ML20210G210
| ML20210G210 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/03/1987 |
| From: | Jordan C, Parkinson G, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F779 | List: |
| References | |
| 239.0(B), 239.0(B)-R01, 239.0(B)-R1, NUDOCS 8702110239 | |
| Download: ML20210G210 (23) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 239.0 (B)
SPECIAL PROGRAM REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 1 TITLE:
CABLE AND RACEWAY PROGRAM Cable and Raceway Program Inadequate (Routing)
PAGE 1 0F 22 REASON FOR REVISION:
1.
Incorporated SRP and TAS consents, and revised to update for new fomat requirements, and to add Section 10.
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I TVA EMPLOYEE CONCERNS REPORT NLMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 s PAGE 2 0F 22 1. CHARACTERIZATION OF ISSUE (S): Concerns: Issues: IN-85-743-006 a. Cable pull slips have inaccurate " Pull slips relative to cable information as to the length of the pulls are generically inaccurate pull s. Inaccurate length of pulls relative to length of pull, which delays production because field is causes delays in production due required to walk down the pull. to craft having to physically ' walk down' system." b. Computer Cable Routing Program is inadequate. WI-85-100-014 " Computer Cable Routing Program c. Cable routing status systems are is inadequate and it's status inadequate. Cables are routinely system is inadequate." scheduled to be added to overfilled conduits. IN-85-743-008 " Conduits are generically d. Conduits are overfilled. [ Addressed overfilled and additional cables in Element Report 238.1(B)] are routinely scheduled to be added to the conduits. This s. causes significant expenditures of manhours in attempting to pull cables where there is no more room available." 2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Documentation Identifiers: o Identified by Nonconformance Report (NCR) - SONECB8501 (B45 850422 259), " Verification of Computer Cable and Raceway Programs and Data" Date 04/22/85 o Identif'ed by Significant Condition Report (SCR) - SONEEE8602 R0 (B43 860123 902), " Computer-Routed Cable Lengths Are Inadequate for OE Calculations Required to Support Electrical Design for Sequoyah Nuclear Plant" Date 01/23/86 f 105?d (01/20/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 (- PAGE 3 0F 22 o Identified by Significant Condition Report (SCR) - SONEEB8620 R1 (B43 860410 910), " Cable Tray Load" Date 02/10/86 o Identified by Significant Condition Report (SCR) - SQNEEB8601 (B42 860117 919), " Cable Weights and Outside Diameters Not Available From a QA Source" Date 01/17/86 o Identified by Sitnificant Condition Report (SCR) - SONECB8601 (BL2 860707 014), " Cable Tray Fill Design Criteria Exceeded" Date 06/27/86 o Identified by Significant Condition Report (SCR) - SONECB8602 (B42 860707 006), "Sequoyah Cable Routing System Data Files Have No Protection From Deletion" Date 07/03/86 o Identified by Nuclear Safety Review Staff (NSRS), Review of Generic Concern Issue, Sequoyah Nuclear Plant, to: NSRS Report No. I-86-251-50N, " Electrical Cables," (Note: NSRS Report 1-65-251-50h was not issued, Attachment 1 is part of GCA-01-46, App. A, 5.v) Date 02/18/86 3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STAltu IN ELEMENT. No further information available. The employee concerns are general in nature and are directed at the cabic and raceway computer program. 4. INTERVIEW FILES REVIEWED: Files IN-85-743 and WI-85-100 were reviewed and no additional unreviewed information for Sequoyah was identified for the concerns addressed in this report. File IN-85-743 contains a short response to concern IN-85-743-006 from Supervisor Electrical Engineering Unit-C. 105?d (01/20/87)
~ TVA EMPLOYEE CONCERNS REPORT NUMBER: 239.0 (8) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 22 5. DOCUMENTS REVIEhED RELATED TO THE ELEMENT: See Appendix A. 6. hHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA 7 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 available transcripts of NRC investigative interviews to determine whether any additional information/ issues exist. b. Reviewed the FSAR for established criteria for cable routing, cable separation, and raceway fill. c. Interviewed TVA users of computer program to understand how the program was actually implemented at the site during plant construction. d. Reviewed existing TVA report (e. g., Attachment I of NSRS Report I-86-251-SQN) including Construction, QA/QC, Operations, and Material Control element reports for the TVA Employee Concerns Special Program to determine whether the issues have been addressed. e. Reviewed other documents (e. g., Desi gn Guide, User's Manual, computer printouts. Sequoyah Nuclear Plant Procedures, and Routing and Pull Slips) to verify the adequacy of the computer program's compliance to QA veri fication. f. Assessed overall computer program for adequacy in tracking input data and veri fication of data used as quality i n fonnation. i 1053d (01/20/87)
