ML20207K665

Rev 1 to Raceway Overfills & Cable Pulling,Conduit Overfills & Cable Damage

ML20207K665
Person / Time
Site:	Sequoyah
Issue date:	12/07/1986
From:	Mcnutt G TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K654	List: ML20207K650 ML20207K665 ML20207K686 ML20207K717 ML20207K731 ML20207K740 ML20207K758 ML20207K785 ML20207K800 ML20207K821 ML20207K827 ML20207K849 ML20207K858 ML20207K881 ML20207K917 ML20207K942 ML20207K968 ML20207K979 ML20207L004 ML20207L017 ML20207L057 ML20207L069 ML20207L089
References
238.1(B), 238.1(B)-R01, 238.1(B)-R1, NUDOCS 8701090479
Download: ML20207K665 (29)

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM p; REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 1 TITLE: RACEWAY OVERFILLS AND CABLE PULLING Conduit Overfills and Cable Damage PAGE 1 0F 25 REASON FOR REVISION:

Revised per TVA comments.

PREPARATION PREPARRBY:Undewa SibNA UKt 1zlrIn

'DATE REVIEWS

--PE ER - REVIEW COMMITTEE SIGNATURE

& !E - 6*Sb DATE TAS:

SIGNATURE DATE CONCURRENCE 5 CEG-H: }Jv2e8 UlY)h /2-[8d>

SRP.

! SIGNATURE DATE SIGNATURE DATE 8701090479 861224 m PDR ADOOK 05000327 P PDR APPROVED BY:

ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1(B)

SPECIAL PROGRAM REVISION NUMBER: 1 m

M PAGE 2 0F 25

1. CHARACTERIZATION OF ISSUE (S):

Concerns: Issues:

IN-85-432-001 a. Conduits and jumpers between cable

" Overfill of cables in conduits trays are overfilled and cable Aux. Control Building El. 757 and additions continue to be routincly Reactor building." scheduled. Overfills beyond safe

- capacities result in an~ unsafe

~~ -- - ~ ~ -

IN-86-036-001 condition and could cause induction

" Electrical Conduits in Units 1 and heating problems (induction and and 2 are overfilled. This may heating or ampacity problems are cause induction / heat problems. addressed in Sequoyah Element Report Some cables may also have been 240.0, " Cable additions routinely damaged by pulling in these scheduled" are addressed in Sequoyah tight conditions, and by using Element Report 239.0).

excessive force installing the fish tape in the conduits." b. Potential cable damage could result from cable pulling in overfilled IN-86-310-001 conduits and other cable pulling

, "The electrical conduit and practices (e.g., wires are stretched, jumpers between cable trays are cables are dragged over other cables, over filled with cables. TVA insulation is damaged by fishtapes and does not use the National nylon parachute cords, mechanical Electrical Codes in construction pulls are not monitored, etc.)

practices. Due to overfill, the Damaged cables would not be discovered cable may have been damaged when until they short cut.

they were pulled."

c. National Electrical Code not IN-85-313-001 followed for conduit fill and

" Overloading of conduits-wire construction practices.

is being pulled through conduit that is loaded with wire such d. Cable trays and cable tray penetra-that it is difficult to push tions are overfilled (discussed in a pencil through. Wire is Sequoyah Element Report 238.3).

being stretched when pulling through these conduits." e. Cable for Unit 2 was being routed through Unit 1 (discussed in Watts Bar Report 239.0) n 0041D (12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238,1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 m.

PAGE 3 0F 25 Concerns (cont'd):

IN-85-506-001 "A recent cable pull (date unknown) was accomplished on a conduit which was overfilled to the point that the 1/8"

'Fishsnake' which guides that cable could barely be inserted.

The conduit is 100% + full as a result of this cable pull."

IN-85-622-001

" Conduit overfilled beyond safe capacity."

IN-85-685-001

" Conduits are generally over-filled beyond acceptable limits."

-IN-85-743-008

" Conduits are generically over-filled and additional cables are routinely scheduled to be added to the conduits. This causes significant expenditures of manhours in attempting to pull cable where there is no more room available."

IN-86-034-001

! " Cable pull required I week to feed fish tape through conduit' - - - - - - - - -

prior to cable pull. Overloading of conduits damages cables."

1N-86-266-003 "Many electrical conduits are l

excessively loaded with cables."

! I N-85-642-001

" Conduit is 98% full of cable and more cable is to be installed."

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM

, REVISION NUMBER: 1 c

PAGE 4 0F 25

!" Concerns (cont'd):

IN-85-856-003

" Conduit and cable trays. are too full."

IN-86-028-002

" National Electrical Standards

! are not being followed. Example:

cable trays and conduits are over full."

IN-86-262-001

" Units 1 and 2. The conduits and cable trays are too full.

It often takes 4-5 days just to pull the fish tape through. This overcrowding is an unsafe condition."

. . , IN-85-832-001

" Overloaded cable tray penetra-tion El 729' Turbine Bldg. &

Control Bldg. El. 737' Aux.

, . Bldg and Control Bldg 741..

. Conduits being filled beyond i National Elec. Code allowance.

Possible damage to cables that l

other cables are being dragged over."

IN-85-312-001

! " Cable trays in [and] conduits are overfilled with cable. The

, cables could be damaged and not discovered until it shorts out."

j IN-85-734-001 l " Conduits / cable trays /penetra-

! tions in Units 1 and 2 are

generically overfilled / overloaded."

l IN-85-367-001

" Cable in conduit damaged by cable pulling practices. (1) conduits are over-filled, (2) fish tapes can damage conduit, especially when they get stuck, j (3) Nylon cord ' Parachute' can cut cable insulation."

i 00410 (12/05/86) l

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TVA EMPLOYEE. CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 r,

PAGE 5 0F 25 Concerns (cont'd):

'IN-86-262-004 "Elev. 729' (above Machine Shop) there are four or five 5" to 6" conduits still'having the fish

. tape in them. The conduit is'so full the fish tape cannot be removed."

