ML20214A480
| ML20214A480 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/12/1987 |
| From: | Jordan G, Martin M, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214A438 | List: |
| References | |
| 238.1(B), 238.1(B)-R03, 238.1(B)-R3, NUDOCS 8705190470 | |
| Download: ML20214A480 (34) | |
Text
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B) 1 SPECIAL PROGRAM REPORT TYPE: SEQU0YAH ELEMENT REVISION NUMBER: 3 L
TITLE: RACEWAY CVERFILLS AND CABLE PULLING Conduit Overfills and Cable Damage PAGE 1 0F 31 REASON FOR REVISION:
'l . Revised per TVA comments.
.2. Revised per SRP and TAS comments and to identify disagreement between FSAR and Design Criteria, and Electrical Design Standard for maximum allowable fill. Added CATO 238.01(B) SQN 05.
- 3. Revised to add the Chronology in Section 9 and Section 10, Corrective Action.
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
-. SPECIAL PROGRAM REVISION NUMBER: 3 b PAGE 2 0F 31
- 1. CHARACTERIZATION OF ISSUE (S):
Concerns: Issues:
IN-85-432-001 a. Conduits and jumpers between cable
" Overfill of cables in conduits trays are overfilled and cable Aux. Control Building El. 757 and additions continue to be routinely Reactor building." scheduled. Overfills beyond safe capacities result in an unsafe IN-86-036-001 condition and could cause induction "EVectrical Conduits in Units 1 and heating problems (induction and and 2 are overfilled. This may heating or ampacity problems are cause induction / heat problems. addressed.in Sequoyah Element Report Some cables may also have been 240.0, " Cable additions routinely damaged by pulling in these scheduled" are addressed in Sequoyah tight conditions, and by using Element Report 239.0).
excessive force installing the ,
fish tape in the conduits." b. Potential cable damage could result from cable pulling in overfilled IN-86-310-001 conduits and other cable pulling "The electrical conduit and practices (e.g., wires are stretched,
jumpers between cable trays are cables are dragged over other cables,
.' over filled with cables. TVA does not use the National Electrical Codes in construction insulation is damaged by fishtapes and nylon parachute cords, mechanical.
pulls are not monitored, etc.)
practices. Due to overfill, the Damaged cables would not be discovered cable may have been damaged when until they short out.
they were pulled."
National Electrical Code not
[
c.
IN-85-313-001 followed for conduit fill and
" Overloading of conduits-wire construction practices.
is being pulled through conduit
! that is loaded with wire such d. Cable trays and cable tray penetra-that it is difficult to push tions are overfilled (discussed in a pencil through. Wire is Sequoyah Element Report 238.3).
being stretched when pulling through these conduits." e. Cable for Unit 2 was being routed t
through Unit 1 (discussed in Watts Bar Report 239.0) k 00410 (04/28/87)
[ - - - - - - - - - - _ - - . _ _ _ . .
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B) a SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 3 0F 31 Q_-
Concerns (cont'd):
IN-85-506-001 "A recent cable pull (date unknown) was accomplished on a conduit which was overfilled to the point that the 1/8"
'Fishsnake' which guides that cable could barely be inserted.
The conduit is 100% + full as a result of this cable pull."
IN-85-622-001
" Conduit overfilled beyond safe capacity."
IN-85-685-001 .
" Conduits are generally over-filled beyond acceptable. limits."
IN-85-743-008
" Conduits are generically over-
-' filled and additional cables
- are routinely scheduled to be added to the conduits. This causes significant expenditures-of manhours in attempting to pull cable where there is no more room available."
IN-86-034-001
" Cable pull required I week to feed fish tape through conduit prior to cable pull. Overloading of conduits damages cables."
IN-86-266-003 -
"Many electrical conduits are excessively loaded with cables."
IN-85-642-001
" Conduit is 98% full of cable and more cable is to be installed."
00410 (04/28/87)
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A
. TVA EMPLOYEE CONCERNS REPORT NUMBER:- 238.1 (B)
N. -SPECIAL PROGRAM REVISION NUMBER: -3 PAGE 4 0F 31
(_
9 Concerns (cont'd):
IN-85-856-003
" Conduit and cable trays are too-full."
IN-86-028-002
" National Electrical Standards are not being followed. Example:
cable' trays and conduits are over full."
IN-86-262-001
>Jnits 1 and 2. The conduits and cable trays are too full.
It often takes 4-5 days just to pull the fish tape through. This ,
- overcrowding is an unsafe condition.."
IN-85-832-001
" Overloaded cable tray penetra-(.} tion El 729' Turbine Bldg. & -
Control Bldg. El. 737' Aux.
Bldg and Control Bldg 741.
Conduits being filled beyond National Elec. Code allowance.
Possible damage to cables that other cables are being dragged over."
IN-85-312-001
" Cable trays in [and] conduits are overfilled with cable. The cables could be damaged and not discovered until it shorts out."
IN-35-734-001 -
" Conduits / cable trays /penetra-tions in Units 1 and 2 are generically overfilled / overloaded."
IN-85-367-001
" Cable in conduit damaged by cable pulling practices. (1) conduits are over-filled, (2) fish tapes can damage conduit, especially when they get stuck,
( (3) Nylon cord ' Parachute' can cut cable insulation."
00410 (04/28/87)
6-
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 5 0F 31
([
Concerns (cont'd):
IN-86-262-004 "Elev. 729' (above Machine Shop) there are four or five 5" to 6" conduits still having the fish tape in them. The conduit is so full the fish tape cannot be removed."
IN-86-254-009
" Conduit running from manholc-1 & 2 to the Aux. Bldg. are overfilled with cables."
IN-86-206-001 "Two 2 conductor #14 safety related .
cables were pulled through over-crowded 3" conduit /condulets with a 1/2 to 3/4 ton come-a-long.
The conduit /condulets were so full, it was difficult to get the fish tape in. Conduit located at '
elevation 737' of Vait #1 Auxiliary Building to the cable spread room, elevation 742, column lines A3-A4 and 'Q' line. The cable was for Unit II, but was being routed through Unit 1. CI does not know if cable was tested af ter installa-tion. Occurred approx. Feb./ March, 1984."
" Crossover electrical conduits are grossly overfilled, and this will cause a heat build-up that will '
degrade cable insulation. This could lead to cable breakdown and failure. This was a routine practice until at least 1984. 4" - 6" Crossovers, 737' El, Auxiliary Bldg."
00410(04/28/87)
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. -TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
- SPECIAL PROGRAM REVISION NUMBER:. 3 PAGE 6 0F 31 i
- 2. HAVE-ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Documentation Identifiers:
o Identified by Nuclear Safety Review Staff (NSRS)
Date 02/29/85 to 04/15/85 NSRS Report No. T-85-06-WBN, ' Investigation of An Employee Concern Regarding Cable Routing, Installation and Inspection At Watts Bar. Nucle'.r Plant" o Identified by NSRS Date _ 02/18/86 Attachment.I to: NSRS Report No. I-85-251-SQN, " Electrical .
Cables"'
o Identified by NCR - WBN 6270 R0 Date 08/20/85 q
NCR - WBN 6270 R0," Cable Sidewall Pressure Calculation" o Identified by NCR - WBN 6347 R0 Date 09/27/85 NCR - WBN 6347 R0," Excessive Conduit Bends" o Identified by: SCR SQNEEB 8529 R0 Date 12/06/85 SCR SQNEEB 8529 R0, " Conduits Containing 400 MCM Cables That Exceeded the Conduit Fill as Specified in DS-E13.1.2 and DS-E13.1.4"
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT.
No further information available. The employee concerns for WBN cited some specific locations, but the implied generic concerns for l
SQN are general in nature. They address overall problems related to conduit overfill and cable damage by cable pulling.
0041D (04/28/87)
i
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
- SPECIAL PROGRAM REVISION NUMBER: 3 o ., .
PAGE 7 0F 31 l (L '
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- 4. INTERVIEW FILES REVIEWED:
The following files were reviewed and no additional unreviewed information for Sequoyah was ider.tified for the concerns in this report.
0W-85-007 IN-86-310' IN-86-206 IN-85-432 IN-85-313 IN-85-367 IN-85-856 IN-85-506 IN-86-254 IN-86-028 IN-85-622 IN-86-262 IN-85-685 IN-85-832 IN-85-743 IN-85-312 IN-86-034 I N-85-734 IN-86-266 Files IN-86-036 and IN-85-642 contain additional information for concerns IN-86-036-001 and IN-85-642-001 regarding location, ,
penetration, and conduit numbers. This information, however, is specific to WBN.
