IR 05000456/1987019

Insp Repts 50-456/87-19 & 50-457/87-17 on 870521-0723.No Violations or Deviations Noted.Major Areas Inspected: Licensee Action on Previously Identified Items & Activities Re Review of Allegations & QA Implementing Procedures

ML20236L400
Person / Time
Site:	Braidwood
Issue date:	08/05/1987
From:	Gardner R, Westberg R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236L343	List: IR 05000456/1987019 ML20236L339
References
50-456-87-19, 50-457-87-17, NUDOCS 8708100238
Download: ML20236L400 (10)

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U.S. NUCLEAR REGULATORY COMMISSION l l

REGION III

Reports No. 50-456/87019(DRS); 50-457/87017(DRS)  ;

Docket Nos. 50-456; 50-457 License No. NPF-72 Construction Permit No. CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: May 21 through July 23, 1987

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Inspector: Rolf A. Westberg 8'[6 f 8'7 Date W'M\ $PvW glgl3y Approved By: Ronald N. Gardner, Chief Plant Systems Section Date

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Inspection Summary l Inspection on May 21 through July 23, 1987 (Reports No. 50-456/87019(DRS);

50-457/87017(DRS))

Areas Inspected: Special unannounced inspection of licensee action on ]

previously identified items (92702) and activities with regard to review '

of allegations and resultant review of QA implementing procedures (51061B)

and quality records (51065B).

Results: No violations or deviations were identified. One previously i identified item was close i I

8708100238 070805 PDR ADOCK 05000456 G PDR

DETAILS l

1. Persons Contacted Commonwealth Edison Company (CECO)

• E. Fitzpatrick, Station Manager

• L. E. Davis, Assistant Superintendent, Technical Services

• M. Orlov, Staff Assistant to Project Manager

• E. Lohman, Project Startup Superintendent

• D. Paquette, Maintenance Assistant Superintendent

• E. L. Martin, Quality Assurance Superintendent

• P. Barnes, Regulatory Assurance Supervisor

• L. W. Raney, Nuclear Safety Supervisor

• E. R. Netzel, Quality Assurance Supervisor

• R. E. Aker, Rad Chem Supervisor

• T. W. Simpkin, Operating Experience Group

• C. Bedford, Regulatory Assurance

• R. Mertogul, Systems Supervisor

• R. Kyrouac, Quality Assurance Supervisor

• L. Kline, Regulatory Assurance Industry Group

• r. J. Ungeran, Unit One Operating Engineer

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.. O'Brien, Tech Staff The inspector also contacted and interviewed other licensee and contractor personnel during this inspectio J

• Indicates those attending the exit meeting on July 23, 1987. }

l, 2. Licensee Action on Previous Inspection Findings <

(Closed) Violation (457/84040-06): Inspection program contains insufficient electrical separation acceptance criteria to verify that design requirements -

had been met (CAT Item Section IIB.1.B(1)). This item was previously reviewed and closed for Unit 1. The review was also applicable for Unit 2. See Inspection Report No. 456/86017(DRS); No. 457/86012(DRS) j for detail q 3. Allegation Followup f (0 pen) RIII-87-A-0019: On February 27, 1987, a former employee I of the L.K. Comstock Company (LKC) telephoned the Region III office j with a multiple part allegation concerning problems with the pulling j of Cable No. IVA-019, i

(1) The following technical concerns were identified: [

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(a) The cable jacket was damaged during the cable pulling prrcess when the sidewall pressure was exceede (b) The sidewall pressure was exceeded because no sidewall pressure calculations were done before the cable pul (c) The dynamometer was rigged wrong as the sheave was supported by ties in two direction (d) A Nonconformance Report (NCR) was written and dispositioned "use-as-is."

