ML20028C178

Final Deficiency Rept 81-05 Re Min Separation Requirements within 4160-volt Switchgear.Initially Reported on 811002. Sargent & Lundy Personnel Retrained in Separation Criteria & Baldwin Assoc Furnished W/Cable Computer Repts

ML20028C178
Person / Time
Site:	Clinton
Issue date:	12/20/1982
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, 1605-L, 81-05, 81-5, U-10015, NUDOCS 8301070151
Download: ML20028C178 (3)

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am8 16 05-L llLIN018 POWER 00MPANY y-10015 CLINTON POWER STATION. P.O. box 678. CLINTON. ILLINOIS 61727 December 20, 1982 Docket Number 50-461 Mr. James G. Keppler ,

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Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Potential Deficiency 81-05 10 CFR50. 55 (e)

Minimum Separation Requirements Within 4160 Volt Switchgear

Dear Mr. Keppler:

On October 2,1981, Illinois Power verbally notified Mr. H.M.

Uescott, NRC Region III, of a potentially reportable deficiency per 10 CFR50. 55 (e) concerning minimum separation requirements for certain components of the 4160 Volt switchgear. This initial notification was followed by four (4) interim reports: L.J. Koch letter U-0326 to J.G. Koppler dated November 6, 1981, U.C. Gerstner letter U-0423 to J.G. Keppler dated February 26, 1982, W.C. Gerstner letter U-0490 to J.G. Keppler dated May 27, 1982, and W.C. Gerstner letter U-0535 to J.G. Keppler dated September 17, 1982. Our investigation into this natter is complete and has determined that this potential deficiency is not reportable under 10CFR50.55 (e) . This report represents a final report of the matter in accordance with 10CFR50.55(e)(3) .

BACKGROUND During September, 1981, three nonconformance reports (NCRs 5425, 5426, 5453) were written against the 4160 Volt switchgear, addressing apparent violations of separation requirements between Class 1E and Non-Class lE circuits inside certain switchgear cubicles. These violations were. identified subsequent to termination of field cables and were found to exist in both current transformer circuits and control wiring circuits. This lack of physical separation in the installed switchgear prompted the investigation into several areas of potential deficiency, including design, construction procedures and controls, and QC training, ggg 27 C301070151 821220 gDRADOCK05000 ((cf[

4 Mr. James C. Keppler December 20, 1982 NRC ' , Page 2 of 3 j

INVESTIGATTON RESULTS .

.i In the area of design, Sargent & Luady (CPS Architect /

Engineer) was requested to review their design and procedures in meeting the requirements of the Clinton Power Station FSAR. This review determined that drawings for the subject 1E equipment did not

meet separation requirements described in IEEE 384. However, Sargent i

& Lundy performed a comprehensive technical analysis of the subject 1E equipment which demonstrated that the safety function of the class IE switchgear was not compromised. Sargent & Lundy also performed a 100% review of their wiring diagrams to determine if other equipment failed to meet the separation requirements of the Clinton Power Station FSAR. The results of their review showed no other equipment

drawings required revision. Therefore, a significant design defi-J ciency per 10CFR50.55(e) has not occurred.

In the area of construction procedures and controls, and QC

training, investigation has revealed that procedures for cable termination and inspection were inadequate to assure and verify that required separation was maintained. The contractor (Baldwin Associates) procedures, BAP 3.3.3 and Quality Control Instraction 408, required inspection of class IE cable terminations for

separation considerations, but did not require inspection of non-class 1E cable terminations within IE panels. If non-1E cables were terminated in a class 1E panel or enclosure after all class IE cables had been terminated and inspected, an inspection to verify separation was not required.

) In order to determine if an actual cable separation violation had occurred in completed work, an investigation was performed to identify equipment which contain cables with a mixture of segregation-

codes (IE/Non-IE and division / division). This list of equipment, defining the scope of potential separation violations, was then analyzed to determine the status of cables pulled and terminated in

the equipment. This analysis identified only those equipments previously documented in NCRs 5425, 5426, and 5453 as having cables j with a mixture of segregation codes pulled and terminated in the i equipment. One additional case was found where cables of mixed

, segregation codes have been pulled to equipment (ISX01PB), however, a

the IE cable has not been terminated or inspected for separation at

! this time. As design analysis has determined the adequacy of those

cases identified in the three NCRs, and as no additional cases of

! separation violations exist at this time, a significant deficiency in construction in accordance with 10CFR50.55(e) has not occurred.

Corrective Action Although our investigation has concluded that a significant

] deficiency in accordance with 10CFR50.55(e) has not occurred,

several concerns were identified which require corrective action.

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Corrective action that has been or will be taken includes the following:

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. s Mr. James G. Keppler December 20, 1982 ffRC

, Page 3 of 3

1. Sargent & Lundy Electrical Design and Drafting personnel have been retrained in applicable separation criteria and in the area of drawing review to prevent future occurrences of separation and segregation violations on design drawings. Methods for resolving potential conflicts were also discussed.

2. Baldwin Associates procedures BAP 3.3.3, Job Instruction E-007 and Quality Control Instruction QCI 408 are being revised to enhance controls for the identification of separation violations. These procedures will call for the identification on the cable termination card of those non-lE cable terminations which are to be made in IE panels.

Non-lE cables termination cards so identified are to be routed to, and cables inspected by, Quality Control for proper divisional separation.

3. Sargent & Lundy is furnishing Baldwin Associates two (2) computer reports which identify cables with mixed segregation codes entering CPS equipment. These reports will form the basis for identifying equipment with a potential for cable separation violations. Baldwin Associates will utilize these reports in implementing the enhanced termination inspection program described in item 2 above.

4. Baldwin Associates has provided training to personnel into the revised procedural requirements identified in item 2 above.

Safety Implications / Significance Our investigation of this matter has concluded that the identified concerns would not have af#ected adversely the safety of operation of CPS. Engineering analysis has shown that the designs as issued on drawings are adequate and result in no adverse safety consequences to the class 1E system.

This letter is hereby submitted as a final report in accordance with 10CFR50.55(e), and I trust that it is sufficient for analysis and evaluation of the investigation and corrective action taken.

Your very truly,

. . Hall Vice President cc: NRC Resident Inspector Director-Quality Assurance Director-Office of I&E, USNRC,_ Washington, DC 20555 Illinois Department of Nuclear Safety