IR 05000423/1988004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-423/88-04 Re Heat Shrink Tubing Over Braided Cable Jacketing.Response Re Other Raychem Installations at Plant Needs Clarification

ML20205N658
Person / Time
Site:	Millstone
Issue date:	10/24/1988
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mroczka E NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 8811040264
Download: ML20205N658 (4)

Text

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OCT 2 41988 . Docket No. 50-423 Northeast Nuclear Energy Company ATTN: Mr. E. J. Mroczka i Senior Vice President- Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen: Subject: Inspection No. 50-423/88-04 This refers to your letter dated August 1,1988, in response to our letter dated June 6, 1988.

' Thank you for informing us of the corrective and preventive actions, documented in your letter to resolve Violation 50-423/88-04-06 relating to heat shrink  ! tubing over braided cable jacketing, j Your response to statements in inspection report E0-423 regarding other Raychem l installations at Millstone 3 with bend radius or splice seal length deficiencies needs clarification. We discussed the bend radius deficiencies with your staff in a telephone conversattor on October 13, 1988. We understand that your installation specification E-350 and installation instructions PII-57100-A did not include explicit guidance regarding Raychem splice bend radius limits.

However, we understand that these documents did reference a Raychem document that did specify limits on splice bend radius. This infcrmation was available before the splices were installed at Millstone 3 in January 1986. With regard to our statements regarding deficient splice seal lengths with teal lengths less than two inches, we understand that your staff's review of this issue did not identify any instances at Millstone 3 where kaychem splices were installed with less than a 2-inch seal length.

We request that you respond to this letter. Your response should address I corrective steps to addrass Raychem splice bend radius deficiencies at - Millstone 3; corrective steps to avoid further bend radius deficiencies and the date when bend radius deficiencies will be corrected.

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OFFICIAL RECORD COPY RL MILL 3 88-04 - 0001.0.0 g

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.  . OCT 8 419?3 Northeast Nuclear Energy Company -2-Your cooperation with us is appreciated.

Sincerely, Crigiral Cicntd Eyt Clifford J. A lercon Thomas T. Martin, Director Division of Reactor Safety Enclosure: Application Guide cc w/ enc 1: W. D. Romberg, Vice President, Nuclear Operations D. O. Nordquist, Director of Quality Services R. M. Kacich, Manager, Generation Facilities Licensing S. E. Jcace, Station Superintendent Public Document Room (POR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Senior Resident Inspec. tor State of Connecticut bec w/ enc 1: Region I Docket Room (with concurrences) M=;==t ^.::iztut, DPE(v/c encl)- DRP Section Chief S. Pindale, RI, Beaver Valley W. Raymond, SRI, Millstone 1&2 D. Jaffe, LPM, NRR R. Bores, DRSS

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C Iq Cf Q RI:DRS RI:DRh RI:DRS Paolino Anderson Durr 10/ft/88 10/If/88 10N/88 0FFICIAL RECORD COPY RL MILL 3 88-04 - 0001.0.1 10/18/88

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WCSF-N Application

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3.3.3 CLEAN AND DEGREASE cable jacket and wire moulatert with a solvent (such as b V t t.1 trichloroethane) whch is approved by the cable matlufacturer. All surf aces must be free of grease, oils, moisture or other contaminaats proof to being brought into contact with Psychem products.

Cable preparaton kits are avadable from Raychem: Kit No. CPK-0140 (contains 6 solvent wipes and I abrasive cloth).

' 3.4 Detail inetsNetion instructione 3.4.1 When shims are required (refer to Section 2.4). INSTALL SHIMS on the wire.

Abgn to within %" of the insulation (or jacket) cutback. SHRINK IN PLACE.

3.4.3 SUDE THE SPLICE SEALING SLEEVE over enhor wire to be sphced. DO NOT SHRINK. If a bolt pad is required (refer to Section 2.3.3) side bolt pad over enhor wire to be sphced. DO NOT SHRINK.

3.4.3 MAKE CONDUCTOR CONNECTIONS. Examine each connection area for sharp edges or protrudog wire strands. Remove these with an abrasive cloth or file.

3.4.4 When bott pad is required. CENTER THE BOLT PAD over the connecton area.

SHRINK IN PLACE.

3.4.5 CENTER THE SPLICE SEALING SLEEVE over the connecten area. Where shims are used, it must overlap the outer shim. SHRINK IN PLACE.