(e) The alleger opined that the cable should be replaced as !

it will blow and take the other cables with it, but LKC l did not want to go to the expense of replacing the cable The purpose of this report is to review the allegers technical concerns onl (2) Relative to the alleger's concerns, the inspector reviewed the following document (a) LKC Procedures l No. 4.3.8, " Cable Installation," Revision . No. 4.8.8, " Cable Inspection," Revision . No. 4.11.1, " Nonconforming Items," Revision (b) CECO Quality Procedure No. 15-1, " Reporting Quality l Nonconformances During Construction and Test," l Revision 1 l (c) LKC Nonconformance Reports No. 547 . No. 540 . No. 5548.

l (d) CECO Nonconformance Report No. 87 (e) Cable Inspection Packages for Cables IVA009, IVA019, IVA029, IVA030, and IVA12 (3) Allegation Review The cable identified by the alleger was one of five cables installed in Conduit No. C0A8541 (5" diameter). The five cables in this conduit were 1VA009, IVA019, IVA029, IVA030,

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and IVA12 Interviews with personnel involved with the cable l installation indicated that IVA019 was hand pushed; however,

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the documentation was lost. This resulted in LKC NCR No. 540 Cables IVA009 and IVA124 were also hand pushed. Cable 1VA030 was hand pulled using pull links that break before the cables sidewall pressure is exceeded. Cable 1VA029 was started as a hand pull with pull links, but when it got stuck in the conduit, the pull was completed as a power pull using a tugger and a dynamometer. As a result of a " Quality First" concern, NCR No. 5470 was generated on the IVA029 cable pull. The NCR was due to procedural violation which occurred when a smaller than specified sheave was used while pulling the cable without requesting a new pulling calculation card. Subsequent to the closing of NCR 5470, when a new cable pulling calculation was performed for the undersized sheave, it was determined that the sidewall pressure had been exceeded This resulted in a new NCR, No. 5548, to disposition the overtensioning. This NCR was dispositioned "USE-AS-IS" based on a successful meggering of the cable.

l (4) Conclusions The inspector's review of the documentation associated with this allegation and the interviews with involved personnel

produced the following conclusions

(a) The alleger apparently identified IVA019 as the damaged

. cable when it was actually IVA029, since IVA029 was the I

only cable in that conduit that was power pulled using a dynamometer. Revi6w of the cable pull inspection records indicated that IVA019 was not damaged. Further, Cable No. IVA019 was hand pushed through the conduit, and since the cable was hand pushed, the sidewall pressure was not exceede (b) The cable jacket on Cable 1VA029 may have been damaged during the cable pulling process when the sidewall pressure was exceeded which substantiates the alleger's I concern. However, it is not safety significant for the following reasons. Cable IVA029 is a three conductor No. 4/0 cable with each conductor separately insulated and the three insulated conductors encased in another insulated jacket. Since a megger test measures the l breakdown resistance of the insulation to high voltage,

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the successful megger test shows that the insulation was not damaged by exceeding the sidewall pressure, j

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(c) The sidewall pressure was exceeded because an undersized i sheave was used during the pulling process. The sidewall !

pressure calculation, that was completed on August 27, 1986, produced an allowable sidewall pressure of 959 pound This was based on a 48" sheave. A 24" sheave was actually used on the pull, which should have reduced the allowable j

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I sidewall pressure to 800 pound Further, the sidewall pressure calculation was incorrect in that it assumed a '

O.707 multiplier on the dynamometer reading based on the way the pull was rigge The use of the undersized sheave was documented in NCR l No. 5470, dated December 1, 1986; however the overtensioning I of the cable was not recognized until LKC NCR No. 5548 was l written on February 17, 1987. This NCR was dispositioned  !

by CECO NCR No. 874 based on a successful megger tes )

The inspector did not view the elapsed time (August to j December 1986) as an attempt to circumvent quality problems; instead, it indicates that the " Quality First" program was working since NCR No. 5470 was written in response to a j quality first ite l (d) The dynamometer was rigged correctl It was constrained in two directions to keep it from pivoting, but it was not constrained directly opposite to the force applied by the tugge Therefore, the pressure indicated by the dynamometer was equal to the sidewall pressure on the cabl (e) LKC NCR No. 5470 was incorrectly dispositioned "USE-AS-IS" based on the incorrect assumptions made in the August 27, 1986 sidewall pressure calculation. This tends to substantiate the alleger's concern; however, it is I not safety significant since ultimately the concern 'j was recognized through the quality first program and dispositioned through the LKC and CECO corrective action program The inspector concluded that even though cable IVA029 was damaged, the successful megger test indicates that the cable should perform it's intended function without failing and endangering the other cables in the same condui b. (Closed) RIII-87-A-0035: On March 26, 1987, an alleger telephoned the Senior Resident Inspector at Braidwood with concerns relative to the ins' allation of electrical connections (butt splices) on thermocouple wir (1) Relative to the alleger's concerns the inspector reviewed the following document (a) LKC Procedures No. 4.3.9, " Cable Termination Installation,"

