ML20207K686
| ML20207K686 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/07/1986 |
| From: | Mcnutt G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K654 | List: |
| References | |
| 238.3(B), 238.3(B)-R, 238.3(B)-R00, NUDOCS 8701090487 | |
| Download: ML20207K686 (40) | |
Text
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s TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM
~~
( REPORT TYPE: SEQUOYAH ELEMENT TITLE: RACEWAY OVERFILLS AND CABLE PULLING Cable Tray Overfills and Wall and Floor Penetrations PAGE 1 0F 30 REASON FOR REVISION:
PREPARATION PREPARED BY:
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' l2 QQ SIGNATURE '
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SIGNATURE DATE CONCURRENCES CEG-H: Ef A bh%k / 2-7-50 SRP:
SIGNATURE DATE SIGNATURE DATE l APPROVED BY:
C.
ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) 8701090487 861224 PDR ADOCK 05000327 P PDR l _ -
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 m
PAGE 2 0F 30
- 1. QLARACTERIZATION OF ISSUES:
Concerns: Issues:
0W-85-007-002 a. Cable trays are overfilled.
" Electrical cable in trays runs completely outside of the trays, b. Cable tray fill criteria for cables especially in bends. Many cable violate the National Electrical trays are grossly over capacity. Code and industry practice.
i These conditions work against the cable trays' purpose of c. Trays do not provide support (cables supporting and protecting the hang loose) and protection to cables cable." running outside of them as a result of overfill. Tray covers cannot be IN-85-186-003 installed as a result of overfill.
" Cable trays are over full in the spreading room, Elev. 729 in d. Plant procedures contain no requirement both units. Other cable trays prohibiting overfilling of cable trays.
in other areas may have the More cables are being added to over-same problem." filled trays.
WI-85-100-Oli e. Cable tray penetrations are over-
" Cable tray fill criteria of filled. More cables are pulled 60% for I&C cables is inadequate. through already overfilled pene-The National Electrical Code trations. Possible cable damage allows 40% and 50% fill on an may result from cable pulling exception basis. TVA violates through overfilled penetrations this code. This industry (addressed in Sequoyah Element practice is 40% fill. This Report 238.1).
situation is made even worse with the addition of spray-on f. Overfilled tray penetrations may fire retardant materials which not be qualified as a pressure take up space in trays." boundary as it is almost impos-sible to apply the RTV silicone IN-85-798-004 foam.
" Cable tray in Aux. Bldg, El.
713 located at the T4 and R line g. Damaged cables would not be dis-
- is too full. 5-6 cables are covered until they short out l hanging loose, but the tray is (addressed in Sequoyah Element
! being loaded with more cables." Report 238.1).
IN-86-238-003 "Many cable trays, Unit 1 and 2,- - - - - - - - - -
are too full of cables."
(
l y
04150 (12/05/86) l
s TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM
/I - REVISION NUMBER: 0 PAGE 3 0F 30 concerns (continued):
85 IN-86-232-002 IN-B(-856-003 "Due to overfilling of cable " Conduit and cable trays are too trays with cable, the penetration full."
seals may not be able to pass a pressure test. The RTV -
-PH-85-003-023- -~ - - - -- -
Silicone seal foam was almost "The cable trays are overfilled (in many instances) impossible plant wide."
to apply due to the number of cables in the penetration." IN-86-028-002
" National Electrical standards IN-85-688-N05 are not being followed. Example
" Inspector on Unit 1 reported cable trays and conduits are to CI one instance of cable overfull."
tray overfilling."
IN-85-312-001 IN-85-919-001 " Cable trays in (SIC) conduits
" Electrical cable tray penetra- are overfilled with cable. The tions are full and cable is cables could be damaged and not still being pulled through discovered until it shorts out."
these penetrations located in the control b1dg." "
Concerned IN-85-734-001 about possible damage to cables " Conduits / cable trays /penetra-in these penetrations resulting tions in Units 1 and 2 are from the cable pulls." generically overfilled /over-loaded."
IN-85-432-002 "Over-filled cable trays, trays IN-86-262-001 filled to the maximum, covers " Units 1 and 2. The conduits can not be installed." and cable trays are too full.
It of ten takes 4-5 days just to IN-85-688-001 pull the fish tape through.
" Plant procedures contain no This overcrowding is an un-requirement prohibiting over- safe condition."
fill of cable trays in safety related installation. Instances IN-85-832-001 where safety related overfills " Overloaded cable tray penetra-have occurred were not provided." tion El 729' Turbine Bldg. &
Control Bldg. El. 737' Aux.
Bldg. and Control Bldg. 741.
Conduits being filled beyond National Elec. Code allowance.
Possible damage to cables that other cables are being dragged over."
m, 04150 (12/05/86)
L
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 4 0F 30 Concerns (continued):
IN-85-207-001 IN-85-519-001 "Enginaering is routing / schedule- " Cable trays overloaded, Aux.
ing cables to be pulled through Bldg. Units 1 & 2, 713' and
" closed" penetrations, due to 737' Elev."
the amount of cable fill, the cable jackets and conductors WI-85-100-015 are damaged during cable tray Cable trays are too heavily through penetration in Aux- filled, and the cables are iliary building Elev. 737'. not properly derated. CI Q line and A3 also, penetra- has no further information.
tion Q-CTP-290-62, approx. Anonymous concern via letter."
location N line and C-10 elev. 729' in Control Bldg.
was full, yet additional cable was routed and pulled through during August 1985.
Construction Department concern. CI has no more information."
2.
HAVEISSUE(S)BEENIDENTIFIEDINANOTHERSYSTEMATICANALYSIS?YES_
Documentation Identifiers:
o Identified by TVA SON SCR Date 06/27/86 _ _ _ _ _ , _ _
i l
SCR - SQNECB8601 R0 (842 860707 014), Cable Tray Fill Design Criteria Exceeded I
l Date 03/21/86 i
SCR - SQNEEB8620 R1 (843 860410 910), Cable Tray Loading i
o Identified by TVA SON SCR Date 01/06/86 SCR - SQNEEB8601 R0 (843 860117 919), Cable Weights and Outside Diameters Not Available From a OA Source 04150 (12/05/86) l __
.t TVA EMPLOYEE -CONCERNS -----
- - - REPORT NUMBER: -238.3(B)---
SPECIAL PROGRAM
, a? REVISION NUMBER: 0 b"
PAGE 5 0F 30 o Identified by TVA SON GCTF Date 05/20/86 TVA, SQN, GCTF Report, Overfill of Cable Travs and Conduits.
R1 o Identified by TVA SON NSRS Date 02/18/86 NSRS Report No. I-86-251-SQN, Attachment 1, Review of Generic Concern Issue. Electrical Cables o Identified by TVA SON GCTF Date 04/25/86 i
TVA, SQN, GCTF Report, Plant Procedures on Overfill of Cable Trays R1 e o Identified by TVA SON GCTF Date 02/09/86 TVA, SQN, GCTF Report, Overfill of Cable Trays o Identified by TVA SON GCTF Date 05/16/86 TVA, SQN, GCTF Report, Cable Tray Fill Criteria. R1 o Identified by TVA SON NCR l
Date 04/11/85 SQN Nonconformance Report NCR SQNECB8501 (842 850412 004),
Verification of Computer Cable and Raceway Programs and Data o Identified by TVA SON ECTG Date 10/21/86 TVA, SQN ECTG Report, No. 304.02, Cable and Conduit.
