Information Notice No. 85-11: Licensee Programs for Inspection of Electrical Raceway and Cable Installations

                                                            SSINS No.: 6835 
                                                            IN 85-11 

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                    OFFICE OF INSPECTION AND ENFORCEMENT 
                           WASHINGTON, D.C. 20555 

                             February 11, 1985 

Information Notice No. 85-11:   LICENSEE PROGRAMS FOR INSPECTION OF 
                                   ELECTRICAL RACEWAY AND CABLE 
                                   INSTALLATIONS 

Addressees: 

All licensees of nuclear power reactor facilities holding a construction  
permit (CP). 

Purpose: 

This information notice is provided to alert recipients of potentially 
significant problems identified during NRC Construction Appraisal Team (CAT)
inspections of licensee programs for the inspection of physical separation 
requirements for electrical raceway and cable installations. It is expected 
that recipients will review the information for applicability to their 
facilities and consider actions, if appropriate, to preclude similar 
problems from occurring at their facilities. However, suggestions contained 
in this notice do not constitute NRC requirements and, therefore, no 
specific action or written response is required. 

Description of Circumstances: 

Comanche Peak Units 1 and 2 

During the NRC CAT inspection conducted at the Comanche Peak Steam Electric 
Station in January and February 1983, a number of areas were identified in 
which physical separation criteria for Class 1E electrical raceway and cable
were not met. These separation deficiencies were associated with redundant 
electrical divisions, internal panel wiring, and separation from other 
equipment such as mechanical components and piping. 

The established facility inspection program did not provide adequate 
controls to ensure that deviations from specified separation criteria were 
promptly identified and corrected. This resulted in part from a licensee 
decision not to inspect electrical installations for physical separation 
until installation was essentially complete. (For details refer to 
Construction Appraisal Team Inspection Report 50-445/83-18, 50-446/83-12.) 




8502060437  
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Washington Nuclear Plant Unit 2 

During the NRC CAT inspection conducted at the Washington Nuclear Plant Unit
2 in May and June 1983, it was observed that the existing program for 
inspecting corrective action for identified electrical raceway deficiencies 
was not adequate. Controls in the Test and Startup organization were 
inadequate to ensure that deficiencies in transferred systems identified by 
the contractor were corrected. 

Although most of the installed Class 1E cable tray met applicable require-
ments, instances of failure to meet physical separation criteria were 
identified during the CAT inspection. (For details refer to Construction 
Appraisal Team Inspection Report 50-397/83-29.) 

Perry Units 1 and 2 

During the NRC CAT inspection conducted at the Perry Nuclear Power Plant in 
August and September 1983, it was determined that separation requirements 
relative to some electrical raceway installations had not been properly 
inspected by site personnel. In numerous installed and inspected cable tray 
segments, quality control (QC) inspections performed to determine the 
acceptability of Class 1E raceway installations did not follow the 
applicable procedures. Inspection records indicated physical separation 
criteria to be acceptable when, in fact, a number of installations examined 
during the CAT inspection did not conform to applicable requirements. In 
another area, adequate procedural controls were not established to ensure 
that the installation of Power Generation Control Complex (PGCC) duct covers 
(barriers) received appropriate inspections. (For details refer to 
Construction Appraisal Team Inspection Report 50-440/83-31, 50-441/83-30.) 

Nine Mile Point Unit 2 

The NRC CAT inspection conducted at the Nine Mile Point Station Unit 2 
during November 1983 identified a number of deficiencies in the inspection 
program for the installation of Class 1E electrical raceway and cable. These 
deficiencies included the failure to perform adequate inspection, inadequate 
procedural controls to ensure that installations conform to applicable 
requirements, and the failure to take appropriate action when deficiencies 
were identified. Inspection records indicated separation to be acceptable 
when, in fact, a number of previously inspected installations examined 
during the NRC CAT inspection did not conform to applicable separation 
requirements. In the area of procedures, adequate installation and 
inspection procedure controls had not been established to ensure that the 
PGCC cable and wiring installations would conform to design requirements. As 
a result, many of the cable and wiring installations in the control panels 
of the PGCC did not conform to applicable separation criteria. The 
inspection program failed to promptly and properly identify and correct 
these separation deficiencies. (For details refer to Construction Appraisal 
Team Inspection Report 50-410/83-18.)  

