ML20212F370

Rev 1 to TVA Employee Concerns Special Program Sequoyah Element Rept 240.0(B), Cable Ampacity:Cable Derating (Design) & Cable Coating Derating

ML20212F370
Person / Time
Site:	Sequoyah
Issue date:	02/23/1987
From:	Mcnutt G, Parkinson J, Stewart D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20212F190	List: ML20212F185 ML20212F275 ML20212F313 ML20212F342 ML20212F370 ML20212F389 ML20212F438 ML20212F458 ML20212F498 ML20212F529 ML20212F562 ML20212F581
References
240.0(B), 240.0(B)-R01, 240.0(B)-R1, NUDOCS 8703050074
Download: ML20212F370 (25)

Text

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, TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM

, -REPORT TYPE:- SEQUOYAH ELEMENT REVISION NUMBER: .1 TITLE: CABLE AMPACITY Cable Derating (Design) and Cable PAGE 10F 23 Coating Derating REASON FOR REVISION:

1. Revised to incorporate SRP and TAS coments, to comply with current format, and to add Section 10, Corrective Action E

m A PREPARATION

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Z ~ I4- Q1 h,,> DATE f SIGNATURE REVIEW 5 l  % Nf]fy--

~ - -

Y'O 9 SIGNATURE (f DATE o 76' 9 DATE ff/* i SIGNATURE CONCURRENCES

. Oew 2J n i,17 CEG-H: $h ~2-lMr7 SRP d i h s/ M 2,-2.3-87 DATE SIGNATURE DATE

/ SIGNATigfff APPROVED BY:

MOSAY ECSP MANA8ER 2Aur1 DATE nix MANAGER OF ' NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files.

8703050074 870226 PDR ADOCK 05000327 i

Y PDR

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.- TVA EW LOYEE CONCERNS REPORT NUMBER: _240.0(B)' .

SPECIAL PROGRAM REVISION NUMBER: 1 I

.PAGE 2 0F 23 l

1. CHARACTERIZATION OF ISSUES:-

Concerns:: . Issues:

- WI-85-100-009

'XX-85-122-027, -028, -029 a. Cable ampacity and cable derating "Sequoyah: Cable ampacity were not properly considered (e.g.,

. problems.where cable derating overcrowding of cables, penetration, was not properly considered." and conduit sealing were not considered in cable derating).

IN-85-272-004-WBN Overfilled conduits may cause

~"'Valcoat ' used in fireproof induction / heat problems.

electricalcablesinbothunits may cause cables to overheat b. Bundling of cables and fireproof-

i. causing degradation of the coating applied to' cables may cause cable insulation." cable overheating and insulation degradation.

IN-85-289-006-WBN L- "Vermasco was applied to cables c. Overheating of cables makes

, prematurely.- Penetrations and instrument readings indeterminate.

conduits were sealed. Vermasco L

D.. was determined to keep heat in d. Potential cable damage could result and deteriorated the insulation. from cable pulling in overfilled This application was discontinued conduits, and insulation is damaged 1-1/2 years ago but the Vermasco by fishtapes. (Addressed in Sequoyah already applied has not been ElementReport238.l(B).)

.s. removed."

r IN-86-254-005

" Electrical cables are bundled

. together and then covered with Vamasco. The thick coating of Vamasco potentially causes heat build up which may cause failure.

This is a generic condition throughout Units I and II. It effects low, medium, and high voltage cables."

IN-86-262-002

" Units 1 and 2, the overcrowding of cables and the application of

a fire retardant to the cables causes an overheating condition.

Therefore making the instrument i readings indeterminate."

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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 1

' PAGE 3 0F 23 Concerns:

IN-86-036-001

" Electrical conduits in Units 1 and 2 are overfilled. This may cause induction / heat problems.

Some cables may also have been damaged by pulling in these tight conditions,_and by using excessive force in installing fish tape in the conduits."

2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Documentation Identifiers:

o Identified by Black & Veatch Finding Report G901 Date 11/02/82 (O o Identified by Nuclear Safety Review Staff Report (NSRS) 1-85-569-WBN, " Cable Overheating and Fire s Retardant" Date 11/20/85 o Identified by Nuclear Safety Review Staff Report (NSRS)

' I-85-705-WBN, " Cable Overheating Due to Fire Retardant" Date 11/19/85 o Identified by Nuclear Safety Review Staff Report (NSRS)

I-85-299-WBN, " Cable Overheating Due to Fire Retardant" Date 12/10/85 o Identified by Nuclear Safety Review Staff Report (NSRS)

I-85-766-SQN, " Proper Cable Derating" Date 03/07/86 03670 (02/13/87)

TVA EMPLOYEE CONCERMS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: I a

PAGE 4 0F 23 3.. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE' IDENTIFICATIONS STAltu IN ELtritNT:

Valcoat, Vermasco, and Vamasco for WBNP. (Vimascoisthecorrect' name 'of the cable coating compound used at WBNP.)

4. INTERVIEW FILES REVIEWED:

The following files were reviewed and no additional information for Sequoyah was identified for the concerns addressed in this report.

IN-85-122 _IN-86-254 WI-85-100 IN-85-272 IN-86-262 IN-85-289 IN-86-036 File IN-86-036 contains additional information for concern IN-86-036-001 regarding conduit numbers. This information, however, is specific to WBN.

F'h 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

-See Appendix A.

! 6. WHAT REGULATIONS, LICENSING COMITMENTS, 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.

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.TVA EWLOYEE CONCERNS. REPORT NUMBER: 240.0(8)

SPECIAL PROGRAM REVISION NUMBER: 1

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PAGE 5 0F 23

18. - ! EVALUATION PROCESS:

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

b. Reviewed FSAR to establish commitments for cable installation and fill requirements.

c. Reviewed engineering design standards and design criteria for cable sizing to assess their adequacy.

d. Reviewed existing Institute of Nuclear. Power Operations (INPO), NSRS, and other TVA reports (e.g., I-85-766-SQN) and findings on cable derating to determine the extent to which iU they satisfy the concerns and whether corrective actions have P

been identified.

e. Reviewed existing TVA Construction, QA/QC. 0perations, and e TVA Material Control Reports for the TVA Employee Concerns Special Program for applicability to the concerns discussed

~p.

in this report.

