ML20212F438
| ML20212F438 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/23/1987 |
| From: | Joyce J, Mcnutt G, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20212F190 | List: |
| References | |
| 242.0(B), 242.0(B)-R02, 242.0(B)-R2, NUDOCS 8703050085 | |
| Download: ML20212F438 (23) | |
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,J < -TVA EMPLOYEE CONCERNS REPORT NUMBER: 2'.2.0 (B)
.SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 2 ,
TITLE: ELECTRICAL SEPARATION Inadequate Electrical and Physical Separation Between Redundant Hiring, PAGE 1 0F 21 Cabling, Equipment and Components REASON FOR REVISION:
- 1. Revised to incorporate TVA comments.
- 2. Revised to incorporate SRP/TAS comments, to include TVA's corrective action plan (see Section 10), and to include chronology.
J 7 PREPARATION-PREPARED BY:
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SIGNATURE DATE / SIGNATUled*/ DATE APPROVED B .
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'DATE' six MANAGER OF' NUCLEAR P0HER DATE CONCURRENCE (FINAL REPORT ONLY) ,
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SRP Secretary's signature denotes SRP concurrences are in files.
.! 8703050085 870226 l PDR ADOCK 05000327 PDR l P 1
.Lf- TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0 (B)
SPECIAL PROGRAM
,.. REVISION NUMBER: 2 PAGE 2 0F 21
- 1. CHARACTERIZATION OF ISSUE (S):
' Concerns: Issues:
HI-85-100-004 a. Review by independent consultant XX-85-122-011, 012, 013 required.to assess electrical and
" Electrical separation and- physical separation adequacy of physical separation of redund- redundant wiring, cable, and components ant wiring and cabling and for as well as equipment.
equipment and-components are inadequate at all plants. CI b. Inadequate separation in trays of expressed that detailed reviews Q and non-Q cables for all voltage need to be made, and are so levels as a result of procedures extensive that a consultant being violated.
probably should be used, providing independence from TVA." c. Cable trays are overloaded as a
. ' [IN-86-254-004 result of inadequate separation.
"CI believes procedures are being violated (in general) when Q and d. Inadequate cable arrangement results non-Q electrical cables are not in covers extending 3 to 4 inches being separated in cable trays, above trays.
This includes low, medium, and high voltage cables. By not k
separating the cables,-the trays are being overloaded."
IN-86-259-006 "Many electrical cables have been placed in cable trays without adequate separation.
Many cable tray covers extend 3.to 4 inches above the tray because of cable arrangement."
IN-86-314-004
" Cable separation is inadequate and in many cases nonexistent."
- 2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by NSRS and SCR SONEEB8634 Date For dates. see Documentation Identifiers below 1083d (02/17/87) t
, - m
TVA EMPLOYEE CONCERNS ~ REPORT NUMBER:' 242.0 (B)
SPECIAL PROGRAM
, REVISION NUMBER: 2 PAGE 3 0F 21 Documentation Identifiers:
o Identified by TVA SON NSRS Date February 27. 1986
'TVA SNP - Nuclear Safety Review Staff Investigation Report No. I-85-133-SQN, Electrical / Physical Seoaration of Redundant Circuit /Eauioment, (02/27/86) o Identified by'TVA SON SCR SONEEB8634 Date Aoril 30.1986 TVA SNP Significant Condition Report SONEEB8634, Minimum Seoaration pistance Between Different Divisional Cable Trav, R0, (04/30/86)-
- 3. DOCUMENT NOS.. TAG NOS.. LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
No further information available.
- 4. INTERVIEH FILES REVIEHED:
Files HI-85-100, XX-85-122, IN-86-254, IN-86-259, and IN-86-314 were reviewed and no additional unreviewed information for Sequoyah was identified for the concerns in this report.
- 5. DOCUMENTS REVIEHED RELATED TO THE ELEMENT:
See Appendix A.
- 6. HHAT REGULATIONS. LICENSING COMMITHENTS. DESIGN REOUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
- 7. LIST RE00ESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER RISCUSSIONS RELATED TO ELEMENT.
See Appendix A
- 8. EVALUATION PROCESS:
- a. Reviewed transcript of NRC investigative interview to extract information applicable to the employee concerns.
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i TVA EMPLOYEE CONCERNS: l REPORT NUMBER: 242.0 (BE SPECIAL PROGRAM
, . REVISION NUMBER: ';2-
~PAGE 4'0F 21~
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- b. _ Reviewed design criteria, FSAR, Westinghouse specification
^ criteria,- and any other applicable documents to establish extent of the' current Sequoyah Nuclear Plant Separation requirements.
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- c. . Reviewed SQN design documents'to determine compliance with the requirements.
- d. Reviewed existing reports (e.g., NSRS Report I-85-133-SQN),.
findings, and responses _ to f_indings to assess their adequacy.
and the extent to which they satisfy the employee concerns.
- e. -Reviewed available Construction, QA/QC, 0perations, and Material Control element reports for the :TVA Employee Concerns ,
Special. Program.
," f f. Performed walkdown~on. sample panels and trays to determine compliance with the separation criteria.
- g. Assessed overall adequacy of SQN separation program.
