IR 05000286/1986024

Insp Rept 50-286/86-24 on 861215-19.Violation Noted:Raychem Splices Identified W/Less than Required 2-inch Overlap & Bending Radii Less than Allowed

ML20211A045
Person / Time
Site:	Indian Point
Issue date:	02/09/1987
From:	Anderson C, Cheung L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210V571	List: IR 05000286/1986024 ML20210V566 ML20210V602
References
50-286-86-24, IEIN-86-003, IEIN-86-053, IEIN-86-3, IEIN-86-53, NUDOCS 8702190081
Download: ML20211A045 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-24 Docket N License No. DRP-64 Priority Category C Licensee: Power Authority of the State of New York

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Indian Point Nuclear Power Plant, Unit No. 3 P. O. Box 215 Buchanan, New York 10511

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Facility Name: Indian Point Unit 3 Inspection At: Buchanan, New York Inspection Conducted: ecember 15-19, 1986 Inspectors: 7 Leosird S. Cheung, R6 actor Engineer date Approved by: b 27 C.J/ Anderson, Chief,PlantSystems date Section, EB, DRS Inspection Summary: Inspection on December 15-19, 1986 (Inspection Report No. 50-286/86-24)

Areas Inspected: Announced inspection of Limitorque valve operator internal wiring and accessories,Raychem Cable Splices, and instrumentation cables, to determine if the licensee 1) had adequately established environmental quali-fication of these items in accordance with the requirements of 10 CFR 50.49 and 2) had adequately addressed the concerns of IE Information Notice 86-03 and IE Information Notice 86-5 Results: One violation was identified with two examples (Raychem splices with less than the required 2" overlap and bending radii less than allowed).

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DETAILS 1.0 Persons Contacted 1.1 New York Power Authority (NYPA)

C. Caputo, Supervising Engineer M. Cass, Assistant to Resident Manager

• G. Dockstader, Maintenance Electrical Engineer J. Gullick, Technical Service Engineer D. Jenny, QC Inspector

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W. Josiger, Resident Manager T. Klein, Senior Nuclear Operation & Maintenance Engineer G. Marvikis, Director, Project Engineering S. Munoz, Technical Service Superintendent F. Pindar, QA Superintendent C. Ramjohn, Plant Engineer J. Russell, Superintendent of Power R. Schimpt, Senior Operation Evaluation Engineer J. Vignola, Maintenance Superintendent S. Zulla, Vice President, Nuclear Engineering U.S. Nuclear Regulatory Commission (NRC)

• R. Barkley, Resident Inspector

• P. Koltay, Senior Resident Inspector

• denotes those persons not present at the exit meetin .0 Purpose The purpose of this inspection was 1) to evaluate the licensee's corrective actions on the Limitorque Valve actuator jumper wires resulting from IE Information Notice 86-03 " Potential Deficiencies In Environmental Qualification of Limitorque Motor Valve Operator Wiring";

2) to evaluate the licensee's corrective actions on the installation of Raychem cable splices resulting from IE Information Notice 86-53

" Improper Installation of Heat Shrinkable Tubing"; and 3) to review the licensee's qualification documents to determine the qualification status of the instrument cables manufactured by Lewis Engineering Corporatio .0 Background

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3.1 Several licensees had discovered in 1985 many Limitorque valve actuators with jumper wires different from those tested by Limitorque in its environmental qualification (EQ) program and internal wiring of the Limitorque operators that either could not be identified or qualification could not be establishe . .

On January 14, 1986, NRC issued Information Notice 86-03 to alert licensees to potential problems regarding the EQ of electrical wiring used in Limitorque valve actuators and to inform them to consider appropriate actions, if applicable, to preclude similar problems from occurring at their facilitie .2 Several licensees had discovered in 1986 that a substantial amount of Raychem cable splices installed previously at their facilities did not conform to the vendor's installation requirements in one or more of the following ways: improper diameters improper overlap length on the wire insulation use of tubing directly over the fabric cover of the wire improper bending of tubing / wires inside junction boxes On June 26, 1986, Information Notice 86-53 was issued to alert the licensee to this potential generic safety problem and to inform them to consider appropriate actions, if applicable, to prevent similar problems at their facilitie .0 Corr 9ctive Actions by Licensee 4.1 Limitorque Valve Actuators In response to NRC Information Notice (IN) 86-03, the licensee had reviewed the applicability of the IN to Indian Point Unit 3, and performed an inspection of all limitorque valve actuators requiring EQ. There are 36 limitorque valves requiring EQ inside the reactor containment and 45 valves outside. Of the 81 valve actuators 78 were found containing wires which could not be identified to be either Rockbestors Firewall SIS or Raychem Flamtrol SIS cables. These 78 valve actuators contain 336 jumper wires. One hundred seventy-four (174) wires were identified to be Rockbestors Firewall or Raychem Flamtrol. The rest (162 wires) were removed and replaced with qualified wire TheresultsofthiIinspectionweredocumentedinWorkRequestN . The inspector randomly selected the following seven inspection records from the Work Request file for review and did not identify any deficiencies:

