ML20086Q124
| ML20086Q124 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/13/1982 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20086Q093 | List: |
| References | |
| 5566N, NUDOCS 8402270442 | |
| Download: ML20086Q124 (8) | |
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Commonwsa,..A Edison g
r Ore 'gu NaS:n:
ara CNca;r, ii. no.s ACO'ess Reply to Posi'Di* e BoI767 Ch:cago. I;hno:s 60690 December 13, 1982 Mr. Jame s G.
Keppler, Regional Administrator Directorate o f Inspection and Enforcement - Region III b ' fOl O3 U.S. -Nuclear Regulatory Commission s
799 Rooseve.Lt Road Glen Ellyn, IL 60137
Subject:
Byron Station Units 1 and 2 I&E Inspection Report Nos.
50-454/52-19 and 50-455/82-14 Reference (a):
Noveraber 12, 1982, letter from C. E. Norel'ius to Cordell Reed.
Dear Mr. Keppler:
Reference (a) provided the results of an inspection conducted by Mr. R. Mendez o f your office on September 16-17, 1982 at Byron Station.
During the inspection it appeared that certain activitien were not in compliance with NRC requirements.
Atta chmen t A to this letter contains Commonwealth Edison's response to the Notice of Violation which was appended to reference (a).
In reviewing the circumstances surrounding these violations, it has been determined that not all of the examples cited are actual items of noncompliance.
The information suoporting this conclusion is presented on a case-by-case basis in the responses contained in Attachment A.
Accordingly, it is respectfully requested that Violations 1 and 2 be withdrawn.
We would be happy to discuss this further at your convenience.
To the best of my knowledge and belie f the statements con-tained 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 employees -
and consultants.
Such-information has been reviewed in accordance with Company practice and I believe it to be reliable.
Very truly yours,
/
L. O. De lGeo rg e Director of Nuclea r Licensing TRT/Im 8402270447. 840222 DEC g 1987, 5566N PDR ADOCK 05000454 G
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AC-ATTACHMENT A Response to Notice of Violation Vi'olation 1 10_CFR Appendix B, Criterion III, states in part, " Measures shall be established to assure that applicable regulatory e
- requirements and the design basis...as pecified in the license application, for those structures and components to which this appendix applies are correctly translated into specifications...
-These measures shall include provisions to assure that appropriate quality standards.are specified and.that deviations from such standa rds are controlled. "
Criterion III further states that, " Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations.
These measures shall -include the establishment of procedures among participating design organizations for the review,
- approval, release...of document s involving design interfaces."
Commonwealth -Edison Company Topical Report CE A, " Quality
. Assurance Program for Nuclear Generating Stations, Revision 15, Section 3.1, dated January 2,1981, states in part "... designs and materials will conform to... standards, regulatory requirements, SAR commitments, and appropriate quality standards as applicabic."
Topical Report CE A further states, "... design evaluation or reviews ?are conducted to written standards and include consideration of quality standa rds, quality. assurance requirements,... interface control...as appropriate."
Contrary' to the above, the following instances of inadequate design control were identifed:
'Tlie FSAR in Paragraph 8.3.1.4.2.1 commits compliance to IEEE s.
384-1974 which states in Section 4.6.1 that "Non-Class lE circuits shall be separated from Class IE circuits by the minimum requirements in Sections 5.1.3, 5.1.4, or 5.6 o r they become associated circuits."
IEEE 384-1974, Section 4.5 identifies separation requirements for associated-circuits.
As o f September 22, 1982,. safety related raceways were in direct contact with non-safety related rr.ceway in three locations two of which: occurred in the Auxiliary Building and one in the upper Cable Spreading Room.
In addition, in three 'other instances the spacing between Class 1E and Non-Class IE cable trays was less than the one inch minimum as specified in IEEE 384-1974 and Section 8. 3.1.4. 2. 2. C o f the FSAR.
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b.
The inspector observed that safety related cable raceway Section 12031C CIE and the cables inside the tray were supporting a section of an HVAC duct.
It appeared that the HVAC duct was braced against the insides.of the Class lE tray.
Al t hou gh, the raceway and the HVAC duct were installed independently to the correct elevations as specified per their respective drawings, it appeared that inadequate design interface control and design review caused the nonconforming condition.
The inspector observed the f ollowing circumstances:
(1)
There is no assurance that Class IE cables have not been damaged as a consequence of the pressure applied by the duct and brace against the cables.