IN-86-254-009

" Conduit running from manholes 1 & 2 to the Aux. Bldg. are overfilled with cables."

IN-86-206-001 "Two 2 conductor #14 safety related cables were pulled through over-crowded 3" conduit /condulets with a 1/2 to 3/4 ton come-a-long.

The conduit /condulets were so . full, - - _ _ _ _ _ _ _ . . _m__.

it was difficult to get the fish tape in. Conduit located at elevation 737' of' Unit-#1 Auxiliary Building to the cable spread room, elevation 742, column lines A3-A4 and 'Q' line. The cable was for Unit II, but was being routed through Unit 1. CI does not know if cable was tested af ter installa-tion. Occurred approx. Feb./ March, 1984."

0W-85-007-003

" Crossover electrical conduits are grossly overfilled, and this will cause a heat build-up that will degrade cable insulation. This could lead to cable breakdown and failure. This was a routine practice until at least 1984. 4" - 6" Crossovers, 737' El, Auxiliary Bldg."

0041D (12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 m

PAGE 6 0F 25

2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Documentation Identifiers:

o Identified by Nuclear Safety Review Staff (NSRS)

Date 02/29/85 to 04/15/85 NRSR Report No. I-85-06-WBN, " Investigation of An Employee Concern Regarding Cable Routing, Installation and Inspection At Watts Bar Nuclear Plant" o Identified by NSRS Date 02/18/86 Attachment 1 to: NSRS Report No. I-85-251-SQN, " Electrical Cables" o Identified by NCR - WBN 6270 R0

'D Date 08/20/85 NCR - WBN 6270 R0," Cable Sidewall Pressure Calculation" o Identified by NCR - WBN 6347 R0 Date 09/27/85 NCR - WBN 6347 R0," Excessive Conduit Bends" o Identified by: SCR SQNEEB 8529 R0 Date 12/06/85 i

l SCR SQNEEB 8529 R0, " Conduits Containing 400 MCM Cables That l l Exceeded the Conduit Fill as Specified in DS-E13.1.2 and DS-E13.1.4"

3. DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT.

No further informatidn available. The employee concerns for WBN - -

! cited some specific locations, but the implied generic concerns for SQN are general in nature. They address overall problems related a to conduit overfill and cable damage by cable pulling.

00410 (12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1

'T N PAGE 7 0F 25

4. INTERVIEW FILES REVIEWED:

The following files were reviewed and no additional unreviewed

.information for Sequoyah was identified for the concerns in this report.

0W-85-007 IN-86-310 IN-86-206 IN-85-432 IN-85-313. . IN-85-367. _ _ _ . _ _ _ _ _ . _ ._ _ _ _

IN-85-856 IN-85-506 IN-86-254 IN-86-028 IN-85-622 IN-86-262 IN-85-685 IN-85-832 IN-85-743 IN-85-312 IN-86-034 IN-85-734 IN-86-266 Files IN-86-036'and IN-85-642 contain additional information for concerns IN-86-036-001 and IN-85-642-001 regarding location, penetration, and conduit numbers. This information, however, is specific to WBN.

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?

See Appendix A.

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.

See Appendix A.

8. EVALUATION PROCESS:

a. Reviewed available transcripts of NRC investigative interviews for additional information on the concerns.

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TVA EMPLOYEE CONCERNS- REPORT NUMBER: 238.1(B) i SPECIAL PROGRAM REVISION NUMBER: 1 7

PAGE 8 0F 25 4

b. Reviewed FSAR and existing applicable TVA Design Standards for commitments and requirements regarding conduit fills.

c. Reviewed SQN cable in conduit routing and conduit fill

, tracking procedures for adequacy.

4

d. Reviewed Construction Specification G-38 and Modifications

and Addition Instructions (M&AI) for cable installation requireme'nts and for inspection instructions.

e. Reviewed existing TVA reports (e.g., GCA-01-46 and GCA-02-47) to assess the extent to which these reports and corrective actions satisfy the concerns.

f. Reviewed existing TVA Construction, QA/QC, Operations, and Material Control reports (e.g., C010900-SQN) for the Employee Concern Evaluation Program for applicability to the concerns discussed in this report.

t

g. Assessed overall adequacy of SQN cable-pulling practices and requirement to identify areas that require further investigation and corrective action.

9. DISCUSSION, FINDINGS, AND CONCLUSIONS l

Discussion:

l

a. Conduit Overfill j Cable routing practices at SQN are addressed in the Generic Concern Task Force (GCTF) report regarding employee concern, --

l

" Overfill of Cable Trays and Conduits" (05/20/86, App. A,

5.m). This report indicates that cables are manually routed in conduits by designers and documented in the computer cable schedule. It is the responsibility of the designer I performing the cable routing to calculate the total cross sectional area (CSA) fill of cables in conduits, whether the cable is newly routed in an empty conduit or added to an existing conduit with existing cables. Maximum allowable conduit fills are specified in Electrical Design Standard

- DS-E13.1.4 (08/24/83, App. A, 5.b) . These fills are in

agreement with the maximum committed raceway fills stated in SNP FSAR Section 8.3.1.4.1.

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l 0041D (12/05/86) i

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM

- -- REVISION NUMBER:--1 -- - --

PAGE 9 0F 25 The- Quality Assurance Evaluation Report (01/06/86, App. A, 5.aaa) of the computer cable routing system determined that for the period prior to March 1986, no documentation was available.to demonstrate that verification of cable routing and raceway CSA was performed before releasing the design to construction. After March 1986 a procedure was implemented to require a checker to verify the manual cable routing and check CSA fill calculation done by the designer prior to releasing the cable pull slips for cable installation. This procedure SQEP-06 (App. A, 5.k) was officially issued in September 1986.