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
!({ - '
See Appendix A.
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUfREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
P See Appendix A.
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPH0hE CALLS, Ali0 OTHER
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DISCUSSIONS RiL TED 10 CLEMENT.
See Apperdix A.
- 8. EVALUATION PROCESS:
- a. Reviewed available transcripts of NRC investigative interviews for additional information on the concerns.
1 00410 (04/28/87)
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM EiVISION NUMBER: 3 s; PAGE 8 0F 31
- b. Reviewed FSAR and existing applicable TVA Design Standards for commitments and requirements regarding conduit fills.
- c. Reviewed SQN cable in conduit routing and conduit fill tracking procedures for adequacy.
-d. Reviewed Construction Specification G-38 and Modifications and Addition Instructions (M&AI) for cable installation requirements and for inspection instructions.
- e. Reviewed existing TVA reports (e.g., GCA-01-46 and GCA-02-47) to assess the extent to which these reports and corrective actions satisfy the concerns.
- f. Reviewed existing TVA Construction, QA/QC, Operations, and liaterial Control reports (e.g., C010900-SQN) for the Employee Concern Evaluation Program for applicability to the concerns.
discussed in this report.
9 Assessed overall adequacy of SQN cable-pulling practices and requirement to identify areas that require further
. q},
investigation and corrective action.
- 9. DISCUESION, FINDINGS, AND CONCLUSIONS Chronology:
05/35 TVA receives ccacerns:
to 08/85: IN-85-313-001 IN-85-734-001 IN-85-312-001 IN-85-743-008 IN-85-367-001 IN-85-832-001 IN-85-432-001 IN-85-856-003 IN 85-506-001 IN-86-028-001 IN-85-622-001 IN-86-034-001 IM-85-642-001 IN-86-036-001
'IN-85-685-001 IN-86-206-001 08/85: An evaluation program is initiated by TVA .to evaluate previously installed class lE cables and to establish the impact of including SWP in cable pull tension limitations 00410(04/28/87)
P s
- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
- SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 9 0F 31 (L-09/85: TVA receives concerns:
IN-86-262-001 IN-86-262-004 IN-86-266-003 IN-86-310-001 09/27/85: Nonconformance Report WBN 6347 R0 issued documenting excessive conduit bends between pull points. An ,
apparent violation of Design Guide DG-E13.1.1 10/31/85: TVA memo Vineyard to Rankin requests investigation of a potential generic condition at Sequoyah described in WBN Nonconformance Report 6347 R0 12/02/85: TVA meno Cantrell to Mason transmits the report
" Evaluation of the Adequacy of Installed Class lE Cable" which concluded that installed cable is adequate and that currently established procedures will ensure the adequacy of future installations 12/06/85: Significant Condition Rcport (SCR) SQNEEB8529 R0 U documents conduits with fills in excess of allowable limits set by design standard
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12/27/85: Engineering Report CAQ SCR SQNEEB8529 R0 concludes that conduit overfills are the result of a failure of design engineering to follow design standards 01/06/86: SCR SQN EEB8601 R0 report issued documenting the use of unverified cable data to calculate raceway fills and side wall pressures (SWP) 04/15/86: Electrical Design Standards .DS-E12.1.13 R2 and DS-E12.1.14 R0 issued incorporating results of TVA tests to established an auditable listing of cable diameters 05/16/86: A Generic Concern Task Force Report finds that the utility portion of TVA/SQN is not subject to NEC requirements 07/24/86: DNE issues calculation indicating that SWP is not a problem at SQN based on a walkdown which supposedly identified the worst case conditions 08/30/86: NRC questions the validity of these so called " worst case conditions" e
i 00410 (04/28/87)
- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM j REVISION NUMBF.R: 3 j
\
C PAGE 10 0F 31 10/07/86: Raughley memorandum directs all the nuclear plants to establish "a sampling program to determine the adequacy of electrical cables with respect to their ampacity ratings" 10/08/86: During a meeting with the evaluation team, TVA acknowledges that SWP calculation was not based on the actual worst cases and commits to reevaluation 11/86: Extensive trend analysis program to be iri effect Discussion:
- a. Conduit Overfill Cable routing practices at SQN are addressed in the Generic Concern Task Force (GCTF) report regarding employee concern,-
" Overfill of Cable Trays and Conduits" (05/20/86, App. A, 5.m). One of the issues investigated in this GCTF report deals with the conduit overfill aspect of the concerns covered by the report. This report indicates that cables are y manually routed in conduits by designers and documented in the computer cable schedule. It is the responsibility of the designer performing the cable routing to calculate the total cross sectional area (CSA) fill of cables in conduits, whether the cable is newly routed in an empty conduit or added to an existing conduit with existing cables. Maximura allowable conduit fills are specified ir. Electrical Design Standard DS-E13.1.4 (08/24/83, App. A, 5.b). The evaluation team determined that these fills are in disagreement with the maximum coriduit fills required per SQN Design Criteria No.
SQN-DC-V-ll .3 ( App. A, 5.j), Section 6.1.2 and committed to in SNP FSAR Section 8.3.1.4.1. The design standard, which is in agreement with the National Electrical Code, specifies maximum fills of 53 percent for conduits containing one cable, 31 percent for conduits containing twa cables, and 40 percent for conduits containing three and more cables. The FSAR and the design criteria allow a maximum conduit fill of 40 percent. This discrepancy was also identified in Attachment 1 to NSRS Report No. I-86-251-SQN (02/18/86; App.
A,5.f).
The Quality Assurance Evaluation Report (10/28/06, App. A, 5.a63) of the computer cable routing system determined that for the period prior to March 1986, no documentation was 00410 (04/28/87)
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. TVA EMPLOYEE CONCERNS' REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3
-b PAGE 110F 31 ;
available to demonstrate that a rification of cable routing and raceway CSA was performed before releasing the design to
-construction.- After March 1986 a procedure was implemented to require a checker to verify the manual cable routing and check CSA fill calculation done by the designer prior to releasing the cable pull slips for cable installation. This procedure SQEP-06 (App. A, 5.k) was officially issued in September 1986.
Another aspect of the cor.ddit fill issue is the fact that unverified cable diameters were used. SQN Significant Condition Report (SCR) SQNEEB8601 R0 (01/06/86, App. A, 5.0) was issued as the result of WBN SCRs WBNEEB8583 R0 and WBNEEB8590 R0. This SCR identified use of unverified cable outside diameters (0D) and cable weights to calculate the CSA for tray and conduit fill, minimum bend and training radius, and sidewall pressure. The SCR stated that the cable weights and outside diameters were not taken from adequately documented sources and the origin of the vendor cable characteristics was unknown. Engineering Report (ER) CAQ No.
SCR SQNEEB8601 R0 (04/16/86, App. A, 5.p) evaluated these unverified values of cable weights and outside diameters and
. Q' found no major: inconsistencies with the QA list of actual values being prepared by EEB Central Staff and concluded that
" existing data would not result in a failure that would impact nuclear safety." A memo from Scruggs to Raughley (09/23/86, App, A, 5.ss) supports the conclusion made in the ER. The memo indicates that a comparison of old and new (verified) 00s for 210 cables revealed that 150 show the original 00 to be larger, 57 show that the new OD is larger and 3 were the same. The memo concludes that no major differences in 00 size existed and, therefore, the possibility of an overfill occurring because of this is very small. A comparison of old and new 00s made by the evaluator revealed that in fact they were close enough to be within a reasonable level of accuracy. lhe evaluation team determined that although the conclusions in the memo and ER seem reasonable, no analyses have been identified to support them. The current verified cable values, as ind.icated in memo from Raughley to Raulston (09/24/86, App. A, 5.qq), are the result of samples of class lE and non-class IE cables sent to TVA's Singleton Materials Lab to establish an auditable listing of cable types with their respective 00s and weights. The test results were tabulated and incorporated into Electrical Design Standard DS-E12.1.13 R2 and DS-E12.1.14 R0, (04/15/86, App. A, 5 99 and 5.11).
00410(04/28/87)
- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 L PAGE 12 CF 31 The cable OD differences discussed above will have no effect on cable ampacities and derating because cable ampacities in conduits are a function of the number of conductors and conduit arrangement, and not of the physical conduit fill.
Furthermore, as part of a program to correct the situation regarding conduit fills, a memo from Raughley (10/07/86, App.
A, 5.tt) directs all the nuclear plants to establish "a sampling program to determine the adequacy of electrical cables with respect to their ampacity ratings" (the induction and heating issues are addressed in detail ir Element Report 240.0). Although TVA indicated (10/08/86, App. A, 7.b) that the extent of conduit overfill at SQN will be determined as a byproduct of this sampling program, the program itself is not clear in this respect as the memo does not specifically require the sampling program to include evaluation of overfilled raceways. No results of this program are available yet. .