(2)
Class lE raceway Drawing 6E-0-30720, s
Revision L, had not specified that cable tray Section 12031C CIE was to support the HVAC duct.
(3)
-The HVAC duct was apparently supported by a Class IE tray without an engineering analysis being performed.
(4)
As of September 22, 1982, the condition had not been identified and consequently no discrepancy report issued.
(5)
The licensee had not identified the apparent conflict among design organizations in, placing the tray and duct within the same space coordinates.
Response
a.
IEEE 384-1974 s tates in Section 4.6.l(3) that "the e f fects of lesser separation (than that described in 4.6.l(1)) or the absence of electrical isolation between the Non-Class 1E circuits or associated circuits shall be analyzed to demonstrate
-that the Class.lE circuits are not degraded below an acceptable level or they become associated circuits."
Sargent & Lundy, as par ~t of their normal electrical separation design review, identifies all instances where the design separation criteria is violated.
An analysis is performed on each identified violation to show that the violation does not degrade the Class lE raceway and 11s therefore acceptable.
This analysis is based on the segregation of the cable raceways involved and/or the Class 1E cables in the affected raceways.
If the violation is determined to be unacceptable, then the affected raceways would require a redesign to correct the adverse condition (e.g. add covers to trays, reinforce cable raceway supports, move cable raceways, etc.).
Each violation is documented and approved by an engineer.
This separation review is an ongoing effort.
All violations will be reviewed ano documented prior to fuel load.
S The 'six-specific ~casessobservededuringsthe* inspection and...
documented in the inspection report involved:instancesewhere the separation between safety related and non-safety related cable trays was less than the one inch minimum vertical separation required-by IEEE 384-1974 Section 4. 6.1(1).
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det'e rmined uthatte achL o fsthexsixa cases t wase p roperlysidenti fied sby Sargent and Lundy and documented as a cable separation criteria violation as part of the review process described above.
After final engineering disposition, these violations will either be justified or a redesign will be instituteo to correct the violations.
In summary, appropriate design control was applied to each of the examples identified in the inspection report.
None constituted an example of noncompliance.
b.
Contrary to the inspection report, the cable tray and HVAC' duct do not physically touch (i.e., they do 'not have metal to metal contact).
Both the raceway and the HVAC duct were installed independently to the correct elevations specified per their respective drawings.
Af ter the HVAC duct was installed, it was enclosed in a fiberglass insulation which does contact the cable raceway but provides no support.
Since both the HVAC duct and the cable raceway are independently supported, and the HVAC insulation is flexible, the insulation contact with the raceway has no detrimental impact on.the safety related cable raceway.
Since ncither the insulated HVAC duct nor the brace comes in contact with the cables inside the safety related raceway, there is no damage to. Class IE cables because of this installation.
Although we would have preferred to have installed this duct farther.away from the raceway, it is not an example of noncompliance because appropriate design control was applied.
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Violation 2 J
10' CFR Appendix B, Criterion X, states in part, " A program for inspections of" activities af fecting quality shall be established and executed...to verify conformance with documented instructions, procedures... f or accomplishing the activity."
Commonwealth Edison Company Topical Report No. CE A, Revision 20, Section 10, states in pa rt, " Quality Assurance inspections...
will be conducted...during construction...to verify conformance to applicable drawings, instructions, and procedures as necessary to verify quality."
Hatfield Electric Company Procedure No.10, Revision 15, dated July 2 7, 198 2, Section 5.1.3 4, states, in pa rt, "If a cable cannot be physically routed according to the routing shown on the cable pull card of if routing tolerances of Drawing 6E-0-3000A are exceeded... cable installation will stop and the owner or S&L will be noti fi ed. "
Contrary to the above, routing tolerances were exceeded for three o f the nine cables the. inspector reviewed.
In each of the three instances QC inspectors f ailed to identify and correct routing discrepancies that exceeded the tolerances o f specification Orawing 6E-0-3000A.
As a result, QC inspectors signed off the inspection reports, although the routing of these cables were not in accordance with _ the cable pull cards.
This is exemplified by the misinstalla-tion of cables:
1V A15 6, IVE034, 2SX34 5.
Response
Routing of Cable 2SX345 At the time of installation, the pull card for cable 2SX345, specified the follcaing routing points:
22025C, 2R479.
The cable was installed as speci fied.
La ter, routing point 22104C was physically moved, requiring the addition of routing point 22104C to the cable tabulation for cable 2SX345.
The addition of routing point 22104C was added to the cable routing on the cable tabulation per FCR No F7515, dated October 26, 1981.