Reviewed derating test reports on cable coating compound and i f.

firestop sealing material (silicone foam)~and their effect on cable ampacities.

A

g. Reviewed design drawings and TVA Construction procedures and kJ specifications to determine requirements for installation of cable tray penetration firestops and cable coating compound.

h. Assessed overal1 adequacy of the cable derating practices and installation and identified areas that require further investigation.

1. Performed SQN walkdown to assess adequacy of installation to design.

9. DISCUSSION, FINDINGS, AND CONCLUSIONS:

[

Chronology:

[.

09/28/76: TVA conducts derating test for cables transitioning l

firestops to determine the optimum foam depth l

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• TVA EW LOYEE CONCERNS REPORT NUMBER: 240.0(B)-

SPECIAL PROGRAM REVISION NUMBER:. 1

• PAGE 6 0F 23 TVA issues memo to SQN and WBN transmitting details.

01/17/77:' fo reconsnended firestops

-t.

11/02/82:

Black & Veatch performs review at WBN and identifies areas of the plant that did not meet FSAR commitment ~

for 6.9 kV cable separation (ampacity) 11/08/83:

A TVA Task Force reviews and responds to the Black &

Veatch finding concerning the 6.9 kV cable separation and cable coating 1985: Six employee concerns are issued 11/20/85: MSRS Report I-85-569 concludes that cables in VI,' V2, and V3 trays had been bundled and coated with fire retardant compound and reconimends. a review of the present installation to determine whether a' problem exists 03/07/86: NSRS Report I-85-766-SQN states that no evidence was found to justify cable ampacity and derating factors

o. in the V-3 trays f '"'

01/06/86: Office of Engineering issues calculation 843 860117 924 justifying the existing design standard ampacity tables t

! Significant Condition Report (SCR) SQNEEB8620 R1 01/07/86: indicates that abandoned cables' in cable trays were not tracked. Engineering Report SCR SQNEEB8620 R1 indicates that unlabeled and untracked abandoned cables existed and tray fill criteria were violated 04/10/86: SCR SQNEEB8620 R1 indicates that abandoned cables in cable trays were not tracked. Engineering Report SCR SQNEEB8620 Rl' indicates that unlabeled ~and untracked abandoned cables existed and tray fill criteria were violated SCR SQNECB8601 R0 indicates that the cable tray fill 06/17/86:

design criteria were exceeded. Engineering Report 1 SCR SQNECB8601 R0 indicate that there were no known violations of tray fill criteria TVA issues new design standard DS-E12.6.3 which 09/02/86:

supersedes existing ampacity tables and establishes new requirements for derating cables 03670. (02/13/87)

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TVA Ef9LOYEE' CONCERNS. REPORT IM BER: '240.0(B) 7 :SPECIAL PROGRAM REVISION NUMBER: -1 PAGE 7 OF 23 TVA issues memo to all nuclear. plants to provide ~

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10/07/86: direction and guidance in the performance of corrective. action for ampacity and to establish a

-sampling program to determine the adequacy of installed cables Discussioni Problems regarding cable derating and cable coating derating

- (Issues "a" through "c") are discussed-in this report. . Issue "d" dealing with conduit overfill and cable damage is addressed in Sequoyah-Element Report 238.1(B)

The sizing and derating of cables installed in raceway is the

• - responsibility of the design _ engineer. _ Failure to properly size cables could result in excessive heat buildup in the raceway and eventual cable failure or fire. In general, the employee concerns 4

question the adequacy of. cable sizing with and without appifcation 2

of fire-retardant' cable coating compound.

a. Cable Ampacity and Cable Derating 4

Cables in Firestops. TVA conducted an ampacity test for

firestoppenetrationsfromOctober5to23,1976(App.A, 5 99). This test concluded that no cable derating was a

required for penetrations using 12 inches of silicone foam (Dow-Corningnumber3-6548). The fire test was conducted M- .

because Electrical Design Standard DS-E12.1.2, (App. A, 5.rr, El . 09/28/76) Rev. O, did not address the additional derating requirements for cables transitioning firestop penetrations

• ( App. A, 5.hh, 02/10/77). A TVA memo from Chandler to Pierce-(App. A,' 5.11, 01/17/77) on the ampacity test results

~ indicated that the optimum depth of the firestop sealant (silicone foam) material was one foot, and a revision to design depths was required to seal cable penetrations. This memo transmitted recommended design information for firestop details to be used for installation in cable tray

[ penetrations on the SQN and WBN projects.

The evaluator compared the TVA test procedures and results

_ with tests performed by Detroit Edison and published November

' 1981 in IEEE Transaction of Power Apparatus and System r ( App. A, 5.kk) . The results of these tests were similar and i' supported TVA's conclusion that no additional derating is

required.

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n REPORT NLMBER: 240,0(B)-

' TVA EW LOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: '1 PAGE 8 0F 23 Conduits are sealed for smoke and hot. gases in accordance .

with SQN drawing 45W880-26,' Firestop Penetrations. This

. drawing requires a depth of sealant (RTV silicone) from 1/2 inch to a maximum depth of 2 inches. The maximum depth of 2 inches is less than the 12 inches tested for the silicone foam'and, therefore, would not require any additional derating.

The TVA test used a test configuration of 30 percent tray

- fill through the penetration. However, the TVA tests do not consider the effect of tray overfill on ampacity. A TVA memo from Raughley to Those Listed (App. A, 5.s, 10/07/86) requests all nuclear plants to conduct a sampling program to evaluate actual installation and to determine effects on cable ampacity. Completion of this program should-address overfill in penetrations.

Cables in Raceway.. The Black and Veatch Finding Report, Finding No. G901, on the review at Watts Bar (App. A,-5.a, 11/02/82) identified areas of the ' plant that did not meet an FSAR commitment for 6.9 kV physical cable separation, and hm.

noted that these cables were coated with a " fire resistive compound" (Vimasco). (The cable coating material used at SQN

• is Flamemastic.)