- Electrical Penetration Breached, R1 l
r l 04150 (12/05/86) m - + -. e--- - - - - - - - , ,--q
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0
<;. i "1
PAGE 6 0F 30 o Identified by TVA SON SCR Date 03/10/86 SQN Significant Condition Report (SCR) No. SQNCE88602 R1, (B25860925 004), Cable Trav Supports.
o Identified by TVA SON ECSP Date 09/19/86 TVA, SQN ECSP Report No. C01900-SON, Cable, R1
- 3. DOCUMENT NOS.. TAG NOS.. LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT No further information is available. The employee concerns are general in nature and address overall generic problems of overfilled trays and tray penetrations, and-possible cable damage----- - - - - - -
during installation.
- 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-85-919 IN-86-262 IN-85-186 IN-85-432 IN-85-832 WI-85-100 IN-85-856 IN-85-207 IN-85-798 PH-85-003 IN-85-519 IN-86-238 IN-86-028 IN-86-232 IN-85-312 IN-85-68a IN-85-734
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
h
) p
- 0415D (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM
( REVISION NUMBER: 0 PAGE 7 0F 30 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,
- b. Reviewed FSAR and existing applicable TVA Design Standards for commitments and requirements regarding tray fill.
- c. Reviewed cable routing and raceway fill tracking procedures
,- for adequacy.
- d. Reviewed Construction Specification G-38 and Modifications and Additions Instructions - M&AI-4, -7, -13, and for cable installation practices and procedures, and for inspection instructions.
- e. Reviewed existing TVA reports (e.g. , GCA-01-46 and GCA-03-48) to assess extent to which existing reports and corrective actions satisfy the concerns.
- f. Reviewed existing TVA Construction (e.g., C010900-SQN),
QA/QC, Operations, and Material Control reports for the Employee Concern Evaluation Program for applicability to the concerns discussed in this report.
- g. Performed walkdowns for the visual assessment of cable tray and cable tray penetration fills, i
- h. Assessed overall adequacy of SQN cable installation practices and identified areas that may require further investigation and corrective action. . . _ _ _ _____
04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(8)
SPECIAL PROGRAM REVISION NUMBER: 0 i,
PAGE 8 0F 30
- 9. DISCUSSION. FINDINGS. AND CONCLUSIONS:
Discussion:
Overfill of cable trays can increase the loads on tray supports and increase the cable insulation temperature where power density is high (e.g., power trays). Where trays are . overloaded, assurance --- -- - -----
must be provided that design limits for supports and cable insulation are not exceeded,
- a. Overfilled Cable Travs The 02/21/85 memo f rom H. C. Abercrombie to Those Listed (App. A, 5.a) addressed the concern that trays and firestops/ pressure seals on Sequoyah are approaching the maximum fill. The memo proposed that the Office of Engineering (0E) develop criteria for determining that a tray or firestop/ pressure seal is physically full.
The memo also proposed that Quality Assurance (QA) then incorporate the OE criteria into procedures for cable pulls and firestop/ pressure seal penetrations. Such procedures would include a mechanism to physically label the penetrations as physically full and notify OE to incorporate this into the cable routing program. QA will perform a survey of firestops/ pressure seals using the OE criteria to ensure that those seals presently full are identified and properly closed.
The 03/28/85 memo from J. P. Vineyard to H. B. Rankin (App. A, 5.b) acknowledged the conditions described in the Abercrombie memo and proposed that OE use cable tray single-line drawings to document filled firestops/ pressure seals and tray segments and correct the existing problems.
This requirement has been incorporated in SQEP-06 ( App. A, 5.aaa, 09/22/86).
The Vineyard memo also indicated that Construction l
i Specification G-38 would be revised to include criteria for handling the identified condition of full cable trays and penetrations. Thus, when QA identifies the full areas, the OE/SQN will show these on the single-line tray drawings so the designers can provide jumper conduits or alternate routes. The evaluation team's review of several single-line tray drawings ( Ap7 A, 5.fff through 5.jjj) shows that the drawings do indicate physically full areas and jumper conduits. These drawings were revised on 05/01/85. However, 04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0.
PAGE 9 0F 30 although criteria for handling the identified condition of full cable trays and penetrations for SQN are not covered in G-38 (App. A, 5.ff, 03/17/86), they are covered in M&AI-04.
Adequacy of procedures is further covered in subsection 9.d of this discussion.
The 02/18/86 NSRS Report I-86-251-SQN, Attachment 1, (App. A, 5.t) contains findings that investigators made regarding tray overfill from their observations and interviews with site personnel. The report states that:
o The disorderly arrangement of cables in trays was the primary reason for the appearance of overfilled trays o Cables in safety-related trays had been installed in a more orderly fashion than in nonsafety-related trays o Very few safety-related trays appeared to be full Power trays observed were not physically full, and cables appeared to be installed in accordance with the design requirements. However, the Flamemastic coating made it dif ficult to observe the spacing between power cables. In general, the trays that were full or that had cables above the side rails carried nonsafety-related instrumentation and control cables. These findings were also identified in the 05/20/86 Generic Concern Task Force (GCTF) report (App. A, 5.s). The NSRS report recommended completion of the corrective action indicated by SCR SONEEB8601 (discussed in
- b. below), evaluation of cable tray physical loading, and improved definition and control of full cable trays.
The 05/14/86 Engineering Report '(ER) ( App'. A, 5.f)' for 'CAQ "-~ ~~ ~~~~~
SCR SQNEEB8620 R0 (App. A, 5.e; 03/21/86) included a review of instrumentation and control cable tray overloading based on selected cable tray profiles which were totally filled with known and unknown (abandoned) cables and covered with 1/4-inch Flamemastic cable coating. The review identified several trays that were filled above the side rails. All these profiles were, however, for non-class 1E trays as determined in the review by the evaluation team.
The ER concludes that overload of cable trays resulting from abandoned cables not being removed or accounted for does not present'a cable ampacity problem. Since the abandoned cables 0415D (12/05/86)
_ ,-..w -_ _ _
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 r
~
PAGE 10 0F 30 are deenergized and do not dissipate additional heat, the evaluation team concurs with the general approach that additional derating may not be required for the active power cables if the active power cables do not exceed the maximum allowable cable tray fills; however, additional analysis is required to support this. Furthermore, as indicated below, sampled class lE power trays GG-A and GR-A do not appear to be overfilled, at least with active power cables. Regarding tray supports, the ER indicates that the worst-case sampling used to resolve the SCR was not sufficiently broad-based to address the adequacy of the cable tray supports.