TVA EMPLOYEE CONCERNS REPORT NUMER: 239.0 (8) SPECIAL PROGRAM REVISION NUMER: 1 / PAGE 5 0F 22 9. DISCUSSION, FINDINGS, AND CONCLUSIONS: Chronology: 04/11/85: Nonconfonnance Report (NCR) SQNECB8501 states that computer cable routing system program does not have verification docunentation or controlled user docunentation 07/85: Concerns IN-85-743-006 and 008 received by TVA 10/11/85: Office of Engineering calculation B25 851011004 issued to verify the computer routing program using 50 randomly selected class 1E cables 11/85: Concern WI-85-100-014 received by TVA 01/14/86: Engineering Report SCR SQNEEB8602 concludes that the inadequacy of cable length infonnation was not a factor in engineering calculations because the computer routed lengths were conservative (longer than actually installed) 01/23/86: Significant Condition Report SCR SQNEEB8602 indicates that the computer-routed cable lengths were 4 inadequate for engineering calculations to support the electrical design 01/17/86: SCR SQNEEB8601 R0 states that the criteria for cable l tray fills (30 percent for power trays with cables above 30 amperes and 60 percent for control and j instrunentation signal trays) have been violated 03/31/86: Office of Engineering calculation B43 860331928 establishes a list of verified cable data that includes the respective cable OD, maximun OD for I individual conductor, and cable weight per foot 03/31/86: Engineering Report SCR SQNEEB8601 R0 concludes that the use of these unverified values in previous calculations would not affect plant safety. Thi s conclusion was reached by comparing previously used values to the list of cable diameters and weights provided in Attachment I to the ER 04/10/86: SCR SQBEEB8620 R1 indicates that there is no method to identify and/or track abandoned cables in the I cable trays when the abandoned cable nunber is reused on a new cable 1053d (01/20/87) l l
TVA EFLOYEE CONCERNS REPORT NUfBER: 239.0 (B) ' SPECIAL PROGRAM REVISION NUISER: 1 PAGE 6 0F 22 { t 05/13/86: Engineering Report SCR SQNEEB8620 R1 adnits the potential for cable tray overfills (this contradicts i ER for SCR SQNECB8601 R0 which, as indicated before, concludes that there are no known cases of cable tray loadings that violate the design criteria), and l concludes that overload of cable trays resulting from abandoned cables not being removed or accounted for i does not present cable ampacity problem ~ 06/27/86: SCR SQNECB8601 RO states that the criteria for cable tray fills (30 percent for power trays with cables above 30 amperes and 60 percent for control and 4 instrtmentation sipal trays) have been violated t 07/07/86: SCR SQNECB8602 notes that data files for the SQN cable routing system have no protection from deliberate or inadvertent deletion of infonnation i i 07/17/86: Engineering Report SCR SQNECB8602 concludes that no l data file problems have been encountered, and j reconnends adding the appropriate protection for data files and programs l 08/04/86: Engineering Report SCR SQBECB8601 concludes that the cable tray loading (fill) was conservative because l fill quantity was based on 3-inch-deep cable trays whereas 4-inch trays were installed at SQN. The ER also states that there are no known cases of cable tray loading that violate the design criteria 09/22/86: Sequoyah Engineering Procedure SQEP-06 R0 issued to include provisions for communications infonnation i feedback regarding cable and raceway installation i status I l 09/29/86: Memo from Raughley to Those Listed provides guidance l to all nuclear projects for the disposition of j problems identified by the ECB cable routing i evaluation team. The memo recommends actions for SQN to implement in response to SCRs SQNECB8601 and 8602 I 10/28/86: Quality Assurance Evaluation Report reviews and evaluates the Sequoyah Computerized Cable Routing System and reconnends corretive actions for several deficiencies outlined in the report t 1053d (01/20/87) i ,,.,,,---,-,-.--=---.-_.,,,-._..,,_----,--,--_-,;,,,,,-----,,-.-n,
TVA EMPLOYEE CONCERNS REPORT NUMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 7 0F 22 Discussion: Problems regarding the Computer Cable Routing Program and associated issues, "a" through "c", are discussed in this report. Issue "d" for conduit overfills is addressed in Sequoyah Element Report 238.1(3). The Computerized Cable Routing System (CCRS) program used at Sequoyah Nuclear Plant is designed to aid the electrical designer in routing cables within the cable tray network. Some features of this system are intended to provide automatic routing of cables in cable trays while maintaining adequate divisional separation between redundant cables as well as voltage level separation. The computer program also computes and tracks the total cross-sectional area (CSA) fill of the cable trays. In general, the employee concerns question the adequacy of the computer program to perform its intended functions. The reliability of the plant's safety systems could be directly affected if redundant systems are subjected to common hazards due to inadequate divisional and voltage level separation. Reliability could also be affected by overfilled raceway, which could create potential problems with cable damage, ampacity, and