFICdTION hHD CLOSEOUT

13. hpproved corrective actions have been(verified as satisfactorilX implemented.

SIGNhTURE TITLE 0

ECSP Corrective Action Trackin Docume=t (CATD>

ECTG C.3 Attachment A

,Page 1 of 1

Revision 2

INITIATION A licable FCSP Re ort No:

-:-.02 S

N Revision l.

2.

3.

5.

6.

Immediate Corrective Action Required:

Z

-es 5

No Stop Work Recommended:

0 Yes S

No CATD No.

30402-S N-01 4.

IN.::=':ION DATE 11-08-8 RESPONSIBLE ORGANIZATION:

Nuclear Consr.r.. =cion PROBLEM DESCRIPTION: 0 (}R 8 NQR MRAI-<. "Control Power anc Si nal Cables

" revision 8 (12-31-85) was found to not have reference to MGAI-13 "Electrical Press.

=e Seal Fire Sto Barrier and Flame Retardant Cable Coat."..

revision 6

(01--8-85).

7.

PREPARED'Y:

NAME T

W 'te 8.

CONCURRENCE:

CEG-H 4 '"'

c-m 9.

APPROVAL:

ECTG PROGRAM MGR.

v<

H ATTACH..~B:-S DAT I"~'-86 E:

lo-DATE:

CORRECTIVE ACTION 10.

PROPOSED'ORRECTIVE ACTION PLAN:

Au ust 13 1986 to incor orat 8c g-I

~g~.DYO

'2

~

~.

~

2 2~

1 9 /7 0 ATTACHM:-.'i:S 11.

12.

PROPOSED BY:

DYRECtBYE/HGR:(

SOS 880922 8.:.

COHCGRREHCE:

CEO-H:

SRP:

/

ECTG PROGRAM MGR:

.~d pJ DATE:

DATE

'ATE:

DATE:

DATE:

DATE:

AKDATF.:

09/25/85 9

I< Iu" VERIFICATION AND CLOSEOUT 13.

Approved corrective actions have been ver'.=."'s satisfactorily implemented.

SIGNATURE DATE 2048T

Cl

<t 0

ATTACHMENT, I LIST OF EVALUATORS 'BY ELEMENT/PLANT 30400 Revision 1

Element 304.01 WBN

~SN B. Z. Meers P. L. Shepherd B. Z. Meers BFN BLN D. B. Thompson M. Stutz R.

M. Gunnels Element 304.02 WBN'.

D. Gardner B.,Z. Meers

~SN P. 'L. Sheperd Element 304.03 WBN G.

D. Gardner B. Z. Meers

~SN P.

L. Sheperd BFN BLN D.

B. Thompson J. Muir Element 304.04 WBN

'B. Z. Meers

II 0