ML20215L872
| ML20215L872 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/07/1987 |
| From: | Russell Gibbs, Martin M TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215L813 | List: |
| References | |
| 242.0(B), 242.0(B)-R03, 242.0(B)-R3, NUDOCS 8705120407 | |
| Download: ML20215L872 (23) | |
Text
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' :: 10' REPORT. NUMBER: 242.0(8).
TVA EMPLOYEE CONCERNS
~# SPECIAL. PROGRAM REVISION NUMBER: .3
~ ~ REPORT TYPE:l SEQUOYAH ELEENT q'. .
Q- } TITLE:.-
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ELECTRICAL SEPARATION
. Inadequate Electrical and Physical-
- Separation Between Redundant Wiring, PAGE 1 0F 21
. Cabling, Equipment and Components-y REASON FOR REVISION:-
- 1. Revised to incorporate TVA comments.-
- 2. . Revised to incorporate SRP/TAS consnents, to include TVA's corrective action plan (see Section 10), and to include chronology.
- 3. Revised to incorporate revised CAPS transmitted by TVA.-
PREPARATION PREPARED BY: ,
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APPROVED BY:
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'O TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0(B)
' s SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 2 0F 21 h
- 1. CHARACTERIZATION OF ISSUE (S):
Concerns: Issues:
WI-85-100-004 a. Review by independent consultant XX-85-122-Oll, 012, 013 required to assess electrical and
" Electrical separation and physical separation adequacy of physical separation of redund- redundant wiring, cable, and components ant wiring and cabling and for as well as equipment.
equipment and components are inadequate at all plants. CI b. Inadequate separation in trays of
. expressed that detailed reviews Q and non-Q cables for all voltage
'need to be made, and are so levels as a result of procedures extensive that a consultant being violated.
probably should be used, providing independence from TVA." c. Cable trays are overloaded as a IN-86-254-004 result of inadequate separation. -
"CI believes procedures are being violated (in general) when Q and d. Inadequate cable arrangement results non-Q electrical cables are not in covers extending 3 to 4 inches being separated in cable trays. above trays.
4 . This includes low, medium, and
( .- high voltage cables. By not separating the cables, the trays are being overloaded."
IN-86-259-006 "Many electrical cables have been placed in cable trays without adequate separation.
$. Many cable tray covers extend 3 to 4 inches above the tray because of cable arrangement."
IN-86-314-004
" Cable separation is inadequate and in many cases nonexistent."
- 2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by N5R5 and SCR SQNEEB8634 Date For dates, see Documentation Identifiers below
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0(8)
', [ SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 3 0F 21 y
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Documentation Identifiers:
o Identified by TVA SQN NSRS Date February 27, 1986 TVA SNP - Nuclear Safety Review Staff Investigation Report No. I-85-133-SQN, Electrical / Physical Separation of Redundant Circuit / Equipment, (02/27/86) o Identified by TVA SQN SCR SQNEEB8634 Date- Apri1 30, 1986
.TVA SNP Significant Condition Report SQNEEB8634, Minimum Separation Distance Between Different Divisional Cable Tray, RO, (04/30/86) .
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEE NT:
No further information available.
- 4. INTERVIEW FILES REVIEWED:
Files WI-85-100, XX-85-122, IN-86-254, IN-86-259, and IN-86-314 were reviewed and no additional unreviewed information for Sequoyah was identified for the concerns in this report.
S. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
l See Appendix A.
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- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A
- 8. EVALUATION PROCESS:
- a. Reviewed transcript of NRC investigative interview to extract information applicable to the employee concerns.
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- C :SPECIAL-PROGRAM REVISION NUMBER: 3 n .
PAGE 4_0F 21-M
-b. Reviewed' design criteria, FSAR, Westinghouse specification criteria,.and any other. applicable documents to establish-extent of the current Sequoyah Nuclear _ Plant Separation requirements.
- c. Reviewed:SQN design documents to determine compliance with the requirements,
- d. _ Reviewed existing reports (e.g., NSRS Report I-85-133-SQN),
findings,.and responses to findings to assess their adequacy.
and the extent to which they satisfy the employee concerns.
- e. - Reviewed.available Construction, QA/QC, Operations, and Material Control element reports for the TVA Employee Concerns
-Special Program.
- f. Performed walkdown on sample panels-and trays to determine.
compliance with the separation criteria.
- g. Assessed overall adequacy of SQN separation program.
IM .