Another aspect of the conduit fill issue is the fact that unverified cable diameters were used. SQN Significant Condition Report (SCR) SQNEEB8601 R0 (01/06/86, App. A, 5.0) was issued as the result of WBN SCRs WBNEEB8589 R0 and WBNEEB8590 R0. This SCR identified use of unverified cable outside diameters (00) and cable weights to calculate the CSA for tray and conduit fill, minimum bend and training radius, and sidewall pressure. The SCR stated that the cable weights

. and outside diameters were not taken from adequately documented sources and the origin of the vendor cable characteristics was unknown. Engineering Report (ER) CAQ No.

SCR SQNEEB8601 R0 (04/16/86, App. A, 5.p) evaluated these unverified values of cable weights and outside diameters and found no major inconsistencies with the QA list of actual values being prepared by EEB Central Staff and concluded that

" existing data would not result in a failure that would impact nuclear safety." A memo from Scruggs to Raughley (09/23/86, App. A, 5.ss) supports the conclusion made in the ER. The memo indicates that a comparison of old and new (verified) ODs for 210 cables revealed that 150 show the

~; original OD to be larger, 57 show that the new OD is larger and 3 were the same. The memo concludes that no major differencas in OD size existed and, therefore, the

possibility of an overfill occurring because of this is very small. A comparison of old and new 00s made by the evaluator revealed that in fact they were close enough to be within a reasonable level of accuracy. The evaluation team determined that although the conclusions in the memo and ER seem reasonable, no analyses have been identified to support

them. The current verified cable values, as indicated in

! memo from Raughley to Raulston (09/24/86, App. A, 5.qq), are the result of samples of class 1E and non-class lE cables sent to TVA's Singleton Materials Lab to establish an auditable listing of cable types with their respective ODs

a and weights. The test results were tabulated and l

incorporated into Electrical Design Standard DS-E12.1.13 R2 l and DS-E12.1.14 R0, (04/15/86, App. A, 5 99 and 5.ii).

00410 (12/05/86) t

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1'(B)

SPECIAL PROGRAM g REVISION NUMBER: 1 PAGE 10 0F 25 The cable OD differences discussed above will have no effect on cable ampacities and derating because cable ampacities in conduits are function of the number of conductors and conduit arrangement, and not of the physical conduit fill.

Furthermore, as part of a program to correct the situation regarding conduit fills, a memo from Raughley (10/07/86, App.

A, 5.tt) directs all the nuclear plants to establish "a 4

i sampling program to determine the adequacy of electrical cables with respect to their ampacity ratings" (the induction and heating issues are addressed in detail in Element Report 240.0). Although TVA indicated (10/08/86, App. A, 7.b) that the extent of conduit overfill at SQN will be determined as a byproduct of this sampling program, the program itself is not i

clear in this respect as the memo does not specifically require the sampling program to include evaluation of overfilled raceways. No results of this program are available yet.

Regarding conduit supports, the evaluation team reviewed the

• cable weights used in the design of these supports (11/20/85, App. A, 5.xx) against a sample of verified cable weights (04/25/86, App. A, 5.yy). This review indicated that although in general the values used for the support design are larger that the verified weights for equivalent cross sectional areas, cases where identified in this random sampling where the opposite occurred (e.g., 3 WDP-1 cables used in a 3-inch conduit). Furthermore, the cable weight 4

used in the support design is based on a maximum conduit fill of 40%. Since no certainty exists that these fills have not been exceeded and no program addressing this aspect at SQN i was identified, the evaluation team could not confirm the adequacy of the supports.

b. Cable Damage The issue regarding cable damage from cable pulling practices

in overfilled conduits (e.g.

excessive cable tension and side wall pressure, improper use of fishtapes, pull-bys, 4

etc.) has been addressed by TVA in several investigations and reports. Although these investigations and reports are l primarily directed at cables in conduits, the evaluation team's assessment is equally applicable to cable damage in i

cable trays and wall and floor cable tray penetrations.

!7 00410(12/05/86) i I

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i TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 m

PAGE 11 0F 25

, TVA memo from Vineyard to Rankin (10/31/85, App. A, 5.w)

, requested investigation of a potential generic condition at Sequoyah described in WBN Nonconformance Report (NCR) No.

6347 R0 (09/27/85, App. A, 5.x). The NCR addresses a condition adverse to quality (CAQ) at Watts Bar Nuclear Plant in which several electrical conduits were installed with more than 360 degrees of accumulated bends between cable pull points. This condition does not meet the requirements of TVA.

Electrical Design Guide DG-E13.1.1 (App. A, 5.y), which states that a conduit run shall not contain more than the equivalent of four 90 degree bends (360 degrees total) between cable pull or termination points. The attached j Determination of Reportability Information Worksheet of 10CFR50.55(a) indicates that cables pulled through more than 360 degrees of conduit bends could result in sidewall '

pressure (SWP) exceeding that allowed by the cable manufacturer and by TVA General Construction Specification G-38. This could result in damage to the cable insulation.

TVA memo Wilson to Abercrombie (07/26/86, App. A, 5.z) s transmitted "SQN - Walkdown Results of Cable Sidewall

, Pressure Issues to Resolve Generic Watts Bar Nuclear Plant (WBN) NCRs 6270 [08/20/85, App. A, 5.aa] and 6347." The walkdown was performed under SQN Special Maintenance Instruction SMI-0-317-32 (06/20/86, App. A, 5.bb), to identify 16 worst case conduits with multiple bends exceeding 360 degrees between pulling points. A computer program using the data compiled during the field walkdown of these conduits was employed to determine the calculated pulling' tension and sidewall pressure, as required by General Construction Specification G-38. DNE Calculation SQN-E2-015 (07/24/86, App. A, 5.cc), indicated that the SWP for class lE cables was l

within the maximum allowable.