- 9. DISCUSSION. FINDINGS. AND CONCLUSIONS L '"
Chronoloav:
i-09/85: Concerns IN-86-254-004, IN-86-259-006, and IN-86-314-004 received by TVA for HBN 11/85: Concerns HI- 85-100-004 and XX-85-122-011, 012, and -013 -
received by TVA for HBN, SQN, BLN, and BFN 11/07/85: OE prepares calculations per 10 CFR 50.49(b) 12/13/85: Significant Condition Report HBNEEB8582 identifies problem at HBN regarding minimum separation distance o between different divisional cable trays as-a result of
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extended tray covers 12/19/85: TVA memo from Chandler to Those Listed requests Sequoyah to review the extended tray cover problem for potential applicability 12/23/85: TVA memo from Hall to Chandler indicates that raised tray cover condition did not exist at SON 02/27/86: Nuclear Safety Review Staff (NSRS) investigates the validity of employee Concern XX-85-122-01 for SQN 1083d (02/17/87) 1
- TVA EMP'LOYEE CONCERNS REPORT NUMBER: 242.0 (B) j
-SPECIAL PROGRAM
,. . REVISION NUMBER: 2 i PAGE 5 0F 21 04/30/86: Significant Condition Report (SCR) SQNEEB8634 is issued to address minimum separation distance between different divisional cable trays in the auxiliary ~
instrument room 06/30/86: OE issues calculations ~ to ensure that the associated
-circuits that fall under Appendix R program will have no-adverse effect on safety 07/08/86: Design input memo authorizes a minimum vertical separation of 1 foot for vertically stacked
- interdivisional trays in the auxiliary equipment room in response to SCR SQNEEB8634 and incorporates separation requirements for internal wiring Discussion:
The employee concerns raised several issues regarding inadequate physical and electrical separation between redundant Class lE equipment and wiring, and between class lE and non-class lE. There is a potential for loss of capability of redundant components to perform their intended safety function in the event of a common
/ failure of improperly separated wirir.g and equipment.
v N' SQN is not committed to comply with either Regulatory Guide 1.75' 3 (App. A, 5'.11; 02/74 and 09/78) or IEEE Standard 384-1974 (App. A, 5.vv). To establish independence and redundancy so as to prevent common failure modes in class lE systems, SQN is committed to the following standards:
, o IEEE Standard 279-1971, " Criteria for Protection Systems for Nuclear Power Generating Systems," states:
, "4.6 Channel Independence. Channels that provide signals for the same protective functions shall be independent and physically separated to accomplish decoupling of the effects of unsafe environmental factors, electric transients, and physical accident consequences documented in the design basis, and to reduce the likelihood of interactions between channels during maintenance operations.or in the event of channel malfunction."
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., TVA' EMPLOYEE CONCERNS REPORT NJMBER:. 242.0 (B)l SPECIAL PROGRAM
, REVISION NUMBER: 2 PAGE 6 0F 21
- g. _
o IEEE Standard 308-1971 "Critoria for Class 1E Electric
. Systems for Nuclear Power Generating Stations" states:
"4.6 Equipment Protection. Class lE electric equipment shall be physically separated from its redundant counterpart or mechanically protected as required to prevent the occurrence of common failure mode."
and "5.2.2(3) Independence. Distribution circuits to redundant equipment shall be physically and electrically independent of each other."
The evaluation team reviewed the issues presented in Section 1 to
' f assess the adequacy of the separation program at SON. Each issue is assessed below.
- a. Nuclear Safety Review Staff (NSRS) investigated the validity of employee concern XX-85-122-011 (see Section 1 for statement of concern). NSRS Report No. I-85-133-SQN on this
(' issue concluded that:
o Separation in the control room area appeared to meet t all aspects of the design criteria SQN-DC-V-12.2, Section 4.2.8.
o All redundant trays except KC-B in the auxiliary instrument room and HN-B in the cable spreading room met the design criteria SQN-DC-V-12.2 requirement for solid tray bottoms and tray covers for redundant trays at crossover points.
o Physical separation as defined in design criteria SQN-DC-V-12.2 was met for the 6900V and 480V shutdown
! boards, reactor MOV boards, reactor vent boards, I control and auxiliary vent boards, 125V vital batteries and vital battery boards, and vital inverters.
Based on its investigation, the NSRS recommended installation of covers on trays KC-B and HN-B in accordance with the design criteria requirements. The NSRS also recommended clarifying the design criteria for separation of cable trays in the auxiliary instrumentation room. A TVA review revealed that the minimum separation of vertical stacked i interdivisional trays in the auxiliary instrument room was 12 inches instead of 3 feet as required by the design 1083d (02/17/87) k
TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0-(B)
SPECIAL~ PROGRAM
, REVISION NUMBER: ~ 2-
. PAGE 7 0F 21 -
-criteria. Consequently, Significant Conditio'n Report (SCR)
SQNEEB8634 RO was issued. The Engineering Report (ER) for this SCR concludes that this condition has no adverse effect on safety and can be resolved by a revision to the design criteria. A design input memo (DIM), Raughley to Electrical Engineering Files (App. A, 5.1; 07/08/86), authorized a-minimum vertical separation of-12 inches for vertically stacked interdivisional trays in the auxiliary instrument room, providing the trays are furnished with solid bottoms and covers. The authorization was based on judgment that.
hazards in the auxiliary instrument room are minimal.
The NSRS conclusion that redundant trays are adequately separated was confirmed by three walkdowns of the spreading and auxiliary equipment rooms by the evaluation team (App. A, 7.b, 7.c, and 7.d). With minor exceptions, r-separation in the auxiliary instrument room is in compliance with the design criteria as modified by the prev _iously discussed DIM. Isolated instance was identified during the walkdown where apparent discrepancies exist between the as-installed condition and the design criteria. Trays above cabinets R11 (XY-1, stacked about 32 inches below XZ-3) and R13 (XZ-2, stacked about 3 feet below XZ-4) have no covers.