The TVA Task Force for Review of Black & Veatch Findings, d1 Category 39 Evaluation Sheet (App. A, 5.b.11/08/83) for

( Sequoyah, indicated that the FSAR comitment for separation of 6.9 kV cables was intended to reduce the electromotive force (EMF) between phases under load and to provide a more conservative design for heat dissipation. However, the Task Force concluded that no credit far this separation was taken for cable derating. The task force also addressed the issue I

dealing with the cable coating, which is discussed in "b" below.

A field walkdown (App. A, 7.b) at SQN revealed that the 6.9 kV cable installation in trays was in compliance with the G-38 Specification (App. A, 5.uu). Cables 2/0 and smaller were randomly laid whereas larger cables were in groups of three. No cable bundles were noted.

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e-TVA EWLOYEE CONCERNS REPORT NLMBER: 240.0(B)- '

SPECIAL PROGRAM REVISION' NUMBER: -1 PAGE 9 0F 23 >

The NSRS' Report No. I-85-766-SQN (App. A, 5.g, 03/07/86)

< cited the Bellefonte Electrical Evaluation Report, Finding E-3 (App. A, 5.pp, 01/85): "No documentation was found.to justify the cable ampacity and derating factors'in the application of _ voltage-level V3 (control level) cables in 60- ,

percent filled trays;" Finding E-5: ' " Electrical Design Standards for all current carrying ampacities are not correct for all voltage levels;" and INPO review of the Bellefonte ,

Project Report, Finding DC3-1 ( App. A, 5.qq, 03/84): "Some electrical calculations were not performed and others did not address-all design conditions," e.g., low voltage cable sizing adequacy, and inclusion of the effect of conduit grouping on cable ampacity.

4 The NSRS report indicated that since the design standards and process for cable sizing are basically the same for all of TVA's nuclear plants the findings were applicable for SQN.

As a result, the Office of Engineering (OE) performed an evaluation of SQN to document the basis for the design

- standard used for cable sizing, the adequacy of the existing  ;

design, and the need for additional studies. OE issued  !

Off calculation 843 860117 924 (App. A, S.y, 01/16/86)in i response to the Bellefonte Review Team finding and concluded  :

L that the ampacities presented in TVA Electrical Design  !

Standards DS-E12.1.1, 12.1.2, 12.1.3, and 12.1.4 are acceptable for all previous designs.

) The cable ampacity issue is further complicated by the ,

uncertainties regarding actual raceway fills. This has been t addressed by TVA in the following documents: ,

o Significant Condition Report SCR SQNECB8601 R0 (App. A, 5.k,06/27/86) indicated that the cable tray fill design criteria were exceeded. Engineering Report SCR '

SQNECB8601 R0 (App. A, 5.m) indicated that there were no known violations of tray fill criteria.

[ o Significant Condition Report SCR SQNEEB8620 R1 (App. A, f 5.q,04/10/86) indicated that abandoned cables in cable trays were not tracked. Engineering Report SCR SQNEEB8620 R1 (App. A, 5.r 05/20/86) indicated that I unlabeled and untracked abandoned cables existed and tray fill criteria were violated.

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i TVA EWLOYEE ~ CONCERNS REPORTNUMBER'!240.0(B)

SPECIAL PROGRAM REVISION NUpBER: 1  ;

PAGE 10 0F 23 o Significant Condition Report SCR SQN EEB8601 R0-(App.iA,'

5.n,01/07/86) indicated that verified cable weights and outside diameters were'not available. Engineering Report SCR SQNEEB8601. R0 (App. A, .5.p, 04/16/86) agreed with the' SCR and included a list of verified cable data that was used in issuance of new design standards for cable DS-E12.1.13 and DS-E12.1.14.

Although the extent of raceway overfill problem is discussed in detail in Element Reports 238.l(B), 238.3(B), and.-

~

239.0(B), the effect of the overfill on ampacity is addressed in this report.

Office of Engineering calculation- 843 860117 924-(App. A, 5.y, 01/16/86) was issued to justify the ampacity tables in Design Standards DS-E12.1.1 through E12.1.4. No evidence was found by the evaluation team that any type of-review was to be conducted to verify that the derating of the-installed cables was in accordance with these tables. ~As a result of-on-going Employee Concern Task Group investigations of ampacity concerns, calculation 843 860117 924 was

(,7 reevaluated,andamemofromRaughleytoThoseListed(App.

A,5.1,08/06/86) was issued to distribute a Problem:

r Identification Report (PIR) GENEEB8605 to.all nuclear plants. This PIR indicated that the design standards are incomplete, lack the definition and information required for proper application, and are supported by incorrect calculations. The proposed corrective action in the PIR was l

to revise the design standard criteria to reflect the minimum requirements necessary to properly size cables for all applications.

TVA issued a new Electrical Design Standard DS-E12.6.3 (App.A,5.h,09/02/86), applicable to all TVA plants. This design standard supersedes Design Standards DS-E12;1.1, DS-E12.1.2, DS-E12.1.3, and DS-E12.1.4 and establisnes new requirements for sizing control and power cables for installation in conduits and cable trays. It also gives

detailsonadditionalderatingforcablecoating) and conduit arranagement (duct banks and exposed compounds 2

Review of this design standard by the evaluation team

determined that although it identifies tray covers and fire

- wrapping material, it does not actually provide standards for derating. Also, design standard DS-E12.6.3 indicates that i

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TVA EMPLOYEE C0kCER.E REPOR1 T"~ TR: 240,0(B)

SPECIAL PROG' TAM REVISIOS NUMBEk: 1

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PAGE 110F P3

.A the worst-case configuration of conduits of six wide.

horizontdly the tables forand V4onr. decpVvertically)was

' v5 (480 used No

- 6.9 kV r. ables. to estaolish justification was given as to why this configuration was chosen since the other configurations la the table in Section 3 show more conservative values.