. Review of this calculation by the evaluator revealed that the selection for worst-case conduit runs does not comply with

> the criteria set forth in the field walkdown procedure I

SMI 317-32 :

{

o The walkdown procedure requires that selected conduits should have more than 360 degrees-between pull points, ---- -.. .--

but 15 of the 16 conduits selected have cumulative bends of less than 360 degrees l Q 00410 (12/05/86)

-- - . . = , _ , . - . , - . - . , , - . , . - - , - , . . - - - - . . -- - . - -

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1(B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 12 0F 25 o The procedure requires that the selected conduit should have a percentage fill greater than 30 percent, but 9 conduits were filled to less than 28 percent o The procedure requires long conduit lengths between pull points, but 9 conduits had distances of>less than 25 feet

o Pulling calculati;ns were based upon only one direction of pulling. This does not cover the possibility for construction to pull the cables in the opposite direction. ,

j However, during the 10/08/86 meeting ( App. A, 7.b), TVA i indicated that it has recognized this deficiency and a new 4

independent review of sidewall pressure for worst case 11/15/86. This conduit is in agreement runs is with scheduled to be completed TVA's interim response by(10/31/86, App. A, 5.zz) to Questions 2, 3, 4, 5, with regard to the identification of worst case pulls in conduits, as part of

) the sixteen questions raised by the NRC (08/30/86, App. A, 5.pp). The revised calculation was not completed at the time 3 of the review by the evaluation team.

TVA memo Cantrell to Mason (12/02/85, App. A, 5.t) transmitted a report on " Evaluation of the Adequacy of Installed Class IE Cable." This report evaluated 4

operational, maintenance, and surveillance test data on cables from TVA's operating plants and available data from other outside sources, such as the Electrical Power Research Institute (EPRI) and Institute of Nuclear Power Operations (INP0). The collected data were reviewed to ascertain any-significant degradation of cable insulation properties in 2 installed class lE cables. The conclusions in the report i regarding adequacy of installed class lE cables were based on the following:

l o The initial results of representative electrical tests

! conducted at different plants (including Sequoyah) during construction, and subsequent periodic bridge, megger, and/or high potential tests on cables for 100 hp and larger motors. The insulation resistance data recorded in the tests varied over a range of acceptable values and revealed no evidence of a trend toward cable insulation

degradation. This is in agreement with TVA's interim i response (10/31/86, App. A, 5.zz) to Question 12 (in-situ testing of cables on a routine basis) of the sixteen

questions raised by the NRC (08/30/86, App. A, 5.pp).

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M TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM j REVISION NUMBER: 1 m

1. PAGE 13 0F 25

!- l o Information on' identified cable failures at several

. plants, including SQN. The report indicated that of the approximately 62,000 cables installed at SQN, available

records show that only 16 cables failed.. Six failures were identified during construction-by high potential tests and are not attributed to cable pulling practices 1

' (three cables were accidently stapled while in storage and for the other three the failure was attributed to improper termination and not to cable failure). For the remainingtencables,whichfailedduringoperation(only i

three of them are safety-related), no records are available to indicate cause of failure. However, these

failures constitute a very small percent-of the total installed cables (0.016 percent) and are considered to be

[ random since.they occurred over 5 years of operation.  ;

1 ~

l o Periodic surveillance (as required in the Technical Specifications, Sections 3.0 and 4.0 [ App. A, 5.u and '

5.v]) to verify operability of all safety systems required for startup, operation, and safe shutdown of the

. , plant. The report concludes that ongoing surveillance is adequate verification of the integrity of installed class i

lE cables .

l The report concluded that for future installations, TVA has

! established adequate cable installation requirements in General Construction Specifications G-38 (App. A, 5.r) and G-40 ( App. A, 5. s) . The report indicated that "following the procedures in these specifications ~during cable installation ~ ~ - - -

and subsequent appropriate maintenance will ensure that the

- cables will function properly throughout their design life",

i which is consonant with proper cable installation practices. .

Also, TVA's interim response (10/31/86, App. A, 5.zz) to I j Question 13 regarding testing or monitoring programs for e

cables suspected of having been abused, indicated that an extensive trend analysis program will be implemented in i

November 1986. This program will track, consolidate and categorize conditions adverse to quality and, therefore, will F i readily identify any adverse trends associated with cabling at any TVA nuclear plant.

] SCR SQNEEB8529 R0 (12/06/85, App. A, 5.a) was issued for SQN as a result of WBN Problem Identification Report (PIR) No. ,

l WBNEEB8546. The PIR identified WBN conduits containing 400 '

i Kcmil cables that exceeded the conduit fill as specified in Electrical Design Standard DS-E13.1.4. The SCR described a similar situation at SQN for 55 conduits containing 400 Kcmil 1

600 V cables in which the percentage fill exceeded the limits  ;

allowed in the standard.

l 00410 (12/05/86)

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.TVA. EMPLOYEE. CONCERNS m REPORT NUMBER:-238.1 -(B)- - -

SPECIAL PROGRAM x REVISION NUMBER: 1 PAGE 14 0F 25 Engineering Report CAQ No. SCR SQNEEB8529 R0 (12/27/85, App.

A, 5.1) indicated that these conduit. overfills resulted from the failure of design engineering to size the conduits in accordance with the total CSA of the cables routed in these conduits as required per DS-E13.1.4. The report concluded that the cables may be used as they are, because visual inspection and continuity /megger test were performed af ter installation to demonstrate the cable integrity, and passed QA inspection in accordance with SNP Inspection Instruction Nos.10 and 28 (06/13/77 and 04/04/83, App. A, 5.d and 5.h).

Although specific records for these cables were not reviewed, the evaluation team verified (10/13/86 through 10/24/86, App.

A, 7.d) that continuity and megger tests, and inspection after installation is performed on all cables and records for this exist and are available at the SQN site. Also, the SCR indicates that credit is given to the fact that the cables have operated for-a considerable length of time without failure.

Attachment 1 to NSRS Report No. I-86-251-SQN (02/18/86, App. A, 5.f) concluded that NSRS Report No. I-85-06-WBN (dates of investigation 02/29/85to04/15/85)(App.A, 5.ccc) is generic to SQN. The NSRS Report No. I-85-06-WBN identified a finding regarding maximum pulling tension or sidewall pressure during installation that was referenced in a TVA memo from Drotleff to Sieberling (06/09/86, App. A, 5.dd). This memo supplements' the Pierce to Whitt memorandum (07/08/85, App. A, 5.ee) in response to NSRS Finding No.