'L 9. DISCUSSION, FINDINGS, AND CONCLUSIONS Chronology:
09/85:- Concerns IN-86-254-004, IN-86-259-006, and
-IN-86-314-004 received by TVA for WBN 11/85:- Concerns WI-85-100-004 and XX-85-122-011, 012, and 013 received by TVA for WBN, SQN, BLN, and BFN' 11/07/85: 0E prepares calculations per 10 CFR 50.49(b) 12/13/85: Significant Condition Report WBNEEB8582 identifies problem at WBN regarding minimum separation distance between different divisional cable trays as a result of extended tray covers 12/19/85: TVA memo from Chandler to Those Listed requests Sequoyah to review the extended tray cover problem for potentidl applicability-12/23/85: TVA memo from Hall to Chandler indicates that raised tray cover condition did not exist at SQN 02/27/86: NuclearSafetyReviewStaff(NSRS)investigatesthe validity of employee Concern XX-85-122-01 for SQN 1083d-1 (03/24/87) l
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- ' ): 3c- . . , REPORT NUMBER:: 242.0(B) lTVAEWLOYEECONCERNS
- " SPECIAL' PROGRAM REVISION NUMBER:- 3 n PAGE 5 0F 21-M")
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.04/30/86: SignificantConditionReport(SCR)SQNEEB8634isissued to address minimum separation distance between
.different divisional cable trays in the auxiliary
-instrument room 06/30/86: 0E issues calculations to ensure that the. associated circuits.that fall under Appendix R program will have ,
no adverse effect on safety 07/08/86: Design input memo authorizes a minimum vertical separation of:1 foot for vertically stacked
.interdivisional trays in the auxiliary equipment room in response to SCR SQNEEB8634 and incorporates separation requirements for. internal wiring Discussion:
-The employee concerns raised several issues regarding inadequate physical and electrical separation between r'edundant Class lE equipment and wiring, and between class lE and non-class lE. There is a potential for loss of capability of. redundant components to f ; perform their intended safety function in the' event of a common C failure of improperly separated wiring and equipment.
.SQN is not committed to comply with either Regulatory Guide 1.75 (App. A, 5.11; 02/74 and 09/78) or IEEE Standard 384-1974-(App.A,5.vv). To establish independence.and redundancy so as to prevent common f ailure modes in class 1E systems, SQN is committed to the following~ standards:
o IEEE Standard 279-1971, " Criteria for Protection Systems for Nuclear Power Generating Systems," states:
"4.6 Channel Independence. Channels that provide signals for the same protective functions shall be independent and physically separated to accomplish decoupling of the effects of unsafe environmental factors, electric transients, and physical accident consequences documented in the design basis, and to reduce the likelihood of interactions between channels during maintenance operations or in the event of channel malfunction."
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4 TVA EMPLOYEE CONCERNS ~ REPORT NUMBER: 242.0(B)
'. SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 6 0F 21
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o IEEE Standard 308-1971 " Criteria for Class lE Electric Systems for Nuclear Power Generating Stations" states:-
"4.6 Equipment Protection. Class lE electric equipment shall be physically separated from its redundant counterpart or mechanically protected as
-required to prevent the occurrence of coninon failure mode."
and "5.2.2(3) Independence. Distribution circuits to redundant equipment shall be physically and electrically independent of each other."
The evaluation team reviewed the issues presented in Section 1 to assess the adequacy of the separation program at SQN. Each issue is assessed below.
- a. Nuclear Safety Review Staff (NSRS) investigated the validity of employee concern XX-85-122-011 (see Section 1 for c.
statement of concern). NSRS Report No. I-85-133-SQN on this
( issue concluded that:
o Separation in the control room area appeared to meet all aspects of the design criteria SQN-DC-V-12.2, Section 4.2.8.
O All redundant trays except KC-B in the auxiliary instrument room and HN-B in the cable spreading room met the design criteria SQN-DC-V-12.2 requirement for solid tray bottoms and tray covers for redundant trays at crossover points.
o Physical separation rs defined in design criteria SQN-DC-V-12.2 was met for the 6900V and 480V shutdown boards, reactor MOV boards, reactor vent boards, control and auxiliary vent boards, 125V vital batteries and vital battery boards, and vital inverters.
Based on its investigation, the NSRS recommended installation of covers on trays KC-B and HN-B in accordance with the design criteria requirements. The NSRS also recommended clarifying the design criteria for separation of cable trays in the auxiliary instrumentation room. A TVA review revealed that the minimum separation of vertical stacked interdivisional trays in the auxiliary instrument room was 12 inches instead of 3 feet as required by the design s
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SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 7 0F 21
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criteria. Consequently, Significant Condition Report (SCR)
SQNEE88634 R0 was issued. The Engineering Report (ER) for this SCR concludes that this condition has no adverse effect on safety and can be resolved by a revision to the design criteria. A design input memo (DIM), Raughley to Electrical EngineeringFiles(App.A, 5.1;07/08/86), authorized a minimum vertical separation of 12 inches for vertically stacked interdivisional trays in the auxiliary instrument room, providing the trays are furnished with solid bottoms and covers. The authorization was based on judgment that hazards in the auxiliary instrument room are minimal.
The NSRS conclusion that redundant trays are adequately separated was confirmed by three walkdowns of the spreading and auxiliary equipment rooms by the evaluation team (App. A, 7.b, 7.c, and 7.d). With minor exceptions, separation in the auxiliary instrument room is in compliance with the design criteria as modified by the previously discussed DIM. Isolated instance was identified during the walkdown where apparent discrepancies exist between the as-installed condition and the design criteria. Trays above
.I cabinets Ril (XY-1, stacked about 32 inches below XZ-3) and
( R13 (XZ-2, stacked about 3 feet below XZ-4).have no covers.
Similarly, the evaluation team verified the NSRS conclusion of adequate physical equipment separation by a sample review of TVA drawings: 47W200-3 for 6900 volt and 480 volt shutdown boards, and 47W200-2 for 120 volt vital inverters.
The evaluation team noted that separation of this equipment conforms to the design criteria requirements.
The NSRS investigation did not cover separation aspects such as separation between divisionalized and nondivisionalized cable trays, cable separation in free air, physical separation of wiring and components internal to panels, and electrical isolation.
No SQN commitments were identified regarding separation between divisionalized and nondivisionalized cable trays.