structual supports. a. SCR SONEEB8602 R0 (01/23/86, App. A, 5.k) states that the computer-routed cable lengths were inadequate for engineering i calculations required to support the electrical design. Accurate cable length data is necessary to ccmpute cable voltage drop. Engineering Report SCR SONEEB8602 R0 (01/10/86, App. A, 5.m) l concludes that the inadequacy of cable length information was not a factor in engineering calculations since the computer-routed cable lengths were conservative (longer than actually installed), and that no further action is required. Although Construction data was available, the evaluation team could find no evidence that feedback was received by Engineering from Construction on the actual installed length for cables and raceways. I 1053d (01/20/87) l
~ TVA EMPLOYEE CONCERNS REPORT NUMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 22 The lack of a requirement for Construction to provide Engineering with actual installed raceway lengths may have contributed in the past to some inaccuracies in the computer-generated Engineering cable lengths indicated on the pull slips. Therefore, Construction walkdowns of cable pull routes were required to ensure that cables were of adequate lengths. However, field walkdown of cable pulls is a common procedure consistent with good construction practice. In 1985, the Construction computer data file was merged into the Engineering computer data file to make cut cable length data available to Engineering. In the past, there was inadequate feedback from Construction to Engineering of actual cable lengths for use in electrical calculations (e.g., voltage drop). TVA has acknowledged this problem and indicated (10/08/86, App. A, 7.c) that current calculations have been updated 5.er cut cable lengths (e.g., 06/20/86, 02/10/86,12/27/85, App. A, 5.y, 5.z, and 5.aa). TVA has also indicated that current procedures ensure that cut or installed cable lengths are used in calculations for future modifications by identifying the estimated lengths as unverified assumptions (unverified assumptions are presently covered by Nuclear Engineering Procedures [NEPs]). This will ensure that the calculation is not considered final until all of the unverified assumptions are verified (estimated lengths converted into cut or installed lengths). Also, the long-term calculation program will result in additional procedures to prevent recurrence. b. fjCR SQi!ECB8501 (04/11/85, App. A, 5.a) states that the CCRS program does not have verification documentation or controlled user documentation and CCRS data and software are being used as quality assurance tools to route cables, update cable and conduit data, and maintain cable tray files (for further information regarding program verification refer to Element Report 205.4). In response to this NCR the Office of Engineering prepared a calculation B25 851011 004 (10/11/85, App. A, 5.b), to verify the cable routing computer program. This verification was based on 50 randomly selected class 1E cables whose routings were compared with tray laj Jut drawings and their from/to locations with the wiring orawings. Review of this calculation by the evaluation team determined that it does not verify the adequacy of the computer automatic routing or other features of the computer program because it: / 1052d (01/20/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 9 0F 22 o Does not demonstrate compliance with separation requirements between redundant or between divisional and nondivisional cables (sample consisted of class 1E cables only ). o Does not demonstrate compliance with requirements for separating cables of different voltage levels, o Does not address adequacy of the computer program to calculate raceway fills. 4 o Does not test the computer program for rejection of erroneous inputs. o Does not test the computer program for refusal to route cables in full trays. o Does not address adequacy of the computer program to 4 calculate cable length used on pull slips. o Modifications / revisions to the CCRS program have not been documented. Verification of the adequacy of the current program will not necessarily demonstrate adequacy of past revisions. All the above items make adequacy of the current installation indeterminate (other factors contributing to this uncertainity are discussed in Sequoyah Element Reports 238.3 and 240.0). The Quality Assurance Evaluation Report (10/28/86, App. A, E.t), discussed later, also addresses these items in the verification portion of its recommended corrective actions. SCR SQNECB8602 R0 (07/07/86, App. A, 5.n) notes that data files for the SQN cable routing system have no protection fron deliberate or inadvertent deletion of information. Engineering Report (ER) SCR SQNECB8602 (07/17/86, App. A, E.o) concludes that no data file problems have been encountered, and that the SCR was issued only to document a potential problem identified by the Engineering Computer Methods Branch (ECB) cable routing evaluation team. The ER recommends adding appropriate protection for data files / programs to ensure that all source / load modules are in secure production version libraries, and to implement ( existing TVA security techniques. 1052d (01/20/87)