Regarding conduit supports, the evaluation team reviewed the cable weights used in the design of these supports (11/20/85, App. A, 5.xx) against a sample of verified cable weights 6: (04/25/86, App. A, 5.yy). This review indicated that
' although in general the values used for the support design are larger than the verified weights for equivalent cross '
sectional areas, cases were identified in this random sampling where the opposite occurred (e.g., 3 WDP-1 cables used in a 3-inch conduit). Furthermore, the cable weight used in the support design is based on a maximum conduit fill of 40%. Since no certainty exists that these fills have not been exceeded and no program addressing this aspect at SQN was identified, the evaluation team could not confirm the adequacy of the supports (note that Electrical Design Standard DS-E13.1.4 allows a maximum fill of 53 percent for conduits containing one cable).
- b. Cable Damage The issue regarding cable damage from cable pulling practices in overfilled conduits (e.g.: excessive cable t.ension and side wall pressure, improper use of fishtapes, pull-bys, etc.) has been addressed by TVA in several investigations and reports. Although these investigations and reports are primarily directed at cables in conduits, the evaluation team's assessment is equally applicable to cable damage in cable trays and wall and floor cable tray penetrations.
0041D (04/28/87)
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 13 0F 31
(
TVA memo from Vineyard to Rankin (10/31/85, App. A, 5.w) requested investigation of a potential generic condition at Sequoyah descoIbed in WBN Nonconformance Report (NCR) No.
6347 R0 (09/27/85, App. A, 5.x). The NCR addresses a condition adverse to quality (CAQ) at Watts Bar Nuclear Plant in which several electrical conduits were installed with more than 360 degrees of accumulated bends between cable pull points. This condition does not meet the requirements of TVA Electrical Design Guide DG-E13.1.1 (App. A, 5.y), which states that a conduit run shall not contain more than the equivalent of four 90 degree bends (360 degrees total) between cable pull or termination points. The attached Determination of Reportability Information Worksheet of 10CFR50.55(a) indicates that cables pulled through more than 360 degrees of conduit bends could result in sidewall pressure (SWP) exceeding that allowed by the cable manufacturer and by TVA General Construction Specification .
G-38. This could result in damage to the cable insulation.
TVA memo Wilson to Abercrombie (07/26/86, App. A, 5.z) transmitted "SQN - Walkdown Results of Cable Sidewall Pressure Issues to Resolve Generic Watts Bar Nuclear Plant
.' (WBN) NCRs 6270 [08/20/85, App. A, 5.aa] and 6347." The walkdown was performed under SQN Special Maintenance Instruction SMI-0-317-32 (06/20/86, App. A, 5.bb), to identify 16 worst case conduits with multiple bends exceeding 360 degrees between pulling points. A computer program using the data compiled during the field walkdown of these conduits was employed to determine the calculated pulling tension and sidewall pressure, as required by General Construction Specification G-38. DNE Calculation SQN-E2-015 (07/24/86, App. A, 5.cc), indicated that the SWP for class IE cables was within the maximum allowable.
Review of this calculation by the evaluator revealed that the selection for worst-case conduit runs does not comply with the criteria set forth in the field walkdown procedure SMI-0-317-32:
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o The walkdown procedure requires that selected conduits should have more than 360 degrees between pull points, but 15 of the 16 conduits selected have cumulative bends of less than 360 degrees 00410 (04/28/87)
- TVA EMPLOYEE CONCERhS REPORT NUMBER: 238.1 (B)
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SPECIAL PROGRAM REVISION NUMBER: 3 k PAGE 14 0F 31 o The procedure requires that the selected conduit should have a percentage fill greater than 30 percent, but 9 conduits were filled to less tha'n 28 percent o The procedure requires long conduit lengths between pull points, but 9 conduits had distances of less than 25 feet o Pulling calculations were based upon only one direction of pulling. This does not cover the possibility for construction to pull the cables in the opposite direction.
However, during the 10/08/86 meeting.(App.A,7.b),TVA indicated that it has recognized this deficiency and a new independent review of sidewall pressure for worst case This conduit runs is scheduled is in agreement to be completed with TVA's interim by(11/15/86.
response 10/31/86, App. A, 5.zz) to Questions 2, 3, 4, 5, with regard to the .
identification of worst case pull: in conduits, as part of thesixteenquestionsraisedbytheNRC(08/30/86, App.A, 5.pp). The revised calculation was not completed at the time of the review by the evaluation team.
TVA memo Cantrell to Mason (12/02/85, App. A, 5.t)
- transmitted a report on " Evaluation of the Adequacy of Installed Class lE Cable." This report evaluated operational, maintenance, and surveillance test data on cables from TVA's operating plants and available data from other outside sources, such as the Electrical Power Research Institute (EPRI) and Institute of Nuclear Power Operations (INP0). The collected data were reviewed to ascertain any significant degradation of cable insulation properties in installed class 1E cables. The conclusions in the report regarding adequacy of installed class lE cables were based on the following:
o The initial results of representative electrical tests conducted at different plants (including Sequoyah) during construction, and subsequent periodic bridge', megger, and/or high potential tests on cables for 100 hp and larger motors. The insulation resistance data recorded in the tests varied over a range of acceptable values and revealed no evidence of a trend toward cable insulation degradation. This is in agreement with TVA's interim response (10/31/86, App. A, 5.zz) to question 12 (in-situ testing of cables on a routine basis) of the sixteen questions raised by the NRC (08/30/86, App. A, 5.pp).
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00410 (04/28/87)
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISICN NUMBER: 3
( PAGE 15 0F 31 o Information on identified cable failures at several plants, including SQN. The report indicated that of the approximately 62,000 cables installed at SQN, available records show that only 16 cables f ailed. Six failures were identified during construction by high potential tests and are not attributed to cable pulling practices (three cables were accidentally stapled while in storage and for the other three the failure was attributed to improper termination and not to cable failure). For the remaining ten cables, which failed during operation (only three of them are safety-related), no records are available to indicate cause of failure. However, these failures constitute a very small percent of the total installed cables (0.016 percent) and are considered to be random since they occurred over 5 years of operation.
o Periodic surveillance (as required in the Technical .
Specifications, Sections 3.0 and 4.0 [ App. A, 5.u and 5.v]) to verify operability of all safety systems required for startup, operation, and safe shutdown of the plant. The report concludes that ongoing surveillanca is f adequate verification of the integrity of installed class
' 1E cables The report concluded that for future installations, TVA has established adequate cable installation requirements in General Construction Specifications G-38 (App. A, 5.r) and G-40 ( App. A, 5.s). The report indicated that "following the procedures in these specifications during cable installation and subsequent appropriate maintenance will ensure that the cables will function properly throughout their design life",
which is consonant with proper cable installation practices.
Also, TVA's interim response (10/31/86, App. A, 5.zz) to Question 13 regarding testing or monitoring programs for cables suspected of having been abused, indicated that an extensive trend analysis program will be implemented in November 1986. This program will track, consolidate and categorize conditions adverse to quality and, therefore, will readily identify any adverse trends associated with cabling at any TVA nuclear plant.
SCR SQNEEB8529 R0 (12/06/85, App. A, 5.a) was issued for SQN as a result of WBN Problem Identification Report (PIR) No.
WBNEEB8546. The PIR identified WBN conduits containing 400 Kcmil cables that exceeded the conduit fill as specified in 00410 (04/28/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 L PAGE 16 0F 31 Electrical Design Standard DS-E13.1.4. The SCR described a similar situation at SQN for 55 conduits containing 400 Kcmil 600 V cables in which the percentage fill exceeded the limits allowed in the standard.
Engineering Report CAQ No. SCR SQNEEB8529 R0 (12/27/85, App.
A, 5.1) indicated that these conduit overfills resulted from the failure of design engineering to size the conduits in accordance with the total CSA of the cables routed in these conduits as required per DS-E13.1.4. The report concluded that the cables may be used as they are, because visual-inspection and continuity /megger test were performed after installation to demonstrate the cable integrity, and passed QA inspection in accordance with SNP Inspection Instruction Nos.10 and 28 (06/13/77 and 04/04/83, App. A, 5.d and 5.h).
Although specific records for these cables were not reviewed, the evaluation team verified (10/13/86 through 10/24/86, App.