I-85-06-W8N-02. The finding indicates that the TVA cable pull procedure did not include SWP calculations or define the method for calculating maximum pull tension (MPT) on multicable pulls. The Drotleff to Sieberling memo, along with the Raughley to Kirkebo memo (06/11/86, App. A, 5.ff) indicated that:

o An evaluation program initiated in August 1985 evaluated the class IE cables already installed in conduits and established the impact of including SWP in the cable pull tension limitation. Review of the estimated SWP to which the cables were subjected against revised SWP limits provided by manuf acturers and by the EPRI Report No.

EL-3333 indicated that none of the installed cables exceeded the allowable SWP (revised limits were about 4-5 times the p(revious to Raulson limits).

10/14/86, Also, App. A, 5.ww)a memo statesfthat romgood Raughley

, construction practices were followed for cable pull-bys d in conduits. This is in agreement with TVA's interim response (10/31/86, App. A, 5.zz) to Question 6 of the sixteen questions raised by the NRC (08/30/86, App. A, 5.pp). Question 6 is with regard to considering pull-bys 00410 (12/05/86) m

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1(8)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 15 0F 25 in the determination of worst case cable pulling situations. The response indicates that good construction practices were used, construction employees knew their business, properly sized manila break ropes were provided, and ample amounts of cable lubricants were used. Review of cable installation records by the evaluation team (10/13/86 to 10/24/86, App. A, 7.d) indicated that QC certified cable pulling records are available for Class 1E cables. However, with very few exceptions, pull tensions, pull rope sizes, and dynamometer readings are not available when mechanical cable pulls were performed, although SQN procedures required their recording. This is confirmed in conversations with SQN QC inspectors (10/13/86 to 10/24/86, App. A, 7.d), who indicated that although pull tensions were monitored, they were not recorded. The use

~

of mechanical devic'es for cable bulling is 'a1so discussed in Construction Report No. C010900-SON (09/22/86, App. A, 5.11)..

o TVA Central Laboratories performed extensive tests on 21 WBN sample cables in addition to representative sample cables from SQN. These samples include different cable types (power, control, signal and instrumentation, and coaxial), types of insulation, Jacket materials, and manufacturers. These cables were pulled through the conduit with tension forces 2 to 12 times the values recommended in G-38. The cables were subjected to pulling tension values near the ultimate copper conductor breaking strength of the cable. Each cable was then inspected, dimensioned, stripped to examine individual conductors of multiconductor cable, and subjected to dielectric breakdown tests. When compared to virgin cable of the same sample, the average breakdown value of the tested cables was within 20% of the average dielectric breakdown value of the virgin cable sample, thus meeting the acceptance criteria set for the test per ASTM D 149. Furthermore, none of the cables revealed any significant degradation of insulation. Based on this test, memo Raughley to Kirkebo (06/11/86, App. A, 5.ff) concluded that higher allowable limits are justified for all cables purchased by TVA.

m 0041D (12/05/86)

.TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 m

j PAGE 16 0F 25 Based on the above, the evaluation team's assessment of cable damage is as follows:

o Continuity and megger/high potential tests are conducted at SQN for all newly installed cables per Inspection Instruction Nos. 10 and 28. Also, bridge and megger/high potential tests are periodically conducted on circuits for 100 hp and larger motors. Although performance'of these tests does not provide full assurance that damaged cables will be detected unless major damage has occurred,

, they are widely used as a supplement to good construction 1

practices as they provide a reasonable assurance that cables are functional.

, o Although SQN has been operational for over 5 years only l' 16 cable failures out of approximately 62,000 installed.

cables have been identified. Out of the 16 cables, six failures, were identified during construction, none of which was attributed to cable pulling practices. The remaining ten cables represent too small of a percentage l of the total installed cables to suspect a generalized

'_j cable damage problem. Furthermore, the evaluation team

] reviewed the trend analysis printout of the Engineering l j

Design Condition Adverse to Quality Database for " Cable" (App. A, 7.e) and determined that none of the reported problems could be attributed to inadequate cable 4

installation practices, j o Although DNE Calculation SQN-E2-015 Rev. O did not

! consider the worst-case conduit runs for calculating the maximum allowable SWP, a revision to this calculation is under way. TVA indicated that revision 1 to this calculation will also take into consideration cable i

pull-bys. Furthermore, tests performed at TVA Central

Laboratories demonstrated that the limiting factor in i

cable pulling is the breaking strength of the conductor.

i The tests also demonstrated that cables can withstand I considerably larger tension forces than reconrnended in

, G-38. These results suggest that the likelihood of the

! cables being subjected to excessive pulling forces i

(without the conductor breaking) is very small. However, revision 1 of Calculation SQN-E2-OlS, considering cable ~ ~~

pulls in overfilled conduits and pull-bys, is required to document that SWP has not been exceeded, i

The ultimate function of electrical cables is to transmit o

the necessary power or signals to operate or actuate l

! electrical equipment and components. In view of this, i

00410 (12/05/86) -

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM n REVISION NUMBER: 1 PAGE 17 0F 25 the periodic surveillance per Technical Specification requirements to verify operability of all safety systems is an adequate way to verify cable functionality, o The extensive trend analysis program scheduled for--- --- -

implementation in November 1986, if properly implemented, should become an adequate tool to anticipate any negative trends associated with cable failures. However, no details on this program have been identified to evaluate its adequacy. .

c. A Generic Concern Task Force (GCTF) Report regarding Employee Concern No. WI-85-100-Oll (05/16/86, App. A, S.q) was generated for SQN to address applicability of the NEC Standards to Sequoyah construction practices and tray overfills. This report concluded that, based on the National Electrical Code, Article 90, Section 2(b), paragraph 5, the electrical utility portion of TVA/SQN is excluded from the requirements of this code. These requirements concerning

^ maximum allowable fill of cables in conduit and cable pulling practices are covered in the SNP FSAR; Design Criteria SQN-DC-V-ll.3; General Construction Specification G-38; and Electrical Design Standard DS-E13.1.4. Since power plants are not subject to following the NEC requirements, the evaluator concurs with the conclusion of the GCTF report.

d. Overfill in cable trays and cable tray penetrations is discussed in Element Report 238.3.