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Inspection record for MOV-984C dated July 22, 1986

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Inspection record for M0V-880D dated July 10, 1986

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Inspection record for MOV-990A dated July 11, 1986

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Inspection record for MOV-789 dated April 29, 1986

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Inspection record for MOV-885A dated April 30, 1986

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Inspection record for MOV-888A dated April 27, 1986

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Inspection record for MOV-852A dated April 27, 1986

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The licensee stated that the original (removed) wires were sent to independent laboratories for analysis and identificatio The re-suits were documented in SE Report P804-01-2 " Evaluation of Wires Removed from Limitorque Operators Installed in Indian Point Unit N " dated September 1986. The licensee claimed that all of the re-moved cables were then identified and qualified and that the qual-ification documents are now in their EQ files. NRC will review these documents during a future inspectio .2 Raychem Cable Splices In response to Information Notice 86-53, the licensee conducted a field inspection of equipment identified in the EQ master list during the outage last summer. This inspection covered equipment both inside and outside of the reactor containment. The inspection was completed on August 29, 198 As a result of this inspection, the licensee identified six report-able deficiencies that were reported to the NRC on September 29, 1986, in LER No.86-008. The licensee also identified other non-reportable deficiencies pertaining to heat shrinkable tubing splice All of these deficiencies were either corrected (through Work Request No. 8918) or justified based on engineering evaluations. The results were documented in file .0 Physical Inspection of Limitorque Valve Actuators 5.1 Scope

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The inspector randomly selected a sample of 8 Limitorque actuators located outside the reactor containment for examination. No actua-tors inside the reactor containment were selected because of their inaccessibility during the inspection. Two of the 8 valve actuators were deactivated (electrically) and the other 6 remained activated while they were being examined. The Limitorque valve actuators selected were:

Valve N Service / location MOV-842,-843 Safety Injection mini-flow valves / safety injection pump room MOV-887A&B Safety injection pump suction isolation / safety injection pump room M0V-888A&B High head safety injection recirculation valves / pipe penetration area MOV-1852A&B Boric injection tank injection valves / safety injection pump roo .

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The covers of these 8 Limitorque actuators were removed for close examination. Items inspected for each actuator included limit switches and rotor shafts, torque switches, jumper and field wiring, terminal blocks and cable splice .2 Findings The inspector noticed that all of the control (jumper) wiring in these 8 operators were either Raychem Flamtrol cables or Rockbestos Firewall cables. However, the following findings were observed:

A) During the course of the inspection, while in the safety in-jection pump room and the pipe penetration area, the inspector identified 4 cable splices (2 in MOV-843, one each in MOV-1852A,B) with splice tubing directly over cable braidin The licensee explained that the area where these actuators are located is a mild area except for radiatio However, there was no analysis or evaluation in the EQ files to justify the quali-fication of these splices. This is an unresolved item pending NRC review of the licensee's corrective action for the quali-fication of these cable splices (50-786/86-24-01).

B) During the course of the inspection, while in the safety injection pump room, the inspector noticed a 10 point terminal block inside the actuator housing of Limitorque valve MOV-842, with power cables wired to it. This terminal block was later identified by the licensee to be a Marathon terminal block. The licensee claimed that they have qualification documents for this type of terminal blocks to show that it is qualified for the e.1vironmental conditions and service voltag C) During the course of the inspection, the inspector identified 2 black wires inside the actuator housing of MOV-1852A, that are taped together with black PVC tape. The licensee later identi-fied these wires to be heater wires, which were disconnected from service after installation. Qualification of these wires is not required. The inspection had no further questions.

t l D) The inspector observed numerous splices with white tape inside i the actuator housing of the 8 inspected limitorque valves. The

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licensee stated that these splices are made of scotch tape which had been tested and qualified, and that the qualification documents are in the EQ files.