A, 7.d). that continuity and megger tests, and inspection after installation is performed on all cables and records for this exist and are available at the SQN site. Also, the SCR indicates that credit is given to the fact that the cables have operated for a considerable length of time without Q failure. , ,
Attachment 1 to NSRS Report No. I-86-251-SQN (02/18/86, App. A, 5.f) concluded that NSRS Report No. I-85-06-WBN (dates of investigation 02/29/85 to 04/15/85) (App. A, 5.ccc) is generic to SQN. The NSRS Report No. I-85-06-WBN identified a finding regarding maximum aulling tension or sidewall pressure during installation t1at was referenced in a TVA memo from Drotleff to Sieberling (06/09/86, App. A, 5.dd). This memo supplements the Pierce to Whitt memorandum (07/08/85, App A, 5.ee) in response to NSRS Finding No.
I-85-06-WBN-02. The finding indicates that the TVA cable pull procedure did not include SWP calculations or define the method for calculating maximum pull tension (MPT) on multicable pulls. The Drotleff to Sieber11n with the Raughley to Kirkebo memo (06/11/86,g App.' A, 5.ff memo, along) indicated that:
o An evaluation program initiated in August 1985 evaluated i the class IE cables already installed in conduits and established the impact of including SWP in the cable ]ull tension limitation. Review of the estimated SWP to w11ch the cables were subjected against revised SWP limits t
0041D (04/28/87)
s TVA EMPLOYEE CONCERNS REPORT N'JMBER: 238.1 (B)
SPECIAL PROGRAM REVISION UUMBER: 3 PAGE 17 0F 31 provided by manufacturers and by the EPRI Report No.
EL-3333 indicated that none of the installed cables exceeded the allowable SWP (revised limits were about 4-5 timesthepreviouslimits). Also, a memo from Raughley to Raulson (10/14/86, App. A, 5.ww) states that good construction practices were followed for cable pull-bys in conduits. This is in agreement with TVA's interim response (10/31/86, App. A, 5.zz) to Question 6 of the sixteen questions raised by the NRC (08/30/86, App. A, 5.pp). Question 6 is with regard to considering pull-bys in the determination of worst case cable pulling situations. The response indicates that good construction practices were used, construction employees knew their business, properly sized manila break ropes were provided, and ample amounts of cable lubricants were used. Review of cable installation records by the evaluation team (App. A, 7.d) indicated that QC certified l cable pulling records are available for Class lE cables.
However, with very few exceptions, pull tensions, pull rope sizes, and dynamometer readings are not available when mechanical cable pulls were performed, although SQN procedures required their recording. This is confirmed
.' in conversations with SQN QC inspectors (App. A, 7.d),
who indicated that although pull tensions were monitored, they were not recorded. The use of mechanical devices for cable pulling is also discussed in Construction Report No. C010900-SQN ( >/22/86, App. A, 5.11).
o TVA Central Laboratories performed extensive tests on 21 WBN sample cables in addition to representative sample cables from SQN. These samples include different cable types (power, control, signal and instrumentation, and coaxial), types of insulation, jacket materials, and manufacturers. These cables were pulled through the conduit with tension forces 2 to 12 times the values recommended in G-38. The cables were subjected to pulling tension values near the ultimate copper conductor breaking strength of the cable. Each cable was then inspected, dimensioned, stripped to examine . individual conductors of multiconductor cable, and subjected to dielectric breakdown tests. When compared to virgin cable of the same sample, the average breakdown value of the tested cables was within 20% of the average 00410-8 (04/28/87)
- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 L PAGE 18 0F 31 dielectric breakdown value of the virgin cable sample, thus meeting the acceptance criteria set for the test per ASTM D 149. Furthermore, none of the cables revealed any significant degradation of insulation. Based on this test, memo Raughley to Kirkebo (06/11/86, App. A, 5.ff) concluded that higher allowable limits are justified for all cables purchased by TVA.
Based on the above, the evaluation team's assessment of cable damage is as follows:
o Continuity and megger/high potential tests are conducted at SQN for all newly installed cables per Inspection Instruction Nos. 28 and M&Al-7. Also, bridge and megger/high potential tests are periodically conducted on circuits for 100 hp and larger motors. Although performance of these tests does not provide full -
assurance that damaged cables will be detected unless major damage has occurred, they are widely used as a supplement to good construction practices as they provide a reasonable assurance that cables are functional.
' o Although SQN has been operational for over 5 years only 16 cable failures out of approximately 62,000 installed cables have been identified. Out of the 16 cables, six failures were identified during construction, none of which was attributed to cable pulling practices. The remaining ten cables represent too small a percentage of the total installed cables to suspect a generalized cable damage problem. Furthermore, the evaluation team reviewed the trend analysis printout of the Engineering Cesign Condition Adverse to Quality Database for " Cable" (App. A, 7.e) and determined that none of the reported problems could be attributed to inadequate cable installation practices, o Although DNE Calculation SQN-E2-015 Rev. O did not consider the worst-case conduit runs for calculating the maximum allowable SWP, a revision to this calculation is under way. TVA indicated that revision 1 to this calculation will also take into consideration cable pull-bys. Furthermore, tests performed at TVA Central Laboratories demonstrated that the limiting factor in cable pulling is the breaking strength of the conductor.
The tests also demonstrated that cables can withstand i
00410-8 (04/28/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3
, b PAGE 19 0F 31 considerably larger tension forces than recommended in G-38. These results suggest that the likelihood of the cables being subjected to excessive pulling forces (without the conductor breaking) is very small. However, revision 1 of Calculation'SQN-E2-015, considering cable pulls in overfilled conduits and pull-bys, is required to document that SWP has not been exceeded.
o The ultimate function of electrical cables is to transmit the necessary power or signals to operate or actuate electrical equipment and components. In view of this, the periodic surveillance per Technical Specification requirements to verify operability of all safety systems is an adequate way to verify cable functionality.
o The extensive trend analysis program scheduled for implementation in November 1986, if properly implemented, should become an adequate tool to anticipate any negative trends associated with cable failures. However, no details on this program have been identified to evaluate its adequacy.
- c. A Generic Concern Task Force (GCTF) Report regarding Emp,loyee Concern No. WI-85-100-Oll (05/16/86, App. A, 5.q) was generated for SQN. One of the issues investigated in this GCTF report deals with the portion of the WI-85-100-011 concern claiming that TVA violates the National Electrical Code at Sequoyah for construction practices and tray overfills. This report concluded that, based on the National Electrical Code, Article 90, Section 2(b), paragraph 5, the electrical utility portion of TVA/SQN is excluded from the requirements of this code. These requirements concerning maximum allowaLie fill of cables in conduit and cable pulling practices are covered in the SNP FSAR; Design Criteria SQN-DC-V-ll.3; General Construction Specification G-38; and Electrical Design Standard DS-E13.1.4. Since power plants are not subject to following the NEC requirements, the evaluator concurs with the conclusion of the GCTF report.
- d. Overff11 in cable trays and cable tray penetrations is discussed in Element Report 238.3.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 L PAGE 20 0F 31 Findings:
- a. The evaluation revealed that accurate conduit fill information is not readily available and, therefore, compliance with FSAR connitment for conduit fill is not verifiable through QA documentation. Also, the maximum allowable conduit fill indicated in Electrical Design Standard DS-E13.1.4 is not in agreement with FSAR and Design Criteria No. SQN-DC-V-li 3 requirements. Furthermore, SQN design engineers used cable weight data from a TVA Design Standard that were taken from non-QA sources. These uncertainties regarding conduit fill and cable weight raise the question about the adequacy of cable ampacities and conduit supports. As previously indicated, a memo from Raughley (10/07/86, App. A, 5.tt) initiated a program to address the cable ampacity issue. However, this memo is not specific with regard to evaluation of overfilled raceways. -
No program that addresses the conduit support adequacy was identified.
- b. Although the adequacy of past cable pulling procedures could not be fully verified because of incomplete records and QA Q documentation, a reasonable assurance exists that no trend of cable failures as a result of cable damage due to pulling should be expected. Any failures that might occur should be considered random failures. Also, completion of DNE Calculation SQN-E2-015, Rev.1, including consideration of cable pulls in overfilled conduits and pull-bys, should further support this assessment, and implementation of the new trend analysis program should adequately anticip' ate negative trends with regard to cable failures. However, revision 1 of the calculation and the trend program were not available at the time of the review.
- c. The NEC does not require utilities (TVA) to comply with the requirements of the code. Therefore, TVA is not obliged to follow NEC for conduit fills and cable pulling practicas.
Conclusions:
- a. Current uncertainties regarding compliance with FSAR commitment regarding conduit fills, adequacy of cable ampacities and conduit supports are the direct result of incomplete records for actual conduit fills. Existing program regarding cable ampacities is not specific with
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- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3
( PAGE 21 0F 31 regard to overfilled raceways. No program has been identified to address the adequacy of conduit supports.