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Waterford Unit 3 

During the NRC CAT inspection conducted at the Waterford Steam Electric 
Station Unit 3 in February and March 1984, it was determined that the 
implementation of the QC inspection program did not effectively identify 
electrical raceway separation deficiencies. The inspection of Class IE 
raceway installations relative to physical separation requirements had not 
been accomplished in accordance with criteria established in the inspection 
documents. Consequently, many of the raceway installations examined by the 
NRC CAT did not conform to applicable FSAR commitments in this area. (For 
details refer to Construction Appraisal Team Inspection Report 
50-382/84-07.) 

Seabrook 

The NRC CAT inspection conducted at the Seabrook Station during May 1984 
identified a number of Class 1E cable installations that, after site QC 
inspection, did not maintain the specified physical separation between 
redundant electrical divisions. Most of these deficiencies involve cable and
control panel wiring that had been transferred to "startup" jurisdiction. 
Corrective action had not been implemented because the deficiencies had not 
been properly identified. (For details refer to Construction Appraisal Team 
Inspection Report 50-443/84-07.) 

River Bend Unit 1 

During the NRC CAT inspection conducted at the River Bend Unit 1 site in 
August 1984, it was concluded that the inspection program for electrical 
raceway and cable was not fully effective. Inspection of some electrical 
raceway installations for physical separation had not been accomplished in 
accordance with criteria established in the applicable procedures. A number 
of installed electrical raceway and cable segments that did not maintain the
required separation between redundant divisions were observed by the NRC CAT
in raceway and cable that had been previously inspected by site QC 
inspection personnel. (For details refer to Construction Appraisal Team 
Inspection Report 50-458/84-23.) 

Shearon Harris Unit 1 

During the NRC CAT inspection conducted at the Shearon Harris Unit 1 site in
October 1984, the NRC CAT identified numerous installations in which the 
FSAR criteria for physical separation between Non-Class 1E and Class 1E 
raceway components were not met. Site inspection personnel did not identify 
the above separation deficiencies because design documents used for 
installation and inspection specified separation criteria that were 
different from the FSAR commitment. Thus, the identified deficiencies were 
the result of the licensee not meeting its FSAR commitments for appropriate 
analysis of changes in separation criteria as addressed in IEEE Standard 
384-74. (For details refer to Construction Appraisal Team Inspection Report 
50-400/84-41.) 

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Discussion: 

During the NRC CAT inspections completed in 1983 and 1984, electrical 
raceway and cable separation deficiencies were identified at eight sites. 
The deficiencies at seven sites were attributed to inadequate site 
inspection or an ineffective site inspection program in this area. At one 
site the deficiency pertained to a conflict between design documents used 
for installation and the FSAR commitment to conform to IEEE Standard 384-74. 
In general, IEEE Standard 384-74 provides the separation criteria for Class 
1E systems and components. Acceptable separation is achieved by safety class 
structures, distance, or barriers, or any combination thereof. Additionally, 
acceptable separation can be established by analysis as provided by IEEE 
Standard 384-74. 

Because separation deficiencies in Class 1E electrical systems, if 
uncorrected, could adversely affect operational safety, recipients of this 
notice should review the information presented to avoid similar deficiencies 
at their facilities. 

No specific action or written response is required by this information 
notice. If you have any questions about this matter, please contact the 
Regional Administrator of the appropriate NRC Regional Office or this 
office. 



                                   Edward L. Jordan, Director 
                                   Division of Emergency Preparedness 
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contact:  Roger Rohrbacher, IE 
                    (301) 492-9660 

Attachment:  List of Recently Issued IE Information Notices