Findings:

a. The evaluation revealed that accurate conduit fill l information is not readily available and, therefore, compliance with FSAR commitment for conduit fill is not verifiable 'brough QA documentation. Furthermore, SQN design engineers used cable weight data from a TVA Design Standard that were tak- from non-QA sources. These uncertainties regarding conduit fill and cable weight raise the question about the adequacy of cable ampacities and conduit supports.

As previously indicated, a memo from Raughley (10/07/86, App.

A, S.tt) initiated a program to address the cable ampacity issue. However, this memo is not specific with regard to evaluation of overfilled raceways. No program that addresses the conduit support adequacy was identified.

- b. Although the adequacy of past cable pulling procedures could not be fully verified because of incomplete records and QA documentation, a reasonable assurance exists that no trend of l 00410 (12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 3

PAGE 18 0F 25 cable failures as a rescit of cable damage due to pulling should be expected. Any failures that might occur should be considered random failures. Also, completion of DNE Calculation SQN-E2-015, Rev.1, including consideration of cable pulls in overfilled conduits and pull-bys, should further support this assessment, and implementation of the new trend analysis program should adequately anticipate negative trends with regard to cable failures. However, revision 1 of the calculation and the trend program were not available at the time of the review.

c. The NEC does not require utilities (TVA) to comply with the requirements of the code. Therefore, TVA is not obliged to follow NEC for conduit fills and cable pulling practices.

Conclusions:

a. Current uncertainties regarding compliance with FSAR commitment regarding conduit fills, adequacy of cable ampacities and conduit supports are the direct result of incomplete records for actual conduit fills. Existing program regarding cable ampacities is not specific with regard to overfilled raceways. No program has been identified to address the adequacy of conduit supports.

Therefore, concerns regarding conduit overfills are valid.

However, new procedure SQEP-06 as well as other programs, discussed in detail in Sequoyah Element Report 239.0 and 240.0, if properly implemented and followed, should prevent recurrence of a~similar~ problem in the future. ~~ ~~~ ~ ~ - -

b. Although the adequacy of past cable pulling procedures could not be verified, the concern regarding cable damage could not be validated as no evidence of cable failures resulting from cable damage could be found. Furthermore, completion of the revision to the DNE calculation and implementation of the new trend analysis program should provide further assurance regarding adequacy of cable installations.

c. Concerns regarding compliance with NEC are not valid as TVA is not obliged to follow NEC for conduit fills and cable pulling practices.

0041D(12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM

, REVISION NUMBER: 1 L

PAGE 19 0F 25 APPENDIX A

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

a. Significant Condition Report (SCR) No. SQNEE88529 R0, (843 851220 904), " Conduits Containing 400 MCM Cables That l Exceeded the Conduit Fill as Specified in DS-E13.1.2 and DS-E13.1.4,"(12/06/85) b., Electrical Design Standard, DS-E13.1.4, R1 " Conduit - Maximum Cable Diameter for Various Rigid Steel Conduits," (08/24/83)

c. SQN Modifications and Additions Instructions M&Al-4, R8,

" Control, Power and Signal Cables," (12/31/85)

d. SNP Inspection Instruction No. 28, " Cable Pulling Inspection, R0," (06/13/77)

e. National Electric Code, NFPA-70-1984

f. TVA, NSRS, Review of Generic Concern Issue, SQN, " Attachment I to: NSRS Report No. I-86-251-SQN,"

Subject:

" Electrical Cables,"(02/18/86)

g. SQN Modifications and Additions Instruction M&AI-7, " Cable Terminations, Splicing and Repairing of Damaged Cables,"

Rev. 8, Section 5.0, " Inspection Criteria of Cables or Internal Panel Wiring," (07/24/86)

h. SNP Inspection Instruction No.10, Sections 7 and 8, paragraphs 7.B.1, 7.8.2, 8.0, and 8.E " Interconnecting Cable Termination and Insulation Inspection, Rev. 16," (04/04/83)

1. SNP FSAR, Section 8.3.1.4.1, Amendment 1, " Cable Derating and Cable Tray Fill"

j. Design Criteria SQN-DC-V-11.3, " Power, Control and Signal Cables For Use in Category 1 Structures," Section 6.1.2,

" Conduit Loading, Rev. 5," (09/30/86)

k. TVA, DNE, Sequoyah Engineering Procedure - SQEP-06 Rev. O,

" Cable and Conduit Procedure for Sequoyah Nuclear Plant,"

(09/22/86)

1. Engineering Report CAQ SCR SONEE88529 R0, (S01860114 928),

,, "W8N Conduits Containing 400 MCM Cables That Exceeded the Conduit Fill as Specified in DS-E13.1.2 and DS-E13.1.4,"(12/27/85) 0041D(12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM g., REVISION NUMBER: 1 PAGE 20 0F 25 APPENDIX A (cont'd)

m. TVA, SQN, Generic Concern Task Force Report, " Overfill of Cable Trays and Conduits, R1," (26 concerns), (05/20/86)

n. TVA memo Chitwood to Raulson/ Vineyard, (843 860203 902),

"Significant Condition Report (SCR) No. SQNEE88529 R0,"

(01/31/86)

o. SCR No. SQNEE88601 R0, (843 860117 919), (01/06/86)

p. TVA memo Wilson to Brimer, "Sequoyah Nuclear Plant Units 1 and 2 - Engineering Report for CAQ Report No. SCR SQNEE8 8601 R0, Rev.1," (825 860416 007), (04/16/86)

q. TVA, SQN, GCTF Report, " Cable Tray Fill Criteria, R1,"

(1 concern), (05/16/86)

r. General Construction Specification No. G-38, Rev. 6,

^ " Installing Insulated Cables Rated Up to 15,000 Volts,"