4 Therefore, issues regarding conduit overfills are valid.
However, new procedure SQEP-06 as well as other programs, discussed in detail in Sequoyah Element Report 239.0 and 240.0, if properly implemented and followed, should prevent recurrence of a similar problem in the future. Also, revision of applicable documents as needed for consistency should resolve the current disagreement between the FSAR and the Design Criteria No. SQN-DC-V-11.3, and the Electrical Design Standard OS-E13.1.4 for the maximum allowable cable i fill in conduits.
I
- b. Although the adequacy of past cable pulling procedures could not be verified, the issue regarding cable damage could not be validated as no evidence of cable failures resulting from cable damage could be found. Furthermore, completion of the-revision to the DNE calculation and implementation of the new
, trend analysis program should provide further assurance regarding adequacy of cable installations.
' not obliged to follow NEC for conduit fills and cable pulling practices.
- 10. CORRECTIVE ACTION:
TVA has generated four corrective action plans (CAPS) to resolve the above findings and to respond to the problems identified on corrective action tracking documents (CATDs) 238.01-SQN-01 through 238.01-SQN-05 (CATO 01 through 05). These CAFs were transmitted via TCAB-054, TCAB-074, and TCAB-088 on 01/13/87, 02/17/87, and 04/21/87, respectively. Further clarification of the CAPS was provided by TVA via teleconference (App. A, 7.h, i, and j).
The first CAP responds to CATDs 01 and 02. CATO 01 asserted that conduit fill information is not readily available nor dAterminable; therefore, compliance with FSAR commitments regarding conduit fills is not verifiable. In addition, because of the uncertainty of conduit fill, CATO 02 questions the adequacy of conduit supports and cable ampacity. To eliminate these uncertainties, TVA has retained theservicesofUnitedEngineersandConstruction(UE&C)toconduct a full systematic analysis of the SQN cable and conduit scheduling program. Furthermore, UE&C will identify any necessary corrective actions required to establish the accuracy of the conduit and cable schedules.
00410-7 (04/28/87)
- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3
-O PAGE 22 0F 31 The UE&C effort will include a review of the practices and procedures utilized in routing, installing, and abandoning cables in conduit during SQN's design, construction, and modification phases up to the present. The purpose of this review is to determine potential root causes for discrepancies and to bound any identified problem areas resulting from these root causes. The scope of this review encompasses thcse procedures and practices applicable to all class lE conduits. This review is a prerequisite to any further review and shall be completed prior to unit 2 restart.
Subsequent to the above review, programs will be developed and implemented to correct all identified discrepanciec, and to mitigate the effects of any generic procedural breakdowns. Furthermore, all discrepancies will be evaluated for their impact on:
o Conduit fill commitment verification o The worst-case' cable pulls o Conduit support adequacy o Cable ampacity
, (
All corrective actions required to resolve problems identified by the UE&C review will be evaluated per restart criteria and only those items meeting these criteria will be implemented before unit 2 restart. The remaining items will be completed as part of a long-term program after restart.
The second CAP is in response to CATO 03 which expresses concern for the completion of documentation to ensure that the maximum sidewall bearing pressure (SWP) was not exceeded during cable installation.
Subsequent to the issuance of this CATO,. revision 2 of calculation 1 DNE SQN-E2-015'was prepared and forwarded to the NRC (App. A, 5.ggg; 12/08/86) to document the maximum SWP for SQN. This transmittal was in response to NRC questions (App. A, 5.pp, 08/30/86) regarding worst case cable pulls. SWP, jamming, and pullbys are all open items with the NRC and NRC concurrence will constitute acceptable closure of this issue. Further, TVA has conducted SWP tests, and plans to conduct further cable tests to ensure that the effects of SWP, pullbys, jamming, and support of cables in vertical conduit has not jeopardized the functional adequacy of cables in conduit (this information was provided as part of the CAP for CATOs 01 and 02).
Finally, as discussed in the previous CAP, TVA wili review this
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- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 Q PAGE 23 0F 31 calculation on the basis of results of the previously described conduit schedule accuracy evaluation and will evaluate any discrepancies for their effect on SWP. Any items identified as potential problems will be evaluated against the restart criteria and those meeting these criteria will be resolved prior to Unit 2 restart. The remaining items will be resolved as part of a long-term program.
The third CAP responds to CATO 04 which highlighted the lack of complete implementation details for the Trend Analysis Program for cable failures. The corrective action was to supply implementation details for review by the evaluation team. A preliminary copy of NEP 9.2, " Trending of Conditions Adverse to Quality,"
(App. A, 5.eee) has been forwarded to, and reviewed by, the evaluation team and found to be sufficient to accomplish its intended function. However, final concurrence from the NRC on parameters to be monitored has not been obtained; therefore, this is an open item pending NRC final concurrence. In addition, a preliminary copy of DNE operating instruction (Apo. A, 5.fff) was forwarded to the evaluation team. This 01 provides for the implementation of NEP-9.2. Further, the Nuclear Quality Assurance q Manual, Part I, Section 2.16, Revision 2 has been issued (01/04/87) and this revision assigns specific responsibility for trending. The program has now been implemented. (Refer to CATO 238.1-WBN-07).'
The fourth CAP addressed CATO 05 that identified a discrepancy in the allowable conduit fills. SQN Design Criteria SQN-0C-V-11.3 (App. A, 5.j) and the SNP FSAR Section 8.3.1.4.1 (App. A, 5.1) specify a maximum of 40 percent fill, whereas electrical Design Standard OS-E13.1.4 (A,p. A, 5.b) permits a range of 30 to 53 percent dependent c. the number and service level of the included cables. The CAP calls for the revision of the allowable conduit fills in the FSAR as p u t of Amendment 5.and the revision of the design criteria to reflect the design standard values which are typical for the inoustry. Both of these activities are not required for restart; however, these revised values will be used in the commitment verification required by the CAP in response to CATDs 01 and 02.
The evaluation team finds all corrective actions to be appropriate and sufficient to resolve the 'indings of this report.
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00410-8 (04/28/87) i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3
(. PAGE 24 0F 31 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. Significant Condition Report (SCR) No. SQNEEB8529 R0, (B43 851220 904), " Conduits Containing 400 MCM Cables That Exceeded the Conduit Fill as Specified in DS-E13.1.2 and DS-E13.1.4,"(12/06/85)
- b. Electrical Design Standard, DS-E13.1.4 R1 " Conduit - Maximum Cable Diameter for Various Rigid Steel Conduits," (08/24/83)
- c. SQN Modifications and Additions Instructions M&AI-4, R8,
" Control, Power and Signal Cables," (12/31/85)
- d. SNP Inspection Instruction No. 28, " Cable Pulling Inspection, R0," (06/13/77) .
