ML20023D488
| ML20023D488 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 02/10/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20023D446 | List: |
| References | |
| 5960N, NUDOCS 8305200540 | |
| Download: ML20023D488 (7) | |
Text
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{ N Commonwealth Ed: son
) One First National Plaza. Chicago Illinois
(
/ } Address Reply to: Post Office Box 767 i
N
,f Chicago. lllinois 60690 l
February 10, 1983 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nucle &r Regulatory Commission 799 Roosevelt Road l
Glen Ellyn, IL 60137
Subject:
Byron Station Doits 1 and 2 NRC Inspection Report Nos.
50-454/82-17 and-50-455/82-12 References (a):
January 11, 1983 letter from C. E.
Norelius to Cordell Reed.
(b):
January 14, 1983 letter from L. O.
DelGeorge to J.
G. Keppler.
(c):
December 13, 1982 letter from L. O.
DelGeorge to J.
G. Keppler.
Dear Mr. Keppler:
Reference (a) provided the results of an inspection conducted by l
Mr. R. S. Love on August 16-20, 23-27 and September 17, 1982 of activites l
at Byron Station.
During that inspection that certain activities l
appeared to be not in compliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison's response to the Notice of l
Violation which was appended to reference (a).
It was also requested that we address in this letter an item which remained unresolved at the completion of this inspection.
Paragraph 3.b.(2) of the inspection report discusses the inspectors
' limited review of records to determine if any on-site QC inspectors had inspected work which they performed in a previous craft capacity.
No such occurrences were identified but a complete review of such records was requested.
This effort is presently in progress and should be complete by March 15, 1983.
The results of this review will be available in the site construction of fice for your review af ter that date.
Addi-l tional19, all craft QC inspectors are being reminded of the regulatory requirements for independence of inspection personnel.
As indicated in the attachment to the letter, we do not agree that all of the items referenced in the Notice of Violation constitute examples of noncompliance.
Item (1) regarding cable tray separation cites situations similar to those identified in Inspection Report Nos.
I 50-454/82-19, 50-455/82-14, and 50-456/82-06.
As indicated in references (b) and (c), we believe that cable tray separation is being appropriately l
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J. G. Keppler February 10, 1983-controlled through existing procedures.
We request that we be given the opportunity to discuss this issue with regional I&E management personnel before further inspections of this type are conducted.
To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison and contractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please direct further questions regarding this matter to this Very ulyyoupt
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L.
Farrar Director of Nuclear Licensing TRT/lm Attachment l
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ATTACHMENT A Response to Notice of Violation Violation 10 CFR 50, Appendix B, Criterion XVI, states in part, " Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and noncompliances are pronptly identified and corrected.
Commonwealth Edison Company Topical Report No. CE-1-A, Revision 21, Section 16, states in part, "A corrective action systen will be used to assure tnat such items as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances which l
are adverse to quality and might affect the safe operation of a nuclear generating station are promptly identified and corrected."
Contrary to the above, the licensee had not taken the necessary actions to assure that an Identified item of noncompliance, concerning (1) the separation criteria between safety-related and non-safety related trays and (2) the seoaration criteria between safety-related and non-safety related cables / wires inside Class lE equipment, were promptly identified and corrected.
This is exemplified by the fact that (1) cable tray separation violations and (2) electrical cable separation violations inside equipment are not being promptly identified and corrected or analyzed.
See the body of the report for examples.
Excerpt 1 from Inspection Report:
l During a tour of the power block with personnel from the Power l
Systems Branch of NRR, it was observed that non-class lE cable tray l
ll445U-C2B passes under Class 1E ladder type cable tray 11441Q-C2E with a vertical separation of approximately 10", metal to metal.
The subject trays are located in Area 5 of the Auxiliary Building at the 426' elevation.
In reviewing the pertinent raceway installation drawing 1-3052A, Revision P, and in discussions with the licensee, it was determined that there are no requirements for the installation of raceway covers or barriers indicated on the subject drawing for tray ll445U-C28.
It was also observed in the upper cable spreading room that non-Class 1E cable tray 220800-C1B passes under Class 1E ladder type cable tray 22129C-ClE with a vertical separation of approximately 10 3/4", metal to metal.
Paragraph 8.3.1.4.2.2 of the Byron /Braidwood FSAR states in part that the vertical separation between Non-Safety Related (non-class lE) and Safety Related (Class lE) cable trays is 12", metal to metal.
' The Region III inspector informed the licensee that failure to promptly identify and control the above nonconforming conditions in accordance with QA program provisions is an item of noncompliance, contrary to the requirements of Criterion XVI of 10 CFR 50,. Appendix B (50-454/82-17-05; 50-455/82-12-05).
CECO-Response The FSAR in Paragraph 8.3.1.4.2.1 commits compliance tn IEEE 384-1974.
1EEE 384-1974 states in Section 4.6.l(3) that "the effects of lesser separation (then thal-described in A.6.1(1)) or the ebsence of electrical isolation between tile Non-Class lE circuits or associated circuits shall be analyzed to oemenstrnte that tne Class lE circuits are not degraded below an acceptable level or they become associated circuits.'
Sargent & Lundy, ss part of t heir notmal electrical separation design review, identifies all Instnoces where the design separation criteria is violated.
An er.alysis is performed on eacn identified violation to show that the violation coes not degrade the Class 1E raceway and is therefore acceptable.
This analysis is based on the seDregation of the cable racewayc involved and/or the Class lE cables in the affected receways.
It tne violstfor is determined to be unacceptable, then the affected raceway would require a redesign to correct the adverse condition (e.g. aod covers to trays, reinforce cable r.ceway supports, move cable raceways, etc.).
Each violation is documented and approved by an engineer.