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6 g-6.0 Physical Inspection of Raychem Cable Splices y 6.1 Scope The inspector randomly selected 24 Raychem cable splices associated '

with 12 pressure transmitters (PT-948 A,B,C, and PT-949A,B,C,' con-tainment pressure transmitters located in the Pipe Penetration Area in the Auxiliary Building; PT-419A,B,C, and PT-429A,B,C, main steam s pressure transmitters located in the Auxiliary Feedwater Pump room).

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The original cables and splices for these transmitters were identi-fied by the licensee, in the inspection effort described in para-graph 4.2, to be of unknown qualification status. These splices were replaced in August 1986, per work request No. 8918, with Rock ' -

bestos Firewall III wires and Raychem WCSF-N cable splices. The

, Raychem cable splices are located inside condulets near the trans-mitter The condulet covers were removed for close examinatio The inspector observed the installed condition of these cable splices. This included flexing of splices, bend radius, seal length, and tubing diameters. The following deficiencies were identifie .2 Findings A) Cable Splice Sealing Length The inspector noticed that parts of the Raychem splices asso-ciated with transmitters PT-419A,B,C and PT-429A,B,C, were inside the electrical conduit, therefore the sealing. lengths for these splices could not be measured. However, while in the Pipe i Penetration area, the inspector identified four splices (the black cables for PT-948B, the black cable for PT-949B, the black and white cables for PT-949A) with seal lengths (overlapping cable insulation) less than 2 inches. This is contrary to the installation instructions prescribed in Work Request ho. 8918 dated August 27, 1986. Step #7 of the instruction states that

" Shrink tubing on splice connection making sure that the minimum covering on insulation is at least 2 inches". The installation record indicated that these splices were installed on August 30, 1986 and inspected by the QC inspector on August 31, 198 This is a violation of 10 CFR 50, Appendix B, Criterion V which states in part " Activities affecting quality shall be prescribed by documented instructions, .... and shall be accomplished in accordance with the instruction ...." (50-286/86-24-02)

B) Minimum Bending Radius Raychem Installation instruction for WCSF-N splices requires the minimum bending radius of in-line tube splices to be 5 times the outside diameter. 10 CFR 50 Appendix 8, Criterion V

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states in part that " Activities affecting quality shall be prescribed by documented instruction, procedures .... and shall be accomplished in accordance with these instructions...."

Contrary to the above on December 17, 1986, the insr?ctor identified that 1) the installation instruction usc! by the licensee to install Raychem WCSF-N splices does not prescribe the minimum bending radius requirement, and 2) there are three in-line cable splices (one for transmitter PT-948C and two for PT-948A) that are bent with a radius much less than 5 outside diameter This is a violatio (50-286/86-24-03).

C) Corrective Actions by the Licensee Upon notification of the findings described in paragraphs A and B above, the licensee performed evaluations on December 19, 1986, the safety impact of the potentially defective Raychem splices. The inspector agreed that the areas where the splices are located is not subject to a steam and high temperature /

pressure environment. Therefore, environmental qualification can be achieved by analyse D) Installation / Inspection Procedures Currently, the licensua does not have procedures for the in-stallation and inspection of Raychem WCSF-N splices. The licensee's craftsmen installed the splices using the instruction steps outlined in the individual maintenance /QA work step lis The inspector reviewed the installation instruction (WR No. 8918 for PI-948A, B, C and PT-949A, B, C) dated August 27, 1986 and determined that these instructions did not contain adequate elements as required by the manufacturer (e.g. the minimum bending radius requirements). Furthermore, some parts of this instruction were confusing (e.g. step #5 " cut heat shrink such that the minimum length to cover the conductor will be 2" on each side of the splice"). Since these Raychem cable splices were procured in " kit" form, cutting may not be required. These instructions could cause incorrect installation of the Raychem splice The licensee stated that they were in t.he process of developing Raychem splices installation / inspection procedures for instru-ment cables and for power cable They expect that these procedures will be completed and issued before the end of January 1987. This item is unresolved pending NRC's review of the licensee's finalized installation / inspection procedures (50-286/86-24-04).

