ML20212H344
| ML20212H344 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/17/1986 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20212H304 | List: |
| References | |
| NUDOCS 8701210371 | |
| Download: ML20212H344 (25) | |
Text
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'O A-O COMANCHE PEAK RESPONSE TEAM RESULTS REPORT j
ISAP:
1.b.4
Title:
Barrier Removal REVISION 1
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saa ea, n-1,, -,.
Issue Coorginato#/
Date
/$ll!$h f
A
&^
view Leader Dat6
%G W izbr/ra JolM W. Beck, Chairman CPRT-SRT Date l
O 8701210371 870116 PDR ADOCK 05000445 A
PDR p.
. 9 Ravision:
1 Paga 1 of 24 RESULTS REPORT sO ISAP I.b.4 Barrier Removal *
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No.
7, Page J-42)
"The TRT determined that the missing barrier (used to separate redundant devices in auxiliary feedwater panel CP1-EC-PRCB-09) and the field wiring not being separated by the required 6 inches (inside panel CPL-EC-PRCB-03) were the only two inetances of Class 1E panel-mounted devices in violation of the separation criteria 4
which require corrective action."
2.0 ACTION' IDENTIFIED BY NRC (NUREG-0797, Supplement No. 7, Item No.'s 6(c) & 6(d), Page J-44)
"TUEC shall accomplish the following actions prior to fuel load:
g Take corrective measures to provide a barrier in auxiliary feedwater panel CP1-EC-PRC3-09 separating redundant flow and pressure instruments.
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Take corrective action to ensure that the required minimum separation of the redundant field wiring identified inside panel CP1-EC-PRCB-03 is maintained either by distance or by an acceptable barrier."
3.0 BACKGROUND
Barrier material supplied by the control board manufacturer was removed, creating a separation violation (panel CPI-ECPRCB-09).
In addition, field wiring was within one (1) inch of device 1-HS-5574, creating a separation violation (panel CPI-ECPRCB-03).
The general subject of the Electrical Action Plans I.b.1, I.b.2 I.b.3, and I.b.4 is electrical separation between cables of redundant ** trains. Action Plan I.b.3 deals with electrical separation outside of electrical panels and is not related to this action plan. However, Action Plans I.b.1 and I.b.2 both deal with i
i Title remains same as that given in Action Plan I.b.4 for historical purposes. However, this report covers the more general topic of electrical separatiwn in multi-train panels.
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All separation requirements in this report are for redundant cables. The word " redundant" as used herein means that the cables requiring separation belong to different trains, i.e., Class 1E train A, Class IE train B, or non-Class 1E train C.
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1 Paga 2 of 24 RESULTS REPORT ISAP I.b.4 (Cont'd)
3.0 BACKGROUND
(Cont'd) electrical separation inside electrical panels. As such, separation findings from these action plans that are similar to the findings found by the NRC-TAT are discussed in this Results Report.
4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The original objective of this action plan was to resolve the identified separation violations.
To achieve this objective, the following tasks were implemented:
-t Replaced missing barrier material Reworked field cables In the process of inspecting the control boards and vertical ventilation panels pursuant to Action Plans I.b.1 and I.b.2, l
additional separation violations involving missing barriers and cable-to-device separation violations were identified. As a result, the scope of this action plan was revised to address all internal panel separation violations not already covered by Action Plans I.b.1 and I.b.2.
4.1.1 Rework of NRC-Identified Deviations f
The barrier material was replaced and the field cables reworked to resolve the separation violations.
Nonconformance Reports were issued to assure proper disposition of these items by TUGC0 Engineering.
The CPRT third-party reviewed the NCRs for adequacy of disposition and subsequent closure.
4.1.2 Evaluation of Other Separation Violations As a part of Action Plans I.b.1 and I.b.2, the Unit 1 control boards and vertical ventilation panels were 4
inspected by CPRT third-party inspectors to identify j
separation violations. TUGC0 QC inspectors performed a validation of the CPRT third-party findings and an inspection of the panels for those separation j
j'g attributes that had been revised to more stringent requirements than those used in the previous Project inspection.
As a result of these inspections, 4
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1 Page 3 of 24 RESULTS REPORT p)
ISAP I.b.4 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) additional separation findings were noted. Those findings not addressed in Action Plans I.b.1 and I.b.2 are included in this action plan.
As described in Action Plans I.b.1 and I.b.2, the Electrical Review Team examined all remaining multi-train panels containing cables.that require electrical separation to determine where SERVICAIR flex
- is used. During this examination, the Electrical Review Team noted additional separation violations.
These findings are also addressed in this action plan.
4.1.3 Use of Results i
Results of the actions taken under this plan were evaluated to establish root causes, generic implications, and appropriate corrective action.
4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective work scope.