Subsequently, SCR SQNCEB8622 R1 (App. A, 5.uu) was issued on 03/10/86 to requite an additional evaluation to resolve cable tray support overloading. The corrective action stated in SCR SQNCEB8622 indicates that an evaluation has been performed to identify 30 worst-case tray supports. In addition, "an additional number of cable tray supports would be analyzed after restart to provide a minimum of a 95 percent confidence level that no more than 5 percent of the supports would exceed design allowables."
<3 The above program ultimately resulted in substantially larger number of worst-case ~ tray supports requiring analysis becauss-~~-~ ~ ~ - - -
a significant number of selected trays exceeded the design limits. This evaluation is documented in SON calculations SQN-E2-016 (App. A, 5.kkk) and SQN-E2-017 (App. A, 5.111).
Review of these documents by the evaluation team determined that the program did not cover the review of trays in areas other than the Control and Auxiliary Buildings (e.g.:
Reactor and Diesel Generator Buildings) and no justification for not covering other areas has been identified. Also the review revealed that the approach and assumptions for this evaluation are adequate except for:
o The assumption that the applied thickness of Flamemastic is 1/4-inch cannot be verified since instances exist where additional cables were added to trays after the initial application of coating.
Coating of the new cables could create thicknesses greater than assumed. Although this is not expected to have a significant impact on the overall weight of the tray segment, using only 1/4-inch of Flamemastic requires justification.
o 04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM
_ __ REVISION NUMBER:_0 _ _ _ _ . _ _ _ _ .
M PAGE 11 0F 30 o The assumption that computed weights of known cables equal to or greater than 14 pounds per foot for vertical trays and 16 pounds per foot for horizontal trays will be sufficient to identify overloaded tray segments requires further justification. Considering that the accuracy of the raceway fill tracking system is not verified and that a large number of selected trays exceeded the design limits during the evaluation, no certainty exists at this time that 14 and 16 pounds per foot will be the limiting weights to properly identify overloaded tray segments.
The results of the program indicate that the Design Basis loading criteria specified in Design Criteria SQN-DC-V-1.3.4 (App. A, 5.mmm) have been exceeded for some of the vertical and horizontal cable trays in the Control and Auxiliary Buildings. Although TVA indicated that this condition will primarily impact vertical tray supports, the evaluation team did not review any resolution or corrective action to this problem as documentation of the analysis of overloaded supports was in progress at time of evaluation. However, TVA c, indicated that corrective actions have been identified to
- correct deviations from design basis requirements.
Completion of this program should also resolve the following NRC observations at Sequoyah that resulted from an inspection performed during July 21-25, 1986 for design baseline verification (App. A, 5.ddd):
o " Review of cross sections of cable trays identified cable masses outside the trays. Consideration should be given to securing the cables and to evaluating resulting eccentricities. An example of this condition was found in the plant at Elevation 714' and Coordinates A12S."
o "A few locations in the cable tray systems appeared to contain large unsupported spans. These locations were identified to technical personnel involved in the evaluation of these systems accompanying the team.
This situation was noted at elevation 714 and coordinates AlQ and A2Q, at elevation 734 at unspecified coordinates, and at elevation 685 in the auxiliary relay room."
04150 (12/05/86)
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(8) i SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 12 0F 30 In response to employee concerns about overfilled cable trays at Watts Bar, the GCTF issued a report on 05/20/86
( App. A, 5.s) to document the review for Sequoyah. The report's review scope was limited to walkdowns of cable trays in the Auxiliary Building and the Cable Spreading Room. Upon a field examination of several cable tray segments that were indicated as being full by cable tray diagrams, some cases were found where the grouped cables and the Flamemastic coating extended well above the cable tray side rails. The GCTF report found that the ER for CAQ SCR SQNEE88620 used a lower than actual weight per cubic foot for the Flamemastic coating and recommended that calculations be revised to reflect this. The evaluation team's review of calculations SQN-E2-016 and SQN-E2-017 revealed that the correct (revised)
Flamemastic coating weight was used. Medium and low voltage power trays were not observed to be overfilled during the GCTF walkdown. Some divisional trays appeared overfilled, but closer. visual examination revealed loose packing and voids because of the random lay of cables, the use of multiple pulls, and the use of Flamemastic.
All this is partly the result of the fact that during the construction phase SQN did not have requirements to prevent filling cable trays above the side rails. Although Construction Specification G-38 Rev. 8 specifies that " cable trays shall not be filled above the side rails except at intersections and where cables -enter or exit the tray," this statement is limited to plants beginning with Bellefonte.
However, requirements that cable trays not be filled above
- the side rails except at intersections and where cables enter or exit the tray were added for SQN on 12/31/85 in Rev. 8 of the Modification and Additions Instruction (M&AI-04). During a plant walkdown, the evaluation team observed (App. A, 7.c, 10/09/86) several trays with cables above the tray side rails (e.g. , KZ-A node 88-130, NN-A node 132-187, KY-A, node l 196-197, GG-A node 103-104, GR-A node 62-63). Although no determination could be made of whether an actual overfill exists since cables are covered with Flamesmastic, a review of the computer cable tray fill printout indicates that calculations based on 18-inch by 4-inch cable trays, show that KZ-A, NN-A, and KY-A are overfilled above 60 percent.
- Power trays GG-A and GR-A are filled below 30 percent and, l therefore, not considered overfilled. However, the accuracy i of the raceway fill tracking system is not verified (this is discussed in detail in Sequoyah Element Report 239.0).
i s
! 04150 (12/05/86) l t
! - _ , _ . _ _ _ . _ - - - - _ - - - - - _ -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ -- ~ '
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM G REVISION NUMBER: 0 PAGE 13 0F 30
- b. Cable Trav Fill Criteria This issue questions the SQN cable tray fill criteria for conformance to the National Electrical Code (NEC) and industry practice. The maximum fill of 60 percent for
-instrumentation control and cables and 30 percent for power cables is stated in the SNP FSAR (App. A, 5.aa) and Design Criteria SQN-DC-V-ll .3 ( App. A, 5.bb) .
The GCTF report regarding Employee Concern No. WI-85-100-011 (App. A, 5.w; 05/16/86) for SQN addresses the applicability of NEC tray fill criteria. This report found that the electrical utility portion of TVA is excluded from the requirements of this code per NEC Article 90, Section 2 (b),
paragraph 5. Since power plants are not subject to follow the NEC requirements, the evaluation team concurs with the conclusion of the GCTF report.
The GCTF report further identified a calculation (App. A, 5.z; 01/31/86) used to justify the 60 percent fill.
Five representative tray sections known to be filled with control cables to 60 percent of the tray cross-sectional area were analyzed. The fullest tray section was used to show that the heat producing cables (carrying control power less than 30 amperes) did not accour.t for more than 30 percent of the tray section fill (30 percent is the maximum fill allowed in a power tray). This approach, modified to accommodate a limited number of heat dissipating cables, agrees with acceptable practices for justifying I&C raceway fills provided that the tray fill information is accurate and trays carrying control power cables are properly selected.
However, the choice of representative tray sections was based i
on unverified computer printout data that are needed to determine tray fill. Thus, verification of the Computer Cable Routing Program discussed in Sequoyah Element Report i
239.0 may impact the justification.