\
Similarly, the evaluation team verified the NSRS conclusion of adequate physical equipment separation by a sample review of TVA drawings: 47H200-3 for 6900 volt and 480 volt shutdown boards, and 47H200-2 for 120 volt vital inverters.
The evaluation team noted that separation of this equipment conforms to the design criteria requirements.
The NSRS investigation did not cover separation aspects such as separation between divisionalized and nondivisionalized
, cable trays, cable separation in free air, physical separation of wiring and components internal to panels, and electrical isolation.
A' No SQN commitments were identified regarding separation between divisionalized and nondivisionalized cable trays.
Although the separation design criteria are silent in this area, the NRC concluded in SQN Safety Evaluation Report (SER) paragraph 8.5.3 that adequate provisions were made to satisfy its concern regarding nondivisional cable trays routed between redundant divisional cable tray stacks. These provisions included coating all cables in the spreading room and providing sprinklers. No minimum spatial separation requirements were given.
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.j TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 8 0F 21 A walkdown by the evaluation team (App. A, 7.d; 10/09/86) identified a nondivisional cable tray riser, AAP, whose cables were in direct contact with divisional tray NO-A (elevation 734 feet, at the floor penetrations between columns A3 and A4 at Q line). All cables were coated with fire retardant material, and the adequacy of this configuration from a separation standpoint appears to satisfy the SER commitments.
Furthermore, the effect of non-class IE system failures on class 1E systems has been addressed by the following:
o The TVA analysis SQN APPR-1 (App. A, 5.y; 06/30/86),
and the corrective actions that resulted from this analysis (covered by ECNs L6313 and L6315), were
, performed to ensure that the " associated circuits" that f fall under the Appendix R program will have no adverse effect on safety.
o An analysis performed for nonsafety-related equipment located in harsh environments (App. A, 5.k; 11/07/85) concluded that no environment-induced failure to this equipment could prevent accomplishment of required
( functions by safety-related equipment.
Similarly, no specific commitments were identified for redundant cable separation in free air. The only reference to this is in paragraph 8.5.3 of the SQN SER and the paragraph only addresses unsupported cable bundles running vertically between cable trays in the same stack. The NRC concludes in the SER that cable coating with fire retardant material adequately addresses this situation. Coating exposed cable surfaces is described in Section 4.2.5 of the
, separation criteria. However, Revision 6 of the criteria indicates that after 10/18/84 cables qualified to IEEE 383 flame test or equivalent do not require coating. The only other place in the criteria where cable separation in free air is addressed is in the second paragraph in Section 4.2.6, and that is limited to the cable spreading room. The criteria require a 3-foot minimum separation between cables of different divisions; otherwise cables must run in metal conduits or enclosed wireways. Walkdowns by the evaluation team of the auxiliary instrument room (App. A, 7.b, 7.c and 7.d) identified cables leaving cable trays LT-A and LT-B (above cabinet 1R48) and going to conduits about i foot 1083d (02/17/87) 1
TVA EMPLOYEE CONCERNS' REPORT NUMBER: 242.0 (B)
SPECIAL PROGRAM
, REVISION NUMBER: 2 PAGE 9 0F 21
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i above.these trays that are within 6 to 9 inches of cables of.
a redundant division. The adequacy of the separation between these cables, since they are located outside the cable spreading room and are coated with fire retardant material,.
appears to satisfy the intent of the_SER commitment.
However, some inconsistency is evident considering that cables in free air in the cable spreading room must comply with separation requirements yet no criteria are provided for separation of cables in free air in the auxiliary instrument room and other plant areas.
The previously identified DIM-(App. A, 5.1; 07/08/86) incorporates SQN separation requirements for internal wiring into Design Criteria SQN-DC-V-12.2. The evaluation team, however, interpreted this as applicable only to the shunt
" I trip circuitry of the~ reactor protection system. In addition to this, a Hestinghouse specification (App. A, 5.e; 07/30/71) provides requirements for separation of internal wiring and components for main control boards. A walkdown of boards 1-M-4,-1-M-5, 1-M-6, 0-M-26, and 1-L-llA by the evaluation team-(App. A, 7.a; 02/27/86) confirmed that the internal
- separation is in accordance with Westinghouse requirements.
,, \l Although there is a commitment in FSAR Section 8.3.1.4.6 to separate internal wiring in all class lE control boards, panels, and relay racks, it is unclear why the commitment was limited to Westinghouse panels and systems.
Design Criteria SQN DC-V-12.2 does not include requirements for separation of internal wiring for all class 1E control boards, panels, and relay racks as stated in the FSAR, and no commitment / requirement (C/R) data sheets on this subject could be found.
Similarly, limited commitments exist for electrical isolation between redundant circuits and between Class lE and Non-Class IE circuits. Although these conmitments have been identified in commitments / requirements (C/R) data sheets, they are not currently reflected in the separation design criteria, as required by SQN Engineering Procedure SQEP-29.
These commitment / requirements are,:
o C/R No. SQN EEBPBN1002 identified a commitment in SNP FSAR Amendment 2, Section 7.1.4.2.1, to define functional, qualification, testing and detailed technical requirements for the TSC/SMS isolators.
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3c iTVA EMPLOYEE CONCERNS ~ . REPORT NUMBER:s 242.0 (B)-
. .=
- SPECIAL PROGRAM .
r -
REVISION NUMBER:-.2 PAGE!10l0F~21?
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o C/R No. SON EEBPBN1085~ identified a ~ commitment in the-
< SER.(03/79), Section-7.2.2-to. upgrade the reactor.
coolant pump underfrequency;and undervoltage trips in .
