IR 05000395/1987030

Insp Rept 50-395/87-30 on 871020-30.Violations Noted.Major Areas Inspected:Followup on Environ Qualification Deficiencies Involving V-stub Taped Splices Used for Various Components

ML20236R462
Person / Time
Site:	Summer
Issue date:	11/12/1987
From:	Conlon T, Paulk C, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236R416	List: IR 05000395/1987030 ML20236R415
References
50-395-87-30, IEIN-86-053, IEIN-86-53, NUDOCS 8711230295
Download: ML20236R462 (7)

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o UNITED STATES '

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o NUCLEAR REGULATORY COMMISSION .

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j 101 MARIETTA STREET, j

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Report No.: 50-395/87-30 i Licensee: South Carolina Electric and Gas Company Columbia, SC' 29218

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q Docket No.: - '50-395 License'No.: NPF-12 f I

Facility Name: Summer Inspection-Conducted: October 20-23, 1987-

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Inspectors: N //-- i o - %

C.7m7tti Date Signed

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C. Pplk Date Signed Accompanying Personne - W. Lev

! Approved by:

T. E. Conlon, Chief

_f6777 /m //- / 2 - f7 Date Signed Plant Systems Section LDivision of Reactor Safety

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SUMMARY Scope: This special, announced inspection.was conducted to followup on EQ deficiencies involving V-stub taped splices used for various component Results: Two violations were identified: Improper Installation of Raychem .l Splices / Sleeves, and V Stub Taped Splices Not Environmentally Qualifie l

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REPORT DETAILS Persons Contacted Licensee Employees

• D. Nauman, Vice President, Nuclear Operations D. Bradham, Director Nuclear Plant Operations

• R. Waselus, Supervisor Electrical Engineering

• J. Skolds, Deputy Director - Operations and Maintenance

• J. Wactor, Nuclear Engineering

• J. Nesbitt, Electrical Maintenance Supervisor

• S. Carroll, Nuclear Engineering

• G. Moaffatt, Associate Manager, Nuclear Engineering

• Frady, Associate Manager, Quality Assurance

• D. Moore, Quality Assurance and Procurement

• Paglia, Manager, Nuclear Licensing

• Leach, Manager, Quality Assurance

• Hunt, Manager Nuclear Quality Control

• Donnely, Nuclear Licensing

• Higgins, Associate Manager, Regulatory Compliance

• Browne, Group Manager, Technical and Support Services

• Koon, Manager, Technical Support

• Quinton, Manager, Maintenance Services

• Parsons, Independent Safety and Evaluation Group Engineer T. Curtin, Instrumentation and Control Supervisor, Nuclear Engineering G. Soult, Operations Manager C. Osier, Associate Manager, Maintenance Engineering C. McKinney, Licensing Specialist, Nuclear Licensing M. Garrett, Supervisor, Quality Assurance R. Collins, Nuclear Quality Control Inspector S. Crumbo, Senior Quality Engineer, Material and Procurement Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne ,

NRC Resident Inspectors R. Prevatte, Senior Resident Inspector i

• P. Hopkins, Resident Inspector

• Attended exit interview

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2. Exit Interview The inspection scope and findings were sunmarized on October,23,1987, with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee. ' The following new items were identified during this inspection: Violation 50-395/87-30-01, Improper Installation of Raychem Splices /

Sleeves, paragraph Violation 50-395/87-30-02, V-stub Taped Splices Not Environmentally Qualified, paragraph 5.b.

h Unresolved Item 50-395/87-30-03, Ambient Temperature Greater Than Design, paragraph The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspectio A telephone conversation was held with licensee management on October 28, 1987, to discuss NRC concerns in connection with the identified unresolved item. Licensee management committed during this conversation to provide a written response regarding corrective actions planned or taken to resolve this deficienc . Licensee Action on Previous Enforcement Matters See paragraph 5 for more ir. formation on previously identified enforcement matte . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve a violation or deviation. One unresolved item identified during this inspection is discussed in paragraph . Followup on Identified EQ Splice Problems Pursuant to information provided by the Senior Resident Inspector on October 9, 1987, licensee management contacted Alabama Power Company concerning the use of unqualified taped slices at Farley nuclear statio They were informed that the concerns involved V-stub configurations made up of Okonite T-95 tape with T-35 overlay. These taped splices were used on 4160V, 600V and 125V DC application During the week of October 12, 1987, licensee management took various actions regarding the use of taped splices at Summer. They determined from research that a straight in-line configuration using Okonite T-95 with T-35 overlay is used for 8 KV power cables only. This configuration