4.2.1 TUGC0 Comanche Peak Project 4.2.1.1 Will process NCRs that were generated due to this action plan.
4.2.1.2 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed inspection reports.
l 4.2.2.2 Will review NCRs generated due to this action
[
plan.
4.2.2.3 Determined root cause and generic-implications of unclassified deviations.
SERVICAIR flexible metallic conduit (referred to in this report as SERVICAIR flex) is the flexible conduit used for separation inside the control room panels.
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1 Page 4 of 24 RESULTS REPORT O.
ISAP I.b.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2.4 Personnel (prior to October 18, 1985)
Mr. M. B. Jones, Jr.
Review Team Leader H
Mr. E. P. Stroupe Issue Coordinator 4.2.2.5 Personnel (starting October 18, 1985)
Mr. J. J. Mallanda Review Team Leader
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Mr. R. J. Bizzak Issue Coordinator Mr. M. B. Jones, Jr.
Third-Party Adviser i
Mr. E. P. Stroupe Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team Ow 4.2.3.1 Inspected completed rework performed to resolve the NRC-TRT findings.
4.2.3.2 Inspected Unit I control room control boards and vertical ventilation panels for compliance to separation guidelines.
4.2.3.3 Personnel Mr. J. L. Hansel Review Team Leader -
QA/QC 4.3 Qualification of Personnel Where inspections required the use of certified inspectors, qualifications at the appropriate level were to the requirements of ANSI N45.2.6, " Qualification of Inspection, i
Examination, and Testing Personnel at Nuclear Power Plants."
l CPRT third-party inspectors were certified to the requirements l
of the third-party employer's Quality Assuracce Program and specifically trained to the CPRT Program Plan.
Third-party participants in the implementation of this action i
plan met the personnel qualification and objectivity I
requirements of the CPRT Program Plan and its implementing procedures.
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Page 5 ot 24 RESULTS REPORT O
ISAP I.b.4 (Cont'd) i 4.0 CPRT ACTION PLAN (Cont'd)
Other participants were qualified to requirecents of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. CPRT activities performed by other than third-party personnel were governed by the applicable principles of Sec. tion III.K,
" Assurance of CFRT Program Quality," of the CPRT Program Plan.
l 4.4 Procedures t
The following CPRT procedure was developed for use in the third-party inspection of the Unit I control room control 4
boards and vertical ventilation panels:
Quality Instruction QI-004, "CPRT Action Item I,b.1 -- i Flexible Conduit to Flexible Conduit Separation; CPRT Action Item I.b.2 - Flexible Conduit to Cable Separation."
4.5 Acceptance Criteria The separation requirements of Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical Details," will be used as the acceptance criteria for this action plan.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summary of Implementation The two violations to the separation criteria for panel-mounted devices identified by the NRC-TRT (NUREG-0797, Supplement 7) have been corrected.
For the separation violations in multi-train panels identified during the implementation of Action Plans I.b.1 and I.b.2, Nonconformance Reports (NCRs) have been issued. These violations are discussed in Section 5.3.
All violations not involving electrical separation that were l-identified during the implementation of this action plan, as l
well as Action. Plans I.b.1 and I.b.2, are covered in Section 5.10. "Out-of-Scope Findings."
5.2 Results of Investigation of NRC-Identified Findings The two findings relative to the separation criteria inside j
panels CPI-ECPRCB-09 and CPI-ECPRCB-03 noted by the NRC-TRT,
. [.. b - --
- - - - ~
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1 Paga 6 of 24 RESULTS REPORT O
ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) one concerning the missing barrier and one concerning inadequate cable-to-device separation, were confirmed to be deviations from the Project separation criteria.
Nonconformance reports (NCRs) E-84-100526 and E-84-100524 were issued to address these deviations.
Upon completion of the rework associated with the NCRs, the Electrical Review Team Leader requested that a CPRT third-party inspector verify that the deviations had been satisfactorily resolved. The inspector verified that the rework specified by NCR E-84-100524 dealing with the missing barrier had been properly implemented. However, a cable-to-device separation violation was found involving the same cable and device as those addressed in NCR E-84-100526.
This violation was subsequently documented on an Electrical o
Equipment Deficiency Report attached to Inspection Report PCV-1-0055859 and corrected by adding cable ties so that
(N proper separation is maintained even if movement of the cable
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is attempted. This corrective action was reinspected by a CPRT third-party inspector and found to be acceptable.
As noted above, a separation violation f.nvolving the same cable and device identified in NCR E-84-100526 was found after the NCR had been completed. The inspection report closing out the NCR as satisfactory was dated October 18, 1984; the CPRT third-party inspection of the rework was performed January 4, 1985. Two possible explanations for this are either that the rework specified by the NCR was not performed satisfactorily or that the rework was done properly, but later activities resulted in movement of the cable. It is unlikely that the rework was not performed satisfactorily since a QC inspection was performed for the rework initiated by the NCR (the NCR only addressed this single separation violation), and the rework was found acceptable.