~ TVA EMPLOYEE CONCERNS REPORT NLMBER: 239.0 (B) SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 10 0F 22 Similarly, the Quality Assurance Evaluation Report (10/28/86, App. A, 5.t) reviewed and evaluated the Sequoyah CCRS and recommended corrective actions for several deficiencies: o Documentation: No controlling documents for system maintenance. o Security: No backup / recovery of system files; no block of access to unauthorized users. o Verification: No documentation of computer program verification. o Procedures: Incomplete computer program usage procedures. TVA indicated (10/24/86, App. A, 7.f) that upon issuance of this Quality Assurance Report (10/28/86, App. A, 5.t), ECB will implement all necessary corrective actions recommended in the report; these will also include corrective actions for the deficiencies outlined in NCR SQNECB8501 and SCR SONECBP602. TVA also reported that some corrective actions have already been started (e.g., program verification, security aspect). Furthemore, ECB procedure ECB-EP 28.01 (07/01/85, App. A, S.bb), already available at the time deficiencies were identified, has been reviewed by the evaluation team and determined to be adequate, if adhered to, to prevent similar deficiencies in the future. c. SCR SQNECB8601 R0 (06/27/86, App. A, 5.d) states that the criteria for cable tray fills (30 percent for power trays with cables above 30 amperes and 60 percent for control and instrumentation signal trays) have been violated. The SCR points out that during the review of the SON Cable Routing System program, it was discovered that cable tray overfill conditions were created by system users raising the maximum allowable tray fill to permit the addition of cables to already full trays. Note that raising the maximum allowable tray fill capacity allows the CCRS to route cables that would otherwise have been rejected by the computer program. Engineering Report SCR SONECD8601 R0 (08/04/86, App. A, 5.e) concludes that the cable tray loading (fill) was conservative because fill quantity was based on 3-inch-deep cable trays whereas 4-inch trays were installed at SQN. The ER also states that there are no known cases of cable tray loading that violate the design criteria (as discussed later, ER SCR SONEED8620 contradicts this statement). 105?d (01/20/87)
TVA EWLOYEE CONCERNS REPORT NUMER: 239.0 (B) SPECIAL PROGRAM REVISION NUMER: 1 PAGE 110F 22 SCR SQNEEB8601 R0 (01/17/86, App. A, 5.f) states that unverified values of cable weights and outside diameters (00) were used in the calculation of conduit and cable tray cross-sectional area fills, minims bend radii, training radii, and side wall pressures. Engineering Report SCR SQNEEB8601 R0 (04/16/86, App. A, 5.g) concludes that the use of these unverified values in previous calculations would not affect plant safety. This conclusion was reached by comparing previously used values to the list of cable diameters and weights provided in Attachnent I to the ER. However, the ER did not indicate how the comparison was made or by what criteria the conclusion for acceptability was reached. The ER also indicates that Attachment I will be used by the Electrical Engineering Branch (EEB) to generate a list of verified cable data. This ER, however, does not address the effect of using unverified values on raceway overfills and, therefore, on raceway supports or cable ampaci ties. Office of Engineering (OE) Calculation B43 860331928, (03/31/86, App. A, 5.h) established a list of verified cable data that included the respective cable 00, maximm OD for individual conductor, and cable weight per foot. Upon completion of the calculation, TVA issued design standards DS-E12.1.13 (04/15/86, App. A, 5.1) and DS-E12.1.14 (04/15/86, App. A, 5.j) to list all cables used at all TVA nuclear plants. SCR SQNEEB8620 R1 (04/10/86, App. A, 5.p) indicates that there is no method to identify and/or track abandoned cables in the cable trays when the abandoned cable neber is reused on a new cable. The SCR concludes that this may result in a violation of SQN design criteria SQN-DC-V-ll.3, which provides maxima acceptable cable tray fills, since abandoned unlabeled cables are no longer considered in the cable tray fill data by the CCRS. Although Engineering Report SCR SQNEEB8620 R1 (05/13/86, App. A, 5.q) adnits the potential for cable tray overfills (this contradicts ER for SCR SQNECB8601 R0 which, as indicated before, concludes that there are no known cases of cable tray loadings that violate the design criteria), and concludes that overload of cable trays resulting from ( 1053d (01/20/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 12 0F 22 abandoned cables not being removed or accounted for does not present cable ampacity problem. The ER indicates that the worst case sampling used to resolve the SCR was not sufficiently broad-based to address the adequacy of the cable tray supports. However, SCR SQNCEB8622 was issued to furnish additional evaluation required to resolve cable tray support overloading. Further