- the reactor trip tsystem to class '1E. - In addition, the underfrequency and;undervoltage
- trips were relocated
. from'the-nonseismic Category I Turbine Building _to:the seismic Category I Auxiliary Buil_ ding.-
o SQN EEBPBN1134 identified a commitment in SER Section 7.3.2 (03/79) to ensure.that inter-train.
interlocks are designed so that.a-failuretin one train will not adversely affect the safety function of the redundant train. The SER reported that the' emergency core cooling and other. Engineered' Safety Features.(ESF) systems were reviewed and several valves were foundlto-be interlocked with valves'in the' redundant train.
' -[ Analysis'showed that the safety system function _could-still be-accomplished even if a failure of the interlock occurred. This commitment which was the same for. Watts Bar, was properly addressed in WBN FSAR-Section 7.1.2.4, but was not included in the SNP FSAR.
Eff o SQN EEBPBN1082 identified a commitment in SNP FSAR Q Amendment 2 Section 7.6.7.1 to ensure that a failure in the nonclass 1E portion of the low temperature interlocks for the Reactor Coolant System (RCS)-
pressure control will not prevent the protective system from performing its protective function. This is accomplished by use of isolation devices in the output-to the interlocks from the protection set racks.
,~
o SQN EEBPBN1013 identified a commitment in FSAR i Amendment 2, Sections 7.2.1.1.8 and'7.2.2.2.3(5), to
, design and qualify isolation amplifiers for the reactor trip system so that a failure in the nonprotective signal circuits will not prevent the protective system from performing its protective function. The i[ nonprotective signal circuits are used for control, indication, and computer monitoring and are derived from protection channels through isolation amplifiers.
- b. Separation requirements for nonsafety-related cable routed in i the same cable tray with safety-related cable are adequately i addressed in design criteria SQN-DC-V-12.2 and i
SQN-DC-V-11.3. Routing of Q and non-Q cables in the same
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.e TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0 (B)
SPECIAL PROGRAM
, REVISION NUMBER: 2:
PAGE 110F 21
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raceway is allowed under the provisions of design criteria SQN-DC-V-12.2,.Section 4.4.1. However,_SQN-DC-V-12.2 does
-not permit a non-Q cable, once routed in a Q tray, to be-subsequently routed in a Q tray containing cables of another division. Similarly, design criteria SQN-DC-V-11.3 has adequate provisions for separating cables of different voltage levels. Consideration of these two criteria is built into the SQN cable routing program. However, although no violations of compliance to these criteria have been identified,- the current lack of verification of this cable routing program results in uncertainties regarding the status of installed cables and makes compliance to these two criteria indeterminate. '(Verification of the cable routing i
program and adequacy the of status of installed cables is discussed in more detail in Sequoyah Element Report.239.0.)
_" f c. Failure to provide adequate separation does not of itself cause cable tray overfilling (overloading). Not exceeding cable tray fill limit is a requirement independent of
. separation. Cable tray overloading / overfilling is addressed in Sequoyah Element Report 238.3.
- d. SCR HBNEEB8582 identified a problem at Hatts Bar Nuclear
, Plant similar to the employee concern regarding inadequate cable arrangement that results in covers extending 3 to 4
, inches above the crossover trays. A TVA memo from Chandler i to Those Listed (App. A, 5.v; 12/19/86) requested Sequoyah review this problem for potential applicability. The problem was reviewed for applicability to Sequoyah, and it was determined that the condition did not exist (Hemo from Hall
, to Chandler, App. A, 5.w; 12/23/85).
During two walkdowns of the cable spreading room and
. auxiliary instrument room (App. A, 7.b and 7.d), the evaluation team observed that separation between covered trays complies with the requirements stated in the design criteria. As noted during these walkdowns, cable tray covers were properly installed (special cable tray cover installation details are described in E-45H880-27, R3,
[ App. A, 5.xx; 04/16/86]), and no raised covers were noted on safety-related cable trays.
i 1083d (02/17/87) 4
TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0 (B)
SPECIAL PROGRAM c REVISION NUMBER: 2 PAGE 12 0F 21 Findinas:
- a. Review of the adequacy of the electrical and physical separation at Sequoyah revealed that:
o SQN is committed to comply with IEEE Standards 279 and 308 for independence and redundancy, but not committed to Regulatory Guide 1.75 or to IEEE Standard 384.
o The HSRS conclusion that divisionalized cable trays are adequately separated in compliance with design criteria was confirmed by walkdowns by the evaluation team, with two minor exceptions where cable tray covers should have been installed but were not.
, o Separation of divisionalized and nondivisionalized
' ( cable trays appears to satisfy SER commitments. Design criteria documents are silent in this area, o Separation of redundant cables in free air appears to satisfy the intent of SER commitments. No criteria could be found for separation of cables in free air except for those in the cable spreading room.
o Separation of internal wiring in specific j Hestinghouse-furnished control boards was confirmed, i during walkdowns, to comply with design criteria.
However, no design criteria were fcund for wiring separation in other class IE control boards, panels, and relay racks as committed in the FSAR.
o Electrical separation and isolation commitments on C/R data sheets have not been reflected in the separation
. design criteria,
- b. Lack of verification of the currently as-installed status of cables in raceways makes compliance to the design criteria N and procedures indeterminate. The status of cables in raceways is addressed in Sequoyah Element Report 239.0.
- c. Cable tray overloading is not a result of inadequate separation. The cable tray overloading is addressed in Sequoyah Element Report 238.3 (B).
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.... TVA EMPLOYEE CONCERNS REPORT NUMBER: 242,0 (B)
SPECIAL PROGRAM
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.. REVISION NUMBER: 2 PAGE 13 0F 21
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- d. No evidence was found during the walkdowns'to indicate that inadequate cable arrangement caused covers to extend above safety-related cable trays.