On the basir of the above discussion and with consideration of the uncertainity of the current cabl t ins'fallation with regard to their ampacities, a corrective act1on was established through a TVA memo from Raughley to Those Listed (App. A, 5.s, 10/07/86). The memo was issued to all nuclear plants to P ovide direction and guidance in the performance of corrective action for caale ampacity, and to establish a s sampling prt; gram to determine the adequacy of installed cables with respect to their empacity rating. The memo o

supplecents DS-E12.6.3 and addresses the derating of cables installed in cable trays with solid tup and bottom covers and in trays covered or enclosed in Appendix R fire wrap materials. As stated in this memo, the information regarding covers and fire wrap will be incorporated in the next

, ('.. revision of Dasign Stadard DS-E12.6.3. This nnmo does not specifically address the sampling or evaluation of. overfilled ,

g raceway. ,

Although this memo provides instructions for a:!ditional derating resulting from the fire wrap materials, a test

}9 conducted by Thenal Science, Inc. at Underwriters Laboratory (UL)onSeptmber 28-29,1906 (Ref. mailgram App. A, 5.tti determined that the ' ire protection material Thermo-Lag 330 may require derating figures greater than those indicated by a previous test. ThernwLag 330 is useo at SQN, and the revised derating for a 1-hr rating was shown to increase from 12.5 percent to 28 percent and for a 3-hr rating from 20.5 percent to 31 percent. When the official UL report is issued, Thermal Science Inc. will evaluate this report and revise Thermo-Lag 330 derating values as required.

b. Bundling of Cables and F'repep;f Coatin.1 NSRS Reports I-85-299-WB 12/10/85, I-85-705-WBN 11/19/85, and I-85-569-WBN 11/20/85 addressed application of the cable coating compound used at Watts Bar Nuclear Piset. Reports I-85-299-WBN ( App A, 5.f) and I-85-705-H2N ( App A, 5.e) reference Report I-85-569-WBN (App A, 5.c), which covers the bunching of cables and application of the fire-retardant coating for WBN.

0367D (02/13/87)

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.y e TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

%- PM ' , ,

SPECIAL PROGRAM W%( gf c ,

REVISION NUMBER: '1 h;,9 f PAGE 12 0F 23 ,

~,

f Report I-85-569-WBN concluded that Voltage Level VI, V2, and e V3 trays (Control and Instrumentation) were bunched together for ease in application of the fire-retardant coating, and this configuration was approved for cable installation in VI,

~

, 5.nn,04/27/81), but not in V2,andV3traysforWBN(App.A,(App.A,5.mm).

V4 (480 V) and V5 (6.9 kV) trays Installation requirements for General Construction Specification G-38, Section 3.2.1.8 (App. A, 5.uu, 03/17/86) state that cable shall be placed in trays "in a neat and orderly fashion." However, no design or installation criteria regarding cable bundling at SQN were identified.

The evaluation team observed during the SQN plant walkdown (App. A, 7.a, 10/09/86) that one 480 V (V4) tray (GG-A, Node 103-104) had all of the cable bundled in the middle of the tray and coated with Flamemastic. This bundling of cable a creates.a cable depth greater than the depths established in d Insulated Cable Engineers Association (ICEA) P-54-440 standard and Design Standard DS-E12.6.3. The ICEA established depths ara based upon a depth of cables randomly routed in the cable tray, not bundled in the middle.

Therefore, the applicability of the ICEA standard to a

( bundled configuration is indeterminate.

t Regarding cable coating, NSRS Report I-85-569-WBN noted that even though there was no evidence to conclude that application of Cable coating WOuld cause overheating, the

( effect of the coating on ampacity was not specifically Q documented for all applications. This supported the WBN pre-INPO Finding PDC 3-4.F (App. A. 5.00, 11/06/85) that necessary documentation has not always been developed to support design criteria and to qualify designs.

The NSRS report recommended a review of present cables with the application of the coating compound to determine or document that no problems exist.

SQN Report GCA-03-49 ( App A, 5.w, 06/06/86) addresses the effect of the coating compound (Flamemastic 77) used at SQN on cable derating. This report referenced two Joslyn Research Tests (App. A, 5.cc, 09/09/77 and 5.dd, 02/24/86) conducted on Flamemastic for coating thickness up to 2 inches. The results of these tests indicated a maximum

/ derating of 5.80 percent for Flamemastic 77, and 9.16 percent for Flamemastic 71A for a 2-inch thickness. The Joslyn 02/24/86 TestReport(App.A,5dd)revisedthederatingof I. ,

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TVA EMPLOYEE CONCERNS' REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION' NUMBER: 1- l I PAGE 13 0F 23 1/4 inch of Flamemastic h upward from 1.41 percent to 2.2 percent. Cables installed in the plant were covered with Flamemastic 77 cable coating compound, at a thickness of 3/16 inch + 1/16 inch. )However, additional cables were added to these trays after the initial application of coatings.

The new cables were then coated, creating coating thicknesses greater than originally tested (1/4-inch).

The Joslyn test (App A, 5.dd) did not address coating applied on top of existing coated cables when additional cables were installed. In this configuration, the existing TVA standard 3/16-inch coat is combined with a new coat of 3/16-inch, so the total thickness could ' exceed 3/8 inch. A TVA memo from Killian to Chandler (App A, 5.gg, 11/09/76) indicated that

} "any buildup of Flamemastic also causes a significant increase in temperatures," when used on cable firestop q penetrations and " extreme care is required during application to reduce the number of these hot spots."

Cable ampacity tests conducted in 1986 (App. A, 5.dd) with a

.s coating depth of 2 inches exceed any probable thickness the

! bs.,y coating could reach during plant construction since this

?- would require the application of at least 10 coats of

$' material to equal the 2-inch thickness tested. The derating presently indicated in Design Standard DS-E12.6.3 has been '

' revised upward to better reflect the probable present thickness of greater than 3/16 inch that may be installed in the plant. Also, these derating values tables for thickness

.. from 1/8 to 2 inches are more conservative than those

! indicated in the Joslyn test.

. Instrument Readings .