assurance that cable tray support problems are addressed is documented in an Unimplemented Design Item evaluation (03/07/86, App. A, 5.r) which states that, "The Civil Engineering Branch will analyze hangers for overloaded cable tray segments. Cable tray supports found to have loads excee'ing their design limits will be modified for new loads." Although the engineering reports did not conclusively resolve the SCRs discussed above, a TVA memo from Raughley (09/29/86, App. A, 5.x) provides guidance to all nuclear projects for the disposition of problems identified these SCRs and by the ECB cable routing evaluation team. The memo recommends the following actions from SON to implement in response to SCRs SONECB8601 and 8602: i L o Input / update cable mark number data file to reflect plant specific CSA or average CSA shown in DS-E12.1.13 and DS-E12.1.14. o Add a data element to the computer program that will furnish the basis for maximum CSA for trays. o Input tray width and depth into the new data fields. o Recalculate all tray fills using updated cable data, o Flag all tray segments that are overfilled and evaluate for acceptability. o Ensure appropriate protection for data files / programs by using existing TVA Computer Security (Resource Access Control Facility [RACF]). In addition to the above, the following additional discrepancies were noted by the evaluation team: o Cables manually routed by Er.gineering without node numbers do not appear in cable tray fill printouts (e.g., 6.9 kV system cables). \\ 1052d (01/20/87)
TVA EMPLOYEE CONCERNS REPORT NUMER: 239.0 (B) S/ECIAL PROGRAM REVISION NUMER: 1 (, PAGE 13 0F 22 o All cables in conduits are manually routed and, therefore, 1 conduit fills are manually computed. There were no procedures for preventing overfills or addition of cables to already full conduits, o Cable cross sectional areas (CSA) entered into tray l section nodes are totaled by the computer program. When cables were revised and re-routed through different tray section nodes, the program did not automatically remove the cable CSA. This was intended to be a manual operation by design and no procedure exists to ensure this was accompli shed. Therefore, tray section nodes (fill) contain CSA for phantom cables. o As previously discussed in "a" of this section, there was no adequately updated information on the status of raceway and cable installation (e.g., installation completion, lengths). Review of a recently issued (09/22/86) Sequoyah Engineering Procedure SQEP-06, RO by the evaluation team indicates that ( adequate methods have been developed to prevent future recurrence af ter the identified problems have been corrected. The procedure has provisions for corrnunicating information feedback regarding cable and raceway installation status, for preventing removal of abandoned cables from the cable schedule loading program, and for preventing overfill of conduits and cable trays. Findings: a. Cable length inaccuracies in the past resulted from inadequate feedback from Construction. This problem has currently been resolved; for future installations adherence to SQEP-06 will prevent recurrence. The effect of inaccurate cable lengths on electrical calculations has been recognized and the actual cable lengths incorporated as required. Current procedures and the long-tenn calculation program l currently under way should prevent recurrence of the problem, as addressed in Sequoyah Element Report 213.1(8). 1053d (01/20/87)
~ TVA DFLOYEE CONCERNS REPORT NUMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 ( PAGE 14 0F 22 b. The Computerized Cable Routing System program has not been properly vert fled in accordance with ECB EP-28.01 for perfonning divisional and voltage level separation, calculating raceway fills, rejecting erroneous inputs, and refusing cable routing in full trays. Therefore, the adequacy of the as-built installed cables cannot be detennined until the program and input data have been verified (other factors contributing to the current as-built uncertainities are addressed in Sequoyah Element Report 238.3, and 240.0). The program is also deficient in the areas of security, controlling docments for system maintenance, docmenting revisions, and program usage procedures. However, actions have been initiated to correct these deficiencies. c. Inadequate status system in the past, primarily for providing reliable raceway fill infonnation, along with nonadherence to maximm allowable raceway fills, has resulted in the current situation of potentially overfilled raceways and the consequent effect on cable damage, seismic supports and cable ampaci tie s. This situation is further complicated by the use 7 ( of unverified cable diameters and weights, by the fact that no records exist for all the abandoned cables, and because Engineering hand routed cables inputted into the computer data base were not calculated into the total cable tray fill. TVA has stated that current programs directed at resolving these problems have been initiated. However, to date, there is no prograr1 to address the Engineering hand routed cables without node nebers.