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1 No. 4.3.17, " Electrical Penetration Installation, Termination, and Maintenance," Revision j i No. 4.3.17.1, " Unit 2 Electrical Penetration Installation, Termination, and Maintenance Procedure," Revision l (b) Conax Maintenance and Installation Manual, No. IPS-37 ]

(c) Sargent and Lundy Specification No. F/L 2804-01,

" Reactor Containment Electrical Penetration Assemblies," Amendment 5, dated October 3, 198 t I

(d) LKC Nonconformance Report No. 5585, " Termination of Cable No. 2RC699 K1E," dated March 6, 198 (e) LKC QC Inspection Checklist of Electrical Terminations >

Form No. 36, " Termination of Cable No. 2RC699 K1E," dated I April 14, 198 )

l (2) The alleger's specific concerns and the inspector's review ]

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(a) Concern No.1 - Crimped connections on Cable No. 2RC699 could be pulled apart by hand. An NCR was written, but j he disagreed with the action taken to prevent recurrenc ] The cable identified by the alleger (2RC699 K1E) is a five conductor (5/C) shielded cable consisting of two No. 14 copper wires and three No. 16 Cromel pair It was terminated en March 3, 1987. During the  !

termination activity, the craft personnel applied  !

tension to the cable to straighten out the cable to keep the splices staggere This caused one Cromel -

conductor to pull out of its butt splic The crimping tool was checked for calibration and found acceptable. The crimping tool and the butt splices were also checked to see if the correct tool and hardware were employed. Both were found to be in accordance with the manufacturer's (Conax)

recommendation . An LKC NCR was generated on March 3, 1987, which documented the above facts. It was dispositioned

"use-as-is" based on the following: The termination configuration was qualified and certified by the vendor (Conax). All tools and butt splices were supplied by the vendo _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ - -

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. The terminations were performed in accordance with the vendor procedur The crimper met the calibration requirements, All of these terminations are QC inspected inproces Upon completion of termination, all splices rest in a cable tray at minimal tension.

I CECO testing verifies electrical acceptance after the termination (meggering).

In addition, craft personnel were given training in the proper handling of the splices to prevent pull-out of the conductors. The alleger stated that he was not happy with this because he felt that some pulling or twisting would occur during normal installatio . The inspector reviewed the documentation relative to this concern and conducted interviews with selected LKC and l

CECO personnel. In addition, CECO Project Field Engineering (PFE), Conax, and Thomas and Betts (Manufacturer of the crimping tool and butt splices) were contacted relative to the mechanical integrity of the crimp connection The inspector's conclusions follow: The pull-out of the butt splice on Cable No. 2RC699 K1E appears to be an isolated case. All penetration butt splices are 100 percent in process inspected by Q This review produced no other NCRs with similar problem b_ . Examination of the Thomas and Betts (T&B) crimping tool, Model No. WT-1300, indicated.that it was to be used for copper conductor only. Since Cromel conductor is a non copper alloy that is much harder than copper, the inspector asked PFE to contact Conax and ask them to justify the use of this tool on Cromel conductor. The justification, dated June 25, 1987, justified its use on Cromel conductors based on the minimum pull-out force requirements of Table 12.1 of Underwriters Laboratories Standard No. UL486. In this case, 30 pounds was the minimum pull-out forc Samples tested by Conax exceeded a pull-out force of 45 pounds. In addition, the environmental qualification of the penetrations by Conax subjected a test specimen to pull tests after thermal aging, radiation exposure, LOCA exposure, and shipping /

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. During the inspection, the inspector observed Burndy butt splices in the LKC warehouse and questioned if they may have been used on the penetration butt splices. The inspector was concerneu since the T&B tool will only make an acceptable crimp on T&B manufactured splices. Because of the inspector's i concern, the butt splices on Cable No. 2RC699 K1E were examined for mechanical integrity and the use of the correct material This examination showed that the splices were mechanically sound and that the correct T&B splices (Catalog No. 2B14 for No. 18-14 conductor) were employed. The inspector visually verified the correct splice marking A Field Problem Report, No. 1096, was generated during the terminating of Cable No. IRC699. It indicated that due to short pigtail leads on the Cromel conductor, the required staggering of the splices could not be achieved. This appears to be a ,

contributing cause to exceeding the 30 pound minimum l pull-out force and the resulting pull-out of the I conductor while trying to straighten out the cable to achieve the required staggering of splice j The T&B Model WT-1300 crimping tool is designed to apply a predetermined amount of force to a splice  ;

and then re' ease when the crimping dies have bottomed  !