- e. National Electric Code, NFPA-70-1984
( l to: NSRS Report No. I-86-251-SQN,"
Subject:
" Electrical j
Cables," (02/18/86) ,
- g. SQN Modifications and Additions Instruction M&AI-7, " Cable Terminations, Splicing and Repairing of Damaged Cables,"
Rev. 8, Section 5.0, " Inspection Criteria of Cables or Internal Panel Wiring," (07/24/86)
- h. SNP Inspection Instruction No. 10, Sections 7 and 8, paragraphs 7.B.1, 7.B.2, 8.D, and 8.E, " Interconnecting Cable Termination and Insulation Inspection, Rev. 16," (04/04/83)
- 1. SNP FSAR, Section 8.3.1.4.1, Amendment 1, " Cable Derating and Cable Tray Fill"
- j. Design Criteria SQN-DC-V-II.3, " Power Control and Signal Cables For Use in Category 1 Structures," Section 6.1.2,
" Conduit Loading, Rev. 5," (09/30/86)
" Cable and Conduit Procedure for Sequoyah Nuclear Plant,"
(09/22/86) l 1. Engineering Report CAQ SCR SQNEEB8529 R0, (501860114 928),
"WBN Conduits Containing 400 MCM Cables That Exceeded the Conduit Fill as Specified in DS-E13.1.2 and
' DS-E 13.1.4,"( 12/27/85 )
i 00410 (04/28/87) l m ..g ;
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 L PAGE 25 0F 31 APPENDIX A (cont'd)
- m. TVA, SQN, Generic Concern Task Force Report, " Overfill of Cable Trays and Conduits, R1," (26 concerns), (05/20/86)
- n. TVA memo Chitwood to Raulson/ Vineyard, (B43 860203 902),
"Significant Condition Report (SCR) No. SQNEEB8529 R0,"
(01/31/86)
- o. SCR No. SQNEEB8601 R0, (B43 860117 919), (01/06/86)
- p. TVA memo Wilson to Brimer, "Sequoyah Nuclear Plant Units 1 and 2 - Engineering Report for CAQ Report No. SCR SQNEEB 8601 R0, Rev.1," (B25 860416 007), (04/16/86)
(1 concern), (05/16/86) '
- r. General Construction Specification No. G-38, Rev. 6,
" Installing Insulated Cables Rated Up to 15,000 Volts,"
(09/15/85); Rev. 8, (03/17/86) t,
- s. General Construction Specification No. G-40, Rev. 8, ,
" Installing Electrical Conduit Systems and Conduit Boxes,"
(10/10/85); Rev. 9, (12/19/85)
- t. TVA memo Cantrell to Mason, " Evaluation of the Adequacy of Installed Class 1E Cables," (B43 851203 915), (12/02/85)
- u. SQN Tachnical Specification, Surveillance Requirements, Section 3.0,(09/17/80)
- v. SQN Technical Specification, Surveillance Requirements, Section 4.0,(09/17/80)
- w. TVA memo Vineyard to Rankin, "Sequoyah Nuclear Plant Units 1 and 2 - Potential Generic Condition Evaluation,"
(B25 851031 008), (10/31/05)
- y. Electrical Design Guide, DG-E13.1.1, Revision 1, " Conduit -
Cable Pull-Point Locations and Support Locations," (02/09/81)
- z. TVA memo Wilson to Abercrombie, "Sequoyah Nuclear Plant -
Walkdown Results of Cable Sidewall Pressure Issues to Resolve Generic Watts Bar Nuclear Plant (WBN) NCRs 6270 and 6347,"
k- (825 860726 001), (07/26/86) 00410 (04/28/87)
TVA EMPLOYEE CONCERiM REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 k PAGE 26 0F 31 APPENDIX A (cont'd) aa. WBN NCR No. 6270 R0, " Cable Sidewall Pressure Calculation,"
(08/20/85) bb. Special Maintenance Instruction SMI-0-317-32, Rev. O, "Walkdown Procedure for Identifying Sidewall Pressure Violations in Conduits with Multiple Bends in The Auxiliary Building Units 1 and 2," (06/20/86) cc. D:;E Calculation, SQN-E2-015, Rev. O, " Identifying Sidewall Pressure Violations," (B25 860724 801), (07/24/86) dd. TVA memo Drotleff to Sieberling, " Watts Bar Nuclear Plant (WBN) - Investigation of An Employee Concern Regarding Cable Routing, Installation, and Inspection - Nuclear Safety Review Staff Report No. I-85-06-WBN," [ Response to six findings],*
(843 860609 927), (06/09/86) ee. TVA memo Pierce to Whitt, " Watts Bar Nuclear Plant - Nuclear Safety Review Staff Investigation of an Employee Concern Regarding Cable Routing, Installation, and Inspection
( Practices - NSRS Report No. I-85-06-WBN," [ Response to ,
finding I-85-06-WBN-02], (F01 850708 604), (07/08/85) ff. TVA memo Raughley to Kirkebo, " Cable Sidewall Bearing Pressure (SWP)," (843 860611912), (06/11/86) gg. Electrical Design Standard DS-E12.1.13. Rev. 2, " Cable -
Class 1E Cable ODs and Weights," (04/15/86) hh. Engineering Related Employee Concern - Special Program,
" Potential Problems Requiring Corrective Action Before Restart," (5 concerns), (09/19/86)
- 11. Electrical Design Standard DS-E12.1.14, Rev. O, " Cable -
Class NC Cable ODs and Weights," (04/15/86) ,
jj, TVA memo McCloud to Those Listed, " Cable Pulling Practices at Sequoyah Nuclear Plant (SQN)," (L33 861020 800), (10/20/86) kk. TVA memo Denice to Abercrombie, Sequoyah Nuclear Plant (SQN)
Generic Concern Task Force (GCTF) Report "IEE Standards Not Included in Electrical Procedures," Employee Concern IN-86-259-X11 (T25 860604 984), (06/04/86)
, 11. TVA Employee Concerns, Special Program - Report No.
\ C010900-SQN Rev. 1, " Cable," (09/22/86) 0041D (04/28/87)
- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 b PAGE 27 0F 31 APPENDIX A (cont'd) mm. TVA memo Chandler to Those Listed, " Potential Generic Condition Evaluation," (B43 851025 913), (10/18/85), and attached NCR 6347 R0, " Excessive Conduit Bends," (09/27/85) nn. TVA, SQN, GCTF Report, "Overtensioning and Minimum Bend Radius Violations of Cables Due to Im Methods, R1," (26 concerns), (proper Cable Installation 05/28/86)
! oo. TVA memo Gridley to Drotleff, "NRC Request for Information Concerning Cable Pulling and Cable Bending Radii at Watts Bar (WBN) and Sequoyah (SQN) Nuclear Plants," (L44 860808 803),
(08/08/86) pp. Letter from Youngblood, NRC, to White, TVA, " Request for Information Concerning Cable Pulling and Cable Bending Radii at Sequoyah," [S10 860904 859], (08/30/86) qq. TVA memo Raughley to Raulston, " Watts Bar Nuclear Plant Units 1 and.2 - Non-QA Values for Cable Weights and Outside Diameters
" Used in Calculations - NCR WBNEEB8589 and WBNEEB8590 -
' 10CFR50.55(e) Final Report," (B43 860926 907), (09/24/86) , l rr. TVA memo Gridley to Drotleff, "NRC Request for Information Concerning Cable Pulling and Cable Bending Radii at Watts Bar (WBN) and Sequoyah (SQN) Nuclear Plants," - Attachment of NRC letter from Youngblood to White (08/04/86), (L44 860808 803),
(08/08/86) ss. TVA memo from Raughley to Roberts, "Sequoyah Nuclear Plant -
Cable Weights and Outside Diameters (0D)," Attachment of TVA memo Scruggs to Raughley (09/04/86), (B43 860923 908),
(09/23/86) tt. TVA memo Raughley to Those Listed, "All Nuclear Plants -
Corrective Action and Sampling Program for Electrical Cable Ampacity," (843 861008 909), (10/07/86) uu. TVA, SQN, Employee Concern Task Group Operations, Report No.
304.01, Revision 1, Subcategory: " Cable and Conduit,"
Element: " Procedure Problems," (10/21/86) vv. Letter from B. J. Youngblood, NRC, to S. A. White, TVA, (06/23/86) with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN [B45 860714 832]
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 C PAGE 28 0F 31 APPENDIX A (cont'd) ww. TVA memo from Raughley to Raulston, "Sequoyah Nuclear Plant Cable Issues - NCR Response," (843 861014 901), (10/14/86) xx. Design Criteria SQN-0C-V-13.10, "0esign Criteria For Seismically Qualifying Conduit Supports," R2 (11/20/85) yy.
OE Calculation " Class lE and Non-Class lE Electrical Cable Weigit/ Foot and Outside Diameter," R0, (826 860425137),
(04/25/86) zz. Letter from Gridley, TVA, to Youngblood, NRC, (L44 861031811) "In the Matter of the Tennessee Valley Authority Docket Nos. 50-327 and 50-328 - Sequoyah Nuclear .
Plant (SQN) - Cable Pulling Questions," (10/31/86) aaa. TVA memo from Johnston to Raughley, " Evaluation of Computerized Cable Routing Systems Final Report,"
(B42 861229 006), (12/29/86), and attached " Evaluation of i.
- Computerized Cable Routing System Final Report, "
(11/01/86). Attachment B to this report is the Quality '
Assurance Evaluation Report - Sequoyah Nuclear Plant Cable Routing System, (10/28/86) bbb.
TVA memo Harding to Wilson, "Sequoyah Nuclear Plant (SQN) -
CablePullingQuestions,"(S10860904859),(09/04/86) ccc. NSRS Report No. I-85-06-WBN, " Investigation of an Employee Concern Regarding Cable Routing, Installation, and Inspection at Watts Bar Nuclear Plant," (Q01 850709 051), dates if investigation 02/29/85 to 04/15/85 '
ddd.
Corrective Actions Plans transmitted via TCAB-054 (01/13/8/),
TCAB-074(02/17/87),TCAB-082(03/31/87), and TCAB-088 (04/21/87) -
eee. Nuclear Engineering Procedure 9.2, Oraft, " Trending of Conditions Adverse to Quality (CAQs)"
fff. Division of Nuclear Engineering Operating Instruction.