== Conclusions:== All issues identified in the employee concerns are valid. TVA needs to develop a method to ensure the computer program does not accept any Engineering hand routed cables unless these cables are j properly accounted for in the raceway fill quantities. However, TVA has acknowledged the other problems identified and corrective actions are in process. Implementation of corrective actions should resolve the current problems. t 1 1053d (01/20/87)
TVA EMPLOYEE CONCERNS REPORT NLSSER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 ~( PAGE 15 0F 22 10. CORRECTIVE ACTION: Corrective Action Plans (CAPS) have been generated by TVA as identified by TCAB-053, dated 01/13/87 ( App. A, 5.dd) in response to four general categories of problems identified in CATDs 239.00-SON-01, -02, -03, and -04. The four general issues are: a. 239.00-SQN-01 : the computerized cable routing program has not properly been verified to assure that it performs its intended function. b. 239.00-SON- 02: the computerized cable routing program is deficient in the areas of security, controlling documents for system maintenance, and program usage procedures, as required in ECB Procedure ECB-EP28.01. c. 239.00-SON-03: the computerized cable routing program pennits the input of manually routed cables in trays without node numbers. d. 239.00-SQN-04: modifications and revisions to the CCRS ( program have not been documented. In the CAP for CATDs 239.00-SQN-01 and -02, TVA indicates that the implementation of its Software Quality Assurance Plan "Will ensure compliance with ECB EP 28.01 in the future. Completion of this plan will not be prior to restart for CATD-01. As an interim measure prior to restart, a test file will be created to verify the proper functioning of the computer program for its key parameters (tray fill, separation, weight, voltage level, etc.). If discrepancies are found the root cause and extent will be determined end all problems resolved prior to restart. If no discrepancies are found implementation of the SQAP will continue." This action plan is acceptable to resolve the problems identified and should preclude future problems with the program. Use of the test file to verify program function prior to restart should provide a high level of confidence in the adequacy of the program upon completion. Application of the procedure ECB-EP 28.01 should protec t the program against unauthorized use. TVA has committed to adhere to the " Software Quality Assurance Plan," which is still in the preliminary stage and under review. Per discussion with TVA (fpp. A, 7 9), this document has been revised since the preliminary copy of the SQAP was received via TCAB-053. ( 1052d (01/?0/P7)
TVA DFLOYEE CONCERNS REPORT NUlOER 239.0 (8) SPECIAL PROGRAM REVISION NUISER: 1 i ( PAGE 16 0F 22 f For CATD 239.00-SQN-03, TVA indicates that "SQN will perfom a manual review of the conduit routing field for all cables, to locate the manually routed cables in trays. These tray node nunbers will then be entered in the computer routing and the effect on tray fill, weight, and cable ampacity will be reevaluated. SQEP-06 will be revised to prohibit manual routing of cables in trays." This action is an acceptable solution to the problem. For CATO 239.00-SQN-04, TVA indicates that "following the verification of the existing program through the use of a sample test file as detailed in the response to CATD 239.00-SQN-1 all data i will be reloaded. This will cause the program to perfom all of its built in checks for separation, voltage segmgation, raceway fill, etc. If none of the cables are rejected it will demonstrate adequacy of past revisions. Any cables which are rejected will be investigated for the cause and the installation reconciled accordingly." In a discussion to clarify the CAP (App. A, 7.h), TVA explained that when the new data are reloaded, the computer will be instructed to reroute all cables in accordance with their original routings. This will ensure that a routing check for separation, tray fill, etc., will be perfomed by the verified j i program. This action is an acceptable solution to the problem. 1 i J T i !( l 1053d (01/20/87)