Conclusions:
The concerns questioning the adequacy of physical and electrical '
separation are valid to the extent that criteria documents do not reflect commitments regarding separation of internal wiring in class 1E control boards, panels, and relay racks or electrical isolation. Also, adequacy of as-installed cable separation in raceways could not be verified. Separation criteria for cables in free air were applied inconsistently since requirements for separation were found for the cable spreading room but not for other plant areas.
(
- 10. CORRECTIVE ACTION In response to the problems identified by the CATD, TVA has generated corrective action plans (CAPS) submitted by TCAB-032 dated 12/15/86, TAB-070 dated 02/04/87, TCAB-072 dated 02/09/87, and
.. TCAB-078 dated 02/17/87 (App. A 5.yy, 5.zz, 5.aaa, and 5.bbb).
i a. CATD 242.00-SON-01 indicated that electrical separation and 4 isolation commitments on C/R data sheets have not been 1 reflected in separation design criteria. TVA agreed in the CAP to review all commitments / requirements (C/Rs) in analysis report number 39, " Electrical Separation," and revise design criteria to ensure that all commitments for electrical separation and electrical isolation of circuits are included.
In addition, TVA will also review the design output documents to ensure that all design criteria have been incorporated. TVA will also ensure that actual installation agrees with the design output documents. CAQs will be generated as needed if deficiencies are found.
h b. CATO 242.00-SQN-02 identified design criteria documents regarding separation requirements for cables in free air only in the cable spreading room, not for other plant areas. TVA i committed to perform an evaluation to determine licensing commitments relating to cable separation in free air in general plant area. Separation requirements will take into
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,,' REVISION NUMBER: 2~
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consideration licensing commitments to keep adequate independence to satisfy single failure' criteria requirements.
In addition, TVA will determine if Design Criteria SQN-DC-V-12.2 need to be revised to address separation of safety related cable in free air and/or if a justification needs to be provided for not requiring cable separation in free
- air. TVA also committed to review design output document to ensure that all design criteria requirements have been incorporated. TVA will ensure that actual installation agrees with the design output documents. CAQS will be generated as needed if deficiencies are found.
- c. CATD 242.00-SQN003 identified isolated instances where:
, o Cable trays LA-A and LT-B above cabinet R48 are 1 foot apart horizontally but have no covers.
t o Trays above cabinets R11 (XY-1, stacked about 32 inches below XZ-3) and R13 (XZ-2, stacked about 3 feet below XZ-4) have no covers. These cases are not in compliance with design criteria requirements for tray separation.
The evaluation team concurs with TVA's statement in the CAP i
that 1-foot horizontal separation, with no stipulation for h covers, is allowed by Design Criteria SON-DC-V-12.2 for cable a trays LT-A and LT-B. Also, the CAP indicates that Problem i Identification Report (PIR) SQNEEB86175 has been generated to identify and document the specific separation problem between cable trays of Channels I, II, III, and IV, as mentinned in the CATD. An Engineering Change Notice will be generated to install the tray covers and bottoms on these cable trays to
! satisfy the separation criteria. PIR SONEEB86175 R1 addressing a generic discrepancy between the design criteria and the
. 45N880 series drawings resulted in a revision to these drawings that eliminated the discrepancy.
TVA also indicated that the complete 45h880 series drawings
/ were thoroughly studied and walkdowns performed as needed to determine the extent of this potentially generic problem. This covered all areas of the plant that had cable trays installed e except the area inside the steel containment of the reactor building (these trays are nonclass 1E). !
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. TVA EMPLOYEt. CONCERNS REPORT NUMBER: 242.0 (B)
SPECIAL PROGRAM
,, REVISION NUMBER: 2 PAGE 15 0F 21
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In addition, TVA performed a field walkdown in all areas where there was a question of train or channel interaction (separation, crossing, etc.), a question of barriers, or where there was a lack of dimensioning on the drawings. The walkdowns revealed that no other cases exist where covers have not been installed per design criteria and/or 45N880 drawings requirements.
In the course of the TVA field walkdown, it was found that trays (channel separation group) running vertically pass within 3 feet of trays (train separation group) running horizontally.
This situation is not specifically addressed in the design criteria intent or the FSAR. As a result, TVA committed that the licensing commitments will be reviewed and barrier criteria requirements consistent with current commitments will be established. Tray covers will be installed if required, and
, f design output documents will be revised accordingly. ,
- d. CATD 242.00-SON-04 stated that the design criteria do not include FSAR commitments for separation of internal wiring in class lE control boards, panels, and relay racks. TVA committed in the CAP to review SQN Final Safety Analysis Report
( (FSAR) Chapters 7 and 8 and the C/R data base to ensure that
(" all electrical commitments and requirements for internal separation are included in Design Criteria SON-DC-V-12.2.
TVA will revise design output documents to ensure that all design criteria requirements are included. Furthermore, TVA will ensure that the actual installation agrees with the design output documents. CAQs will be generated as needed if deficiencies are found.
The evaluation team concurs that the corrective action plans
, adequately address the problems in the CATDs, and adherence to the implementation schedule will close the issues of electrical separation.