The NSRS I-85-569-WBN (App. A, 5.c) report also indicated that the concern related to indeterminate instrument readings l

resulting from cable overheating could not be substantiated l

because the instrumentation system is low current and, l

therefore, does not result in overheating of instrument cables or cause indeterminate readings. The evaluating team agrees with NSRS conclusion regarding instrument readings.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(8)

SPECIAL PROGRAM REVISION NUMBER: 1 f

PAGE 14 0F 23 Findings:

a. Although TVA has demonstrated by test that no additional cable derating is required for cables transitioning firestops, no evaluation or test has been conducted on overfilled cable trays in firestops. In view of the current uncertainity regarding adequate deratings of installed cables, TVA has now initiated a sampling program to determine-the extent and effect of tray covers and fire. wraps on cable

. ampacity. No specific requirements were identified for the sampling program to include evaluation of overfilled raceways.

The originally issued Design Standards DS-E12.1.1, E12.1.2, E12.1.3, and E12.1.4 did not furnish the definition and L information necessary for proper application.of the ampacity tables.. In' September 1986, TVA issued Design Standard i DS-E12.6.3 which voided these existing design standards. The

- new standard reflects the new QA cable data shown in Design Standards DS-E12.1.13 and DS-E12.1.14 as well as application 3

' for derating cables for tray covers, coating compound, and ~

c- Appendix R fire wrap (App. A, .5.s). The new design standard, W however, does not justify why a conduit configuration of six p' wide horizontally ampacity tables for and one V4 and VSdeep 480 V(vertically was and 6.9 kV) established for cables.

b. The use of Flamemastic cable coating compound on cables has y

y been tested by an independent ~1aboratory, and cable derating values have been established. TVA has incorporated the

[ derating values.into Design Standard DS-E12.6.3 to be used f

for cable sizing. Since the values used in the design standard are more conservative (greater) than the values

[ established by test, the implementation of the design L' standard values represents acceptable practice. Therefore, i cables coated witt. Flamemastic will not be degraded by L

overheating.

As noted during a field walkdown at the SQN plant, some V4 f (480 V) cables were bundled in the center of the tray and l

l coated with Flamemastic. Therefore, the adequacy of applying ICEA standards for the derating of bundled V4 (480 V) cables cannot be determined.

c. Because they have low current levels, instrument cables are not overheated. lherefore, no effect is imposed on instrument readings by cable heating.

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'TVA EMPLOYEE-CONCERNS.

REPORT NUMBER: 240.0(B)

SPECIAL' PROGRAM REVISION NUMBER: :1.

'PAGE 15 0F.23- .

Conclusion:

The issues expressed in the employee concerns'are valid to the.

extent that the cable derating and sizing did not properly address. )

the cable tray fill', cable coating compound, cable bundling, overfilled trays in firestops,-tray covers,-and Appendix R fire wrap at the time the concerns were expressed. TVA has-since recognized the problem areas and has initiated corrective actions, except for derating for overfilled raceway, cable bundling, and

- overfilled. raceway in firestops.

Satisfactory completion of current corrective actions and establishment of corrective actions for the outstanding items, will adequately address the cable derating problem. Proper application of Design Standard DS-E12.6.3 should prevent recurrence of similar problems, provided the derating value assumption for the conduit arrangement of six wide and one deep is adequately' justified.

_10. CORRECTIVE ACTION:

.(73 Corrective action plans (CAPS) have been generated by TVA as

' identified by TCAB-053, dated 12/18/86 (App. A, 5.yy) and TCAB-075, dated 02/14/87 (App. A, 5.zz) .in response to four general categories of problems identified in CATDs 240.00-SQN-01, -02, -03, j' and -04. The four general issues are:

a. 240.00-SQN-01 : No evaluation / test conducted on overfilled cable trays in firestops was identified.

The new Design Standard DS-E12.6.3 does not

b. 240.00-SQN-02:

justify worst case conduit configuration of six wide horizontally and one deep vertically for ampacity tables on V4-V5 (480 V - 6.9 kV) cables.

c. 240.00-SQN-03: V4 (480 V) power cables are bundled in trays and coated with Flamemastic. The configuration creates cable depths greater than ICEA-P-54-440 and DS-E12.6.3 established depths.

d. 240.00-SQN-04: The cable derating in overfilled raceway has Current sampling program for determining not been evaluated.

the adequacy of electrical cables with respect to their ampacities does not specifically require sampling of overfilled raceways.

0367D (02/13/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 1 i I

PAGE 16 0F 23 The CAP for CATD 240.00-SQN-01 states:

"The fire stop test configuration will be reviewed to determine the effect of overfilled conditions on the allowable ampacity of the cables. An appropriate derating factor will be determined to ensure that cables in an overfilled firestop do not exceed their qualified insulation temperature rating. All SQN power cables trays which pass through a fire stop and exceed the

. maximum established fill will be determined. The.

ampacity of all cables (safety-related and nonsafety-related routed with safety-related

[ associated]) in these trays will be verified using the established derating and DS-E12.6.3. All other power cable trays which pass through fire stops will have-I' their tray fill frozen at or below the maximum established value."

This action is an acceptable solution to the problem.

g

- The CAP for' CATD 240.00-SQN-02 states

1 . (k..

"DNE calculation EEB-CSTF-0001 titled ' Methodology Used as a Basis for Cable Ampacities Shown in TVA Electrical b

Design Standards DS-E12.6.3' will be revised to add an appendix titled ' Documentation and Justification of Assumed Worst Case Conduit Grouping (1 Vertical

(-

6 Horizontal, 0.86 Multiplying Factor).'"

This action is an acceptable solution to the problem.

The CAP for CATD 240.00-SQN-03 states:

"An analysis will be performed to determine the effect on the ampacity of a cable due to bundling the cables in a portion of the tray, as opposed to spreading them out over the full width, as well as the application of multiple coats of fire retardant cable coatings. The analysis will be based on data on overfilled trays in calculation SQN-E2-017 which was prepared for SCR Installation spec. G-38 SQNEEB8620 and SCR SQNCEB8622.

-[" will be revised to mandate installation over the full tray width. All discrepancies discovered during this review will be documented on an SCR."