A revised cable pull card was received on-site subsequent to the NRC inspection.
This is not an example of noncompliance because the cable was pulled properly and the FCR procedure was properly implemented.
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Routing of Cables IVA156 and IVE034 Item C.5 on drawing 6E-0-3000A, sheet 3 states:
" A cable entering a pan within 3 feet of a routing point marker, (1) may not have that routing point number listed in its routing, even though the cable does cross the point or (2) may have that routing even though the cable does not cross the routing point.
Each o f these conditions is acceptable and no notification is required."
This prevision is included to acknowledge the minor dimensional variations which are inherent in the process of placing routing markers on cable pans in the field on the basis of scale drawings..
The routing for cable IVA156 is specified as follows:
- 1689A, conduit IC2198.
As installed, the ca'ble exits the conduit and enters the cable pan at exactly routing point 1694A.
According to Item C.5, the routing specification could also have been:
- 1689A, 1694A, conduit 1C2198.
The routing for cable IVE034 lists routing point 11520L as one of its.Iouting points.
The cable does not actually cross this point.
Within three feet of routing point ll520L, the cable exits the pan and enters the pan immediately below it within three feet of routing point 11520M, crosses ll520M and cont 1 Dues on into riser 1R339.
According to Item C.5 there are several correct specifications of this routing, including the one used.
These. cables, IVA156 and IVE034, are installed in accordance with design instructions as detailed in Item C.5 of drawing 6E-0-3000A, Sheet 3.
These are not examples of noncompliance because the routing was accomplished in accordance with established instructions.
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Violation 3 10 CFR 50, Appendix B, Criterion XVI states in part, " Measures shal] be established to assure that conditions adverse to quality,
such as... deficiencies, deviations...cnd noncompliance are promptly identified and corrected."
Commonwealth Edison Company Topical Report No. CE-1 A, Revision 15, states in pa rt, " A corrective action system will be used to a ssure that such items as... deviations...and nonconformances which are adverse to quality and might affect the safe operation of a nuclear operating station are promptly identified and corrected."
Contrary to the above, the inspector observed four Class lE cables and two associated cables within six inches from the top of Non-class 1E tray with associathd cable IMS148 in actual contact with non-safety cables.
Ha tfield Electric Company Procedure No.10 requires that separation of Class 1E and Non-class IE cables be not less than twelve inches in free air.
Aoditionally, in the licensee's response to item of noncompliance 81-16-01 and 81-12-01 for Byron Units 1 and 2, respectively, the licensee made a commitment that all cable separation problems for Unit 1 be identified and a log established by March 1982, and for Unit 2 by June 1982.
However, the licensee coul.d not provide documented identified. evidence that the nonconforming condition had been previously Corrective Action Taken and Results Achieved The separation criteria contained in the electrical contractor's Procedure Number 10 -requires that separation be maintained between Class 1E an Non-class 1E cables in free air.
This criteria was written into the procedure to address the problem of separation of two or more cables which were traveling in free air, such as the interface between cable raceway and equipment and panels, and as such, would not be held stationary in free air by any barriers (such as conduit).
Tne particular case observed by the NRC Inspector involved the
' separation of cables in air along their routing, to cables which were in a raceway.
the separation distance between the cables in a raceway and cablesSpe which exited conduits and continued in air for approximately a foot to where they entered the cable pan, directly above this raceway, to continue their routing.
The separation criteria required by Procedure Number 10 for cables in free air is not imposed here since the cables are not ire free air but are held in place by a cable tray.
This is not the type of cable separation problem included in the scope of the June 1982 commitment.
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y Upon further inspection of these cables which exiteo che conduits, it was discovered that the cable identification markers on three of the six cables were of the wrong color code. - All six of these cables are C IB, (non-safety related) however, three of them were incorrectly marked as CIE (safety related). As discussed with the NRC these cables
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serve safety-related functions and are connected to components in the turbine building.
Tney are routed in conduit in the turbine building and in safety-related cable pans in the auxiliary building.
All cables were marked with the proper identification markers and the cables were trained to obtain the proper separation required.
Corrective Action Taken to Avoid Further Noncompliance The electrical contractor's Procedure Number 10 will be revised to address separation requirements between cable (s) in raceways and cable (s) in open cir.
Date When Full Compliance Will Be Achieved We expect to have the electrical contractor's Procedure Number 10 revised to include the necessary requirements and implemented by Ja nua ry 31, 1983.
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