SCR SQNECB8601 R0 (App. A, 5.c, 06/27/86) states that the criteria for cable tray fills (30 percent for power trays with cables above 30 amperes and 60 percent for
~ instrumentation and control trays) have been violated. The SCR points out that during the review of the SQN Cable Routing System program, it was discovered that cable tray overfill conditions were created by system users raising the maximum allowable ~ tray fill' to permit ~ the addition of cables to already full trays. Note that raising the maximum allowable tray fill capacity allows the Computerized Cable f7' Routing System (CCRS) to route cables that would otherwise have been rejected by the computer program.
04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: O e '
PAGE 14 0F 30 Engineering Report SCR SONECB8601 R0 ( App. A, 5.d; 08/04/86) concludes that the cable tray loading (fill) was conservative because fill quantity was based on 3-inch deep cable trays whereas 4-inch trays were installed at SQN. The ER also states that there are no known cases of cable tray loading that violate the design criteria (as discussed earlier, ER SCR SQNEE88620 contradicts this statement).
SQN SCR SQNEEB8601.R0 (App. A. 5.j) was issued on 01/06/86 to address the generic problem of unverified values of' cable outside diameters (OD) and weights. These unverified ODs were used to calculate the cable tray cross-sectional fill.
Although verified values are required for these calculations, the cable outside diameters were not available from a documented source and the origin of the values used was unknown. The 04/14/86 ER CAQ SCR SQNEEB8601 R0 (App. A, 5.k) stated that the unverified values have been evaluated and no major inconsistencies were found. The ER concluded that past calculations and the design that was based on these values "will not result in a failure that would impact nuclear safety." An attachment to the 09/04/86 memo from M. J. Scruggs to W. S. Raughley ( App. A, 5.vv) compares the original cable cross-sectional areas and cable ODs with the new (actual) average values. The Scruggs memo indicates that of the 210 cable mark numbers reviewed, "150 mark numbers show the original OD to be larger than the new, 57 mark numbers show the new OD to be larger than the original 00 and three were the same." The Scruggs memo also indicates that there are still some cable mark numbers at Sequoyah for which verified ODs are not yet available, but efforts are being made to determine the values. T. W. Roberts was instructed by a 09/23/86 memo from W. S. Raughley (App. A, 5.00) to change the resident data of cable physical dimensions and weights in the SQN Cable Routing System using the new verified values. TVA indicated that this effort was completed and that new verified values were used in previously discussed calculations SQN-E2-016 and SQN-E2-017.
The evaluation team believes that although the ER for SCR SQNEEEJ601 R0 conclusion is reasonable in that nuclear safety is not impacted, no analysis was included to support the conclusion.
04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: O
'q PAGE 15 0F 30 t
The cable OD differences discussed above could have an effect on cable ampacities and derating because cable ampacities in-cable trays depend on the-cable tray fill. Furthermore, as part of a program to correct the problems with cable tray
' fill, a memo from Raughley (10/07/86, App. A, 5.qq) directs all the nuclear plants to establish "a sampling program to determine the adequacy of electrical cables with respect to j their ampacity ratings." _(The induction and heating issues
~
are addressed in detail in Sequoyah Element Report 240.0.)
, Although TVA indicated (10/08/86, App. A, 7.e) that the extent of cable tray overfill at SQN will be determined as a byproduct of this sampling program, the program itself is not 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.
Design Criteria document SQN-DC-V-11.3 uses the industry criterion of 30 percent fill for power trays. The industry criterion for instrumentation and control (I&C) trays generally allows fills to be between 40 to 50 percent, and,
.r' with appropriate justification, the fill may exceed
, ; 50 percent. Because of the low energy level of the cables l generally installed in I&C trays, the heating effect is not a consideration except when control power cables are mixed with
! the I&C cables. However, this is also acceptable, if it can
{ be demonstrated that control power cables do not account for more than 30 percent of the cable tray fill and that an acceptable power dissipation level per linear foot is not Fills in these trays are limited primarily for the exceeded.
sake of an orderly installation appearance, to provide access to cables, and to allow the installation of tray covers when required.
i
- c. Lack of Support and Protection for Cables This issue refers to some cables being run completely outside-the trays, especially in bends, and some cables " hanging i loose." In addition, tray covers cannot be installed because l trays are overfilled.
TVA ECSP Report C010900-SON ( App. A, 5.ww; 09/19/86) discusses the investigation of cables improperly routed outside of cable trays. It concludes that this routing has occurred in one or two instances, but that there is no massive amount of unsupported cable at Sequoyah, unlike Watts
! Bar where many instances were discovered. However, the Watts
<rs Bar cables were found to be temporary construction and 04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 Q _ _ _ .-
-~ PAGE 16 0F 30 --~ ~~~~ ~ ~~-
. security cables. Because of a misinterpretation of Construction Specification G-38 Section 3.2.1.8.2(b), " site personnel believed before December 31, 1985" that "it was acceptable to run cable outside of cable trays." The ECSP report also concludes that a walkdown is needed to verify
. that all permanent cables are in cable trays to ensure that G-38 has not been misinterpreted at SQN. The report does not, however, identify the walkdown as a corrective action item.
['
The evaluation team conducted a walkdown on 10/09/86 (App. A, 7.c) and did not observe cables running outside of trays or-i hanging loose from-trays as a result of overfills. The team did observe cables lying on top of the Flamemastic coating i
but not fastened to existing cables or the tray. However, G-38 and M&AI-04 do not require such cables to be fastened.
1 Regarding the concern that cable tray covers cannot be installed because the trays are overfilled, the evaluation team has reported in Sequoyah Element Report 242.0 that cable tray covers are properly installed on safety-related trays.
43 This observation is based on walkdowns of the Cable Spreading
?4 Room and of the Auxiliary Instrument Room. A subsequent walkdown ( App. A, 7.c) of other areas in the plant indicated that there are several tray sections where tray covers could not be installed if they were required, but the evaluation team found that tray covers were not required in any of these cases because divisional separation was not required or because the tray sections are non-class lE.
, d. No Plant Procedure Requirements To Prohibit Overfilling This issue is concerned with whether there are procedures to i' prevent cable tray overfills. In the discussion of issue "a," it was noted that TVA had recognized the overfill problem and proposed a plan to identify the overfilled trays and penetrations and to provide alternate routes.
1 The FSAR states that tray fills will be limited to 30 percent i for power trays and 60 percent for instrumentation and control trays. Engineering design standards also impose this limitation.
i
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.---ycr_- ., ,-- --,-w-r -- ,, ,sw,- y.m_,y--, com-----,e----- - , - . , , - , - - - - - - ,- ,, . . . . - - - - - - -
TVA EMPLOYEE CONCERNS PEPORT NUMBER: 238.3(B)
SPECIAL PROGRAM p REVISION NUMBER: O PAGE 17 0F 30 GCTF reports (App. A, 5.u and 5.v) issued on 02/09/86 and 04/25/86 address SQN plant procedures on overfill of cable t rays . The reports limited the investigation to instrumentation and control trays because fill restrictions on power trays are more stringent. The reports state that there is no design requirement that cables cannot extend above the side rails of cable trays and that M&AI-04 (App. A, 5 99) was revised to instruct maintenance and construction personnel to install jumper conduits "to bypass blocked areas as determined by the cognizant engineer."