This action is an acceptable solution to the problem.

i l 0367D (02/13/87) l L

j 7 '

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)1 SPECIAL PROGRAM REVISION NUMBER: 1

.i PAGE 17 0F 23 -

The CAP for CATD 240.00-SQN-04 states:.

"The determination of the effects of overfilled tray ~

raceways will be limited to V4 level cables. Cables in V5 level trays, above size 2/0 are installed with maintained spacing. .The ECTG verified by field inspection that V5 level cables were properly-installed. Cables in V3 trays were shown in calculation EEB-CSTF-001 to have sufficient margin to be independent

- of the expected variations in tray fill.

The ampacities of cables in V4 tray in DS-E12.6.3 are based on a maximum fill of'30 percent. All safety-related and associated nonsafety-related cables routed in V4 trays which exceed 30 percent will be individually reviewed to ensure that they will not '

operate above their qualified insulation temperature rating. The technical basis for this evaluation will be ~

DS-E12.6.3, IPCEA P-54-440 and IEEE Transactions Paper 70 TP-557-PWR.

f N# In order. to have an accurate database on which to evaluate tray fill, corrective action for the following must be completed before this effort can begin.

-1. ECTG CATD 239.00-SQN-01

2. ECTG CATD 239.00-SQN-03

3. PIR SQNEEB8754

4. ECTG CATD .109.00-NPS-05 for verified cable 0.D.'s Design standard DS-E12.6.3 will be revised-to include the derating effects of overfilled trays-in firestops.

Completion of items 1-4 above will ensure that an accurate database exists by which to limit tray fills to the predetermined maximum."

This action is an acceptable solution to the problem.

i.

l.

I E .

0367D (02/13/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM 1' REVISION NUMBER:

PAGE 18 0F. 23 APPENDIX A

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

a. Black and Veatch Finding Report G901, (11/02/82)

b. TVA Task Force for Review of Black and Veatch Findings - Task Force Category 39 for Sequoyah Nuclear Plant Units- 1 and 2 Rev.1, '(11/08/83)

c. Nuclear Safety Review Staff Report I-85-569-WBN, " Cable Overheating and Fire Retardant Coating," (11/20/85)

d. TVA memo from Cottle to Whitt, (No RIMS), " Response to NSRS Report I-85-569-WBN," (01/30/86)

e. Nuclear Safety Review Staff Report I-85-705-WBN, " Cable Overheating Due to Fire Retardant," (11/19/85) s f.

Nuclear Safety Review Staff Report I-85-299-WBN, " Cable Overheating Due to Fire Retardant," (12/10/85)

, p, 7.

g. Nuclear Safety Review Staff Report I-85-766-SQN, " Proper g

Cable Derating," (03/07/86)

h. Electrical Design Standard DS-E12.6.3, R0 (805 860905 501),

y$ " Cable, Ampacity Tables For Auxiliary and Control Power 4 Cables (0-15,000V)," (09/02/86)

1. TVA memo from Raughley to Those Listed, (842 860808 908),

"All Nuclear Plants - Problem Identification Report PIR GENEEB8605," (08/06/86)

TVA memo from Raughley to Those Listed (No RIMS), "Ampacity J. of Power Cables in Duct Bank," (05/30/86)

k. Significant Condition Report SCR SQNECB8601 R0, (B42 860707 014), " Cable Tray Fill Design Criteria Exceeded,"

(06/27/86)

m. Engineering Report SQNECB8601 R0, (S56 860804 820), " Cable Tray Design Criteria Exceeded," (08/04/86) l 03670 (02/13/87)

1 REPORT NUMBER: 240.0(B)

TVA EMPLOYEE CONCERNS REVISION NUMBER: 1 PAGE 19 0F 23 APPENDIX A (cont'd)_

n. .Significant Condition Report SCR SQNEEB8601 R0, (843 860117 919), " Cable Weights and Outside Diameters Not Available from a QA Source," (01/17/86)

p. TVA memo from Wilson to Brimer, (B25 860416 007), "Sequoyah Nuclear Plant Units 1 and 2 - Engineering Report for CAQ Report No. SCR SQNEEB8601 R0, Rev.1," (04/16/86)

q. Significant Condition Report - SCR SQNEEB8620 R1, or identifying. abandoned cables in cable trays), (04/1 I r.

TVA memo from Wilson to Brimer, (825 860520 002),

" Engineering Report - SCR SQNEEB8620R1, Rev. O, " Cable Tray h Loading" (No method of tracking or identifying abandoned cables in cable trays)," (05/20/86)

) TVA memo Raughley to Those Listed, (843 861008 909), "All s.

Nuclear Plants - Corrective action and Sampling Program For J" Electrical Cable Ampacity," (10/07/86) b4 t

t. Letter from Mills, TVA, to Denton, NRC, (L44 841018 800)," Fire Retardant Coating - Vimasco &

Flamemastic," (10/18/84) 3 W Sequoyah Generic Concern Task Force Report GCA-01-46, (No 7 u.

RIMS), " Overfill of Cable Trays and Conduits," (05/20/86)

J v. Sequoyah Report GCA-03-48, (No RIMS), " Plant Procedures on Overfill of Cable Trays," (04/25/86)

w. Sequoyah Report GCA-03-49, (No RIMS), " Thickness of Fire Protection Coating on Cables," (06/06/86)

x. Sequoyah Report GCA-04-50, (No RIMS), " Cable Tray Fill Criteria"

y. Office of Engineering Calculation B43 860117 924,

" Justification For Use of TVA's Ampacity Tables," (01/16/86)

z. Office of Engineering Calculation B43 860331928,

" Determination of Class lE Electrical Cable Weight / Foot and Outside Diameter," (03/31/86) aa. Electrical Design Standard DS-E12.1.13, (805 860423 501),

l " Cable, Class lE Cable 00s and Weights," (04/15/86) 0367D (02/13/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 20 0F 23 APPENDIX A (cont'd) bb.. Electrical Design Standard DS-E12.1.14, R0, (805 860429 505),