3.4.6 DO NOT FLEX spbce untd comfortable to touch. It may then be formed to a max-imum five times the outside diameter bend radius. DO NOT VIOLATE CABLE SEND RADIUS.

4.0 inopoetion of installation Tubing is "funy recovered" when both of the following critena are met: 1. O tter surface is smooth and has a glossy appearance.

2. Inere is a visible flow of adhesive at each end of the tubing. (The outer sleeve is not required to shrink down to the cable or enNbit adhesive flow where it overtaps a shim ) 4.1 Overheating Overheatmg of the tubing must ce avoided. This is evidenced by scorching or bhstering on the surface. Any minor surface scorching that can be removed by solvtfit cleaning is acceptable. Tubing wah deep blistereg must be replaced.

4.3 Underheating WCSF N tubing which has a lumpy appearance not conforming to the substrate of has a dut surf ace has not been heated sufficiently. Underheatog can be cot-rected at any twne by reheating and contmuing the thrmking process.

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    [[mTIcfm'o'. CONNECTICUT 061410 non us-sooo August 1, 1988 Q1cket No. SQ !?]

6911kB Re: 10 CFR 50.49 Mr. William V. Johnston, Acting Director Division of Reactor Safety U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Dear Mr. Johnston:

Millstone Nuclear Power Station, Unit No. 3 Response to Notice of Violation inspection Report No. 50-423/88 04 1. INTRODUCTION By letter dated July 6,1988, the NRC transmitted its Inspection Report No. 50-423/88 04 and associated Notice of Violation relating to the Region I Staff's announced inspection of March 14-18, 1988, of Millstone Nuclear Power Station, Unit No. 3. In its letter the Staff identified one Severity Level IV violation, four sotential violations, and three unresolved items. The Staff requestec that Northeast Nuclear Energy Company (NNECO) respond to the Notice of Violation within 30 days of the date of the Inspection Report. In addition, the Staff requested NNECO to attend an enforcement conference to discuss the four potential viola-tions. This enforcement conference was held on July 20, 1988. At this meeting, NNECO provided information regarding the potential violation pertaining to Raychem splices. At the conclusion of this portion of our presentation, the Staff suggested that NNECO include that information when responding to the subject Notice of Violation. By this letter, NNECO responds to the Notice of Violation and the potential violation regarding Raychem splices.

II. EEt0][$PONSE TO V10L41103 . NNEr0's response to the Severity Level IV violation identified by the Staff is set forth below:

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A. Staff Statement of the Vigttlig.n

 "10 CFR 50.49, paragraph (f), requires that electrical equipment important to safety must be qualified by test and/or analysis, dU Q b50"I 6fY'

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Mr. William A07358/Page 2 August 1, 1988 i Contrary to the above, on March 18, 1988, the NRC identified Raychem cable splices installed in safety related EQ equipment that did not meet the requirements in that the heat shrink tubing was applied over braided cable jacketing. This was not a qualified configura-tion prior to the time of new test data, dated March 1987, which determined the splices were qualified.

This is a Severity Level IV violation, Supplement I."

B. NNECO Statement of Position NNECO does not contest the Notice of Violation as stated and accordingly admits there was insufficient documentation in the files to support the installation of Raychem splice over braided cable jacketing prior to March 1987.

C. Root Cause Craft personnel failed to follow the specified vendor product installation procedure during installation of these Raychem splices.

D. Corrective Steos Tilta

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This installation was discovered on March 16, 1988, during the plant walkdown phase of Inspection No. 50 423/88 04. Qualification of this configuration was previously demonstrated by test in March 1987. This test data had been evaluated and included in the i Millstone Unit No. 3 Raychem qualification file prior to the inspec-I tion.

E. (orrective Actions to Prevent Recurrence The following corrective actions have been implemented

. 1. Craft personnel have received additional training to emphasir i the importance of following all specified procedures during d component installations, p 2. Craf t, inspection, supervisory, and engineering personnel have received specific Raychem installation training conducted by qualified Raychem Corporation representatives.

F. Due for Full Como11an_tt

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Full compitance was achieved in March 1987. Pursuant to the requirements of 10 CFR 50.49, paragraph (f), this Raychem configura-tion was qualified by test as of that time.