Blocked areas are interpreted by the evaluation team as tray segments where additional cables, if installed, would protrude above the cable tray side rails. The reports conclude that these instructions will prevent cables from being installed above the cable tray side rails and that acceptable cable tray fill controls and procedures are in place at SQN.
Review of M&AI-04 by the evaluation team indicates that the field cognizant engineer must obtain DNE approval before deviating f rom _ a designed routing for a cable. .This requires -. _ _ _ _ _
c his coordination with DNE to resolve a routing problem or to provide alternate routing. DNE will in turn issue a new cable card with the agreed changes. However, the M&AI is not specific regarding coordination with DNE when jumper conduits are added to prevent installation of cables above the cable tray side rails.
On 09/22/86 TVA issued the Sequoyah Engineering Procedures, SQEP-06 ( App. A, 5.aaa), to provide instructions for writing, routing, issuing, and revising cable schedules. The procedures give specific instructions for consideration of abandoned cables and tray loading. These include:
o Early warning when instrumentation and control trays are approaching maximum fill -- which was reduced (effective 03/01/86) from 60 percent of an 18-inch by 4-inch tray to f.0 percent of an 18-inch by 3-inch tray (the actual tray side rails are 4 inches) o Checking each new computer-generated route for I&C cables to ensure that it does not use filled (above 60 percent of the 18-inch by 3-inch tray) or blocked tray sections o Recommendation of Civil evaluation of tray support
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loading conditions if there is any suspicion of f established values being exceeded 04150 (12/05/86)
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TVA EMPLOYEE-CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 g'"
e PAGE'18 0F 30 4
The evaluation team finds that the procedural controls'in i
' place at SQN apply to the modifications and additions phase and not to the construction phase. No evidence, however,
' exists that the actual. tray fills identified as part of the '
programs to verify adequacy of tray supports and cable ampacities will be reflected in the raceway fill tracking system for future use. -The procedures, M&AI-04, and SQEP-06 are considered sufficient to prevent future overfilling of I&C trays only. SQEP-06 does not provide specific instructions for power trays.
e.&f. Overfill of Cable Tray-Penetrations These two issues are concerned with possible cable damage and 1
possible loss of penetration pressure integrity resulting from pulling cables through overfilled penetrations. (A related concern that overfilled cable penetrations may have to be evaluated for impact on cable ampacity is addressed in
, Sequoyah Element ~ Report 240.0.)
I Cable tray penetrations are sealed so that the pressure integrity or fire boundary of the wall or floor is not ;
compromised. The following discussion summarizes the evaluation team's assessment of overfilled penetrations and -
} methods used to breach the penetrations.
- l t
In addition to the potential ampacity and high temperature problems of power tray penetrations and firestops, overfills may compromise the firestop/ pressure integrity because cables are packed tightly in the penetration. This may leave no i room between the cables for the fire seal compound (RTV ,
silicone foam). This also applies to cable tray penetrations '
i which require pressure seals. Although no clear definition
[ currently exists of what should.be considered an overfilled ;
l penetration, the evaluation team observed potential overfills ,
j during a walkdown performed on 11/04-06/86 (App. A, 7.d).
i This overfill assessment was based on potentially overfilled trays going through these penetrations and was primarily l observed at the instrumentation and control cable tray i penetrations. The integrity of completed firestops and pressure seals is not easily verifiable since they are covered with Ceraform boards and Flamemastic coating.
l However, installation and repair procedures for these '
penetrations are detailed in M&AI-13 ( App. A, 5.xx) discussed
[ below.
i j 04150 (12/05/86) i l
i
' TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 19 0F 30 The ECTG Report 304.02-SQN dated 10/21/86 (App. A, 5.tt) addresses a concern about incorrect breaching of cable tray penetration fire seals. The concern was that steel fish-tape is being used in lieu of nonmetallic rods to break penetration seals, resulting in possible damage to existing cables in the breached penetrations. Although breaching tools made of nonmetallic materials are preferred and recommended, M&AI-13, Rev. 6 (App. A, 5.xx) does allow the use of metallic breaching tools at the discretion of the responsible engineer. Steel fish-tapes were used only-where -- - - - - - - - ;
space restrictions prohibit the use of longer, inflexible probes. Although the report concludes that the use of a nonmetallic probe does not preclude cable damage if misused by the craf t, various nonmetallic breaching tools and fish-tape have been used since 1979 (in accordance with M&AI-13) without any known cable damage. Therefore, the report determined that the concern is not valid at SQN.
M&AI-13 establishes requirements for installation and repair of electrical pressure seals, firestop barriers, and fire retardant coating. The M&AI permits use of a metallic breaching tool at the discretion of the responsible engineer. However, the foreman shall note and sign the comment section on the data sheet, " Breaching and Resealing the Pressure Seals and Firestops," that the metallic tool is free of burrs and sharp edges. A hold point for QA signoff on the same data sheet requires verification that the breached pressure seal or firestop has the required silicone foam applied around the added cable, that the Ceroform boards are replaced, and that Flamemastic is applied to the cable.
Thus, the evaluation team finds that M&AI-13 properly includes hold points for QA inspection of the installation process and instructions for documentation records to be completed by the QA inspector to ensure integrity of the pressure seals and firestops.
Also, Surveillance Instruction SI-233.2 provides for visual inspection for electrical penetration of fire barriers. The inspections are performed at least every 18 months to meet Technical Specification requirements and prior to returning a fire barrier to service af ter repairs or maintenance.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM
,_ REVISION NUMBER: 0 PAGE 20 0F 30 The evaluation team considers that TVA has adequate procedures and controls for installing and breaching tray penetrations seals, and for subsequent inspection of the work to verify restoration of the pressure or fire integrity of the breached barrier. M&AI-13 covers both pressure and firestop sealing, and SI-233.2 covers periodical visual inspection of firestops.
The cable damage aspect is addressed in detail in Sequoyah Element Report 238.1. Although this report is primarily directed at cable pulling in conduits, the evaluation team's assessment and conclusions regarding cable damage during installation are equally applicable to cables going through cable tray penetrations.
Findings:
- a. Review of cable tray fills revealed the following:
o Power cable trays did not appear to be overfilled.
However, no final assessment can be made until the accuracy of the raceway fill tracking system is verified. Also, no analysis has been identified to support the assumption that no additional derating is required for power cables when the overfill is the result of abandoned (deenergized) cables, o The raceway fill tracking system, although not verified, indicates that a number of I&C trays are overfilled. This is supported by the effort performed under SCR SQNCEB8622. In fact, the fills determined f rom the profiles obtained during the walkdowns are generally larger than the fills in the raceway fill tracking system. - - " ~ ~ ~
In addition, review of the current program under SCR SQNCEB8622 to determine the adequacy of cable tray supports indicates that:
o Insufficient evidence exists to justify that computed weights of known cables equal to or greater than 14 pounds per foot for vertical trays and 16 pounds per foot for horizontal trays are adequate cut off points to provide an acceptable level of confidence regarding identification of overloaded tray segments.