" Cable, Class NC Cable ODs and Weights," (04/15/86) cc. Joslyn Research Center, " Test Report .- The Effect of Flamemastic 77 Fire Protective Coating on the Ampacity of A Grouped Power and Control Cable Assembly Tested for the Flamemaster Corporation, Sun Valley, California, Test Number 77-098," (09/09/77) dd. Joslyn Corporation, " Test Report of The Effect of Flamemastic 71A and Flamemastic 77 Fire Protective Coatings on the Ampacity of a Grouped Power and Control Cable Assembly Tested for the Tennessee Valley Authority, Knoxville, Tennessee, Test Number 85-033," (02/24/86) ee. TVA memo from Beasley to Vineyard, (B05 860214 001),

"Sequoyah Nuclear Plant - QA Review of Operational Readiness - NSRS Open Items - Surveillance Report No. S86-10" h ff. Watts Bar Nuclear Plant FSAR, Section 8.3.1.4.1, " Cable Derating and Cable Tray Fill" gg. TVA memo from Killian to Chandler, (WBN 761111 013), " Watts Bar Nuclear Plant - Sequoyah Nuclear Plant Units 1 and 2 -

Cable Sleeve Penetration Tests," (11/09/76) 3 1

h h .- TVA memo from Sudduth to Electrical Engineering Files, (EEB 770211908), "Sequoyah Nuclear Plant Units 1 and 2 -

Evaluation of Test Results of Cable Ampacity. Tests for Completed Fire Stop Penetrations," (02/10/77) ii. TVA memo from Chandler to Pierce, (EEB 770118 910), "Sequoyah Nuclear Plant Units 1 and 2 - Design of Electrical Fire Stop Penetrations," (01/17/77) jj. IEEE Transaction on Power Apparatus and Systems, Volume 90/1971, (IEEE paper 70 TP557 PWR), "Ampacity For Cables in Randomly Filled Trays By J. Stolpe", (January-June 1971)

I 03670 (02/13/87)

F TVA EMPLOYEE CONCERNS- REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: l' PAGE 21 0F 23- .

APPENDIX A (cont'd) kk. IEEE Transaction of Power Apparatus and System, Volume PAS-100, No.11, 4680-5, "Ampacity Test of a Silicone Foam Firestop in a Cable Tray," Detroit Edison Co., (Nov 1981) mm. TVA Design Information Request - Wilkins to Cantrell-(WBN 810729162) "4 Voltage Level Cable Grouped - Designed Information Request (DIR) - No. E-56" (07/29/81). Response-

- to DIR (SWP 81 0902 028) nn. TVA Design Information Request - (WBN 810427101) " Cable Grouped in Tray-and Coated with Vimasco - Design Information Request (DIR) - No. E-55," (04/27/81).

l oo. TVA memo from Lyons to Coan (B49 851106 001), " Watts Bar Nuclear Plant - Pre-INP0 Design Evaluation," and attached Pre-INPOreport,(11/06/85) i pp. Bellefonte Electrical Evaluation - January 1985 qq. Bellefonte Nuclear Plants, Units 1 & 2, Tennessee Valley

@) Authority - March 1984 i Electrical Design Standard DS-E12-1.2, R0, " Cable .- Conductor rr.

Current Carrying Capacity Cross-Linked Polyethylene Insulated 4

1 Cable (0 - 15,000 V), (09/28/76) a ss. Insulated Cable Engineers Association ICEA Pub. No. P-54-440,.

"Ampacity, Cables in Open-Top Cable Trays, August 1979" tt. Mailgram Rubin Feldman to Bechtel Power Corp. Re: Thermo-Lag 330, dated 10/02/86 uu. General Construction Specification, G-38, Rev. 8, " Installing Insulated Cables Rated up to 15,000 volts" (03/17/86) i vv. TVA SQN Drawing 45W880-26 (Sheet 26) Rev.19, " Conduit and Cable Tra Grounding Sheet 13," -(07/18/85)ys - Fire Stop Penetrations Detail ww. Electrical Design Standard DS-E13.5.1, R0, " Raceways, Electrical Penetration Firestops and Pressure Seals,"

(12/05/77) i I

l l

03670 (02/13/87) 1

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 'l PAGE 22 0F 23 APPENDIX A (cont'd) xx. 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 yy. Letter from G. R. McNutt, TVA, to G. L. Parkinson, Bechtel, TCAB-053, " Corrective Action Plan," date 12/18/86

22. Letter from G. R. McNutt, TVA, to G. L. Parkinson, Bechtel, TCAB-075, " Corrective Action Plan," date 02/14/87

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

a. FSAR 8.3.1.4.1 - Cable Derating and Cable Trey Fill

b. Engineering Design Standard - DS-E12.1.13, Rev.1, (01/13/86) b- c. Engineering Design Standard - DS-E12.1.14, Rev.1, (01/13/86)

! d. Engineering Design Standard - DS-E12.6.3, Rev. O, (09/02/86) y e. SNP Inspection Instruction No. A4, Rev. 9, (06/16/83) b

? f.

SNP Construction Procedure No. E-10, Rev. 2, (09/06/79)

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

a. Field Walkdown at Sequoyah site conducted by Jack Wheeler (Bechtel), and George Bell (TVA) 10/09/86.

b. Field Walkdown at Sequoyah site conducted by David Knudsen (Bechtel) (11/21/86)

.:j 03670 (02/13/87)

TVA EMPLOYEE CONCEP.NS REPORT NUMBER: 240.0(B)~

-SPECIAL PROGRAM REVISION. NUMBER: 1 1

PAGE 23 0F 23 ,

CATO LIST The following CATDs identify and provide corrective actions for the findings in this report:

240 00 SQN 01 (CAP revised 02/13/87) 240 00 SQN 02 (CAP revised 02/13/87) 240 00 SQN 03 (CAP revised 02/13/87) 240 00 SQN 04 (CAP revised 02/13/87)

(

i 1

I 03670 (02/13/87) i

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TENNESSEE VALLEY AUTHORITY PAGE -

151 REFERENCE - ECPS120J-ECPS121C RUN TIME - 12:57:19 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER .)

- 1 ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

• RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 24000 CABLE AMPACITY 3

I S GENERIC KEYHORD A i

4 H APPL QTC/NSRS P KEYHORD B SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C i CONCERN KEYHORD D-

! HUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION

-) "VALCCAT", USED TO FIREPROOF ELECTRI NONCONFORMANCE IN 272-004 EN 24000 N HBN YNYY I-85-299-HBN SR CAL CABLE IN BOTH UNITS, MAY CAUSE C' CONST PROCESS T50088 REPORT ABLES TO OVERHEAT CAUSING DEGRADATIO ELECTRICAL .I

) N OF THE CABLE INSULATION. CABLE 24000 N HBN YNYY I-85-705-HBN SR VERMASCO HAS APPLIED TO CABLES PREMA NONCONFORMANCE IN 289-006 EN TURELY. PENETRATIONS AND CONDUITS H CONST PROCESS .