In addition, at least ten work l
authorizations on the subject panel were active betweca ths completion of the NCR and the CPRT reinspection.
Therefore, it is likely that subsequent work activities in Panel cpi-ECPRCB-03 resulted in movement of the cable. Two possible explanations for this are:
- 1) Construction, startup, and operations personnel were not sensitized to the fact that work they perform must not result in separation violations, and s
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3 Revision:
1 Page 7 of 24 RESULTS REPORT O'
ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- 2) Cables that can be moved and remain in a position that creates separation violations were r.ot adequately secured.
The action taken to resolve the first issue identified above was to institute a training program to sensitize craft, QC, 2
startup, and operations personnel working in multi-train panels to the importance of maintaining electrical separation.
The second issue involves cables that can be moved to create' ssparation violations and remain in the new position. To prevent this from occurring in the future, QC Inspection Procedures QI-QP-11.3-28, " Class 1E Cable Terminations,"
QI-QP-11.3-40, " Post Construction Inspection of Electrical 6
Equipment and Raceways," and QI-QP-11.3-55, " Turn-Over Walkdown," were revised to include a check to identify unsecured cables that can be moved to crette a separation violation and remain in that position, QC Inspection Procedure QI-QP-11.3-40 will be used for the final baseline inspections discussed in Section 5.7.
5.3 Additional Separation Violations This section discusses all of the additional separation findings identified during the implementation of Action Plans 1.b.1 and I.b.2.
Ihese findings can be grouped into the following two categories:
a)
Separation violations in the centrol room control boards and vertical ventilation panels identified by the CPRT third-party inspectors and TUGC0 QC j
inspectors.
b)
Separation violations in multi-train electrical panels other than the control boards and vertical ventilation panels. These violations were noted by the Electrical Review Team during its examination of multi-train panels for SERVICAIR flex, by the CPRT third-party inspectors during their activities associated with Action. Plans I.a.2 and I.a.3, and by TUGC0 QC inspectors during their review of the Electrical Review Team's findings.
5.3.1 Deviations in the Control Room Control Boards and O
Vertical Ventilation Panels i
The CPRT conducted a third-party inspection of the control room control boards and vertical ventilation
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1 Pags 8 of 24 O
RESULTS REPORT
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ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) panels to identify all. cable separation violations.
This inspection was performed shortly after the TUGC0 post-construction inspection of these panels. As discussed in Action Plans I.b.1 and I.b.2, the CPRT inspectors used preliminary, conservative separation guidelines. When the final separation criteria
- were developed, TUGC0 validated the CPRT findings against the final criteria. Since this validation, in some cases, required field verification, it was decided to perform concurrently a reinspection of the control boards and vertical ventilation panels for those separation attributes that were revised to more restrictive requirements. During this reinspection process, the TUGCO inspectors noted additional t
separation violations unrelated to either the CPRT third-party findings or the revised attributes.
The cable separation deviations found during the two inspections noted above can be grouped into the following ten categories:
w 1)
Cable-to-SERVICAIR flex separation violations (deviations noted in ' Action Plan I.b.2) 2)
Missing or inadequate barriers (similar to one of the NRC findings quoted in Section 1.0 of this report) 3)
Cable-to-device separation violations i
(similar to one of the NRC findings quoted in
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Section 1.0 of this report) i 4)
Cable-to-cable separation violations 5)
Cable-to-wireway separation violations 6)
Cable-to-conduit separation violations 7)
Cable-to-barrier separation violations 8?
SERVICAIR flex-to-conduit separation violations The final separation criteria are the separation criteria developed as a result of Action Plans I.b.1 and I.b.2.
See Detail 61 of i
I Drawing 3323-El-1702-02and DCA 21,448." Revision 1 Cable and Raceway Separation Typ l
- Details, k
t Revision:
Pags 9 of :
RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 9)
Separation not maintainable 10)
Findings related to the design of the electrical panel (wireway covers missing, gaps in wireway, wireways touching wireways)
Note that neither inspection resulted in any deviations associated with Action Plan I.b.1 - SERVICAIR flex-to-SERVICAIR flex. The deviations found by the CPRT third-party inspectors and TUGC0 QC inspectors for each of the categories listed above are summarized in Table 1.
CPRT findings that did not meet the preliminary, conservative separation guidelines, but did meet the final separation criteria, are not included in Table le regardless of whether or not a Nonconformance Report was written. Deviations found by both the CPRT third-party inspectors and the TUGC0 QC inspectors are only listed once.
5.3.2 Deviations in Other Multi-Train Panels During the Electrical Review Team's examination of multi-train panels for SERVICAIR flex performed for Action Plans I.b.1 and I.b.2, separation violations were.noted in panels other than the control boards and vertical ventilation panels. The Electrical Review Team did not perform a complete inspection of the
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panels for separation violations; the violations noted were those found while examining panels for the use of SERVICAIR flex. The subsequent TUGC0 review of these panels to validate the CPRT third-party findings resulted in the identification of additional findings.