ou It is calibrated through the use of go-no go gauge Therefore, if the tool is calibrated and the correct butt splice is used, an acceptable splice will result. The examination in 3.b.(2)(a) 3 e above verified the correct splice was used, the termination QC inspection report documented that the tool was calibrated, and the inspector visually verified that an acceptable crimp had been made on splices removed from Cable 2RC699, Megger testing verifies the acceptance of the insulation only since a splice with inadequate crimpling will also pass a megger test. Therefore, the critical attribute for an acceptable splice is the mechanical integrity which was found acceptable in 3.b(2)(a) 3 b and c abov The inspector concluded that the pull-out of the Cromel conductor on Cable 2RC699 K1E documented on LKC NCR No. 5585 was an isolated case and as such was not safety significan The inspector also concluded that the disposition of the NCR was acceptabl _ _ _ _ _ - - _-_ _ ___ _ ___ _ _ - - -

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(b) Concern No. 2 - Project Construction Department (PCD) was buying off on things that would not have been allowed in Unit 1, such as, running short of cable and splicing pieces and hanging cables by rope which results in dents and bumps in the insulation. The alleger admitted that none of the specifications for insulation had been exceede . Since no specific examples of running short of cable and splicing in pieces were identified, the inspector examined the concern generically. This examination produced the following information: Regulatory Guide No.1.75 takes a position that cable splices in raceways should be prohibited; however, the Braidwood FSAR, Amendment 43, dated September 1983, took the position that cable splices, either within raceways or at the interface of raceways and equipment are permitted provided they are intended by the plant design as indicated on the design document This position was accepted by the NR Sargent and Lundy (S&L) Standard No. EA-208 B/B,

" Control Cable Splicing," notes that no cable splices shall be permitted unless approved by S& The splices shall be made only at locations specified on the electrical installation drawings, Since January 1,1987, six safety-related cables have be2n splice These were 2FW264 C2E, 2MS126 K3R, 2MS125 K3R, 2MS684 C2E, 2MS102 K1R, and 2MS106 KIR.

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2M3125 and 2MS126 were approved by S&L on Engineering Change Notice (ECN) No. 36747 which revised Drawing No. 20E-2-4109J, Revision G, and No. 20E-2-4111C, Revision L. In addition, Field Problem Report No.1202 identified that ECN No. 36747 did not specify a particular type of splice. The problem report disposition referred to Drawing No. 20E-0-3000N-Sht. 2, Note 10A, which duplicated the instructions of S&L Standard No. EA-208 B/B. Cables 2FW264 and 2MS684 were approved on ECN No. 36506 and Cables 2M5102 and 2MS106 were documented in Drawing No. 20E-0-3000N, Sht. 2, Note 12A, which called for splice Non safety-related cables are spliced after receiving permission from PC Non safety-related work is outside the quality assuran:e program and is not subject to review by the NR Only 12 examples of safety-related cable splices

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The inspector concluded thac the alleger was referring to the splicing of non safety-related cables since PCD is the approver and as such has no safety significanc . Relative to the alleger's concern of dents and bumps in the insulation caused by hanging cables with ropes, the l inspector had previously determined in NRC Inspection Report No. 50-456/86036(DRS); 50-457/86028(DRS) that LKC Procedure No. 4.8.8, " Cable Installation Inspect' n,"

contained CECO's criteria for the evaluation of damage to cables. This procedure also requires LKC to notify CECO by NCR if minor kinks, dents, twists, or gouges are found. The problem indicated by the alleger fits the above categories. Further, the alleger admitted that none of the specifications for the cable had been exceede The inspector concluded that this concern had no safety significanc . Exit Intervig l The inspector met with licensee and contractor representatives denoted in Paragraph I during and at the conclusion of the inspection on July 23, 198'/ . The inspector summarized the scope -

results of the inspection and discussed the likely content of this inspection report. The licensee

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acknowledged the information and did not indicate that any of the f

information disclosed during the inspection could be considered

, proprietary in natur l 10