ML20214U625

Rev 3 to TVA Employee Concerns Special Program,Electrical Penetration Breached

ML20214U625
Person / Time
Site:	Sequoyah
Issue date:	11/20/1986
From:	Lagergren W, Murphy M, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20214G966	List: ML20214G963 ML20214G989 ML20214T991 ML20214U124 ML20214U174 ML20214U216 ML20214U247 ML20214U308 ML20214U341 ML20214U367 ML20214U384 ML20214U415 ML20214U473 ML20214U502 ML20214U520 ML20214U550 ML20214U625 ML20214U639 ML20214U689 ML20214U749 ML20214U779 ML20214U814 ML20214U843 ML20214U860 ML20214U882 ML20214U924 ML20214V018 ML20214V037
References
304.02-SQN, 304.02-SQN-R03, 304.02-SQN-R3, NUDOCS 8612090330
Download: ML20214U625 (6)

Text

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. . TVA EMPLOTEE CONCERNS REPORT NUMBER: 304.02 SQN

. SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 3 TITLE: Electrical Penetration Breached REASON FOR REVISION:

To Incorporate SRP Comments TAS Conuments and Sequoyah Revision 1 Corrective Action Response.

To Incorporate SQN Corrective Action Response Revision 2 To Incorporate Editorial Comuments From TAS Revision 3 PREPARATION PREPARED BY:

P. L. Shepherd 11-13-86 SIGNATURE DATE

, REVIEWS PEER:

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/ SIGNATURE TAS-Y -

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CONCURRENCES Og12Ohh p P CEG-H: .- me Ibd -N SRP: h-+1 Il-28-sc SIGNATURE DATE G SIGNATURE

• DATE APPROVED BY:

Y ECSP MANhGER lf~$0'8(P DATE N/A MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

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m TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Cable and Conduit i

Element: Electrical Penetration Breached Report Number: 304.02 - SQN, Revision 3 IN- 85-207-002 l

Evaluator: P. L. Shepherd _ 11-13-86 P. L. S ephe Date Reviewed by: //b'f$dfil' OPSCFgM ber

//~lY~Sb Date Approved by: f. . %v II-s/ -f L W.R. Lager,grpn Date 1604T l

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i I. Electrical Penetration Breached l

! This report evaluates the concern that a steel fish-tape is being used l to breach penetration seals in lieu of fiberglass or wooden rods.

II. Specific Evaluation Nethodology This element consists of one concern identified at WBN and determined to be generic to Sequoyah.

IN-85-207-002 " Crafts are using steel fish-tape in lieu of fiberglass l or wood rods to breach penetration seals. This may cause damage to existing cables in the breached penetration. This practice of using

! steel fish-tapes violates procedure NAI-14 and Construction Management lR3 I

(known) memorandum of approximately July 1984. This is a construction department concern, and additional information is on file, withheld due to confidentiality."

The K-form was reviewed to determine the specific areas of concern.

Referenced documents were researched to determine the requirements, and other historical documents including NSRS and Quality Technology Company (QTC) (ERT) reports were reviewed. Cognizant engineers and craft in Unit A of the Modifications Branch of the Division of Nuclear Construction (NU CON) at Sequeyah (SQN) were interviewed to determine current practices being used at SQN. Cognizant engineers in the Division of Nuclear Engineering (DNE) were interviewed to clarify current requirements along with any pertinent history.

III. Findings NSRS Report I-85-702-WBN, " Breaching Electrical Penetrations,"

(Reference 4) documents the results of the investigation of concern IN-85-207-002 at WBN.

The SQN procedure that applies to the subject concern is Modifications j and Additions Instruction M&AI-13 (Reference 1). The review of this instruction revealed different requirements for breaching equipment being used on cable tray penetrations and conduit seals. According to the instruction, the use of a steel fish-tape is acceptable for breaching cable tray penetrations but a nonconductive probe must be used to breach conduit seals.

A review of all previous revisions of M&AI-13 showed this: l

1. A 1/2" conduit with a wooden conical nose was used as a breaching I tool from December 4, 1979 until January 21, 1982 (Revisions 0, 1, IR1 and 2) l

2. Revision 3 was effective from January 21, 1982 until l February 22, 1982, and required that the breaching tool be l nonmetallic. l Page 1 of 3

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III. Findings (continued)

3. From February 22, 1982 until the current revision (Revision 4, 5, I and 6) metallic breaching tools were authorized for use under i special conditions. l The author of NEAI-13 Revision 3 used, SQA 119 Attachment 1, dated IR3