~
o The program only covers review of cable trays in the Control and Auxiliary Buildings.
04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAl. PROGRAM REVISION NUMBER: 0 f "
PAGE 21 0F 30 o Multiple application of Flamemastic cable coating (as is ,
the case at SQN) may result in thicknesses greater than 1/4-inch. The cable coating weight is, however, calculated based on a maximum thickness of 1/4-inch.
o Weights for a number of trays exceeded the Design Basis loading criteria in Design Criteria SQN-DC-V-1.3.4.
Documentation of the analysis for resolution of deficiencies and implementation of needed corrective actions was in progress at time of evaluation.
- b. The NEC does not require utilities (TVA) to comply with code requirements; therefore, TVA is not obliged to follow NEC for tray fills. Current SQN fill criteria of 30 percent for power trays is consistent with industry standards. Although the 60 percent fill criterion for I&C trays exceeds the industry standard of 50 percent, it is acceptable if adequately justified. The current approach to justify the 60 percent fill agrees with acceptable practices; however, no evidence exists that the representative tray sections were properly selected to assure that control power cables do not account for more than n.
F 30 percent of the cable tray fill and that an acceptable power dissipation level per linear foot is not exceeded.
Furthermore, the ongoing sampling program to determine cable adequacy with respect to ampacity rating does not clearly address.the evaluation of overfilled raceways.
- c. A walkdown performed by the evaluation team did not find cables running outside of cable trays. The concern that tray covers cannot be installed on class 1E trays that require tray covers was not verified by the walkdowns performed.
- d. Plant procedures to prohibit overfill of trays and penetrations have been established in SQEP-06 and M&AI-04 only recently.
However, these procedures are not clear in the areas of conduit jumpers and power trays. Also, no evidence exists that the actual tray fills identified as part of SQN's ongoing programs will be reflected in the raceway fill tracking system for future use.
- e. The concerns that cable tray penetrations are overfilled could not be confirmed by the evaluation team through walkdowns or examination of the design documents. Also, no documents were identified defining allowable cable fill in penetrations.
Overfilled penetrations may af fect cable derating (discussed in Sequoyah Element Report 240.0) and may result in cable damage (discussed in Sequoyah Element Report 238.1). However, current
(- procedures that will prevent overfills in cable trays should automatically prevent overfills in cable tray penetrations.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 238.3(B)
REVISION NUMBER: 0 PAGE 22 0F 30
- f. M&AI-13 addresses the installation and repair of electrical pressure seals and firestops; current procedures adequately address installation, repair, and inspection of electrical firestops and pressure seals to ensure their integrity; and includes adequate requirements for QA inspection of the installation process. SI-233.2 covers periodical visual inspection of firestops.
Conclusions:
- a. The issue regarding tray overfills is valid, particularly for I&C trays. Regarding the overfill effect on cable ampacities, no analysis has been identified to support assumptions regarding the effect of abandoned cables on cable ampacities. TVA is currently carrying out a program to resolve the issue of overfill effect on cable tray supports.
Proper implementation of the program and completion of corrective actions should settle the issue. Completion of the program should also adequately resolve the NRC observations during inspection for baseline verification.
e, b. The issue about NEC applicability for cable tray fill is considered not valid as_TVA is. not. obliged to follow NEC for--- - - - - - - -
raceway fills. TVA criteria for cable tray fill are in general agreement with industry standards although current justification for 60 percent in I&C trays cannot be confirmed.
- c. The issue of loose cables outside of trays could not be validated in the walkdowns by the evaluation team. Although these were not exhaustive walkdowns, they are considered adequate to determine that cable installation outside of cable trays is not a problem at SQN. Likewise, the issue that tray covers could not be installed (where required) is not valid.
- d. The concern that plant procedures do not contain requirements to prohibit overfill of trays is valid as procedures to prevent overfills have only recently been established. TVA's present procedures (SQEP-06 and M&AI-04) should prevent future overfilling of trays once actual tray fills, conduit jumpers, and power tray aspects are clarified, gs 04150 (12/05/86)
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SPECIAL PROGRAM
, REVISION NUMBER: 0
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PAGE 23 0F 30
- e. Although a number of tray penetrations appeared to be overfilled, a visual inspection during walkdowns by the evaluation team could not determine the validity of the issue about overfilled tray penetrations. However, current TVA programs should resolve the problems associated with potential overfills and current procedures should prevent recurrence.
- f. The issue about pressure boundary integrity of overfilled penetrations is not considered valid. SQN has adequate procedural controls for applying and inspecting the pressure seal process.
l 1
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SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 24 0F 30 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. TVA memo from H..L. Abercrombie to Those Listed, "Sequoyah Nuclear Plant (SQN) - Loading of Cable Trays and Fire Stops /
Pressure Seals," (LO4 850220 930), (02/21/85)
- b. TVA memo from J. P. Vineyard to H. B. Rankin, "Sequoyah Nuclear Plant - Loading of Cable Trays and Fire Stops /
Pressure Seals,"..(B25 850328 009),-(03/28/85) -
- d. SQN Engineering Report CAQ SCR SQNECB8601 R0, (S56 860804 820), (08/04/86) l e. SQN Significant Condition Report (SCR) No. SQNEE88620 R1, (843 860410 910), (03/21/86)
- e f. SQN Engineering Report CAQ SCR SQNEEB8620 R0, S01 860521 871), (05/14/86) 9 WBN Significant Condition Report (SCR) No. WBNEEB8589 R0 (843 851231 925), (12/27/85)
- (843 851231 928), 12/27/85)
- 1. WBN Engineering Report CAQ SCR WBNEEB8589 and WBNEEB8590 (B45 860113 280), (01/13/86) i j. SQN Significant Condition Report (SCR) No. SQNEEB8601 R0 (B43 860117 919), (01/06/86)
- 1. BLN, Problem Identification Report (PIR) No. PIRBLNEEB8601
. (843 860116 934), (01/13/86)
- m. TVA memo from Chitwood to Raulston, " Watts Bar Nuclear Plant Unit 1, 50.55(e) Interim Report Input - Significant Condition Report 8589 R0," (B43 860123 908), (01/15/86) i 4
(.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM
' ,f:' . REVISION NUMBER: 0 PAGE 25 0F 30 APPENDIX A (cont'd)
- n. TVA memo from Chitwood to Raulston, " Watts Bar Nuclear Plant Unit 2, 50.55(e) Interim Report Input - Significant Condition Report 8590 R0," (B43 860123 909), (01/16/86)
- o. TVA memo from Raulston to Gridley, " Watts Bar Nuclear Plant -
Units 1 and 2 - Non-QA Values for Cable Weights and Outside Diameters Used in Calculations, 10CFR50.55(e) Report No. 1, (Interim), NCR W8NEEB8589 and WBNEEB8590," (845 860218 256),
(02/18/86)
- p. TVA memo f rom Raughley 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) Report No. 2 (Interim),"
(843 860602 907), (06/02/86) 4 i
- q. OE Calculation (843 860331928), " Determination of Class 1E Electrical Cable Weight / Foot and Outside Diameter," All TVA
, Nuclear Plants, (12/20/85) m
. r. TVA memo Cantrell and Mason, " Evaluation of The Adequacy of a
Installed Class lE Cables," (843 851203 915), (12/02/85)
- Conduits," Rev. 1, (05/20/86)
- t. NSRS Report No. I-86-251-SQN, Attachment 1, Review of Generic Concern Issue, " Electrical Cables," (02/18/86)
J
, Trays," Rev. 1, (04/25/86)
- x. TVA memo from Wigington to Electrical Engineering Files, "WBN Units 1 and 2 - Documentation of the Effect of Vimasco Cable Coating on Cable Ampacity," (843 860121 947), (01/22/86)
I y. Factory Mutual Research Report No. J.I. OF005 AF, l
" Examination of the Effect of Vimasco Cable Coating No. 2-8 on Ampacity in Cable Trays," (12/19/80) f 4
04150 (12/05/86) s
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: O p.