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Mr. William V. Johnsten A07358/Page 3 August 1, 1988 III. RELATED POTENTIAL VIOLATION 88 04 06 j A. Statement of the Issue

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NRC Inspection Report Issue 50 423/88 04 06 states, "a review of j ' licensee walkdown records for Raychem splices indicate (s) additional i' nonconforming conditions involving excessive splice bends (less than u the recommended 5X outside cable di meter) and splice seal length

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areas of less than 2 inches." Accorjing to the Staff, these def t-ciencies constitute a potential violation of 10 CFR 50.49 in that

x the splices were not qualified per the instruction procedures in effect at the time of the installation.

, [ 8. hNECO Position Regardina the Existence of a Violation 1 NNECO does not agree with the Staff's conclusions that installation V of Raychem splices with a bend radius less than SX the outside cable f diameter was contradictory to the Raychem procedure / instructions existing at that time. NNECO followed existing procedures with regard to these installations at the time the plant went into operation.

. NNECO also does not agree that the Millstone Unit No. 3 walkdown records indicate that the Raychem installation had splice lengths of s less than two inches.

s C. fltsis for Denyino that a Deficiency Existed

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[ The original installation of the splices was made in accordance with Millstone Unit No. 3 Electrical Installation Specification No. E-350. This procedure stated that Raychem installation instructions shall be in accordance with Raychem's "Product Installation and Inspection Guide WrSF N Heavy Wall, Flame Retarded Nuclear Cable Sleeves" (Pil-57100 A) and installation instructions provided with each kit. E 350 also states that

  \ Quality Control personnel shall verify (in accordance with l

s specifications) that proper Raychem components are used,

  - manufacturer's installation instructions have been followed,
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and an acceptable splice has been made.

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  , During the time at which Raychem Product Guide PII 57100 A
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   (November 1982) was in effect, Raychem did not specify bend radius acceptance criteris. Accordingly, contrary to the inspection report findings, the Raychem installations were made J' ,   in accordance with procedures in existence at that time. Upon l \.' issuance of NRC Information Notice 86 53 (June 26, 1986), NNECO pj gjf,3  a %u 7hd
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Mr. William A07358/Page 4 August 1, 1988 took reasonable and prudent actions to address the issue. Bend radius criteria were first published in PII-57100 D (November 1987). 4 g?7 2. Seal Lenath Contrary to the NRC inspection report, NNE W s review of walkdown records does not reveal any instances whera Raychem splices with less than 2 inch seal lengths ex t!;t. NNECO Quality Control personnel witnessed the installation of some of  ; the splices and did not note any such deficiencies in seal length. NNECO had no other indications that such deficiencies in seal length exist. Therefore, NNECO denies that the alleged deficiency in seal length existed. It should be noted that after issuance of Information Notice 86-53, in which this issue  ; was raised, NNECO took reasonable and prudent actions to address it. * D. Safety Sianificance These issues have no safety significance because the March 1987 testing has established that a bend radius much less than 5X the outside diameter and seal lengths much less than 2 inches are qualified configurations. Accordingly, no replacements or modifica- < tions of the components were required to establish or maintain qualification.

E. Other Factors that Should Be Considered 1. Notwithstanding the final determination regarding the existence of a violation, craft personnel have received additional training to emphasize the importance of following procedures I during component installations.

2. In addition to the above, specific Raychem training was provided by Raychem personnel to ensure that installations were correct.

3. The EQ file was revised prior to the inspection to include test data (dated March 1987) that confirms the qualification of Raychem splices less than a 2 inch seal length and bends of less than 5X the outside diameter of the cable. The Staff has . concurred with the acceptability of the March 1987 report to  !

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further establish qualification. (See Inspection l Report 50 423/88 04 at p. 21.) i

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Mr. William A07358/Page 5 August 1, 1988 If you have questions regarding the information contained in this letter, please contact us.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY d MroczkV Se for Vice President cc: W. T. Russell, Region I Administrator D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 W. J. Raymond, Senior Resident inspector, Millstone Unit Nos. 1, 2, and 3 U.S. Nuclear Regulatory Comission Document Control Desk Washington, D.C. 20555 STATE OF CONNECTICUT ss. Berlin COUNTY OF HARTFORD Then personally appeared before me E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensee herein, and that the statements contained in said information are true and correct to the best of d his knowledge and belief.

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