ML20138R879
| 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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OFFICIAL RECORD COPY
RL MILLSTONE 3 84-23 - 0001.0.0
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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.
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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.
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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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