Although the separation design criteria are silent in this area, the NRC concluded in SQN Safety Evaluation Report (SER) paragraph 8.5.3 that adequate provisions were made to satisfy its concern regarding nondivisional cable trays routed between redundant divisional cable tray stacks. These provisions included coating all cables in the spreading room and providing sprinklers. No minimum spatial separation requirements were given.
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~ REPORT NUM8ER: 242.0'(8)
REVISION NUMBER: 3 4
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%4 A walkdown by the evaluation team (App.- A, 7.d; 10/09/86) identified a nondivisional cable tray riser, AAP, whose.
cables were in direct contact with. divisional tray NO-A-(elevation 734 feet at the floor penetrations between columns A3 and A4 at Q line). All cables were coated with fire retardant material, and the adequacy of this
- configuration from a separation. standpoint appears to satisfy the SER commitments.
Furthermore, the effect of non-class 1E system failures on class IE systems has been addressed by the following:
Tne TVA analysis SQN APPR-1 (App. A, 5.y; 06/30/86),
o and the corrective actions that resulted from this analysis (covered by ECNs L6313 and L6315), were performed to ensure that the " associated circuits" that fall under the Appendix R program will have no adverse effect on safety.
o An analysis performed for nonsafety-related equipment located in harsh environments (App. A, 5.k; 11/07/85) k concluded that no environment-induced failure to this t equipment could prevent accomplishment of required functions by safety-related equipment.
Similarly, no specific commitments were identified for redundant cable separation in free air. The only' reference to this is in paragraph 8.5.3 of the SQN SER and the paragraph only addresses unsupported cable bundles running vertically between cable trays in the same stack. The NRC concludes in the SER that cable coating with~ fire retardant material adequately addresses this situation. Coating exposed cable surfaces is described in Section 4.2.5 of the separation criteria. 'However, Revision 6 of the criteria indicates that after 10/18/84 cables qualified to'IEEE 383 flame test or equivalent do not require coating. The only other place in the criteria where cable separation in free l air is addressed is in the second paragraph in Section'4.2.6, l
and that is limited to the cable spreading room. The i.
criteria require a 3-foot minimum separation between cables of different divisions; otherwise cables must run in metal conduits or enclosed wireways. Walkdowns by the evaluation i team of the auxiliary instrument room (App. A, 7.b, l
7.c and 7.d) identified cables leaving cable trays LT-A and l
LT-B (above cabinet 1R48) and going to conduits about 1 foot a=
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above these trays that are within 6 to 9 inches of cables of a redundant division. The adequacy of the separation between these cables, since they are located outside the cable i l
spreading room and are coated with fire retardant material, appears to satisfy the intent of the SER commitment.
However, some inconsistency is evident considering that J cables in free air in the cable spreading room must comply l I
with separation requirements yet no criteria are provided for separation of cables in free air in the auxiliary instrument room and other plant areas.
The previously identified DIM (App. A, 5.1;07/08/86) ,
incorporates SQN separation requirements for internal wiring into Design Criteria SQN-DC-V-12.2. The evaluation team, .
however, interpreted this as applicable only to the shunt trip circuitry of the reactor protection system. In addition l to this, a Westinghouse specification (App. A, 5.e; 07/30/71) l l
provides requirements for separation of internal wiring and I components for main control boards. A walkdown of boards 1-M-4, 1-M-5, 1-M-6, 0-M-26, and 1-L-11A by the evaluation i
- team (App.A,7.a;02/27/86) confirmed that the internal l
- k. separation is in accordance with Westinghouse requirements.
Although there is a comitment in FSAR Section 8.3.1.4.6 to l separate internal wiring in all class lE control boards, l l
panels, and relay racks, it is unclear why the commitment was limited to Westinghouse panels and systems. j Design Criteria SQN DC-V-12.2 does not include requirements l
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for separation of internal wiring for all class 1E control I boards, panels, and relay racks as stated in the FSAR, and no commitment / requirement (C/R) data sheets on this subject could be found. '
Similarly, limited commitments exist for electrical isolation between redundant circuits and between Class 1E and Non-Class lE circuits. Although these commitments have been identified in commitments / requirements (C/R) data sheets, they are not currently reflected in the separation design criteria, as required by SQN Engineering Procedure SQEP-29.
These commitment / requirements are:
o C/R No. SQN EEBPBN1002 identified a commitment in SNP FSAR Amendment 2, Section 7.1.4.2.1, to define and detailed functional, qualification, technical requirements fortesting the TSC/SMS isolators.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 242.0(B)
REVISION NUMBER: 3 PAGE 10 0F 21 O C/R No. SQN EEBP8N1085 identified a comitment in the SER (03/79), Section 7.2.2 to upgrade the reactor coolant pump underfrequency and undervoltage trips in the reactor trip system to class lE. In addition, the underfrequency and undervoltage trips were relocated from the nonseismic Category I Turbine Building to the seismic Category I Auxiliary Building.
o SQN EEBPBNil34 identified a comitment in SER Section 7.3.2 (03/79) to ensure that inter-train interlocks are designed so that a failure in one train
- will not adversely affect the safety function of the redundant train. The SER reported that the emergency core cooling and other Engineered Safety Features (ESF) systems were reviewed and several valves were found to be interlocked with valves in the redundant train.