DNE-01-3003, " Trend Analysis Operating Instruction," 2nd Oraft 999 Letter from Gridley, TVA, to Youngblood, NRC, "SQN-Cable Pulling Questions: SupplementalResponses,(L44861208800),
(12/08/86) 00410-7 (04/28/87)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 s,
PAGE 30 0F 31 APPENDIX A (cont'd)
- f. Meeting in Knoxville, TN, T. Shea, TVA and T. Sarver, Bechtel,BLT-123,(01/28/87) ,
- g. Teleconference between T. Shea, K. Browr., TVA, and T. Sarver, U. Rieder, Bechtel, IOM 647,(02/14/87)
- h. Teleconference between G. McNutt, R. Reeves, C. Lyke, TVA, and C. Jordon, I. Don-Doncow, T. Sarver, Bechtel, IOM 681,
, .,. (02/21/87)
, i. .Teleconference between T. Shea, C. Lyke, R. Reeves, c .G. McNutt, TVA and T. Sarver, I. Don-Doncow, C. Jordan, 8(chtel, IOM 726,(02/23/87)
- j. Teleconference birtween G. McNutt, R. Williams, R. Denning, R. McKay, J. Swearingen and R. Reeves, TVA, and C. Jordan, I. Don Doncow and T. Sarver, Bechtel, IOM 939,(04/27/87)
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- TVA EMPLOYEE CONCERNS REPORT NUMBER: 238.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 3 C. PAGE 31 0F 31 CATO LIST I The following CATO forms identify and provide corrective actions for the findings included in this report:
238 01 SQN 01 Revised 12/05/86; CAP revised 04/21/87)
H 238 01 SQN 02 Revised 12/05/86; CAP revised 04/21/87) l 238 01 SQN 03 Revised 12/05/86; CAP revised 01/13/87) i 238 01 SQN 04 (Issued 12/05/86; CAP revised 01/13/87) 238 01 SQN 05 (Added 01/08/87; CAP revised 02/17/87)
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REFERENCE - ECPS120J-ECP3121C TENNESSEE VALLEY AUTHORITY PAGE -
89 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER ' RUN TIME - 13:58:39 ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 03/19/87
- EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY CATEGORYs Eli DES PROCESS & OUTPUT SUBCATEGORY: 23801 CONDUIT OVERFILLS S
H I REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN CONCERN NUMBER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN. CONCERN DESCRIPTION
________________ ___ _ _ ___ __ __ __ __ ___ == ______ - - - -
IN 312-00101 EN 23801 S HBN 1Y Y Y Y QTC CABLE TRAYS IN CONDUITS ARE OVERFILLED HITH CABLE.
T50188 2 SR SR SR SR THE CABLES COULD BE DAMAGED AND NOT DISCOVERED U NTIL IT SHORTS OUT. LOCATION 737' AUX BUILDING AN 02 EN 23803 S HBN 1N Y Y N D 741' AND 749' CONTROL BUILDING AND SPREAD ROOM.
2 NA SR SR NA CI COULD NOT PROVIDE ANY SPECIFIC CONDUlT OR CABL E TRAY NUMBERS. NO ADDITI0flAL INFORMATION AVAILAB LE. CONSTRUCTION CONCERN. UNIT 1 & 2.
IN 313-00101 EN 23801 N HBN 1Y Y Y Y QTC OVERLOADING OF CONDUITS-HIRE IS BEING PULLED THRU T50188 2 SR SR SR SR CONDUIT THAT IS LOADED HITH HIRE SUCH THAT IT IS D IFFICULT TO PUSH A PENCIL THRU, HIRE IS BEING STR ETCHED HHEN PULLING THRU THESE CONDUITS. UNIT 2 A NNULUS AREA. CI COULD NOT PROVIDE SPECIFIC CONDUI T NUNBERS. CONSTRUCTION CONCERN. NO ADDITIONAL I NFORMATION AVAILABLE.
IN 367-00101 EN 23801 N HBN 1Y Y Y Y QTC CABLE IN CONDUIT DAMAGED BY CABLE PULLING PRACTICE T50096 2 SS SS SS SS S. (1) CONDUITS ARE OVER-FILLED (EG1" CONDUIT IN CEILING OF NORTH FAN ROOM. UNIT 2 - THIS HAS RUN LATE DEC. '84, AND 2" CONDUIT BEHIND NEARBY SECURI TY OFFICE). (2) FISH TAPES CAN DAMAGE CONDUIT, ES PECIALLY HHEN THEY GET STUCK (EG ACCUMULATOR ROOM 84, UNIT 2* JUNCTION BOX 81922A, -2" CONDUIT CUT OF BOTTOM - 82VC1201A. TOOK 3 DAYS TO GET FISH TAPE
- PARTHAY IN, UN-STUCK. AND CABLES RE-PULLED.) (3)
NYLON CORD " PARACHUTE" CAN CUT CABLE INSULATION (
IN 432-00101 EN 23801 N kBN 1 Y .Y Y Y QTC OVERFILL OF CABLES IN CONDUITS IN AUX. CONTROL BU T50041 2 SS SS SS SS ILDING ELEV. 757 AND REACTOR BUILDING.
IN 506-00101 EN 23801 N HBN 1Y Y Y Y QTC A RECENT CABLE PULL (DATE KN0HN) HAS ACCOMPLISHED T50044 2 SS SS SS SS ON A CONDUIT HHICH HAS OVERFILLED TO THE POINT THA T THE 1/8" "FISHSNAKE" HHICH GUIDES THAT CABLE CDU
, LD BARELY BE INSERTED. CI EXPRESSED THAT THE COND UIT IS 100% + FULL AS A RESULT OF THIS CABLE PULL.
~ LOCATION GIVEN HAS 708' ELEVATION, RUNNING FROM
~
THE CONTROL ROOM TO THE UNIT 2 ANNULUS AREA, THEN INTO A PENETRATION. OTHER DETAILS ARE KNOHN (FORE MAN'S NAME).
IN 622-00101 EN 23801 N HBN 1Y Y Y Y QTC CONDUIT OVERFILLED BEYOND SAFE CAPACITY. NO FURTH T50060 2 SS SS SS SS ER DETAILS AVAILABLE FROM CI.
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I REFERENCE - ECPS120J-ECP5121C TENNESSEE VALLEY AUTHORITY PAGE -
90 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 13:58:39 DNP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 03/19/87 '
EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY CATEGORYa EN DES PROCESS & OUTPUT SUBCATEGORY: 23801 CONDUIT OVERFILLS S
H 1 REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN CONCERN DUMBER CAT CAT D LOC BF BL SQ NB REPORT ORIGIN CONCERN DESCRIPTION
--- ----- - --- - - - - - - - - . . . - - - - - ------ __ _ - - - _ _ _ = - - - - - _ - - - - - - - - _ - - - - _ _ _ _ _ -
IN 642-00101 EN 23801 N HBN IY Y Y Y QTC CONDUIT IS 98% FULL OF CABLE AND MORE CABLE IS TO T50133 2 SR SR SR SR BE INSTALLED. REACTOR 82, RACEHAY, 713' ELEV. A2
~
20 DEGREES AND PIPE NO. 2VC2580A. CONSTRUCTION DE PT CONCERN. CI HAS NO FURTHER INFORMATION.
IN 685-00101 EN 23801 N HBN 1Y Y Y Y QTC CONDUITS ARE GENERICALLY OVERFILLED BEYOND ACCEPTA T50068 2 SS SS SS SS BLE LIMITS. NO FURTHER DETAILS AVAILABLE. NO FDL LOH-UP REQUIRED.
IN 734-00101 EN 23801 S HBN 1Y Y Y Y QTC CONDUITS / CABLE TRAYS / PENETRATIONS IN UNITS 1 8 2 A
., T50069 2 SR SR SR SR RE GENERICALLY OVERFILLED /DVERLOADED. NO LOCATION S/ SPECIFICS PROVIDED. NO FOLLOH-UP REQUIRED.
02 EN 23803 S HBN 1N Y Y N 2 NA SR SR NA ,
IN 743-00801 EN 23801 S HBN 1Y Y Y Y QTC CONDUITS ARE GENERICALLY OVERFILLED AND ADDITIONAL T50076 2 SS SS SS SS CABLES ARE ROUTINELY SCHEDULED TO BE ADDED TO THE CONDUITS. THIS CAUSES SIGNIFICANT EXPENDITURES 0 02 EN 23900 S HBN 1Y Y Y Y F MANHOURS IN ATTEMPTING TO PULL CABLE HHERE THERE 2 SS SS SS SS IS NO MORE ROOM AVAILABLE. NO MORE FURTHER DETAI LS AVAILABLE.
