ML20138R879

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-423/84-23. Spec E-350 Will Be Revised to State Secure & Not Support Cables.Response to Cable Marking Appears Adequate
ML20138R879
Person / Time
Site: Millstone 
Issue date: 11/13/1985
From: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Opeka J
NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 8511190186
Download: ML20138R879 (2)


See also: IR 05000423/1984023

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NOV 131985

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Docket No. 50-423

Northeast Nuclear Energy Company

ATTN: Mr. J. F. Opeka

Senior Vice President - Nuclear

Engineering and Operations Group

P. O.' Box 270

Hartford, Connecticut 06101

Gentlemen:

Subject: NRC Region I Inspection No. 50-423/84-23

This refers to your letter dated April 19, 1985, in response to our letter dated

March 20, 1985 and to the telephone conference call between Mr. S. Orefice of

your staff and Mr. J. P. Durr of my staff on October 25, 1985.

With respect to the violation regarding cables from vertical tray 3TC0010 which

were unsupported for a distance of 10 feet, you state that the intent of the

specification No. E-350 is to secure the cables and not to support them. This

intent will be reflected in a revision to the specification.

You stated that

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controls on unsupported cable lengths were being separately analyzed on a case

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by case basis and that the 4.5 foot requirement had no bearing on this engineer-

ing feature.

For the violation dealing with cables being run outside of raceways and con-

duits, you stated in our telephone conversion that these cables are in the

cable spreading room, a non-hazard area, and should not require protection from

hazards provided by trays, ducts, or conduits. You further stated that this

area will be analyzed for hazards in an ongoing plant study to assure hazards

are not present.

Your response to the marking of cables appears to be adequate.

Thank you for informing us of the corrective and preventive actions documented

in your letter and our subsequent telephone conference. These actions will be

examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

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Sincerely,

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Northeast Utilities

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V. Papadopoli, Construction Quality Assurance Supervisor

E. R. Foster, Director of Generation Construction

E..J. Mroczka, Vice President, Nuclear Operations

D. O. Nordquist, Manager of Quality Assurance

R. T. Laudenat, Manager, Generation Facilities Licensing

W. D. Romberg, Station Superintendent

Public Document Room (PDR)

Local Public Document Room (LPDR)

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Nuclear Safety Information Center (NSIC)

NRC Senior Resident Inspector

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State of Connecticut

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Region I Docket Room (with concurrences)

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April 19,1985

Docket No. 50-423

A04760

Mr. Stewart D. Ebneter, Director

Division of Reactor Safety

Region I

U.S. Nuclear Regulatory Commission

631 Park Avenue

King of Prussia, PA 19406

Reference:

(1)

5. D. Ebneter letter to

W.. G. Counsil, " Inspection Report

No. 50-423/84-23," dated March 20,1985.

Dear Mr. Ebneter:

Millstone Nuclear Power Station, Unit No. 3

IE Inspection Report No. 50-423/84-23

Response to Violation

As a result of an inspection conducted by your office from October 22-26, 1984

at the Millstone Nuclear Power Station, Unit No. 3, the following violation was

identified and transmitted to us in Reference (1):

VIOLATION

10 CFR 50, Appendix B, Criterion V, states, in part, " Activities affecting

quality shall be prescribed by documented instructions

shall be

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accomplished in accordance with these instructions."

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Licensee Electrical Installation Procedure No. E-350, Revision 6

dated April 20,1984, page 3-29, Section 3.2.4.9, line 28.51 states, in

part, that: " Unsupported lengths of cable shall not exceed 4.5 feet;"

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Line 25.14 of Section 3.2.31, page 3.34 of Procedure E-350 states, in

part, that: " Cables shall be installed in cable trays, conduits, in

accordance with drawings, cabic schedules;"

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Section 3.2.2.9 of Procedure E-350 states, in part, that: " safety-

related cables are to be marked using color tape at the entrance of

enclosures and at intervals of 15 feet."

Contrary to the above,

a.

Cables from vertical tray 3TC0010 to horizontal trays 3TC0020 and

3TC0080 were unsupported for a distance of 10 feet.

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b.

Cable vertical runs in the cable spreading room, of 20 feet or more,

were attached to the support structure by plastic (non-seismic) tie

wraps.

c.

Black cables entering electrical penetration No. F3V, located inside

the containment, were not identified as required to indicate

division / channel orientation.

The above examples of failures to follow procedures are in violation of

10 CFR 50, Appendix B, Criterion V. This was determined to be a Severity

Level V violation.

I

In accordance with Reference (1), Northeast Nuclear Energy Company (NNECO)

hereby p,rovides the following response to this notice of violation:

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RESPONSE

Condition

a.

Cables from vertical tray 3TC0010 to horizontal trays 3TC0020 and

3TC0080 were unsupported for a distance of 10 feet.

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b.

Cable vertical runs in the cable spreading room, of 20 feet or more,

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were attached to the support structure by plastic (non-seismic) tie

wraps.

Response

Electrical

installation

Specification

Procedure

N o.

E-350,

Section 3.2.4.7, specifies Kellems grips which can be used for supporting

of cables on any vertical slope and also describes the requirements for

the sizing and spacing of supports. This is in strict compliance with the

National Electric Code Article 300-19. The use of the wraps with a

4.5 foot spacing requirement is for the securing of cables, which is in

compliance with Article 336-5 of the National Electric Code.

'

Corrective and Preventive Actions

No field changes have to be made because vertical cables have been

installed in accordance with procedures.

Electrical Installation

Specification Procedure No. E-350, Section 3.2.4.9 will be revised to

clarify the 4.5 foot spacing requirement in respect to the securing of

cables, not the supporting of cables, which is in compliance with the

National Electric Code Article 336-5.

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Condition

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Black cables entering electrical penetration No F3V, located inside

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the containment, were not identified as required to indicate

division / channel orientation.

Response

Electrical Specification E-350, Section 3.2.2.9 allows the use of black

jacketed cable, when approved by the engineer, as a substitute for cables

that are supplied by the manufacturer with color coded jackets. The

black jacketed cable shall be color coded with the appropriate colored

tape to identify this cable as a Category I redundant cable installation.

This tape shall be applied at a point of entry to and exiting from

enclosed areas.

The cables that were observed by the inspector at penetration No. F3V

did not have the tape at the entry point as required by the specification.

Corrective and Preventive Actions

These cables had the tape applied on the same day this violation was

noted by the inspector. An inspection of other penetrations for a similar

situation was performed and no further problems were noted.

This is considered to be an isolated case and no further corrective action

is necessary.

We consider this to be our final report for this violation. We trust that the above

information satisfactorily responds to your concerns .

Very truly yours,

NORTHEAST NUCLEAR ENERGY COMPANY

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W. G/Counsil

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Senior Vice President

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