- n addition, the CPRT third-party inspectors, during their inspections associated with Action Plans I.a.2 and I.a.3, noted four panels with separation violations.
There are 13 Unit I control room control boards and vertical ventilation panels and 75 other Unit I and common area electrical panels that require separation between redundant trains.
In these other 75 panels, the CPRT third-party identified 47 that contained separation violations. These violations were transmitted to TUGCO for resolution. For 17 of the
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panels, the violations had previously been identified on Nonconformance Reports and either accepted use-as-is by engineering evaluation or had not yet been dispositioned.
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Page 10 of 2 i
RESULTS REPORT ISAP 1.b.4
.(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Thus, there were 30 of these other panels in which separation violations were found that previously had not been identified by the Project. During the TUGC0 review of these panels, several additional deviations in the same panels were noted; all deviations were reported on Nonconformance Reports (NCRs). All' deviations were violations of the original separation criteria as well as the final separation criteria.
i The majority of the items reported on the NCRs (40 out of a total of 61) were for cable-to-cable separation
-violations. Fifteen of the NCR items involved cable and some form of conduit, i.e.,
rigid metallic, SERVICAIR flex, Greenfield flex, or Sealtite flex. The remaining six items involved cable-to-device, cable-to-wireway, and improper barrier material violations.
5.4 Safety Significance Evaluation The CPRT third-party and TUCCO inspections of the control room control boards and vertical ventilation panels resulted in 227 separation violations being found. The NRC-TRT identified two separation violations,.as noted in Section 1.0 of this report.
Examinations of multi-train panels other than the control boards and vertical ventilation panels resulted in 61 separation violations being found.
Those cases in which only the final separation criteria were not satisfied are not deviations since they do not represent violations of the criteria in existence at the time of installation. The fact that the original separation criteria i
were changed when construction was essentially complete is addressed in Section 5.8, " Observations."
In order to determine whether or not the remaining separation violations, i.e., violations of the original separation criteria, are safety-significant, it would be necessary to conduct an extensive testing and analysis program for the various types of cable insulation and circuit functions for the cables involved. Rather than perform this type of safety significance evaluation, the Electrical Review Team decided to classify the above deviations as " unclassified deviations."
As such, a root cause analysis and generic implications i
evaluation were performed, and a corrective action program 1
will be implemented.
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Pago 11 of 2' RESULTS REPORT O
ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.5 Root Cause Analysis Because separation violations were found to be so widespread in the multi-train panels for Unit i and common areas, the CPRT third-party considered that the following must have occurred:
The original installation was not properly performed AND The subsequent Quality Control (QC) inspection did not detect and ensure correction of the violation 6
AND/OR I
Work and/or testing performed subsequent to the cable installation and inspection resulted in separation violations.
Each of the above events was investigated to determine if the root causes and/or contributing causes of separation violations could be identified. The elements of organization, personnel, procedures & criterfa, and environment were examined to determine how they might contribute to produce the above circumstances. The number of deviations that were found indicate that the deviations are not isolated to any one panel or person.
From this investigation, the Electrical Review Team hypothesized that the following factors were possible contributors to the separation violations identified in this report:
Insufficient supervisory emphasis on establishing and maintaining separation Inadequate craft, QC, startup, and operations procedures Lack of effective training Major modifications to panels in the late stages of the construction process Panel designs that are not conducive to maintaining separation
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Paga 12 of ;c RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The lack of a requirement that cables be secured to prevent inadvertent movement that could result in a separation violation
- Inadequate coordination among engineering, construction, QC, startup, and operations Because the separation violations were not restricted to any one group on site, i.e.,
construction, QC, startup, or operations, the root cause(s) must address all the organizations involved. The following factors are considered to be root causes of separation violations in multi-train panels:
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- Insufficient supervisory emphasis on establishing and maintaining separation Informal discussions with Project personnel indicate O
that separation may not have been a major concern to craf t and inspection personnel during cable installation activities. For example, during the human factors engineering (HFE) modifications performed on the control boards, the major emphasis was on completing the physical work.
Inspections for separation were made only for the particular conductors being terminated, per the in-process inspection procedure. The identification of any separation violations that were inadvertently created during the installation process, involving cables other than those being installed, was not emphasized. The rationale was I
that the final post-construction inspection would identify all violations, which then would be corrected.
Though this may have been en efficient method of completing the modifications, it may have had a l
detrimental impact on craft and QC inspection personnel in that they may have been given the impression that separation is not a critical element of proper installation.
A review of the post-construction inspection of the control boards that was performed in late 1984 and early 1985 indicated that the number of violations i
found was too large to allow for a proper inspection.
over 350 violations were found in the eleven control
'O boards. The large number of violations that were found would indicate that the inspectors were confronted with a difficult inspection task and could have failed to k
Revision:
I, Paga 13 of I' RESULTS REPORT ISAP I.b.4 4'
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) find all violations.