Analysis showed that the safety system function could still be accomplished even if a failure of the interlock occurred. This comitment which was the same for Watts Bar, was properly addressed in WBN FSAR Section 7.1.2.4, but was not included in the SNP FSAR.
o SQN EEBPBN1082 identified a comitment in SNP FSAR Amendment 2, Section 7.6.7.1 to ensure that a failure in the nonclass lE portion of the low temperature interlocks for the Reactor Coolant System (RCS) pressure control will not prevent the protective system from performing its protective function. This is accomplished by use of isolation devices in the output to the interlocks from the protection set racks. ,
o SQN EEBP8N1013 identified a commitment in FSAR Amendment 2, Sections 7.2.1.1.8 and 7.2.2.2.3(5), to design and qualify isolation amplifiers for the reactor trip system so that a failure in the nonprotective .
signal circuits will not prevent the protective system from performing its protective function. The nonprotective signal circuits are used for control, indication, and computer monitoring and are derived from protection channels through isolation amplifiers,
- b. Separation requirements for nonsafety-related cable routed in the same cable tray with safety-related cable are adequately addressed in design criteria SQN-DC-V-12.2 and l SQN-DC-V-II.3. Routing of Q and non-Q cables in the same s
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raceway is allowed under the provisions of design criteria SQN-DC-V-12.2, Section 4.4.1. However, SQN-DC-V-12.2 does not permit a non-Q cable, once routed in a Q tray, to be subsequently routed in a Q tray containing cables of another division. Similarly, design criteria SQN-DC-V-11.3 has adequate provisions for separating cables of different voltage levels. Consideration of these two criteria is built into the SQN cable routing program. However, although no violations of compliance to these criteria have been identified, the current lack of verification of this cable routing program results in uncertainties regarding the status of installed cables and makes compliance to these two criteria indeterminate. (Verification of the cable routing program and adequacy the of status of installed cables is discussed in more detail in Sequoyah Element Report 239.0.)
- c. Failure to provide adequate separation does not of itself -
cause cable tray overfilling (overloading). Not exceeding cable tray fill limit is a requirement independent of separation. Cable tray overloading / overfilling is addressed in Sequoyah Element Report 238.3.
- d. SCR WBNEEB8582 identified a problem at Watts Bar Nuclear Plant similar to the employee concern regarding inadequate cable arrangement that results in covers extending 3 to 4 inches above the crossover trays. A TVA memo from Chandler to Those Listed (App. A, 5.v; 12/19/86) requested Sequoyah review this problem for potential applicability. The problem was reviewed for applicability to Sequoyah, and it was determined that the condition did not exist (Memo from Hall to Chandler, App. A, 5.w; 12/23/85).
During two walkdowns of the cable spreading room and auxiliary instrument room (App. A, 7.b and 7.d), the evaluation team observed that separation between covered trays complies with the requirements stated in the design criteria. As noted durin were properly installed (g thesecable special walkdowns, cable tray covers tray cover installation details are described in E-45W880-27, R3,
[ App.A,5.xx;04/16/86]), and no raised covers were noted on safety-related cable trays.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0(B)
SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 12 0F 21 Finding:
- a. Review of the adequacy of the electrical and physical separation at Sequoyah revealed that:
o SQN is comitted to comply with IEEE Standards 279 and 308 for independence and redundancy, but not committed to Regulatory Guide 1.75 or to IEEE Standard 384.
o The NSRS conclusion that divisionalized cable trays are adequately separated in compliance with design criteria was confirmed by walkdowns by the evaluation team, with two minor exceptions where cable tray covers should have been installed but were not.
o Separation of divisionalized and nondivisionalized cable trays appears to satisfy SER comitments. Design criteria documents are silent in this area.
o Separation of redundant cables in free air appears to satisfy the intent of SER comitments. No criteria could be found for separation of cables in free air
( except for those in the cable spreading room.
o Separation of internal wiring in specific Westinghouse-furnished control boards was confirmed, during walkdowns, to comply with design criteria.
However, no design criteria were found for wiring separation in other class lE control boards, panels, and relay racks as comitted in the FSAR.
o Electrical separation and isolation comitments on C/R data sheets have not been reflected in the separation design criteria.
- b. Lack of verification of the currently as-installed status of cables in raceways makes compliance to the design criteria and procedures indeterminate. The status of cables in raceways is addressed in Sequoyah Element Report 239.0.
- c. Cable tray overloading is not a result of inadequate separation. The cable tray overloading is addressed in Sequoyah Element Report 238.3 (8).
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SPECIAL PROGRAM REVISION NUMBER: 3-PAGE 13 0F 21
- d. No evidence was found during the walkdowns to indicate that inadequate cable arrangement caused covers to extend above safety-related cable trays.
Conclusions:
The concerns questioning the adequacy of physical and electrical separation are valid to the extent that criteria ' documents do not-reflect comitments regarding separation of internal wiring in class lE control boards, panels, and relay racks or electrical iso _lation. Also, adequacy of as-installed cable separation.in raceways could not be verified. Separation criteria for cables in free air were applied inconsistently since. requirements for se)aration were found for the cable spreading room but not for.
otler plant areas.
- 10. CORRECTIVE ACTION In response to the problems identified by the CATD, TVA has generated revised corrective action plans (CAPS)-submitted by
-( TCAB-084 dated 03/31/87.