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.- . TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0 (B)
- SPECIAL PROGRAM
.. . ~ REVISION NUMBER: 2 PAGE 16 0F.21 APPENDIX A
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- 5. DOCUMENTS REVIEMED RELATED TO THE ELEMENT:
- a. NSRS Report I-85-133-SQN, " Electrical / Physical Separation of Redundant Circuit / Equipment," (02/27/86)
- b. SON Design Criteria for Separation of Electric Equipment and Hiring (SQN-DC-V-12.2), R6, (09/30/85)
- c. SQN Design Criteria for Normal and Emergency Ac Auxiliary Power System-(SQN-DC-V-II.4.1), R2, (07/22/86)
' f e. Westinghouse Specification Criteria for Internal Hiring (678855), R0, (07/30/71)
- f. Hiring Diagram, Control Boards Critical Hiring Braid Installation (E-45H1640 R3), (05/3/84)
/ g. TVA memo from Young to Pedde, (BLN 850225 087), "BLN Office
( ,. of Construction (OC) Action Team Response to Electric Report," (02/25/85)
" Employee Concern XX-85-122-001 - Electrical and Physical Separation of Redundant Circuits and Equipment," (05/05/86)
, i. TVA memo from Hilson to Raulston (B25 860509 004) SQN -
SCR SONEEB8634 R0, (05/09/86)
. j. SCR SQNEEB8634 R0, " Minimum Separation Distance Between Different Divisional Cable Trays," (04/30/86)
- k. OE Calculation, "Nonsafety-Related Electrical Equipment Important to Safety per 10CFR50.49(b)," (B25 851107 300),
(11/07/85)
- 1. TVA memo from Raughley to Electrical Engineering Files (843 860710 921), " Design Input Memo on Separation of Electrical Equipment and Hiring Design Criteria SQN-DC-V-12.2," (07/08/86)
- m. Letter Mills to Adensam (A27 840827001), " Design Information of Reactor Trip System Resulting From NRC Questions on Generic Letter 83 Salem ATHS Events," (08/27/84) 1083d (02/17/87)
)
4 : .- TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 17 0F 21
. w.
APPENDIX A (cont'd)
- n. TVA memo from Standifer to Ennis, "Hatts Bar Nuclear Plant -
Addendum to Employee Concern Investigation Report I-86-570-HBN," (01/02/86)
- o. TVA memo from Standifer to Ennis, "Hatts Bar Nuclear Plant -
Employee Concern Investigation Report Number I-85-570-HBN,"
(12/13/85)
- p. TVA memo from Ennis to Standifer, "Hatts Bar Nuclear Plant -
Employee Concern Investigation Report Transmittal," (11/15/85)
< q. TVA memo from Chitwood to Raulston and Standifer, (B43 860224 940), "Hatts Bar Nuclear Plant Units 1 and 2 -
i., f Significant Condition Report No. SCR HBNEEB8582," (02/24/86)
- r. NRC-01E Reportability Information Distribution (B45 860206 828), SCR HBNEEB8582, " Minimum Separation Distance between Different Divisional Cable Tray Crossings,"
(12/31/85)
- s. TVA memo from Chitwood to Raulston, (843 860124 930)
) "
"10CFR50.55(e) Final' Report on Subject SCR," (01/24/86) l t. Significant Condition Report HBNEEB8582 (843 851219 906),
" Minimum Separation Distance Between Different Divisional Cable Tray," (12/13/85)
- u. Mechanical Layout of Control Boards Drawing Nos.
M4 47H605-10 R19, M4 47H605-13 R13, M4 47H605-14 R21, M4 47H605-19 R10, and M4 47H600-55 RIO
- v. TVA memo from Chandler to Those Listed, (843 851219 905)
" Potential Generic Condition Evaluation," (12/19/85)
I w. TVA memo from Hall to Chandler, (B25 851226 013), " Response to Memo From Chandler to Those Listed," (12/23/85) i- x. Drawing 47H200-2, " Equipment plan - El. 749.0 and Above,"
R13, Drawir.g 47H200-3, " Equipment Plan - El. 734.0 and El.
732.0," R15
- y. OE calculations, " Analysis of Ac/Dc Instrument and Control (I&C) Power System to Identify Associated Circuits," 10CFR50, Appendix R. (843 860630 901), (06/30/86)
, 1083d (02/17/87)
I
e
...- TVA EMPLOYEE CONCERNS ' REPORT' NUMBER: 242.0 (B)
SPECIAL PROGRAM
,y- REVISION NUMBER: 2 PAGE 18 0F 21 APPENDIX A (cont'd)
- z. TVA memo to Cox from Hosely, (B21 860723 002), "BLN NCR's 919 and 1040," (07/27/86) aa. NCR 3686 R0, (BLN 841109 107), (11/01/84) bb. TVA memo to Hodges from Cox, BLN NCR 3865, (BLN 850117 114),
"Bellafonte Nuclear Plant - Nonconforming Condition Report (NCR) 3865," (01/17/85)
N cc. TVA memo to Hodges from Cox, BLN NCR 2295, (BLN 840418 109),
"Bellafonte Nuclear Plant - Nonconforming Condition Report (NCR) 2995," (04/17/84) 3 , f dd. C/R No. SQN EEBPBN1085 (source of C/R SER 3/79) ee. C/R No. SQN EEBPBN1134 (source of C/R SER 3/79) ff. C/R No. SQN EEBDRH1065 (source of C/R SER 3/79) gg. C/R No. SQN EEBDRH1063 (source of C/R SER 3/79) hh. Letter from B. J. Youngblood, NRC, to S. A. White, TVA (B45 860714 832), with the attached transcript of the l- ,
investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN (06/23/86)
- 11. Regulatory Guide 1.75, R0 and R2, " Physical Independence of Electric Systems," (02/74 and 09/78) jj. C/R No. SQN EEBPBN1002 (Source of C/R FSAR Amendment 2,
. Section 7.1.4.2.1, page 7.1-19, paragraphs 5 and 7)" TSC/SMS Isolators - Define Functional, Qualification, Detailed i
Technical Requirements (e.g., maximum Cred. Voltage) and Testing Requirements" kk. C/R No. SON EEBPBN1085 (Source of C/R SER 3/79) "Undervoltage and Underfrequency Trips Upgraded to Class 1E and Hoved to 4 Auxiliary Building to Satisfy NRC Requirements Heets IEEE 279"
- 11. C/R No SON EEBPBN1134 (Source of C/R 3/79) " Assurance That Intertrain Interlocks Are Designed Such That a Failure in One Train Hill Not Adversely Affect Devices in Other Train"
(
1083d (02/17/87) i1
. l
..' TVA EMPLOYEE CONCERNS REPORT NUMBER: ~242.0 (B)
SPECIAL-PROGRAM
- ' REVISION NUMBER: 2 l
l r PAGE 19 0F 21 ~
APPENDIX A (cont'd) mm.- C/R No.'SQN EEBPBN1082 (Source'of C/R FSAR Amendment 2 Section 7.6.7.1) "A Failure in the Non IE Part of the Low Temperature Over Press Circuit Hill Not Harm the Protection Set Because of Isolation Device" nn. C/R No.-SQN EEBPBN1013 (Source of C/R FSAR Amendment 2, Sections 7.2.1.1.8 and 7.2.2.2.3[5]) " Design Bases and
' Qualification Testing Requirements for Reactor Trip System Isolation Amplifiers"
, oo. TVA memo from Raughley to Those- Listed, (843 860619 913),
- "EEB Efforts Relative to Design, Baseline, and Verification Program," (06/18/86)
IEEE-279-1971, " Criteria for Protection System for Nuclear pp.
Power Generation Stations."-
qq. IEEE-308-1971, " Class lE Power Systems for Nuclear Power Generating Stations" 1 rr. Title 10 of the Code of Federal Regulations, Part 50, 10CFR50 Appendix A. " General Design Criteria 17," (07/07/71)
I '
ss. Title 10 of the Code of Federal Regulations, Part 50,10CFR50 Appendix R tt. SQN Safety Evaluation Report (SER) uu. Regulatory Guide 1.6, " Independence Between Redundant Standby (Onsite) Power Sources and Between Their Distribution Systems" I
vv. IEEE-384-1974, " Trial-Use Standard for Separation of Class IE
.l Equipment and Circuits" ww. SQN Engineering Procedure SQEP-29, " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant,"
- (07/18/86)
1 yy. TCAB-032, Corrective Action Plan (CAP) for Sequoyah Element Report 242.0(B), (12/15/86) l .
1083d (02/17/87)
m TVA EMPLOYEE CONCERNS _ REPORT NUMBER: 242.0 (B) j SPECIAL PROGRAM f., .
REVISION NUMBER: 2 PAGE 20 0F 21 h
APPENDIX A (cont'd) j zz. TCAB-070, Corrective Action Plan (CAP) for Sequoyah Element Report 242.0(B), (02/04/87) aaa. TCAB-072, Corrective Action Plan (CAP) for Sequoyah Element Report 242.0(B), (02/09/87) bbb. TCAB-078, Corrective Action Plan (CAP) for Sequoyah Element Report 242.0(B), (02/17/87)
- 6. WHAT REGULATIONS. LICENSING COMITNENTS. DESIGN RE0VIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
, f Equipment and Hiring," R6, (09/30/85)
- b. SQN Design Criteria SQN DC-V-11-4.1 " Normal and Emergency Ac Auxiliary Power System," R2, (07/22/86)
- c. IEEE-279-1971, " Criteria for Protection System for Nuclear Power Generating Stations"
~
) ,
- e. IEEE-308-1971, " Class lE Power Systems for Nuclear Power Generating Stations"
- 7. LISI_RE_00ESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
- a. Walkdown performed by J. Wheeler, Bechtel, and N. Black, TVA,
, (BLT-080), (08/23/86) j b. Halkdown performed by J. Benkert, Bechtel, and H. Liao, TVA, (IOM 557), (09/17/86) g
- c. Walkdown performed by J. Benkert, Bechtel, and C. Dodson, TVA, (IOM 556), (09/18/86) 3
- d. Walkdown performed by J. Wheeler, Bechtel, and G. Bell, TVA, (BLT-061), (10/09/86) d' 1083d (02/17/87)
)
a
- /-
TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0 (B)'
SPECIAL PROGRAM i
REVISION NUMBER: 2 PAGE 21 0F 21 1
(. ; . i CATD LIST The following CATDs identify and provide corrective actions for the findings included in this report:
242 00 SON 01 (02/07/87; CAP revised 02/13/87)
, 242 00 SQN 02 (02/07/87; CAP revised 02/06/87) 242 00 SON 03 (02/07/87; CAP revised 02/04/87) 242 00 SQN 04 (02/07/87; CAP revised 02/06/87) b.
4 4
)
s 1083d (02/17/87)
n .
REFERENCE - ECPSI20J-ECPS121C TEri!!ESSEE VALLEY AUTHORITY PAGE -
156 FREQUENCY - REQUEST OFFICE OF NUCLEAR P0HER RUN TIME - 12:57:19
) ONP - ISSS - RHM EMPLOYEE C0t4CERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86.