-August 18, 1981, to initiate the procedure revision. During an l interview with this author he was asked his reasons for his use of the l words "any tool made of nonmetallic material" should be used as a lR1 breaching tool. His response was he was trying to change from the tool I described in Revisions 0, 1, and 2 to "any" tool. He stated that he did I not have a specific reason (such as cable insulation damage) for l stating nonnotallic other than good practice. I l The change request that resulted in Revision 4 of N&AI-13 dated l February 22, 1986, requested the ". . . use of metallic breaching tools I under special conditions. . . ". The current Revision 6 of N&AI-13 lR1 uses the words "At the discretion of the responsible engineer a l metallic breaching tool may be used". l According to interviews with Electrical Modifications personnel, l 1/2" conduit, fish-tape and various nonmetallic breaching tools have l been successfully used to breach penetrations since 1979 in accordance lR1 with M&AI-13 without any known cable insulation damage. This same fact l was stated in Employee Concerns Task Group's (ECTG) C010900 SQN Report. lR3 It was determined from the interviews with the site modifications personnel that they prefer to use a nonmetallic probe to breach all penetrations / seals where possible and only use a steel fish-tape where

, space restrictions prohibit the use of a longer, unflexible probe. No j violations of the current site instructions were discovered from these r interviews.

However, during this evaluation it was discovered that Modifications and, Additions Instruction M&&I-4 " Control, Power, and Signal Cables."

l Revision 8, dated December 31, 1985 (Reference 2) does not reference l M&AI-13 and does not show any responsibility for the craft to be aware of the requirements of M&AI-13. Also Electrical Design Standard DS-E13.5.1, " Raceways - Electrical Penetration Fire Stops and Pressure Seals, " Revision 0, dated December 5, 1977 gives guidelines on breaching penetrations on nuclear plants built after WBN.

Conclusions Based on the findings, this concern was determined to be not valid at i SQN. The use of a nonmetallic probe does not preclude cable insulation 1 damage resulting from the misuse of the probe by the craft. A metallic lR1 i

tool can be used to breach penetrations safely, without damaging cable l i

insulation as indicated by six years of modification work at SQN in I accordance with N&AI-13. l IV. Root Cause No root cause could be determined by this evaluation.

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V. Generic Applicability This concern is specific to Watts Bar and could apply to Browns Ferry and Bellefonte Nuclear Plants depending upon the requirements established in their procedures. There are no upper-tier document I requirements governing the use of breaching tools. The quality of IR1 workmanship at SQN does not indicate the need for more specific l requirements than those included in site procedures. l VI. References

1. Modifications and Additions Instruction N&AI-13. " Electrical Pressure Seal, Fire Stop Barrier and Flame Retardant Cable Coating, " Revision 6, dated January 28, 1985

2. Modifications and Additions Instruction N&AI " Control, Power, and Signal Cables, " Revision 8, dated December 31, 1985

3. TVA General Construction Specification Number G-38, " Installing Insulated Cables Rated up to 15,000 Volts " Revision 7, dated January 15, 1986

4. NSRS Investigation Report I-85-702 'JBK, " Employee Concern IN-85-207-002 - Breaching Electrical Penetrations," dated November 22, 1985

5. Electrical Design Standard DS-E13.5.1, " Raceways - Electrical Penetration Fire Stops and Pressure Seals," Revision 0, dated December 5, 1977 VII. Immediate or Long-Term Corrective Action M&AI-4 was revised on August 13, 1986 to incorporate the reference to l M&&I-13. IR1 SQN Corrective Action Plan response to (CATD Number 30402-SQN-01) lR2 accepted. l I

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e-REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PACE -

FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME - Il RUN DATE - 10I i[) ONP - ISSS - RhM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

LIST OF EMPLOYEE CONCERN INFORMATION CATEGORYs OP PLANT OPER. SUPPORT SUBCATEGORY: 30402 ELECTRICAL PENETRATION BREACHED KEYHORD A

() S H

GENERIC APPL QTC/NSRS P KEYHORD B 1

CONCERN SUB R PLT BBSH INVESTI0ATION S CONCERN KEYHORD C NUMBER CAT CAT D LOC FL45 REPORT R DESCRIPTION KEYHORD D

'O OP 30402 N HBN NNYN I-85-702-NBN NS CRAFTS ARE USING STEEL FISH TAPE IN INSTALLATION IN 207-002 SPECIFICATIONS T50157 REPORT LIEU OF FIBERGLASS OR HOOD RODS TO B REACN PENETRATION SEALS. THIS MAY C ELECTRICAL AUSE DAMAGE TO EXISTING CABLES IN TH CABLE i() E BREACHED PENETRATION. THIS PRACTI CE OF USING STEEL FISH TAPES VIOLATE-S PROCEDURE MAT-14 AND CONST. MGNT.

() (KNOWN) MEMO OF APPROX. JULY 1984.

CONSTR. DEPT. CONCERN. ADDITIONAL I NFORMATION IN FILE, HITHHELD DUE TO CONFIDENTIALITY. NO FOLLOHUP REQUIR

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1 CONCERNS FOR CATEGORY OF SUBCATEGORY 30402 GD ,

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