- a. CATD 242.00-SQN-01 indicated that electrical separation and isolation commitments on C/R data sheets have not been reflected in separation design criteria. TVA committed to review all commitments / requirements (C/Rs) in the design bases in C/R Analysis Re determine if the C/Rs port 039, must be"addressed Electrical before Separation,"
or after-to
, restart. TVA indicated that no action will be taken before' l
restart if the C/R is addressed in the design criteria, design j output document, construction requirement / procedure, or through
- verification of physical installation or analysis.
! If the C/R has not been addressed, any required analysis, inspections, or modifications to ensure compliance will be done l before restart.
TVA also stated that any required changes to design criteria or design output documents will be made after restart unless the i changes support modifications that are required for restart.
! Furthermore, TVA will implement the appropriate measures to ensure that the effect of any C/Rs which are not adequately covered in design criteria or design output document will be l
addressed in all ECNs in the interim before the design criteria and design output document are updated.
fk. A CAQ will be generated for any deficiencies identified.
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- b. CATD 242.00-SQN-02 identified design criteria documents
" regarding separation requirements for cables in free air only in ,the cable spreading room, not for other plant areas. TVA committed that the same process outlined in the corrective action plan CATD 242 00 SQN 01 will be followed to ensure that any commitment for separation in free air, or a more general cor.mitment to keep adequate indupendence to satisfy single failure criteria requirements is met. This review will be completsd before~ restart. CAQS will be generated as needed if deficiencies are found.
- c. CATD 242.00-SQN-003 identified isolated instances where:
,1 o Cable trays LA-A and LT-B above cabinet R48 are 1 foot apart horizontally but have no covers.
o Trays above cabinets Rll (XY-1, stacked about 32 inches below XZ-3) and R13 (XZ-2, stacked about 3 feet below XZ-4)havenocovers. These cases are not in compliance with. design criteria requirements for tray separation.
6 The. evaluation team concurs with TVA's statement in the CAP k- that 1-foot' horizontal separation, with no stipulation for covers, is allowed by Design Criteria SQN-DC-V-12.2 for cable trays LT-A and LT-8. Also, the CAP indicates that Problem IdentificationReport(PIR)SQNEEB86175hasbeengeneratedto identify and document the specific separation problem between cable trays of Channels I, II, III, and IV, as mentioned in the CATD. An engineering change notice will be generated to install the tray covers and bottoms on these cable trays to satisfy the separation criteria. PIR SQNEEB86175 R1 addressing a generic discrepancy between the design criteria and the 45N880 series drawings resulted in s revision to these drawings that eliminated the discrepancy.
TVA also indicated that the complete 45N880 series drawings were thoroughly studied and walkdowns performed as needed to determine the extent of this potentially generic problem. This covered all areas of the plant that had cable trays installed except the area inside the steel containment of the reactor building (thesetraysarenonclasslE).
In addition, TVA performed a field walkdown in all areas where there was a question of train or channel interaction (separation, crossing,etc.),aquestionofbarriers,orwhere there was a lack of dimensioning on the drawings. The
( walkdowns revealed that no other cases exist where covers have not been installed per design criteria and/or 45N880 drawings
( requirements.
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. SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 15 0F 21 s..
In the course of the TVA field walkdown, it was found that trays (channel separation group) running vertically pass within 3 feet of trays (train separation group) running horizontally.
This situation is not specifically addressed in the design criteria or the FSAR. - As a result, TVA comitted that the same process outlined in corrective action plan CATD 242.00-SQN-01 will be followed for all separation C/Rs. Implementation of this process will ensure that all comitments for separation between trays running horizontally and trays running vertically, or a more general comitment to keep adequate independence to satisfy the single failure criteria requirements; are properly addressed. CAQs will be generated as.needed if deficiencies are found.
- d. s CATD 242.00-SQN-04 stated that the design criteria do not include FSAR comitments for separation of internal wiring in
- class lE control boards, panels, and relay racks. TVA indicated that the review process outlined in the CAP for CATD ~
242.00-SQN-01 for all separation C/Rs will ensure that all comitments for separation of internal wiring in class lE
' ' ' control boards, panels, and relay racks are properly
, addressed. CAQs will be generated as needed if deficiencies
- - .are found.
L The evaluation team concurs that the corrective action plans adequately address the problems in the CATDs, and adherence to the t , < t implementation schedule will close the issues of electrical
'i separation.
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ed Ij/ _ . 1083d-3 (04/02/87) l 1 - . aQ- J
- TVA EMPLOYEE CONCERNS' REPORT NUMBER: 242.0(B)
SPECIAL PROGRAM REVISION NUM8ER: 3 PAGE 16 0F 21
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s.
APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMNT:
a '. NSRS Report I-85-133-SQN, " Electrical / Physical Separation of Redundant Circuit / Equipment," (02/27/86)
- b. SQN Desi Wiring (gn Criteria for Separation of Electric Equipment and SQN-DC-V-12.2),R6,(09/30/85)
- c. SQN Design Criteria for Normal and Emergency Ac Auxiliary Power System (SQN-DC-V-ll.4.1), R2, (07/22/86)
- e. Westinghouse Specification Criteria for Internal Wiring -
(678855),R0,(07/30/71)
- f. Wiring Diagram, Control Boards Critical Wiring Braid Installation (E-45W1640R3),(05/3/84)
N g. TVA memo from Young to Pedde, (BLN 850225 087), "BLN Office of Construction (0C) Action Team Response to Electric Report," (02/25/85)
" Employee Concern XX-85-122-001 - Electrical and Physical Separation of Redundant Circuits and Equipment," (05/05/86)
SCR SQNEEB8634 R0, (05/09/86)
- j. SCR SQNEEB8634 R0, " Minimum Separation Distance Between Different Divisional Cable Trays," (04/30/86)
- k. OE Calculation, "Nonsafety-Related Electrical Equipment Important to Safety per 10CFR50.49(b)," (B25 851107 300),
(11/07/85)
- 1. TVA memo from Raughley to Electrical Engineering Files (843 860710 921), " Design Input Memo on Separation of Electrical Equipment and Wiring Design Criteria SQN-DC-V-12.2," (07/08/86)
- m. Letter Mills to Adensam (A27 840827001), " Design Information of Reactor Trip System Resulting From NRC Questions on Generic Letter 83 Salem ATWS Events," (08/27/84)
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1083d-1 (03/24/87)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0(B)
SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 17 0F 21 7
APPENDIX A (cont'd)
- n. TVA memo from Standifer to Ennis, " Watts Bar Nuclear Plant -
Addendum to Employee Concern Investigation Report I-86-570-WBN," (01/02/86)
- o. TVA memo from Standifer to Ennis, " Watts Bar Nuclear Plant -
Employee Concern Investigation Report Number I-85-570-WBN,"
(12/13/85)
- p. TVA memo from Ennis to Standifer, " Watts Bar Nuclear Plant -
Employee Concern Investigation Report Transmittal," (11/15/85)
- q. TVA memo from Chitwood to Raulston and Standifer, (843 860224 940), " Watts Bar Nuclear Plant Units 1 and 2 -
Significant Condition Report No. SCR WBNEEB8582," (02/24/86)
- r. NRC-0IE Reportability Information Distribution (B45 860206 828), SCR WBNEEB8582, " Minimum Separation Distance between Different Divisional Cable Tray Crossings,"
(12/31/85) s
- s. TVA memo from Chitwood to Raulston, (843 860124 930)
"10CFR50.55(e) Final Report on Subject SCR," (01/24/86)
- t. Significant Condition Report WBNEEB8582 (843 851219 905),
" Minimum Separation Distance Between Different Divisional Cable Tray," (12/13/85)
- u. Mechanical Layout of Control Boards Drawing Nos.
i M4 47W605-10 R19, M4 '47W605-13 R13, M4 47W605-14 R21, M4 47W605-19 R10, and M4 47W600-55 R10
- v. TVA memo from Chandler to Those Listed, (843 851219 905)
" Potential Generic Condition Evaluation," (12/19/85)
- w. TVA memo from Hall to Chandler, (B25 851226 013), " Response to Memo From Chandler to Those Listed," (12/23/85)
- x. Drawing 47W200-2, " Equipment plan - El. 749.0 and Above,"
R13, Drawing 47W200-3, " Equipment Plan - El. 734.0 and El.
732.0," R15
- y. OE calculations, " Analysis of Ac/Dc Instrument and Control (I&C) Power System to Identify Associated Circuits," 10CFR50,
. Appendix R, (843 860630 901), (06/30/86) i N 1
1083d-1 (03/24/87)
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0 (B)-
SPECIAL PROGRAM .
REVISION NUMBER: 3 PAGE 18 0F 21 APPENDIX A (cont'd) .
- z. TVA memo to Cox from Hosely, (821860723 002), "BLN NCR's 919 and 1040," (07/27/86) aa. NCR 3686 R0, (BLN 841109107), (11/01/84) bb. TVA memo to Hodges from Cox, BLN NCR 3865, (BLN 850117114),
"Bellafonte Nuclear Plant - Nonconforming Condition Report (NCR) 3865," (01/17/85) cc. TVA memo to Hodges from Cox, BLN NCR 2295, (BLN 840418109),
"Bellafonte Nuclear Plant - Nonconforming Condition Report (NCR) 2995," (04/17/84) dd .- C/R No. SQN EEBPBN1085 (source of C/R SER 3/79) ee. C/R No. SQN EEBPBNll34 (source of C/R SER 3/79) ff. C/R No. SQN EEBDRW1065 (source of C/R SER 3/79)
K .. gg. C/R No. SQN EEBDRW1063 (source of C/R SER 3/79) hh. Letter from B. J. Youngblood, NRC, to S. A. White, TVA (B45 860714 832), with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN (06/23/86)
- 11. Regulatory Guide 1.75, R0 and R2, " Physical Independence of Electric Systems," (02/74 and 09/78) jj. C/R No. SQN EEBPBN1002 (Source of C/R FSAR Amendment 2, Section 7.1.4.2.1, page 7.1-19, paragraphs 5 and 7)" TSC/SMS Isolators - Define Functional, Qualification, Detailed Technical Requirements (e.g., maximum Cred. Voltage) and Testing Requirements" kk. C/R No. SQN EEBPBN1085 (Source of C/R SER 3/79) "Undervoltage and Underfrequency Trips Upgraded to Class 1E and Moved to Auxiliary Building to Satisfy NRC Requirements, Meets IEEE 279"
- 11. C/R No. SQN EEBPBN1134 (Source of C/R 3/79) " Assurance That Intertrain Interlocks Are Designed Such That a Failure in One Train Will Not Adversely Affect Devices in Other Train" 1083d-l (03/24/87)
-n-- -- m _.