PAGE 26 0F 30 APPENDIX A (cont'd)
- z. OE Calculation (843 860131 925), " Justification of TVA's Ampacity Tables as Related to NV-3, NV-10 and NV-ll Cable Trays, Conduits and Underground Conduit Banks," (01/31/86) aa. SQN FSAR, Section 8.3.1.4.1, Amendment 1, "Co51e Derating and Cable Tray Fill" bb. Design Criteria SQN-DC-V-11.3, " Power, Control and Signal Cables for Use in Category 1 Structures," Section 6.2.2,
" Cable Tray Loading," Rev. 5, (09/30/85) cc. Electrical Design Standard DS-E12.1.13, Rev. 2, " Cable-Class 1E Cable 00s and Weights," (04/15/86) dd. Electrical Design Standard DS-E12.1.4, Rev. O, " Cable - Class NC Cable ODs and Weights," (04/15/86) ee. National Electrical Code, NFPA-70-1984 rs. ff. General Construction Specification No. G-38, " Installing
'T Insulated Cables Rated Up to 15,000 Volts," Rev. 8, (03/17/86) '
gg. SQN Modifications and Additions Instructions M&AI-4, R8 and R9, " Installation of Control, Power and Signal Cables,"
(12/31/85) (08/13/86) hh. SQN Modifications and Additions Instruction M&AI-7,
" Inspection Criteria of Cables or Internal Panel Wiring,"
Rev. 8, Section 5.0 (07/24/86) ii. J. Stolpe, "Ampacities for Cables in Randomly Filled Trays,"
IEEE Transactions Paper, (07/31/70) jj. SQN, Technical Specification, Surveillance Requirements, Section 3.0 (09/17/80) kk. SQN, Technical Specification, Surveillance Requirements, Section 4.0 (09/17/8C)
- 11. SQN Inspection Instruction No.10, Sections 7 and 8,
" Interconnection Cable Termination and Insulation Inspection," Rev. 16, (04/04/83)
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SPECIAL PROGRAM REVISION NUMBER: 0
. h
PAGE 27 0F 30 APPENDIX A (cont'd) i mm. SQN Nonconformance Report NCR SQNECB8501 (242 850412 004),
(04/11/85) nn. SQN Nonconformance Report NCR SQNEE88501 R2, (843 850501 953), (04/25/85) oo. TVA memo from W. S. Raughley.to T. W. Roberts, "Sequoyah Nuclear Plant - Cable Weights and Outside Diameters (00),"
(843 860923 908), (09/23/86) pp. TVA memo from W. S. Raughley to Those Listed, "All Nuclear Projects - Coordinated Response to Cable Routing SCRs,"
B43 860929 904), (09/29/86) qq. TVA memo from W. S. Raughley to Those Listed, "All Nuclear Plants - Corrective Action and Sampling Program for Electrical Cable Ampacity," (843 861008 909), (10/07/86) rr. TVA memo from C. H. Sudduth to Electrical Engineering Files, r7 "SQN Units 1 and 2, Evaluation of Test Results and Cable
- Ampacity Tests for Completed Fire Stop Penetrations,"
4 (EEB 770211 908)~',~(02/10/77) ss. 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 V .
tt. TVA, SQN, ECTG Report, " Cable and Conduit, Electrical Penetration Breached", No. 304.02, Rev.1 (10/21/86) uu. SQN Significant Condition Report (SCR) No. SQNCEB8622 R1, (B25860925 004), (03/10/86) vv. TVA memo from M. J. cc t 19<. o W. S. Raughley, "Sequoyah ,
Nuclear Plant - Cabie hief and Outside Diameters (00),"
(B25860904 001), (Osjs4/b.,
ww. TVA, SQN, ECSP Report No. C010900-SQN, Rev. 1 " Cable,"
(09/19/86)
, xx. SQN Modifications and Additions Instruction M&AI-13, Rev. 6,
" Electrical Pressure Seal, Firestop Barrier and Flame 1
Retardant Cable Coating," (01/28/85) 04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPCRT NUMBER: 238.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 6'
PAGE 28 0F 30 APPENDIX A (cont'd) yy. TVA, Electrical Design Standard DS-E13.5.1, Rev. O,
" Electrical Penetration Fire Stops and Pressure Seals" (12/05/77) zz. SQN, Special Maintenance Instruction SMI-0-317-36, "Walkdown of Cable Tray Supports for All Areas" (excluding the Annulus Area), Rev. O, (06/20/86) aaa. Sequoyah Engineering Procedures, SQEP-06,Section VIII,
" Conduit and Cable Procedure," Rev. 0 (09/22/86) bbb. Letter from Gridley, TVA, to Youngblood, NRC, "In the Matter of the Tennessee Valley Authority Docket Nos. 50-327 and 50-328," (Draft) ccc. Unimplemented Design Item Evaluation (B25 860310 714), "SCR '
SQNEEB8620, Cable Tray Loading" (03/07/86) ddd. Letter f rom J. M. Taylor, NRC, to C. C. Mason, TVA,
Subject:
Report Nos. 50-327/86-45 and 50-328/86-45, (10/31/86) eee. Surveillance Instruction, SI-233.2, R0, " Visual Inspection of i Penetration Fire Barriers-Electrical" (10/02/85) fff. SQN Drawing 45N881-12 RS, " Conduit & Grounding Cable Tray Single Line Node Voltage Level 10, 11," (05/01/85) i ggg. SQN Drawing 45N881-17 R4, " Conduit & Grounding cable Tray Single Line Node Voltage 4,12, & 13 (480V)," (05/01/85) hhh. SQN Drawing 45N881-18 R3, " Conduit & Grounding Cable Tray Single Line Node Voltage Level 4,12, & 13 (480V)," (05/01/85) lii. SQN Drawing 45N881-21 R6, " Conduit & Grounding Cable Tray Single Line Node Voltage Level 3, 10, & 11," (05/01/85) jjj. SQN Drawing 45N881-22 R3, " Conduit & Grounding Cable Tray Single Line Node Voltage Level 3, 10, & 11," (05/01/85) kkk. SQN Calculation SQN-E2-016, " Control and Auxiliary Building Vertical Cable Tray Loading," (825 861010 800), (10/10/86) 111. SQN Calculation SQN-E2-017, " Control and Auxiliary Building Horizontal Cable Tray Loading," (825 861106 809), (11/06/86)
/^ mmm.