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is qualified per the EQ. Report and is in.accordance with design details depicted on drawing S-200-912, Construction Guidelines for Cable Installation. Additional research revealed that 600V or 125V DC cable terminations may be made by use of either Raychem heat-shrink kits or

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Kerite taped splices. A V-stub taped splice is permitted per drawing S-200-912. However, further research revealed that the Kerite report on cable splices did not address this configuration, and an EQ test was never performed by the. vendor for V-stub taped splice Licensee management subsequently determined the scope of the problem by review of the " CHAMPS" computer printout of taped connections in the plant. This printout listed a total of 29 components having taped splices which require replacement every 10 years. Additionally, review of the implementing procedure EMP 405.003 revealed that the instruction.did not provide for taping within the crotch of .the V-stub splices. Walkdown of equipment outside the reactor building was, therefore, initiated to -

determine the taped configuration that existed in the fiel Inspection of the RHR Room Cooling Fan motor equipment number XFN0046A-M identified V-stub taped spliced terminated in accordance with EMP 405.003. Corrective action.in the form of Nonconformance Notice. Number 2852 was prepared and additional walkdown of various equipment was, performed for identification and correction of the deficient taped splice NRC Region 11 performed a reactive inspection October '20-23,1987, to followup' on deficient V-stub splices identified by the license An assessment of the scope 'of the problem was performed by review of Engineering Change Notice (ECN) Number 1775 This design change impacted various electrical systems. It was implemented -for low voltage Kerite power cable terminations outside the reactor building to ensure that the-taped connections would be qualified for High Energy Line Break -(HELB)

environment, and environment where the total integrated dose exceeds 105 Rad An additional deficiency concerning the qualified 40 year life of Kerite power cable taped connections used insi_de the reactor building was also addressed by this ECN. Attachments to the ECN, ie List Nos. I and 2 identified the inside and outside containment power cable splices that were within the scope of the design chang The inspectors determined that power cable splices within the containment (List No. 2) were not replaced by ECN No. 1775E. A surveillance program was proposed to replace these cable splices on a specified frequenc This is the CHAMPS program the licensee has previously used to determine the scope of the problem. A comparison of the equipment listed on the CHAMPS printout and equipment' contained in List 2 was performed and the results were acceptable. From further review of ECN Nos. 1760, 1768 FM, and 1830, the inspectors determined the use of V-stub taped splices to be restricted to low power cable terminations. -The team concluded that the use of unqualified V-stub taped splices appears to be isolated to the equipment previously identified by the' licensee. Walkdown of equipment

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was also performed by th.e inspectors to provide some degree of assurance l that the scope -of the problem was as determined by the . license l Deficiencies, unrelated to the V-stub splices, identified during these walkdowns are addressed elsewhere in this repor An inspection of personnel training provided QC inspections and electrical craft workers was performed. Based on review of training records and interviews-with licensee personnel, it appears that personnel training in low voltage termination / splices was inadequate during the time frame' the V-stub splices were being installed. A generic problem with EQ training

- l was identified by the licensee for personnel involved in the EQ program i and is documented in Audit Report No. CGS 2-0468-QA, dated July 3, 198 Corrective action plans developed to specifically address this concern for QC inspectors, and electrical craft workers were reviewed and determined !