Furthermore, subsequent rework to correct.these separation violations and other i
nonconforming items not related to separation was undoubtedly extensive and could have resulted in additional separation violations.
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The final assurance of electrical separation relied on the final post-construction inspection. In-process work did not receive the attention to detail that it deserved. The " wait till we are done", attitude resulted in many violations. This can be verified by examining the post-construction inspection reports for the control boards. The extent of the violations that 1
were found (approximately 350 ) obviously made the
-t final inspection more difficult than it would have been otherwise.
The impression that the Electrical Review Team received
, O was that the Project did not place the proper emphasis on electrical separation, that the prevailing attitude was that somehow everything would be shown acceptable prior to fuel load, and that the existing system for establishing and maintaining separation would work.
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The practice of deferring separation considerations and i
the supervisory attitude inferred from it is determined to be a root cause affecting both the craft's inability to establish and maintain separation and QC's failure to detect and ensure correction of the separation violations.
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Inadequate craft, QC, startup, and operations i
procedures The craft procedure for terminating cables, 35-1195-EEI-8, " Class 1E and non-Class IE Cable Terminations," did not contain separation requirements until June 1985. Therefore, the only formal direction l
provided to the craft prior to that time was the separation criteria presented in Electrical Erection l
Specification 2323-ES-100, which was referenced by the craft procedure. The omission of separation j
requiremants in the termination procedure is judged to have had the effect of minimizing to craft personnel the importance of establishing separation inside panels.
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Pags 14 of 2-A RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
During a review of startup and operations procedures, it was observed that the separation criteria were never explicitly discussed in the procedures. Therefore, if work requiring partial disassembly of the wiring in the panels was necessary, the cognizant person would not, by procedure, have access to the detailed separation requirements.
In addition, the procedures allowed startup and operations personnel to perform certain work activities in multi-train panels without requiring a subsequent inspection of the work.
The QC procedure for the in-process inspection of a termination is QI-QP-11.3-28, " Class 1E Cable Terminations." The following historical shortcomings t were identified in QI-QP-11.3-28:
- Veri.fication of separation attributes was deleted from the procedure from 4/80 through 8/80
- The procedure does not address inspection of non-Class 1E cables in multi-train panels
- The procedure only addresses field-run, redundant cables.
Taken individually, none of these shortcomings, except the last one, would affect the final installation since a post-construction inspection is performed to QC I
Procedure QI-QP-11.3-40, " Post Construction Inspection of Electrical Equipment and Raceways." The fact that non-Class 1E cables were not required to be inspected could have a major impact on installations made after the post-construction inspection since all separation l
violations of non-Class 1E cables with installed Class IE cables would neither be inspected nor identified by QC inspectors.
Until 1986, both QI-QP-11.3-28 and QI-QP-11.3-40 only addressed field-run, redundant cables. The assumption appeared to be that the vendor-installed cables would have adequate separation as provided by the vendor.
Since subsequent work in the panels could create separation violations, the procedures should not have limited inspections to field-run cables.
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Pags 15 of 20 RESULTS REPORT O
ISAP 1.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- Lack of effective training Prior to May 1985, cra'ft training dealing specifically with electrical separation was comprised of reading the Electrical Erection Specification ES-100 and associated procedures, classroom instruction, and on-the-job training (0JT). The subject of internal panel reparation in ES-100 consists of one paragraph, Paragraph 4.11.3.3 (2), and an associated three-page Design Change Authorization (DCA). Considering the 1
size of the overall specification (approximately 140 pages plus over 65 active DCAs as of May 1986), it is clear that the reading assignment would not, by itself, ensure adequate training on the subject of separation t I
inside panels. As noted above, the procedure for terminating cables did not mention separation requirements prior to June 1985.
The CPRT third-party reviewed the lesson plans used for training craft personnel involved with terminating cables. Separation requirements were not included in the lesson plans reviewed, although personnel attending these classes state that separation was discussed.
It would appear that the majority of the training would have occurred on the job when new personnel were placed with experienced craftsmen familiar with the job requirements. Since a majority of the electrical panels do not require cable separation (i.e., they l
contain only one train), it is possible that some of the craft trainees were not provided with sufficient experience in dealing with cable separation requirements.
The training of quality control inspectors was similar to that provided to the craft. Training consisted of classrcom reading of the procedures, written examinations, and on-the-job training.
it is difficult to reconstruct the extent of training I
that was provided to craft and QC inspectors in the late 1970s and early 1980s. Indications are that training on separation was provided, but the extent of the training is difficult to, determine. However, the O
effectiveness of the training was limited by the lack of emphasis placed on separation during in-process installatior. of cables.