LIST OF EMPLOYEE CDitCERN IllFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUSCATEGORY: 24200 ELECTRICAL SEPARATI0tl S GENERIC KEYHORD A H APPL QTC/NSRS P KEYl!ORD 9 C0tiCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYWORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYNORD D
)
IN 254-004 EN 24200 N HBN N !! Y Y SR CI BELIEVES PROCEDURES ARE BEING VIO NONCONFORMANCE T50203 REPORT LATED (IN GENERAL) HHEN Q A!!D NON-Q C0tlST PROCESS ELECTRICAL CABLE ARE NOT BEING SEPAR ELECTRICAL
-I ATED IN CABLE TRAYS. THIS INCLUDES CABLE LON, MEDIUM, AND HIGH VOLTAGE CABLE.
BY NOT SEPARATING THE CABLE, THE T RAYS ARE BEING OVERLOADED. CI HAS N
-) 0 FURTHER INFORMATION. CONSTRUCTION DEPT. CONCERN.
IN 259-006 EN 24200 N HBN NNYY I-85-570-NBN SR MANY ELECTRICAL CABLES HAE BEEN PLAC HONCONFORMANCE
-3 T50149 REPORT ED IN CABLE TRAYS HITHOUT ADEQUATE S C0tlST PROCESS EPARATION. MAtlY CABLE TRAY COVERS E ELECTRICAL XTEND 3 TO 4 INCHES ABOVE THE TRAY B CABLE ECAUSE OF CABLE ARRANGEMENT. CONSTR
! UCTION DEPT. CONCERN. CI HAS ADDITI DNAL INFORMATION. NO FOLLOH-UP REQU' IRED.
IN 314-004 EN 24200 N HBN NNYY I-85-706-HBN SR CABLE SEPARATI0ft IS IrlADEQUATE AND I NONCONFORMANCE T50165 REPORT N 11ANY CASES NONEXISTENT. CONSTRUCT CONST PROCESS 1011 CONCERil. C/I HAS NO ADDITIONAL ELECTRICAL INFORMATION. SEPARATION r
HI -8S-100-004 EN 24200 N llBN YYYY SR ELECTRICAL SEPARATION AND PHYSICAL S NONCONFORMAtlCE T502Il K-FORM EPARATION OF REDUNDANT HIRING AtID CA CONST PROCESS BLING AND FOR EQUIPMENT AND COMPONEN ELECTRICAL .,
TS ARE INADEQUATE AT ALL PLANTS. CI CABLE EXPRESSED THAT DETAILED REVIENS !!EE D TO BE MADE, AND ARE SO EXTENSIVE T HAT A C0tlSULTANT PROBABLY SHOULD BE USED. PROVIDING IllDEPE!!DENCE FROM T VA. CI HAS NO FURTHER INFORMATI0tl.
ANONYMOUS CONCERN VIA LETTER.
XX 122-011 EN 24200 N SQN YYYY I-85-133-SQN SS SEQUOYAH: ELECTRICAL SEPARATION AND N0tlCONFORMANCE T50214 REPORT PNYSICAL SEPARATI0tl 0F REDUNDANT HIR C0tlST PROCESS ING AND CABLING AFID FOR EQUIPMENT AN ELECTRICAL D Cor:PONENTS ARE INADEQUATE AT ALL P CABLE LANTS. CI EXPRESSED THAT DETAILED R EVIENS NEED TO BE HADE, AtID ARE S0 E XTENSIVE THAT A C0tlSULTANT PROBABLY SHOULD BE USED, PROVIDING INDEPEtIDEN CE FORM TVA. CI HAS NO FURTHER INFOR MATION. ANONYMOUS CONCERN VIA LETTE ,j 7 R.
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- REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -
157 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:57:19
-) ONP ISSS - RfC1 .. EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & CUTPUT SUBCATEGORY: 24200 ELECTRICAL SEPARATION I S GENERIC KEYWORD A H APPL QTC/NSRS P KEYWORD B CONCERN SUB R PLT B B S II INVESTIGATION S CONCERN KEYWORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYMORD D 3
XX 122-012 EN 24200 N BLN YYYY I-ES-121-BLN SR BELLEFONTE: ELECTRICAL SEPARATION AN HONCONFORMANCE T50214 K-FORM D PHYSICAL SEPARATION OF REDUNDANT H CONST PROCESS IRING AND CABLING AND FOR EQUIPMENT ELECTRICAL 3 AND COMPONENTS ARE INADEQUATE AT ALL CA5LE
~
PLANTS. CI EXPRESSED THAT DETAILED REVIENS NEED TO BE MADE, AND ARE SO s
EXTENSIVE THAT A CONSULTANT PROBABL Y SHOULD BE USED, PROVIDING INDEPEND ENCE FROM TVA. CI HAS NO FURTHER I NFORMATION. ANONYMOUS CONCERN VIA L
- ETTER.
g ,
XX 122-015 EN 24200 N BFN YYYY I-85-I49-BFN SR BROHN'S FERRY: ELECTRICAL SEPARATION N0!!CONFORMANCE T50214 K-FORM AND PHYSICAL SEPARATION OF REDUNDAN CONST FROCESS T HIRING AND CABLING AltD FGE CUUIPME ELECTRICAL
) NT AND CGMPONENTS ARE INADEQUATE AT AL L .Pi. ANIS . CI EXPRESSED TMAT DETAI CABLE LED REVIENS NEED TO BE MADE, AMD ARE
$3 EXTENSIVE THAT A CONS 3fl ui!T PROB 3 ABLY SMGGLD BE USED, PRC'dIDING INDEP ENDENCE FROM T9 5.. CI HAS NO FURTHE R INFORM 5 TION. Ah0NYMOUS CONCERM VI '
3 T. LETTER.
^-
7 CCMCERNS FOR CATEGCRY EN SUB % EGORY 24200 ,
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