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Specific concerns identified by the inspection team and which were discussed at the exit interview are described belo While performing walkdowns of condulets and junction boxes to obtain sample data to confirm that no tape splices existed except as noted

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by the CHAMPS search, a Raychem splice was found by the inspectors- i with a bend radius that exceed five times.the outside diameter of the installed sleev This was the- only installation deficiency '

identified out of approximately five items looked a Also, an inspection of the A RHR pump re-taping by the inspectors identified

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Raychem sleeves that were not properly shrun Both of these are examples of non-compliance with procedures, inadequate QC inspection, and inadequate response to-Information ,

Notice 86-53. Both conditions also existed-prior to the November 30, 1985, deadline for compliance with 10 CFR 50.4 The splice / sleeve

) I configurations were not in accordance with the tested configuration, I however, they were qualified for their designed functio The response to Information Notice 86-53 stated: "It appears that-the problems addressed in the IEN resulted from a lack of procedural l

guidance, training, and QC coverage... All of these areas were positively addressed from plant construction through plant operation l at VCS." It took approximately six months to issue this response and no walkdowns of splices were performed nor were planned to be performed as a result of the evaluation. The response was not timely nor adequate in that improper splices were found by the inspectors

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with minimal effor The sleeve on the RHR motor was found to have been installed.in 1982 and the motor had been worked on several times during the following five years without anyone noticing the improper sealing. The splice on the solenoid was made in November 1985, and was verified to be in accordance with the procedure by the same person who' verified the

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sleeve installation for the RHR motor. These examples indicate that walkdowns of. environmentally qualified equipment were either not performed, or were not adequately performe These are identified as Violation 50-395/87-30-01,- Improper Installation of Raychem Splices / Sleeve b. During. the course of the' inspection, the team reviewed existing qualification documentation on tape splices used at V. C. Summe Specifically, file EQF-CA7-K03-0682 for Kerite- Tape Splice, Type S-2NS-NUC, was reviewe This file established.the qualification of-an in-line tape splice for a 10 year ' qualified life constructed .in accordance with Kerite drawing S-2NS-NUC. The qualification was based on similarity to Kerite splice S-5NS-NUC which was successfully tested by Kerite on a single conductor #6AWG 5KV non-shielded power cable. The original file did not specifically authorize the use of a V-stub configuratio It was noted, however, that the latest -

revision to the file, dated 10/13/87, allowed.the use of a V-stub configuration provided that the crotch area of the splice was sealed with insulating tape for a minimum of 2" from any exposed conductor The plant procedures which provided the installation details for the tape splices,. namely the construction drawings and electrical maintenance termination procedures, allowed an end to end (V stub)

splice in confined areas where there was insufficient _ room for an in-line splic The drawings and procedure, however, did not specifically state to seal the crotch are The omission of this detail resulted in the splice being installed in an unqualified configuratio When this condition was noted by the licensee, l affected components were identified, a Justification for Continued Operation (JCO) was prepared and immediate corrective action was undertaken to correct the nonconforming condition. The JC0 addressed the specific operating requirements of the nonconforming components and referenced other industry tests where similar type splices were tested. The team concluded, after reviewing the JC0 and othe ,

information provided by the licensee, that the splices as installed I were qualifiable based on the following: '

Test reports of specific materials used in V. C. Summer splices

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9ther tests performed on similarly configured splices Actual verification of installed splices Quality controls in effect during splice installation

Although the splices were determined to be qualifiable, the fact that they existed in an unqualified conf 4uration after the November 30, 1985 deadline constitutes a violation of 10 CFR 50.49. This is Violation 50-395/87-30-02, V-stub Ta:>e Splices Not Environmentally j Qualifie i

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c. During a walkdown of selected plant equipment verifying adequate terminations, the team noted that the ambient temperature in the West Penetration Area, Elevation 436', appeared to be higher than the 104 F maximum temperature specified in the FSAR for this locatio When the licensee measured the ambient temperature in this area, a value of 118 F was noted. .In addition, a local temperature of 146 F was measured near a main steam line which contained some equipment such as solenoid valves and limit switches that were required to be environmentally qualified. The team was concerned that this increase in temperature, both ambient and localized, from the original design were not accounted for in determining .the qualified life of EQ equipment located in this area. The team also questioned what other areas experienced similar conditions and what equipment was affecte This item was left as Unresolved Item 50-395/87-30-03, Ambient Temperatures Greater Than Design.

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