e ~ TVA DFLOYEE CONCERNS REPORT NUpBER: 239.0 (B) SPECIAL PROGRAM REVISION NUpBER: 1 ( PAGE 17 0F 22 APPENDIX A 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT: a. TVA memo from Roberts to Vineyard, (B42 851021004), "Sequoyah Nuclear Plant Units 1 and 2 - NCR SQNEC88501 - Verification of Computer Cable and Raceway Programs and Data," (10/21/85), [ attachment NCR SQNECB8501 - (842 850412 004), (04/11/85)] b. Office of Engineering Calculation, (825 851011000), " Corrective Action for NCR SQNECB8501 by SQN Design Docunent Check," (10/11/85) c. Failure Evaluation / Engineering Report for SCR 3QNECB8501 (B45 850422 259), "Docunentation of QA Verification of Computer Programs and Data " (04/22/85) d. Significant Condition Report SCR SQNEC88601 R0, (B42 860707 014), " Cable Tray Fill Design Criteria Exceeded," (06/27/86) k ) e. Engineering Report SQNECB8601 R0, (S56 860804 820), " Cable Tray Design Criteria Exceeded," (08/04/86) l f. Significant Condition Report SCR SQNEEB8601 R0, (843 860117 919), " Cable Weights and Outside Diameters Not Available from a QA Source," (01-17-86) g. TVA memo from Wilson to Brimer, (B25 860416 007), "Sequoyah Nuclear Plant Units 1 and 2 - Engineering Report for CAQ Report No. SCR SQNEEB8601 R0," Rev.1, (04/16/86) h. Office of Engineering Calculation, (843 860331928), "Detennination of Class IE Electrical Cable Weight / Foot and Outside Diameter," (03/31/86) 1. Electrical Design Standard DS-E12.1.13, (805 860423 501), " Cable, Class 1E Cable ODs and Weights," (04/15/86) J. Electrical Design Standard DS-E12.1.14. Rev. 0 (805 860429 505), " Cable, Class NC Cable ODs and Weights," (04/15/86) k. Significant Condition Report SCR SQNEEB8602 R0, (843 860123 902), " Computer-Routed Cable Lengths Are Inadequate for OE Calculations Required to Support Electrical ( Design for Sequoyah Nuclear Plant," (01/23/86) 1053d (01/20/87)
TVA EWLOYEE CONCERNS REPORT NUMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 [ PAGE 18 0F 22 APPENDIX A (Cont'.d) m. TVA memo from Vineyard to Rankin, (B25 860110 002), " Transmitting Engineering Report SCR SQNEEB8602 R0 - Computer-Routed Cable Lengths Are Inadequate for OE Calculations Required to Support Electrical Design for Sequoyah Nuclear Plant," (01/10/86) n. TVA memo from Roberts to Wilson, (B42 860707 005), "Sequoyah Nuclear Plant Unit I and 2 - Significant Condition Report (SCR) - SQNECB8602 R0," (842 860707 006) " Data Files Have No Protection From Deliberate / Inadvertent Deletion," (07/07/86) 1 o. TVA memo from Wilson to Wallace, (B25 860717 001), "Sequoyah Nuclear Plant Units 1 and 2 - Engineering Report for CAQ Report No. SCR SQNECB8602R0," ($53 860721951) " Data Files Have No Protection From Deliberate / Inadvertent Deletion" (07/17/86) p. Significant Condition Report - SCR SQNEEB8620 R1, (843 860410 910), " Cable Tray Loading" (No method of tracking ( or identifying abandoned cables in cable trays), (04/10/86) q. TVA memo from Wilson to Brimer, (B25 860520 002), " Engineering Report - SCR SQNEEB8620 R1," Rev. O, 05/13/86, (05/20/86) r. Unimplemented Design Evaluation, (B25 860310 074), "SCR SQNEEB8620, Cable Tray Loading," (03/07/86) s. Sequoyah Engineering Procedure - SQEP-06 Rev. O, " Cable and Conduit Procedure for Sequoyah Nuclear Plant," (09/22/86) t. TVA memo from Johnston to Raughley, " Evaluation of Computerized Cable Routing Systems Final Regort " (B42 861229 006), (12/29/86), and attached Evaluation of Computerized Cable Routing System Final Report, " (11/01/86). Attactment B to this report is the Quality Assurance Evaluation Report - Sequoyah Nuclear Plant Cable Routing System, (10/28/86) u. Conduit and Cable Schedule Sequoyah Nuclear Plant - Computer Printout Cable Tray Sevent with Cross-Sectional Area Tray Fill - Received 08/14/86 (Printout does not have date or revi sion. ) 1053d (01/20/87)