(09/15/85); Rev. 8, (03/17/86)

s. General Construction Specification No. G-40, Rev. 8,

" Installing Electrical Conduit Systems and Conduit Boxes,"

(10/10/85); Rev. 9, (12/19/85)

t. TVA memo Cantrell to Mason, " Evaluation of the Adequacy of Installed Class 1E Cables," (843 851203 915), (12/02/85)

u. SQN Technical Specification, Surveillance Requirements, Section 3.0, (09/17/80)

v. SQN Technical Specification, Surveillance Requirements, Section 4.0,(09/17/80)

w. TVA memo Vineyard to Rankin, "Sequoyah Nuclear Plant Units 1 and 2 - Potential Generic Condition Evaluation,"

(825 851031 008), (10/31/85)

x. WBN NCR No. 6347 R0, " Excessive Conduit Bends," (09/27/85)

y. Electrical Design Guide, DG-E13.1.1, Revision 1, " Conduit -

Cable Pull-Point Locations and Support Locations," (02/09/81)

z. TVA memo Wilson to Abercrombie, "Sequoyah Nuclear Plant -

~

Walkdown Results of Cable Sidewall Pressure Issues to Resolve Generic Watts Bar Nuclear Plant (W8N) NCRs 6270 and 6347,"

(825860726001),(07/26/86) 00410 (12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1(8)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 21 0F 25 APPENDIX A (cont'd) aa. WBN NCR No. 6270 R0, " Cable Sidewall Pressure Calculation,"

(08/20/85) bb. Special Maintenance Instruction SMI-0-317-32, Rev. O, "Walkdown Procedure for Identifying Sidewall Pressure Violations in Conduits with Multiple Bends in The Auxiliary Building Units 1 and 2," (06/20/86) cc. DNE Calculation, SQN-E2-015, Rev. O, " Identifying Sidewall Pressure Violations," (825 860724 801), (07/24/86) dd. TVA memo Drotleff to Sieberling, " Watts Bar Nuclear Plant (WBN) - Investigation of An Employee Concern Regarding Cable Routing, Installation, and Inspection - Nuclear Safety Review Staff Report No. I-85-06-WBN," [ Response to six findings],

(843 860609 927), (06/09/86) ce. TVA memo Pierce to Whitt, " Watts Bar Nuclear Plant - Nuclear Safety Review Staff Investigation of an Employee Concern Regarding Cable Routing, Installation, and Inspection Practices - NSRS Report No. I-85-06-WBN " [ Response to finding I-85-06-WBN-02), (F01850708 604), (07/08/85) ff. TVA memo Raughley to Kirkebo, " Cable Sidewall Bearing Pressure (SWP)," (843 860611 912), (06/11/86) gg. Electrical Design Standard OS-E12.1.13, Rev. 2, " Cable -

Class 1E Cable 00s and Weights," (04/15/86) hh. Engineering Related Employee Concern - Special Program,

" Potential Problems Requiring Corrective Action Before Restart," (5 concerns), (09/19/86)

11. Electrical Design Standard OS-E12.1.14, Rev. O, " Cable -

Class NC Cable 00s and Weights," (04/15/86) jj.

TVA memo McCloud to Those Listed, " Cable Pulling Practices at' -

Satuoyah Nuclear Plant (SQN)," (L33 861020 800), (10/20/86) kk. TVA memo Denise to Abercrombie, Sequoyah Nuclear Plant (SQN)

Generic Concern Task Force (GCTF) Report "IEE Standards Not Included in Electrical Procedures," Employee Concern IN-86-259-X11, (T25 860604 984), (06/04/86)

O

11. TVA Employee Concerns, Special Program - Report No.

C010900-SQN Rev.1, " Cable," (09/22/86) 00410 (12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 22 0F 25 APPENDIXA(cont'dl mm. TVA memo Chandler to Those Listed, " Potential Generic Condition Evaluation," (843 851025 913), -(10/18/85), and attached-- - - - -- -

NCR 6347 R0, " Excessive Conduit Bends," (09/27/85) nn. TVA, SQN, GCTF Report, "0vertensioning and Minimum Bend Radius Violations of Cables Due to Improper Cable Installation Methods, R1," (26 concerns), (05/28/86) oo. TVA memo Gridley to Drotleff, "NRC Request for Information Concerning Cable Pulling and Cable Bending Radii at Watts Bar (WBN) and Sequoyah (SQN) Nuclear Plants," (L44 860808 803),

(08/08/86) pp. Letter from Youngblood, NRC, to White, TVA, " Request for Information Concerning Cable Pulling and Cable Bending Radii at Sequoyah," (08/30/86) qq. TVA memo Paughley to Raulston, " Watts Bar Nuclear Plant Units 1

. and 2 - Non-QA Values for Cable Weights and Outside Diameters Used in Calculations - NCR WBNEEB8589 and WBNEEB8590 - ,

10CFR50.55(e) Final Report," (B43 860926 907), (09/24/86) rr. TVA memo Gridley to Drotleff, "NRC Request for Information Concerning Cable Pulling and Cable Bending Radii at Watts Bar (WBN) and Sequoyah (SQN) Nuclear Plants," - Attachment of NRC letter from Youngblood to White (08/04/86), (L44 860808 803),

(08/08/86) ss. TVA memo from Raughley to Roberts, "Sequoyah Nuclear Plant -

Cable Weights and Outside Diameters (00)," Attachment of TVA memo Scruggs to Raughley (09/04/86), (843 860923 908),

(09/23/86) tt. TVA memo Raughley to Those Listed, "All Nuclear Plants -

Corrective Action and Sampling Program for Electrical Cable Ampacity," (843 861008 909), (10/07/86) uu. TVA, SQN, Employee Concern Task Group Operations, Report No.