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Design Criteria ~ SQN-DC-V-1.3.4 R0, " Category I Cable Tray Support Systems," (08/20/75) 04150 (12/05/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM r REVISION NUMBER: 0 PAGE 29 0F 30 APPENDIX A (cont'd)
- 6. WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
- b. Design Criteria SQN-DC-V-11.3, " Power, Control and Signal Cables for Use in Category 1 Structures"
- c. ~ ~~
Electrical Desi~gn ~ Standard DS-E12.1.4, " Cable - Class NU~ ~~
~ ~ ~ ~ ~
Cable 00s and Weights"
- d. Electrical Design Standard DS-E12.1.13, " Cable-Class lE Cable ODs and Weights"
- e. General Construction Specification No. G-38, " Installing Insulated Cables Rated Up to 15,000 Volts"
- 7. LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
- a. Telecon between Jack Wheeler, Bechtel, and Jack Prince, TVA, SQN, Review of actual tray fill quantities versus cable schedule printouts (10/16/86)
- b. Review of cable installation records (e.g., pull slips, computer printouts) and personnel interviews (including electricians and section supervisor for electrical modifications) at SQN by D. Knudsen and M. Ibanez between 10/31/86 and 11/07/86.
- c. Walkdown performed by J. Wheeler, Bechtel, and G. Bell, TVA, (10/09/86)
- d. Walkdown performed by D. Knudsen, Bechtel, between 11/04/86 and 11/06/86
- e. Raughley, McNutt, Skinner, TVA, Shea, Stone & Webster, Jordan, Don-Doncow, Wheeler, Rifai, Bechtel, meeting at Knoxville (10/08/86)
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i TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.3(B)
SPECIAL PROGRAM
,., REVISION NUMBER: O PAGE 30 0F 30 CATD LIST The following CATD forms are included as part of this report:
238.03(B) SQN 01 238.03(B) SQN 02 238.03(B) SQN 03 238.03(B) SQN 04 238.03(B) SQN 05 238.03(B) SQN 06 238.03(B) SQN 07 238.03(B) SQN 08 238.03(B) SQN 09 4
04150 (12/05/86)
ECTG C.3 c
i~
Attachment A Page 1 of 1 Revision 2 .A.- - - - - - - - - - -
ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION
- 1. Immediate Corrective Action Required: E Yes O No
- 2. Stop Wort Recommended: O Yes a No
- 3. CATD No. 238. 01 - S G W -O I 4 INITIATION DATE /2 f bigf
- 5. RESPONSIBLE ORGANIZATION: 'D N E: ' '
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DATE: l'1lf" /8 4 CONCURRENCE: CEG-H' % W , N (/M C DATE: /2-7 4.
9.
APPROVAL: ECTG PROGRAM MGR. 0 DATE:
CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
l O ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR: D&TE:
! 12. CONCURRENCE: CEG-H: DATE:
l SRP: DATE:
[ ECTG PROGRAM MGR: DATE:
l UERIFICATION AND CLOSE0tfT
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- 13. Approved corrective actions have been verified as satisfactorily implemented.
l SIGNATURE TITLE DATE
ECTG C.3 f-o Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION
- 1. Immediate Corrective Action Required: E Yes O No
- 2. Stop Wort Recommended: O Yes E No
- 3. CATD No . 2 38. 0 3 - S &M - 02_. 4 INITIATION DATE 12 fff84
- 5. RESPONSIBLE ORGANIZATION: .'b N E '
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- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
SRP: DATE:
ECTG PROGRAM MGR: DATE:
VERIFICATION AND CLOSEOUT
! e 13.
' Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE l
ECTG C.3 c Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION
- 1. Immediate Corret tive Action Required: 5 Yes O No
- 2. Stop Wort Recomn ended: O Yes S No
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- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
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ECTG PROGRAM MGR: DATE:
UERIFICATION AND CLOSEOUT - ~
- 13. Approved corrective actions have been verified as satisfactorily implemented.
I SIGNATURE TITLE DATE
ECTG C.3 c Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION
- 1. Immediate Corrective Action Required: 5 Yes O No
- 2. Stop Wort Recommended: O Yes E No
- 3. CATD No. 23,8 03 -M h} - O 4 4 l INITIATION DATE ~(2 ' 5'l O [
- 5. RESPONSIBLE ORGANIZATION: 'b4 E, 3
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CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
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- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
SRP: DATE:
ECTG PROGPJLM MGR: DATE:
UERIFICATION AND CLOSEOUT r
- 13. Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE IITLE DATE
e- ECTG C.3 Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document ICATD)
INITIATION
- 1. Immediate Corrective Action Required: 5 Yes O No
- 2. Stop Wort Recommended: O Yes
- 3. R No 5.
CATD No. 23 8. 03 - CQM- Of 4 INITIATION DATE 12lf kd RESPONSIBLE ORGANIZATION:_ b R F_, ' '
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- 12. DATE:
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DATE:
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ECTG PROGRAM MGR: DATE:
UERIFICATION AND CLOSEOUT r
13.
Approved implemented. corrective actions have been verified as satisfactorily SIGNATURE IITLE DATE
- ECTG C.3 Attachment A Page 1 of 1
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ECSP CORRECTIVE Action Tre.eting Document (CATD)
INITIATION
- 1. Immediate Corrective Action Required: W Yes
- 2. O No Stop Wort Recommended: O Yes a No
- 3. CATD No. 2 38.03 -094 - n 6 4 5.
RESPONSIBLE ORGANIZATION': hMR INITIATION DATE lif 8 5 6.
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- 12. DATE:
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Approved implemented.corrective actions have been verified as satisfactorily SIGNATURE TITLE DATE
ECTG C.3 Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION
- 1. Immediate Corrective Action Required:
- 2. Stop Wort Recommended: O Yes
$ Yes O No 3.
W No CATD No. 2 38. 03 idM - 07 4 INITIATION DATE l2, f 86
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VERIFICATION AND CLOSEOUT i-13.
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4 ECTG C.3 Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document 1CATD)
INITIATION 1.
2.
Immediate Corrective Action Required: N Yes O No Stop Wort Recommended: O Yes O No
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- 5. RESPONSIBLE ORGANIZATION:
INITIATION DATE C') / 8 b 6.
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CORRECTIVE ACTION
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- 12. DATE:
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ECTG PROGRAM MGR: DATE:
VERIFICATION AND CLOSEOUT 13.
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ECTG C.3 Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION
- 1. Immediate Corrective Action Required: O Yes
- 2. a No Stop Wort Recommended: 0 Yes 5 No
- 3. CATD No. 23 9.0 S - 4 GM - C 9 a. INITIATION DATE 12/5fgf
- 5. RESPONSIBLE ORGANIZATION: b H E. ' '
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- 8. DATE: 62./ S~ / A d 9.
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- 12. DATE:
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- 13.
Approved implemented.
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