T50167 REPORT 9 J ERE SEALED. VERMASCO HAS DETERMINED ELECTRICAL TO KEEP HEAT IN AND DETERIORATED TH CABLE E INSULATION. THIS APPLICATION HAS DISCONTINUED 1 1/2 YEARS AGO BUT THE- ,)

3, VERMSCO ALREADY APPLIED HAS NOT BEE N REMOVED. BOTH UNITS. CONSTRUCTION DEPT CONCERN. CI HAS NO MORE INFOR MATION.

.]. .

)

IN 036-001 EN 23801 S HBN YYYY SR ELECTRICAL CONDUITS IN UNITS 1 & 2 A NDHCONFORMANCE 24000 K-FORM RE OVERFILLED. THIS MAY CAUSE INDUC CONST PROCESS T50189 EN ELECTRICAL TION / HEAT PROBLEMS. SOME CABLES MAY I

) ALSO HAVE BEEN DAMAGED BY PULLING I CONDUIT N THESE TIGHT CONDITIONS, AND BY USI NG EXCESSIVE FORCE IN INSTALLING THE FISHTAPE IN THE CONDUITS. DETAILS ,

KNOHN To QTC, HITHHELD DUE TO CONFID 1)

-)

ENTIALITY. CONSTRUCTION DEPT CONCER N. CI HAS NO ADDITIONAL INFORMATION

)

')

24000 N HBN YNYY SR ELECTRICAL CABLES ARE BUNCHED TOGETH NONCONFORMANCE 4

IN 254-005 EN ZR AND THEN COVERED HITH VAMASCO. T CONST PROCESS I T50208 REPORT d HE THICK COATING OF VAMASCO POTENTIA ELECTRICAL 3*

i > LLY CAUSES HEAT BUILD UP-HHICH MAY C CABLE AUSE FAILURE. THIS IS A GENERIC CON DITION THROUGHOUT UNITS I AND II. I T EFFECTS LOH, MEDIUM, AND HIGH VOLT 1

8 AGE CABLE. SPECIFIC AREAS IDENTIFIE )

D ARE THE AUX. BUILDING, ELEVATIONS

"" 757, AND 772. CI HAS NO FURTHER INF ORMATION. CONSTRUCTION DEPT. CONCER i, ' N. . .)

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152

- ECPS120J-ECPSI21C TENNESSEE VALLEY AUTHORITY

-)

REFERENCE FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN TIME - 12:57:19 RUN DATE - 12/02/86 ')

ONP - ISSS - RHM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 24000 CABLE AMPACITY KEYWORD A )

I S GENERIC KEYHORD B H APPL QTC/NSRS P CONCERN KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION S KEYHORD D NUMBER CAT CAT D LOC FLqB REPORT R -DESCRIPTION g)

) SR UNITS 182. THE OVERCRONDING OF CABL NONCONFORMANCE IN 262-002 EN 24000 N HBN YNYY I-85-569-HBN CONST PROCESS T50148 REPORT ES AND THE APPLICATION OF A FIRE RET ARDANT TO THE CABLES CAUSES AN OVERH ELECTRICAL .

3 EATING CONDITION THEREFORE MAKING TH INSTRUMENT / MECH E INSTRUMENT READINGS INDETERMINATE.

LOCATION EXAMPLE IS THE 737' ELEV, e-SPREADER ROOM. CONSTRUCTION DEPT C V I ONCERN. CI HAS NO FURTHER INFORMATI ON. NO FOLLOH UP REQUIRED SR CABLE AMPACITY PROBLEMS HHERE CABLE- NONCONFORMANCE .:

HI 100-009 EN 24000 N HBN YYYY CONST PROCESS .d s

REPORT DERATING HAS NOT PROPERLY CONSIDERED T50211 . CI HAS NO ADDITIONAL INFORMATION. ELECTRICAL ANONYMOUS CONCERN VIA LETTER. CABLE NONCONFORMANCE 7

) XX 122-027 EN 24000 N SQN YYYY I-85-766-SQN SS SEQUOYAH: CABLE AMPACITY PROBLEMS HH ERE CABLE DERATING HAS NOT PROPERLY CONST PROCESS T50215 REPORT ELECTRICAL CONSIDERED. CI HAS NO ADDITIONAL INF ORMATION. ANONYMOUS CONCERN VIA LET CABLE

?>

) TER.

YYYY I-8 5-772-BLN SR BELLEFONTE: CABLE AMPACITY PROBLEMS NONCONFORMANCE XX 122-028 EN 24000 N BLN HHERE CABLE DERATING HAS NOT PROPERL CONST PROCESS T50215 REPORT ELECTRICAL 9 3 Y CONSIDERED. CI HAS NO ADDITIONAL INFORMATION. ANONYMOUS CONCERN VIA CABLE LETTER.

SR BROHN'S FERRY: CABLE AMPACITY PROBLE- NONCONFORMANCE 9

) XX 122-029 EN 24000 N BFN YYYY I-85-976-BFN CONST PROCESS REPORT MS HHERE CABLE DERATING HAS NOT PROP T50215 ERLY CONSIDERED. CI HAS NO FURTHER ELECTRICAL INFORMATION. ANONYMOUS CONCERN VIA CABLE .'

• LETTER.

9 CONCERNS FOR CATEGORY EN SUBCATEGORY 24000

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