5
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Pag 2 16 of 24 RESULTS REPORT
.O ISAP I.b.4 (Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The training of startup and operations personnel was not investigated since the applicable procedures did not explicitly address the separation criteria.
Although they contributed to the problem, the following factors were not found by the Electrical Review Team to be root causes:
Major modifications to panels in the late stages of.the j
construction process i
Modifications made to the control boards to accommodate human factors engineering (HFE) requirements were extensive and made the establishment of electrical i
separation within the panels more difficult.
However the fact that not all panels in which e
i separation violations were found were extensively O
modified after construction was essentially c'omplete indicates that this factor, though it may have reeulted in some separation violations, is not a root cause.
Panel designs that are not conducive to maintaining separation One aspect of the panels that makes separation difficult to establish and maintain is that there are a minimal number of wireways provided for field-run cables. This results in cables being exposed between the panel entry point and the termination blocks or devices. This, in turn, results in the need for larger separation distances betweer. exposed cables than would otherwise be required if the cables were routed in wireways. Additionally, support attachment points are relatively sparse, which makes it difficult to secure cables in a way so as to prevent separation violations due to inadvertent movement of cables. In addition, the control boards are very congested and contain fairly complex wiring arrangements.
However, the fact that separation violations exist in a large percentage of the panels, many of which are relatively uncongested, indicates that the above factors are not the root causes of separation O
violations. They are, however, contributing factors for the greater number of deviations found in the control boards and vertical ventilation panels than in other multi-train panels.
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Page 17 of D RESULTS REPORT O
ISAP I.b.4 l
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
' The lack of a requirement that cables be secured to prevent inadvertent movement that could result in a r-separation violation The Electrical Erection Specification does not state that wiring should be secured to prevent separation violations as a result of inadvertent movement of the cables. As discussed in this Results Report, this is a concern in maintaining separation throughout the life of the plant.- The lack of properly-secured cables in combination with eubsequent work activities undoubtedly resulted in separation violations.
4 However, the lack of a requirement to properly secure t cables does not by itself cause separation violations; securing cables is an additional preventive measure.
i Furthermore, violations were found to exist where it was apparent that the cables had not been moved from their installed position.
Inadequate coordination among engineering, construction, QC, startup, and operations There appears to have been a lack of coordination among the groups involved, i.e., engineering, construction, I
QC, startup, and operations. Separation problems have been recognized as an issue since the arrival of the control boards on site; however, no particular emphasis i
had been given by startup and operations to this issue.
Operations has an electrical. specification, TES-100, similar to the Electrical Erection Specification 2323-ES-100. Nonetheless, changes made to ES-100 were not incorporated into the Operations specification.
Engineering maintains two sources of separation criteria -- Electrical Erection Specification 2323-ES-100 and Drawing 2323-El-1702-02, " Cable and Raceway Senaration Typical Details." The craft procedure teferences the specification; current Quality Control procedures reference the drtaing. The QC procedures are more detailed in that they list multi-train panels where separation is not required; the craft procedures contain no such information.
O Operations and startup procedures do not contain the detailed, internal panel separation criteria, nor do they reference engineering documents where the criteria b
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Pags 18 of D RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) can be found. An adequate interface among the groups involved could have ensured that the separation criteria are presented more precisely and are sufficiently detailed to be. implemented.
Inadequate coordination among the groups involved does not itself cause separation violations. However, proper coordination would likely have led to early detection and correction of the problem.
The previous discussions detail the identified root causes and other contributing factors that collectively explain why separation violations were found to be so widespread throughout the multi-train panels for Unit i and common areast As noted above, the factors of major panel modifications and panel designs not conducive to maintaining separation do not apply to all the panels where separation violations were O,
noted. The lack of a requirement to properly secure cables does not by itself cause separation violations; securing cables is an additional preventive measure. Furthermore, violations existed where it was apparent that the cables had not been moved from their installed position.
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Inadequate coordination among the groups involved is a factor that does not itself cause separation violations. However, proper coordination could have detected and corrected the problem.
In sunmiary, the root causes appear to be inadequate craft, QC, i
startup, and operations procedures; a lack of effective craf t and QC training; and insufficient supervisory emphasis. All the groups involved, i.e., craft, QC inspectors, startup i
personnel, and operations personnel, were affected by one or more of the above root causes.
In addition, the effects of these root causes would apply to all multi-train panels.
5.6 Generic Implications I
Since the criteria, procedures, and personnel associated with the control boards and vertical ventilation panels are the l
same na those for other multi-train panels, the implications of the root cause are not limited to the control boards and vertical ventilation panels, but extend to all multi-train O
panels. As noted above, separation violations were noted in 43 of the 88 multi-train panels. Therefore, corrective actions must address all multi-train panels.
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4 L-2 _ _ __ _._,. _ _ _ -. _ _.-
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1 Pcg2 19 of 24 RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The procedures, training, and supervision related to cable separation inside electrical panels are limited to multi-train electrical panels. Based on the above, it is judged that the generic implications of the above root causes are confined to multi-train panels. The possibility that similar concerns may exist in other areas of plant electrical separation will be investigated in Action Plan VII.c.