- IN 832-00101 EN 23801 S HBN 1Y Y Y Y QTC OVERLOADED CABLE TRAY PENETRATION ELEV. 729' TURBI T50086 -
2 SR SR SR SR NE BUILDING AND CONTROL BUILDING ELEV. 737' AUX.
BUILDING AND CONTROL BUILDING 741', CONDUITS BEIN s 02 EN 23803 S HBN 1N Y Y N G FILLED BEYOND HATIONAL ELEC. CODE ALLOHANCE. P 2 NA SR SR NA OSSIBLE DAMAGE TO CABLES THAT OTHER CABLES ARE BEI NG ERAGGED OVER.
E IN 856-00301 EN 23801 S HBN 1Y Y Y Y QTC CONDUIT AND CABLE TRAYS ARE TOO FULL. UNIT 51 AND T50094 2 SR SR SR SR 82. NG MORE INFORMATION AVAILABLE. NO FOLLOH UP REQUIRED.
( 02 EN 23803 S HBN 1N Y Y N 2 NA SR SR NA
~
IN 028-00201 ~ EN 23801- S HBN 1Y Y Y Y QTC NATIONAL ELECTRICAL STANDARDS ARE NOT BEING FOLLOH T50110 2 SS SS SS SS ED. EXAMPLE: CABLE TRAYS AND CONDUITS ARE OVER FU LL. CI HAS NO ADDITIONAL INFORMATION.
02 EN 23803 S HBN 1N Y Y a 2 NA SS SS NA
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i REFER EllCE - ECPS120J-ECPS121C TEllHESSEE VALLEY AUTHORITY PAGE -
91 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIM ~ - 13:58:39 DNP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 03/19/87 .
EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY CATEGORY: E!1 DES PROCESS & OUTPUT SUBCATEGORY: 23801 CONDUIT OVERFILLS S
H- 1 REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN .
CONCERN NUMBER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION IN 034-00101 EN 23801 N HBN 1Y Y Y Y QTC AUX. BLDG. UNIY 2 EL. 73-CABLE PULL REQUIRED 1 HEE T50111 2 SR SR SR SR K TO FEED FISH TAPE THRU CONDUIT PRIOR TO CABLE PU LL. OVERLOADING OF CONDUITS DAMAGES CABLES. CI H AS NO ADDITIONAL INFORMATION. NO FOLLOH UP REQUIR ED.
l IN 036-00101 EN 23801 S HBN 1Y Y Y Y QTC ELECTRICAL CONDUITS IN UNITS 1 & 2 ARE OVERFILLED.
I T50189 2 SR SR SR SR THIS MAY CAUSE INDUCTION / HEAT PROBLEMS. SOME CA I BLES MAY ALSO HAVE BEEN DAMAGED BY PULLING IN THES 02 EN 24000 S HBN 1Y Y Y Y E TIGHT CONDITIONS, AND BY USING EXCESSIVE FORCE I 2 SR SR SR SR H INSTALLING TPE FISHTAPE IN THE CONDUITS. DETAIL S KNOHN TO QTC, HI1HHELD DUE TO CONFIDENTIALITY.
I CONSTRUCTION DEPT CONCERN. CI HAS NO ADDITIONAL I k HFORMATION.
IN 206-00101 EN 23801 N HBN 1Y Y Y Y QTC TH0 2 CONDUCTOR 814 SAFETY RELATED CABLES HERE PUL T50227 2 SR SR SR SR LED THROUGH OVERCROHDED 3" CONDUIT /CONDOLETS WITH A 1/2 TO 3/4 TGH COME-A-LONG. THE CONDUIT / CONDOLE TS HERE SG FULL, IT HAS DIFFICULT TO GET THE FISH I
I TAPE IN. CONDUIT LOCATED AT ELEVATION 737' 0F UNI
' T 81 AUXILI ARY BUILDING TO THE CABLE SPREAD ROOM, ELEVATION 742, COLUMN LINES A3-A4 AND "Q" LINE. T s
HE CABLE HAS FOR UNIT II, BUT HAS BEING ROUTED THR
> OUGH UNIT I. CI DOES NOT KNOH IF CABLE HAS TESTED AFTER INSTALLATION. OCCURRED APPROX. FEB./ MARCH, IN 254-00901 EN 23801 N HBN 1Y Y Y Y QTC CONDUIT RUNNING FROM MANHOLES 1 & 2 TO THE AUX. BL
{
, T50209 2 SR'SR SR SR DG. ARE OVERFILLED HITH CABLES. CONSTRUCTION DEPT
. CONCERN. CI HAS NO FURTHER INFORMATION.
l IN 262-00101 EN 23801 S HBN 1Y Y Y Y QTC UNITS 182. THE CONDUITS AND CABLE TRAYS ARE FAR T T50143 2 SR SR SR SR 00 FULL. IT OFTEN TAKES 4-5 DAYS JUST TO PULL THE FISH TAPE THROUGH. THIS OVERCRONDING IS AN UNSAF 02 EN 23803 S HBN 1N Y Y N E CONDITION. CONSTRUCTION DEPT CONCERN. CI HAS N 2 NA SR SR HA 0 FURTHER INFORMATION. NO FOLLOUUP REQUIRED
~ IN 262-00401 CO 19200' S HBH 1N N N Y QTC ELEV. 729' (ABOVE MACHINE SHOP) THERE ARE FOUR OR T50145 2 NA NA NA SR FIVE 5" TO 6" CONDUITS STILL HAVING THE FISH TAPE IN THEM. THE CONDUIT IS SO FULL THE FISH TAPE CAN 02 EN 23801 S HBN 1Y Y Y Y NOT BE REMOVED. CONSTRUCTION DEPT CONCERN. CI HA 2 SR SR SR SR S NO FURTHER INFORMATION. NO FOLLOHUP REQUIRED
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PAGE -- 92
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY RUN TIME - 13:58:39 REFERENCE OFFICE OF NUCLEAR PONER FREQUENCY - REQUEST RUN DATE - 03/19/B7 , .
-ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 23801 CONDUIT OVERFILLS S
H 1 REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN REPORT ORIGIN CONCERN DESCRIPTION CONCERN NUMBER CAT CAT D LOC BF BL SQ HB ==-
__=....--
- _ - =--
1Y Y Y Y QTC MANY ELECTRICAL CONDUITS ARE EXCESSIVELY LOADED HI ZH 266-00301 EN 23801 N HBN TH CABLES. (E.G., AREA IN REACTOR BUILDING UNIT N T50255 2 SS SS SS SS 0.- 2, AZIMUTH 190, ELEVATION 735' PENETRATION HO.
29). NO ADDITIONAL INFORMATION AVAILABLE IN FILE.
CONSTRUCTION DEPARTMENT CONCERN.
s 1Y Y Y Y QTC CI FEELS THAT THE ELECTRICAL CONDUIT AND JUMPERS B IN 310-00101 EN 23801 N HBN ETHEEN CABLE TRAYS ARE OVER FI'. LED HITH CABLE. CI T50163 2 SS SS SS SS STATES THAT TVA DOES NOT USE THE NATIONAL ELECTRI C CODES IN CONSTRUCTION PRACTICES. CI FEELS THAT, DUE TO THE OVERFILL, THE CABLE MAY HAVE BEEN DAMA GED WHEN THEY HERE PULLED. CI STATED THAT NEAR TH
< E CENTER OF THE CABLE SPREAD ROOM, NEAR THE CEILIN D
g G, IS A 2" CONDUIT HHICH IS OVERFILLED. CONSTRUCT
- ION DEPT CONCERN. CI HAS NO FURTHER INFORMATION.
3 NO FOLLONUP REQUIRED.
1Y Y Y Y QTC CROSSOVER ELECTRICAL CONDUI7S ARE GROSSLY OVERFILL ON 007-00301 EN 23801 N HBN ED, AND THIS HILL CAUSE A EdAT BUILD-UP THAT HILL T50224 2 SR SR SR SR DEGRADE CABLE INSULATION. THIS COULD LEAD TO CABL
$ E DREAKDOHN AND FAILURE. 4" fHIS HAS A ROUTINE PRACT ICE UNTIL AT LEAST 1984. - 6" CROSSOVERS, 73T' EL, AUXILIARY BLDG. CI HAS NO FURTHER INFORMATI0 N CONSTRUCTION DEPARTMENT CONCER'l NO FOLLOW UP. REQ UIRED.
22 CONCERNS FOR CATEGORY EN SUBCATEGORY 23801 e
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