- .- s: _
H TVA EPFLOYEE CONCERNS REPORT NUMEER: 242.0-(B)
.SPECIAL PROGRAM.
REVISION NUMBER: t 3 y.
W PAGE 19 0F 21.
t APPENDIX A (cont'd) mm. C/R No. SQN EEBPBN1082 (Source of C/R FSAR Amendment 2, Section 7.6.7.1) "A Failure in the Non IE Part of the Low
' Temperature'Over Press Circuit _Will Not Harm the Protection Set Because of Isolation Device" n n .' - C/R No. SQN EEBPBN1013-(Source of C/R FSAR Amendment 2, Sections'7.2.1.1.8 and 7.2.2.2.3[5]) " Design Bases and Qualification Testing Requirements for Reactor Trip System Isolation Amplifiers"
'oo. TVA memo from Raughley to Those Listed, (B43 860619 913),
"EEB Efforts Relative to Design, Baseline, and. Verification Program," (06/18/86) .
pp. IEEE-279-1971, " Criteria for Protection System for Nuclear Power Generation Stations." -
qq. . IEEE-308-1971, " Class lE Power Systems for Nuclear Power '
= Generating Stations"
. :L 4
, V Title 10 of-the Code of-Federal Regulations, Part 50, 10CFR50 rr.
Appendix A, " General Design Criteria 17," (07/07/71)
'ss. . Title 10 of the Code of Federal Regulations,'Part 50, 10CFR50 i
Appendix R tt. SQN Safety Evaluation Report (SER) i
, uu. Regulatory Guide 1.6, " Independence Between Redundant Standby
- (Onsite) Power Sources and Between Their Distribution Systems" vv. IEEE-384-1974, " Trial-Use Standard for Separation of Class IE Equipment and Circuits" ww. SQN Engineering Procedure SQEP-29, " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant,"
(07/18/86) xx. TVA Drawings 45W880-27 R3, " Conduit and Grounding Cable Trays Detail Sheet 14," (04/16/86) yy. TCAB-032, Corrective Action Plan (CAP) for Sequoyah Element Report 242.0(B), (12/15/86)
. (( , .
1083d-l (03/24/87)
- j O TVA EMPLOYEE CONCERNS REPORT NUMBER: 242.0(B)
SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 20 0F 21 APPENDIX A (cont'd) zz. TCAB-070, Corrective Action Plan (CAP) for Sequoyah Element Report 242.0(B), (02/04/87)
TCAB-072, Corrective Action Plan (CAP). for Sequoyah Element
~
aaa.
Report 242.0(B), (02/09/87) bbb. TCAB-078, Corrective Action Plan (CAP) for Sequoyah Element Report 242.0(B), (02/17/87) ccc. TCAB-084, Corrective Action Plan (CAP) for Sequoyah Element Report 242.0(B), (03/31/87)
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTER .
APPLY OR CONTROL IN THIS AREA?
- a. SQN Design Criteria SON DC-V-12.2 " Separation of Electric Equipment and Wiring," R6, (09/30/85)
- b. SON Design Criteria SON DC-V-11-4.1 " Normal and Emergency Ac
( Auxiliary Power System," R2, (07/22/86)
- c. IEEE-279-1971, " Criteria for Protection System for Nuclear Power Cenerating Stations"
- d. SON FSAR Chapter 7 and 8
- e. IEEE-308-1971, " Class lE Power Systems for Nuclear Power Generating Stations"
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
- a. Walkdown performed by J. Wheeler, Bechtel, and N. Black, TVA, (BLT-080), (08/23/86)
- b. Walkdown performed by J. Benkert, Bechtel, and H. Liao, TVA, (IOM 557), (09/17/86)
- c. Walkdown performed by J. Benkert, Bechtel, and C. Dodson, TVA,(IOM 556), (09/18/86)
- d. Walkdown performed by J. Wheeler, Bechtel, and G. Bell, TVA, (BLT-061), (10/09/86)
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1083d-3(04/02/87)
.: 7
- REPORT NUMBER: 242.0(B)
~.' TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION _ NUMBER: 3 PAGE 21 0F 21 f.
t, CATD LIST The following CATDs identify and provide corrective actions for the findings included in this report:
242 00-SQN 01 (02/07/87; CAP revised 03/25/87 242 00 SQN 02 (02/07/87; CAP revised 03/25/87 242 00 SQN 03 (02/07/87; CAP revised 03/25/87 242 00 SQN 04 (02/07/87; CAP revised 03/25/87) kh l
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- ECP$120J-ECPS121C TENNESSEE VALLEY AUTHORITY' RUN . TIME 13:58:39*
REFERENCE ;
0FFICE OF NUCLEAR P0HER - RUN DATE - 03/19/87 . s FREQUENCY- - REQUEST EMPLOYEE CONCERN. PROGRAM SYSTEM (ECPS)' .
ONP - ISSS - RHH EMPLOYE2 CONCERN INFORMATION BY CATEGORY / SUBCATEGORY-. -
SUBCATEGORY: 24200 ELECTRICAL-SEPARATION ,
CATEGORY: EN DES PROCESS-& OUTPUT .
S H 1 REPORT APPL SUB R PLT. 2 SAF RELATED HISTORICAL ~ CONCERN CONCERN DESCRIPTION .>
D LOC BF.BL SQ HB REPORT.. ORIGIN '
CONCERN NUMBER . CAT CAT QTC . CI: BELIEVES PROCEDURES ARE BEING VIOLATED (IN GENE' IN 254-00401- EN 24200 N HBN 1. N N Y Y.