The facts related to the root causes have been transmitted to the QA/QC Review Team for further evaluation during their edilective evaluation program.
S.7 Correctite Actions t
All deviations to the separation criteris have either been noted on Nonconformance Reports or otherwise corrected. The Project is currently dispositioning the NCRs; the disposition of the NCRs will be reviewed by the Electrical Review Team.
TUGC0 is developing a corrective action program to resolve I
separation issues identified during the implementation of Action Plans I.b.2 and I.b.4.
The major elements of the program are described below.
TUGC0 recognizes the need to establish and maintain cable separation-inside electrical panels for all stages of plant life -- construction, start-up, and operations. Key elements to achieving these objectives are the establishment of precise l
criteria, the training of responsible personnel, the timely performance of inspections, and the control of activities l
performed after inspections have been completed. To this end.
TUGC0 is currently taking the following actions:
- 1) Updating of all procedures, drawings, specifications, etc., dealing with internal separation to clarify the criteria
- 2) Instituting a special trainir.g program to ensure that personnel involved with multi-train panels, i.e. craft, QC inspectors, engineers, start-up personnel, and operations personnel, are sensitized to the need to establish and/or maintain separation
- 3) Job-specific training for craft, QC inspectors, start-up, and operations personnel to the revised docraents 1-.
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l' Paga ~20 of la RESULTS REPORT ISAP I.b.4 s
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
- 4) Performing a baseline inspection, which includes verification of all separation attributes, to ensure that the required separation criteria have been met
- 5) Controlling access to panels requiring cable separation after the baseline inspection indicates a satisfactory configuration.
i The above corrective actions are aimed at establishing and maintaining electrical separation in electrical panels. The responsibility of establishing and verifying separation lies with construction and QC personnel. To enhance the performance of these groups, the craft Procedure EEI-8, " Class i
LE and Non-Class IE Cable Terminations," and the QC procedureg for in-process and final inspections of cable separation will be revised to define more precisely the requirements for cable separation. In addition, training will be performed to I
sensitize personnel to the necessity of establishing and maintaining separation.
After construction of a panel has been completed, maintaining separation is the responsibility of startup and operations personnel. Procedures will be revised or new procedures j
written that specifically address the separation criteria.
l Startup and operations personnel involved with multi-train panels will also receive training to sensitize them to the i-necessity of establishing and maintaining separation. Prior j
to turnover to operations, a complete reinspection of the panels to assure proper separation will be performed, and the panels will be tagged as multi-train panels. For those panels currently under Operations' custody, the above reinspection and tagging will be performed af ter the necessary document revisions and training have been completed. Subsequent work
'will be performed via a Work Order in accordance with Operations Procedure STA-606, " Work Requests and Work Orders."
l The Electrical Review Team has reviewed the corrective actions proposed by the Project and concurs that, if implemented as planned, these actions will correct the identified deviations and adequately address the root causes determined by the l
Electrical Review Team. The above program adequately addresses the generic implication associated with all multi-train panels.
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Pcgs 21 of 24 RESULTS' REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.8 Observations Two observations were made by the Electrical Review Team during the implementation of this action plan. The first observation involves recent changes in the separation criteria for power cables inside panels. In mid-1985, more stringent separation criteria were specified for 120 Vac lighting and convenience receptacle wiring. Criteria for other power i
cables are being developed. The revision of separation criteria for power cables after the electrical panels have essentially been completed suggests a design issue requiring further investigation by the Design Adequacy Review Team, i
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The second observation involves the method by which criteria-t
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are issued. The primary source of separation criteria is j
Drawing 2323-El-1702-02, " Cable and Raceway Separation Typical i
j Details." Revisions to the separation criteria are made to l
this drawing. Since the separation criteria are not i
explicitly incorporated into craft, quality control, startup, and operations procedures, changes to the separation criteria do not result in changes to procedures. Since the procedures are not revised, training to the new criteria is not ensured.
f The above observations have been transmitted to the Design Adequacy and QA/QC Review Team Leaders, as appropriate, to be included in their collective evaluation programs.
f 5.9 Unit 2 Electrical Panels The inspections and examinations performed under this action plan involved Unit I and common area electrical panels.
However, the TUGC0 program outlined in Section 5.7 will apply 4
to Unit 2 also. This corrective action will ensure that the installed configurations meet the final Project separation criteria.