~ TVA DFLOYEE CONCERNS REPORT NUMER: 239.0 (8) SPECIAL PROGRAM REVISION NUMER: 1 ( PAGE 19 0F 22 APPENDIX A (Cont',d) v. Sequoyah Generic Concern Task Force Report GCA-01-46, (no RIMS ntnber), " Overfill of Cable Trays and Conduits," (06/27/86) w. Sequoyah Report GCA-03-48, (no RIMS nuber), " Plant Procedures on Overfill of Cable Trays," (04/25/86) x. TVA memo from Raughley to Those Listed, (843 860929 904), "All Nuclear Projects - Coordinated Response to Cable Routing SCRs," (09/29/86) y. Office of Engineering Calculation, (843 860620 923), "Ac APS Voltage and Loading Analysis," (06/20/86) z. Office of Engineering Calculation (843 860210 924), "125V De Vital Instruent Power System Design Verification - Preliminary," (02/10/86) aa. Office of Engineering Calculation, (B43 851230 901), "120V Ac ( Vital Control Power System Design Verification - Preliminary," (12/27/85) bb. Engineering and Computer Methods Branch (ECB) Procedure - ECB-EP 28.01, (842 850710 510), " Computer Activities Requiring Quality Assurance - Computer Usage, Computer Program Documentation, and Computer Resident Data " (07/01/85) cc. 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) dd. Letter from G. R. McNutt, TVA, to G. L. Parkinson, Bechtel, TCAB-053, " Corrective Action Plan," (01/13/87) { 1053d (01/20/81)
TVA DFLOYEE CONCERNS REPORT NUf8ER: 239.0 (B) SPECIAL PROGRAM REVISION NUPSER: 1 [ PAGE 20 0F 22 APPENDIX A (Cont',d) 6. nelAT REGULATIONS, LICENSING COSMITMENTS, DESIGN REQUIREMENTS OR OlHER APPLY (R CONTROL IN THIS AREA? a. SNP FSAR, Section 8.3.1.4.1, " Cable Derating and Cable Tray Fill" b. SNP FSAR, Section 8.3.1.4.3, " Sharing of Cable Trays and Routing of Nonsafety-Related Cables" c. SNP FSAR Section 8.3.1.4.5, " Cable and Cable Tray Markings" d. Design Criteria No. SQN-DC-V-11.3, Section 6.2.2, " Cable Tray Loading" e. Sequoyah Engineering Procedure - SQEP-06 Rev. O, " Cable and Conduit Procedure for Sequoyah Nuclear Plant," (09/22/86) f. Electrical Design Standard DS-E12.1.13, (805 860423 501), " Cable, Class IE Cable ODs and Weights," (04/15/86) g. Electrical Design Standard DS-E12.1.14, Rev. 0 (005 860429 505), " Cable, Class NC Cable ODs and Weights," (04-15-86) h. Engineering and Computer Methods Branch (ECB) Procedure - ECB-EP 28.01, (B42 850710 510), " Computer Activities Requiring Quality Assurance - Computer Usage, Computer Program Doctraentation, and Computer Resident Data," (07/01/85) 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND 01HER DISCUSSIONS RELATED TO ELEMENT. (in a. Telecon Wheeler, Bechtel, to Craijhead, TVA, IOM 254, (09/09/86) b. Meeting Nesbitt, Hutson, TVA, and Don-Doncow, Wheeler, Bechtel, BLT-061, (10/08/86) c. Telecon Whooler, Bechtel, to Prince. TVA, IOM 320,(10/16/86) ( 1053d (01/20/87)
TVA DFLOYEE CONCERNS REPORT NtNBER: 239.0 (B) SPECIAL PROGRAM REVISION NLNSER: 1 ( PAGE 210F 22 APPENDIX A (Cont'.d) d. Telecon Wheeler, Bechtel, to Skinner, TVA, IOM 324,(10/20/86) e. Telecon Wheeler, Bechtel, to Skinner, TVA, ION 342,(10/24/86) f. Telecon Wheeler, Bechtel, to Skinner, TVA, IOM 410,(11/18/86) g. Telecon Wheeler, Bechtel, to Perry, TVA, ION 553,(01/20/87) h. Telecon Wheeler, Bechtel, to Skinner, TVA, IOM 554,(01/21/87) 1 l ' ( 1053d (01/20/87)
TVA DFLOYEE CONCERNS REPORT NUMBER: 239.0 (B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 22 0F 22 CATD LIST The following CATDs identify and provide corrective actions for the findings included in this report: 239 00 SQN 01 (01/12/87) 239 00 SQN 02 (01/12/87) 239 00 SQN 03 (01/12/87) 239 00 SQN 04 (01/12/87) C i 1053d (01/20/87)
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- 18 CEFERENCE
- ECPSI20J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 150 FREQUENCY - REQUEST OFFICE'0F NUCLEAR P0HER RUN TIME - 12:57:19 ) ONP - 1555 - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTrUT SUBCATEGORY: 23900 CABLE AND RACEHAY PROGRAM l S GENERIC KEYHORD A H APPL QTC/NSRS P KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D ) IN 743-006 EN 23900 N HBN YYYY IN-85-743-006 NO PULL SLIPS RELATIVE TO CABLE PULLS A SCHEDULE T50076 REPORT RE GENERICALLY INACCURATE RELATIVE T' PERSONNEL FEELINGS 0 LENGHT OF PULL, WHICH CAUSES DELAY ELECTRICAL ) S IN PRODUCTION DUE TO CRAFT HAVING CABLE TO PHYSICALLY "HALK DOHN" SYSTEM. N O FURTHER DETAILS AVAILABLE. ) IN 743-008 EN 23801 S HBN YYYY SS CONDUITS ARE GENERICALLY OVERFILLED NONCONFORMANCE T50076 EN 23900 K-FORM AND ADDITIONAL CABLES ARE ROUTINELY CONST PROCESS SCHEDULED TO BE ADDED TO THE CONDUIT ELECTRICAL S. THIS CAUSES SIGNIFICANT EXPENDIT CONDUIT I URES OF MANHOURS IN ATTEMPTING TO PU LL CABLE HMERE THERE IS NO MORE ROOM AVAILABLE. NO MORE FURTHER DETAILS AVAILABLE. HI I00-014 EN 23900 N HBN YYYY SR COMPUTER CABLE ROUTING PROGRAM IS IN NONCONFORMANCE T502I2 REPORT ADEQUATE AND IT'S STATUS SYSTEM IS I CONST PROCESS NADEQUATE. CI HAS NO FURTHER INFORM ELECTRICAL I ATION. ANONYMOUS CONCERN VIA LETTER CABLE 3 CONCERNS F0R CATEGORY EN SUBCATEGORY 23900 ) 1 b d -}}