304.01, Revision 1, Subcategory: " Cable and Conduit,"

Element: " Procedure Problems," (10/21/86) vv. Letter from B. J. Youngblood, NRC, to S. A. White, TVA, (06/23/86) with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First

.-- Tennessee Bank Building in Knoxville, TN i

0041D (12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1(8)

SPECIAL PROGRAM g REVISION NUMBER: 1 5:e PAGE 23 0F 25 APPENDIX A (cont'd) ww. TVA memo from Raughley to Raulston, "Sequoyah Nuclear Plant Cable Issues - NCR Response," (843 861014 901), (10/14/86) xx. Design Criteria SQN-DC-V-13.10, " Design Criteria For Seismically Qualifying Conduit Supports," R2 (11/20/85) yy. OE Calculation " Class 1E and Non-Class 1E Electrical Cable Weight / Foot and Outside Diameter," R0, (826 860425137),

(04/25/86) zz. Letter from Gridley, TVA, to Youngblood, NRC, (L44 861031 811) "In the Matter of the Tennessee Valley Authority Docket Nos. 50-327 and 50-328 - Sequoyah Nuclear Plant (SQN) - Cable Pulling Questions," (10/31/86) aaa. Quality Assurance Evaluation Report - Sequoyah Nuclear Plant Cable Routing System, (10/28/86) bbb. TVA memo Harding to Wilson, "Sequoyah Nuclear Plant (SQN) -

Cable Pulling Questions," (SIO 860904859),(09/04/86) ccc. NSRS Report No. I-85-06-W8N, " Investigation of an Employee Concern Regarding Cable Routing, Installation, and Inspection at Watts Bar Nuclear Plant," (Q01850709 051), dates of ~ ~ ~ ~ ~~~

investigation 02/29/85 to 04/15/85

6. WHAT REGULATIONS, LICENSING C0PMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?

a. FSAR Section 8.3.1.4.1, " Cable Derating and Cable Tray Fill"

b. General Construction Specifications G-38, " Installing Insulated Cables Rated Up to 15,000 Volts," and G-40,

" Installing Electrical Conduit Systems and Conduit Boxes"

c. Design Criteria, SQN-DC-V-11.3, " Power, Control and Signal Cables For Use in Category 1 Structures"

d. Electrical Design Standard, DS-E13.1.4 R1, " Maximum Cable Diameter for Various Rigid Steel Conduits"

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.

a. Telecon between J. Wheeler, Bechtel, and Paul Craghead, TVA, regarding SQN Cable and Raceway Schedule, (09/09/86) 00410(12/05/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1(B)

SPECIAL PROGRAM

., REVISION NUMBER: 1 PAGE 24 0F 25 APPENDIX A (cont'd)

b. Raughley, McNutt, Nesbitt, Skinner, TVA, Shea, Stone & Webster, Jordan, Don-Doncow, Wheeler, Rif ai, Bechtel, meeting at Knoxville (10/08/86).

c. Liakonis, Nesbitt, Neely, TVA, Don-Doncow, Bechtel, meeting inKnoxville(10/09/86).

d. Review of cable installation records (e.g., pull slips, cable tests) and personnel interview (including electricians and former QC inspectors) at SQN by D. Knudsen, Bechtel, between 10/13/86 and 10/24/86.

e. Review of the Engineering Design Condition Adverse to Quality (CAQ) Database, search for " Cable" as of 10/31/86 by M.

Ibanez, Bechtel, (10/31/86) 77, 00410(12/05/86)

L

TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1(B)

SPECIAL PROGRAM 1

e,;. REVISION NUMBER: 1 PAGE 25 0F 25

. CATD LIST j The following CATD forms are included as part of this report:

238.01(B) SQN 01 (Revised 12/05/86) 238.01(B) SQN 02 Revised 12/05/86)  :

238.01(B) SQN 03 Revised 12/05/86)

- 238.01(B) SQN 04 Issued 12/05/86) i 1

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INITIATION

1. Immediate Corrective Action Required: 5 Yes 2.

O No Stop Wort. Recommended: O Yes a No

3. CATD No. 338.01 - i Ott - 01 b 5.

4 INITIATION DATE (2 RESPONSIBLE ORGANIZATION: St% E 6.

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8. CONCURRENCE: CEG-H 9.

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APPROVAL: ECTG PROGRAM MGR. O DATE:

CORRECTIVE ACTION

10. PROPOSED CORRECTIVE ACTION PLAN:

11. O ATTACHMENTS PROPOSED BY: DIRECTOR /MGR: DATE:

12. CONCURRENCE: CEG-H: DATE:

SRP: DATE:

ECTG PROGRAM MGR: DATE:

VERIFICATION AND CLOSEOUT D ~' 13.

Approved implemented.

corrective actions have been verified as satisfactorily SIGNATURE TITLE DATE

a ECTG C.3

,m Attachment A U.

Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)

1. Immediate Corrective Action Required: a Yes O No

2. Stop Wort. Re O Yes a No

3. CATD No. 23 hommended:.01 - 6 & r44 - 0 2, 5.

INITIATION DATE 12 80 RESPONSIBLE ORGANIZATION: M G. '

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VERIFICATION AND CLOSEOUT im 13.

Approved corrective actions have been verified as satisfactorily implemented.

SIGNATURE TITLE DATE

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r. ECTG C.3 Attachment A Page 1 ef 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)

INITIATION

1. Immediate Corrective Action Required: E Yes O No

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3. CATD No. 7.~38. 01 - G QM-0 3 4

5. INITIATION DATE l'2 /f f d$

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13. Approved corrective actions have been verified as satisfactorily implemented.

SIGNATURE TITLE DATE

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i ECTG C.3 1 Attachment A Page 1 of 1 i Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)

INITIATION

1. Immediate Corrective Action Required: E Yes O No

2. Stop Wort Recommended: Yes E No

3. CATD No. 238.ol- SQd O 04 i

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4 INITIATION DATE l2 I E 85 RESPONSIBLE ORGANIZATION: _ if4E:. '

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ECTG PROGRAM MGR: DATE:

UERIFICATION AND CLOSEOUT P

l' 13. Approved corrective actions have been verified as satisfactorily implemented.

i SIGNATURE TITLE DATE

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