This separation review is an " ongoing" effort and includes the review of changes made as a result of ECN's and FCR's.
All violations will be reviewed and j
documented by S&L prior to fuel load.
The electrical contractor on site installs and-inspects the electrical installation to the requirements of the approved design documents which are issued for construction (i.e. drawings, ECN's and l
FCR's).
The installation contractor does not inspect the j
installation for compliance to the requirements of IEEE standards or the FSAR.
Excerpt 2 from Inspection Report:
During a tour of the power block, the inspector observed that minimal progress is being made in the identification and resolution of the cable separation problems inside Class lE panels, cabinets, and switchgears.
Following is a brief history of the separation problems:
i y
~
l f (1)
On December 18, 1980, CECO prepared NCR F-580 to document the fact that Class lE and non-Class lE cables were in direct contact with one another inside 480V Unit Substation LAP 98E, 4160V switchgear LAP 05E, 4160V switchgear LAP 06E, 4160V switchgear 2AP05E, and 4160V switchgear 2AP06E. IEEE standard 384-1974, as stipulated in the Byron /Braidwood Final Safety Analysis Report, requires that redundant Class lE cables / wiring be separateo by a minimum distance of 6 inches, or barriers be Installed between the cables / wiring, or an analysis may be performed.
(2)
During the week cf July 7-10, 1981, Region III inspectors met with the licensee and Sargent and Lund/ (S&L) representatives to discuss the corrective action to be taken to correct the lack of separatica identified by NCR F-580 and the corrective action to preclude repetition.
During this meeting, the licensee stated d
that construction personnel would be instructed to rework the cables identified b, NCR F-!80 and if these efforts to achieve the separation criteria were unruccessful, the licensee would document this condition to S&L, where en analysis would be performed to demonstrate that the lack of separation would not result in a degradation of the performance of the cables' safety related function.
The licensee further stated that current procedures would be revised cr a 1ew procec'ure written to assure that each instance of inadequate cable separation would be identified and controlled.
During this Irispection, the inspector made this matter an unresolved item penal 10 a review of the licensee's corrective action during a suosequent inspection.
Tracking numbers 50-454/81-08-05 and 50-455/81-07-04 were assigned.
(3)
Hatfield Electric procedure number 11, Class I Cable Termination and Splicing, was revised to include the inspection attribute, cable separation inside electrical equipment.
Paragraph 5.1.5.2 of the subject procedure states in part, "If any field conditions prevents compliance with the following separation and criteria, HECo QA/QC should be notified per Procedure #6, reported to CECO for disposition."
Procedure Number 6 is titled, " Reporting of Damaged or Nonconforming Material or Equipment".
i (4)
During this reporting period, the inspector made a spot check of panels and cabinets in the Unit 1 Auxiliary Electrical Equipment Auxiliary Building, 451' elevation, and it was observed
- Room, that there were numerous examples of Class lE and non-Class 1E cables being ty-wrapped together.
In panel 1PA20JA, it was l
observed that a Division 1 Engineered Safety Feature (ESF) cable In the was ty-wrapped to a Division 2 ESF associated cable.
panels checked, the inspector did not observe any Hold Tags associated with cable separation problems in the panels.
In discussions with the licensee, it was learned that the subject panels had as yet to be checked for cable separation compliance to the requirements of IEEE-384.
l
- J t. The inspector informed the licensee that failure to promptly 1
identify and control the above nonconforming conditions in accordance with QA program provisions is another example of noncompliance to the requirements of Criterion XVI of 10 CFR 50, Appendix B (50-454/82-17-06; 50-455/82-12-06).
CECO Response It is the licensee's position that this is not & violatien of the requirements of IEEE-384.
In fr.ct, IEEE-420 allow s the bundling together of Class 1E and non-Class 1E curcuits inside of panels.
The lessor separation requirements of both of thesa IEEE standards is allcred as long as an analysis is perf un,ed to decermine 4
acceptability.
In February 1978, S&L established within their organization I:4terface Review Reports (IRR).
One of the purposes of the 19R process was to address separation of cables in free air and inside equipment.
IRR's are generated from a computer printout which identifies any potential problems from bundling of cables or from cables trained inside a panel.
These are reviewed and analyzed by an engineer (using the schematics) for its effect on redundancy, Tne anal / sis and recommen-dations are then approved by the Senicr Electrical Project Engineer.
This same process is also done for IRR's which may be generated as a result of S&L's review of ECN's, FCR's and NCR's.
The IRR process is an " ongoing" effort at S&L.
The electrical contractor on site, installs and inspects the electrical installation to the requirements of the approved design decuments which are issued for construction (i.e. drawings, ECN's and i
FCR's).
The installation contractor does not inspect the installation for compliance to the requirements of IEEE standards.
The licensee, in an effort to enhance the IRR process at S&L, revised the installation contractors procedures to include inspection attri-butes for cable separation.
Corrective Action Taken and Results Achieved i
To address the failure of the electrical contractor to report cable separation problems per their Procedure No. 6, the following actions have been taken:
1.
Following the NRC's inspection the contractor was instructed to identify panels which contained cable separation problems per the requirements of their Procedure No. 11.
2.
As of December 15, 1982, the contractor has identified approximately 50 panels which contained violations of the criteria of their Procedure No. 11.
The contractor has placed Hold Tags on these panels and has notified CECO per their Procedure No.
6.
Corrective-Action to Avoid Further Noncompliance The electrical contractors procedures which contain inspection attributes for cable separation are being revised.
The cable separation criteria contained in these procedures will remain the same, however the identification and reporting requirements are being i
changed.
A new form titled " Cable Separation Conflict Report" (CSCR) ic being instituted.
]
Date V_ hen Full Compliance Will Be,, Achieved The contractors procedures will be revised and implemsntec by March 1, 1983.
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