RAL) HHEN Q AND NON-Q ELECTRICAL CABLE ARE NOT BEI i T50208 2 NA NA SR SR 'NG SEPARATED IN CABLE TRAYS. THIS INCLUDES LON, M r
t
' EDIUM, AND HIGH VOLTAGE CABLE. BY NOT' SEPARATING THE CABLE, THE TRAYS ARE BEING OVERLOADED. CI HAS' NO FURTHER INFORMATION.'.. CONSTRUCTION DEPT. CONCE RN.
I-85-570-HBN QTC MANY ELECTRICAL CABLES HAE BEEN PLACED IN CABLE TR IN 259-00601 EN 24200 N HBN 1N N Y Y AYS WITHOUT ADEQUATE SEPARATION. MANY CABLE TRAY T50149 2 NA NA SR SR COVERS EXTEND 3 TO 4 INCHES ABOVE THE TRAY BECAUSE OF CABLE ARRANGEMENT. CONSTRUCTION DEPT. CONCERN
. CI HAS ADDITIONAL*
INFORMATION. NO FOLLOH-UP RE
- f. l QUIRED. .
1N N Y Y I-85-706-HBN QTC' . CABLE SEPARATION IS INADEQUATE AND IN MANY CASES N IN 314-00401 EN 24200 N HBN ONEXISTENT. CONSTRUCTION CONCERN.' C/I HAS NO ADD '
T50165 2 NA NA SR SR ITIONAL INFORMATION.
R 1Y Y Y Y QTC ELECTRICAL SEPARATION AND' PHYSICAL SEPARATION '(
HI 100-00401 EN 24200 N HBN EDUNDANT HIRING AND CABLING AND FOR EQUIPMENT AND *:
CI EXPRE T50211 2 SR SR SR SR' COMPONENTS ARE INADEQUATE AT ALL PLANTS.
SSED THAT DETAILED REVIENS NEED TO BE MADE, AND AR.
E SO EXTENSIVE THAT A CONSULTANT PROBABLY CI SHOULD HAS'. B E USED. PROVIDING INDEPENDENCE FROM TVA.
NO FURTHER INFORMATION. zANONYMOUS CONCERN VIA LET s TER.
I-85-133-SQN QTC SEQUOYAH ELECTRICAL SEPARATION AND PHYSICAL SEPAR-s XX 122-01101 EN 24200 N SQN 1Y Y Y Y ATION OF REDUNDANT HIRING AND CABLING AND FOR EQUI' T50214 2 SS SS SS SS PMENT AND COMPONENTS ARE INADEQUATE AT ALL PLANTS.
CI EXPRESSED THAT DETAILED REVIEHS NEED To BE MA DE, AND ARE 50 EXTENSIVE THAT A CONSULTANT PROBABL E Y SHOULD BE USED, PROVIDING INDEPENDENCE FORM TVA.
M CI HAS No FURTHER.INFORMATION. ANONYMOUS CONCERN
.VIA LETTER, d 1Y Y Y Y' QTC 'BELLEFONTE: ELECTRICAL SEPARATION AND PHYSICAL SEP
"" XX 122-01201 EN 24200' N BLN 'ARATION OF REDUNDANT HIRING AND CABLING AND FOR EQ'
- T50214 2 SR SR SR SR ' UIPMENT AND COMPONENTS ARE INADEQUATE AT ALL PLANT -
S. CI EXPRESSED THAT DETAILED REVIEWS NEED TO BE MADE, AND ARE SO EXTENSIVE THAT A CONSULTANT PROBA BLY SHOULD BE USED, PROVIDING INDEPENDENCE FROM TV
- ' A. CI-HAS NO FURTHER INFORMATION. ANONYMOUS CON
- 1 CERN VIA LETTER.
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PAGE~ - 106 9 :
- ECPSI20J-ECPS121C TENNESSEE VALLEY AUTHORITY RUN TIME - 13:58:39 REFERENCE '
- REQUEST OFFICE OF HUCLEAR POWER .. RUN DATE . - 03/19/87
- FREQUENCY EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
DNP - ISSS - RHit EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY .
SUBCATEGORY: 24200 ELECTRICAL SEPARATION CATEGORY: EN DES PROCESS & OUTPUT .
S H 1 REPORT APPL CONCERN.
SUB R PLT 2 SAF RELATED HISTORICAL CONCERN DESCRIPTION BF BL SQ HB REPORT ORIGIN.
CONCERN NUMBER CAT CAT D LOC QTC BROWN'S FERRY: ELECTRICAL SEPARATION AND PHYSICAL XX 122-01301 EN 24200 N BFN 1Y Y Y Y SEPARATION OF REDUNDANT HIRING AND CABLING AND FOR T50214 2 SR SR SR SR EQUIPMENT AND COMPONENTS ARE INADEQUATE AT ALL PL -
ANTS. CI EXPRESSED THAT DETAILED REVIENS NEED TO BE MADE, AND ARE SD EXTENSIVE THAT A CONSULTANT PR-DBABLY SHOULD BE USED, PROVIDING INDEPENDENCE FROM TVA. CI HAS NO FURTHER INFORMATION. ANONYMOUS CONCERN VIA LETTER.
7 CONCERNS FOR CATEGORY EN SUBCATEGORY 24200 ,
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