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7.0 Detailed Review of the Raychem Splices EQ File

, The inspector reviewed the EQ file for Raychem WCSF-N cable splices

(EQ-SE-16.01.01) to ascertain whether the files contained sufficient evidence that the Raychem Splices used at Indian Point Unit 3 are qualified for the environmental conditions in which they must operate, and that the qualification documents in the file were auditabl .1 Documents reviewed in this determination included

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, (a) Wyle Lab Test Report No. 58442-1 "EQ test of,Raychem WCSF- nuclear in-line cable assemblies for Raychem Corporation" dated

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May 15, 1980

(b) Wyle Lab Test Report No. 58442-2 "EQ test report of Raychem nuclear cable breakout and sealing kits for Raychem Corporatio (c) SCEW sheet for Raychem Model WCSF-N splices, dated December 15, 198 (d) Franklin Institute Research Laboratories report F-C4033-1 " Test of Raychem Flamtrol insulated and jacketed electrical cables under simultaneous exposure to heat, Gamma radiation, steam and chemical spray while electrically energized" dated January 197 "' (e) Wyle Report No. 48485 " Nuclear environmental assessment report on Raychem Splices with 1/8" Overlaps for use in Indian Point

Unit 3" dated September 25, 198 .

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7.2 Finding The licensee attempted to qualify the Raychem splices with less than 2" overlaps using Wyle Report No. 48485. However this report indicates that no insulation resistance were measured for the test samples during the simulated LOCA tes Insulation resistance measurement is tacc tant to cables used for nuclear plant transmitter Sma:1 e ate currents (e.g.10 ma) may

not be able to be detected by th, .e n .;trumente in the test setup l described in the report. However, with this leakage current applied to the transmitter current loop, (typically 4-20 ma), unacceptable error may be produce The licen:,ae stated that they would contact Wyle to obtain a i

satisfactory resolution of this issue. -This item is unresolved pending NRC' review of the licensee's corrective action to provide i supportive documents for the qualification of Raychem cable splices l with less' than 2" overlaps (50-286/86-24-05).

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E 8.0 Personnel Training on Raychem Splices On October 29, 1986, a Raychem Splice seminar was given by Raychem per-sonnel to four NYPA personnel (assistant plant engineer, maintenance supervisor, QA engineer, and the training specialist). In house training sessions on Raychem Splices were given to the craftsmen and QA/QC per-sonnel on August 22, 28, and 29, 1986. The attendance sheets indicated that six QA/QC personnel and 28 craftsmen received the training. Training materials were based on Raychem Instruction on WCSF-N Splices. The in-I spector reviewed the training record and identified no deficiencie However, based on the findings described in paragraph 6.2, additional training (especially hands-on type training) may be desirable for the craftsmen and QA/QC inspectors to minimize the possibility of incorrect installation .0 Qualification Status of Instrument Cable Manufactured by Lewis Engineering Corporation An EQ test was conducted by Wyle Laboratory in June, 1986 on instrumenta-tion cables removed from inside the reactor containments of Indian Point Units 2 and 3. These samples had been installed for an average of 10 years. The cables were manufactured by Lewis Engineering Corporatio The results of the test were documented in Schneider Engineering report N P804-04-1. The inspector reviewed pertinent qualification documents to ascertain whether the Lewis cables are qualified for the environmental conditions in which they must operate. The following documents were reviewed:

1) Schenider Engineers report No. P804-04-1 " Test report for EQ of Lewis Engineering 2 of 4 conductor 16 AWG, silicone rubber insulated cables" dated November 198 ) Wyle test report No. 48339-1 " Nuclear EQ of 2 conductor and 4 conductor 16 AWG SR insulated cables for IP2 and IP3" dated June 4, 198 ) SCE report No. P803-09-2 " Test procedure for qualification test of Lewis Engineering electrical cables for IP2&3 Nuclear Power Plants",

Revision 1 dated June 20, 1986.

l The test results indicate that the minimum insulation resistance is 1 x l 107 ohms at 150 VDC measured at 6h minutes into the simulated LOCA tes The inspector had no additional concerns regarding the EQ type of cable type. Unresolved item 50-286/86-13-01 is considered close .0 Unresolved Items Unresolved items are matters which more information is required in order to ascertain whether they are acceptable items, or violation Unresolved items identified during this inspection are discussed in Details, paragraphs 5.2, 6.2 and 7.2.

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11.0 Exit Meeting The inspector met with licensee and construction representatives (denoted in paragraph 1.0) at the conclusion of the inspection on December 19, 1986 at the plant sit The inspector summarized the scope of the inspection, the inspection findings and confirmed with the licensee that the documents reviewed by the inspector did not contain any proprietary information. The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary informatio At no time during this inspection was written material provided to the licensee.

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