5.10 Out-of-Scope Findings l
During the implementation of the I.b Action Plans, findings unrelated to electrical separation were identified. These j
findings can be summarized in the following categories:
i a) Loose fittings and couplings, loose or damaged support clamps, loose light fixtures, etc., for the electrical l
metallic tubing (EFT) and rigid conduit used in the control room control boards and vertical ventilation
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1 I
Pcg2 22 of 24 A
RESULTS REPORT ISAP I.b.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) panels. These findings were noted during the CPRT third-party inspection of the control room control boards and vertical ventilation panels, b) Drawing errors involving the identification of two associated cables as Class 1E cables; drawing error for switch locations in CPX-ECPRCV-03; drawing error on the labeling of lighting transformer XF-SCI-3.
' c) Incorrect tagging of four conductors in an electrical panel as train A rather than train B.
d) The lack of or inadequate supports on SERVICAIR flex and other cables.
6 e) Two vendor drawings specifying different current ratings for the same fuse.
O These categories do not relate to electrical separation and have been transmitted to,the appropriate Review Team Leaders as "out-of-scope findings" for their evaluation. The specific findings have been addressed by TUGC0 and either accepted as is or, in most cases, Nonconformance Reports or Design Change Authorizations to drawings have been issued. It should be noted that the requirement to support SERVICAIR flex at least every three feet is a requirement added to the final separation criteria. Therefore, the findings in category (d) do not represent hardware installation deviations.
6.0 CONCLUSION
S The actions identified by the NRC in Section 2.0 of this report were to take corrective measures to correct two instances of separation violations noted in panels CP1-ECPRCB-03 and CP1-ECPRCB-09. The two violations have been corrected.
In NUREG-0797, Supplement No. 7, Page J-53, the NRC states that, "The TRT concludes that the unjustified installation of cables and flexible conduits inside panels that do not meet minimum separation i
requirements has generic implications.
The TRT findings on cable separation may be indicative of poor QC personnel training in procedural requirements for installation and inspection."
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1 Pags 23 of 24 f
RESULTS REPORT ISAP I.b.4 (Cont'd) 6.0 CONCLUSICNS (Cont'd)
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-As discussed in Sections 5.5 and 5.6, the Electrical Review Team has investigated the situations leading to the various separation findings and concurs with the NRC that there are generic implications that extend, as a minimum, to all multi-train panels.
However, the Electrical Review Team believes that the root cause is broader than the one hypothesized by the NRC, i.e., poor QC training. The root causes determined by the Electrical Review Team involve inadequate procedures, a lack of effective craf t and QC training, and insufficient supervisory emphasis on separation.
TUGC0 has proposed a corrective action program, as discussed in Section 5.7, that addresses the apdating of all procedures, drawings, specifications, etc. dealing with internal separation.
Subsequent training, base-line inspections, and controlled access.g to the panels will ensure that all concerns involving separation in electrical panels are resolved.
7.0 ONGOING ACTIVITIES NCRs issued for the control room control boards and vertical ventilation panels as a result of deviations related to this action plan and Action Plan I.b.2 have not yet been completely resolved.
The Electrical Review Team will review the disposition of the NCRs.
After the NCRs'are closed, TUGC0 will perform a post-construction.
inspection of these panels, which will include verification of adequate separation. This inspection will be overviewed by the CPRT third-party.
In addition, the CPRT third-party will review the disposition of
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NCRs for all other multi-train panels issued to resolve separation i
deviations identified during the implementation of the 1.b Action Plans.
i As discussed in Section 5.7, TUGC0 also is in the process of developing and implementing a program to establish and maintain separation within electrical panels. The Electrical Review Team l,
will review this program as it is being developed.
l Upon the completion of the above ongoing activities, a Supplemental l
Report will be issued; this supplement will provide the results of the activities described above.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE
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The program described in Section 5.7 will ensare that separation i
inside multi-train panels in Units 1, 2, and common areas will be j
established and maintained.
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R vicient I
Pegs 24 of 24 i
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RESULTS REPORT w
ISAP I.b.4 (Cont'd)
TABLE 1 Summary of Separation Violations Identified in the Control Room Control Boards and Vertical Ventilation Panels by the CPRT Third-Party Inspectors and TUGC0 QC Inspectors.
i CPRT Category Third-Party TUGC0 Total Vo*
Vn*
Vo Vn Vo Vn 4
- 1) Cable-to-SERVICAIR Flex (1.b.2) 14 7
8 22 7
- 2) Missing or Inadequate
-1 Barrier
.2 4
1 1
3 5
- 3) Cable-to-Device 10 4
1 11 4
- 4) Cable-to-Cable 9
22 31 i
- 5) Cable-to-Wireway 9
14 10 19 14
- 6) Cable-to-Conduit 3
3
- 7) Cable-to-Barrier 1
6 7
- 8) SERVICAIR flex-to-Conduit 1
1
- 9) Separation Not Maintainable 7
2 9
- 10) Panel Design 46 45 46 45 45 36 97 49 142 85 Vo are violations of both the original (pre-CPRT) criteria and the final separation criteria. Vn are violations of the final separation criteria only; they do not represent violations of the original aeparation criteria that were in effect when the cables were installed.
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