ML20029B767

Responds to Unresolved Items Re Incorrectly Sized Shims/Sleeves Used in Environ Qualified Raychem Insulated Conductor Splices

ML20029B767
Person / Time
Site:	Clinton
Issue date:	03/04/1991
From:	Jamila Perry ILLINOIS POWER CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
JSP-0148-91, JSP-148-91, NUDOCS 9103140395
Download: ML20029B767 (17)

Text

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CLINTON POWEH STATION. P o. IlOX 678, CLIN 10N, ILLINOIS 61727 0078 Tl:LEPilONi: (217) 035 H881 m'

JSP-0148-91

- March 4, 1991 1

Docket No. 50-461 Mr. A. B. Davis Regional Administrator, Regior III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen-Ellyn, IL 60137 r

Subjects Incorrectly sized Shims /Sleevor Used in Environmentally Qualified Raychem Insulated i

conductor Solicos Unresolved Item 90028-02 Dear Mr. Davist-This letter is submitted in response to the subject Unresolved Item. It providos the results of the Illinois Power Company investigation of nonconformancos concerning the installation of Raychem insulated conductor splicos.

As documented in Illinois Power Company (IP) letters U-601453 dated May 16, 1989, and U-601591 datod January 12, 1990, IP committed-to replacing terminal blocks with Raychom  ;

insulated splices or other qualified devices for instrument and control circuits required to operate in 100% relative i humidity.(RH) harsh environments. The scope of the terminal i block-replacement work included 13 electrical penetrations and 114. junction boxes.

One electrical penetration was completed'during the1firct refueling outage (RF-1), six penetrations wore completed in Planned outage Number 3

-(IC-3), and the. remaining six penetrations were completed during the second refueling outage (RF-2). Six' junction

- boxes were completed in PO the remaining 108 junction-boxes were-completed during RF-2.

During a revie51 of-documentation used in making AMP parallel splices, engineering personnel identified a

-potential nonconformance in tho application of Raychem -1 shim / sleeve material. 'rne Raychem material is used to environmentally coal spliced connections. Field inspection confirmed procedural nonconformances oxicted for some

, splicos in electrical penetrations 1EE20E and 1EE218.

Specifically, Raychem tubing was used outside of the ranges provided in CPS procedure 8492.01, " Cable Termination and Repair".

9103140395 910304 PDR .ADOCK 05000461 -

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i' To fully evaluate the generic-implications associated with the incorrect selection of Raychem insulated splice materials, an l~

f Inspection plan was developed. The Inspection Plan provided:

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1) A complete documentation review of splice installation

records for work performed in electrical penetrations  ;

i during PO-3 and RF-2. l

' 2) A complete documentation review of splice installation records _for work performed in junction boxes during PO-3 and RF-2.

, 3) Field inspections of accessible splices in electrical penetrations and jn junction boxes for work performed during PO-3 and 14-2.

4) Decision points to-modify the-sample size of-the number of splices to be field inspected.

In parallel with the performance of the inspection plan, the fonvironmental qualification requirements were analyzed based on the environmental conditions present at the_ location of certain penetrations.within the plant. This analysis demonstrated that all the penetration' splices were environmentally qualified in the as found configuration and is documented in an engineering "i evaluation associated with condition Report No. 1-90-12-027.

IP evaluated the records for a total of 2530 splicos in  ;

electrical penetrations and a' total af 1548 splices in junction boxes. Additionally, IP inspected a total of 788 splices in ,1

= electrical penetrations and 987 splices in junction boxes. .

A' review of splice installation records identified a total of 31 splices in electrical penetrations and 37 splices in junction boxes as. suspect. Splices were considered suspect when incomplete or incorrect' parts were listed on the Maintenance Work Requests (MWR). Yhe suspect splices were inspected. Results of {

the field-inspections showed that, of the 31 suspect splices in i electrical per.atrations, 20 splices were found to be in noncomplianct.with procedural requirements. Thirty-seven suspect splices in j'anction boxes- were inspected, 21 of which were found to be in noncompliance with procedutal requirements. Based on-inspection results obtained during'the inspections of suspect splices in the electrical penetrations and in-junction boxes-,a

. management decision was made to field inspect all in-line -

. junction box splices and to expand,the sample size of field inspections for accessible in-line splices in electrical-penetrations. As a result of the field inspections, a total of eight additional l splices in electrical penetrations and eight a additional splices in-junction boxes were identified as not conforming to procedural requirements. At the conclusion of inspection activities, all in-line-splices in junction boxes and all' accessible in-line splices in ten of the 12 electrical 'l penetrations ~ completed during pO-3 and RF-2 were inspected.

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The root cause of the nonconformances was human error.

Personnel erred in the selection of Raychem tubing for chims and sleever. All errors involved the incorrect use of Raychem i WCSF-70-N or WCSF-115-N insulating material on splices containing

1. 12AWG or 19/25 wire. Most of these errors occurred when the craftsmen performed calculations for a proposed shim to determino j if the outside diameter would fit within the use-range of the j selected sleeve and did not ensure the shim's use range was '

acceptable for the wire.

The actions required by the Inspection Plan have been completed with satisfactory results. Of 2530 splices contained in electrical penetrations, 788 splices were inspected-Nonconforming splices were reworked to meet procedural requirements; however, IP analysis demonstrated that these nonconforming splices met the Raychem non-accident use range and thus were capable of meeting environmental requirements in their initial as-built configuration. Splicos in electrical penetrations that were not inspected include: 1) inaccessible splicos (1199 splices), 2) in-line splices in wo instrumentation penetrations (512 splicos), and 3) "Y" and "V" type splices (31 splices). _These were not inspected because 1) identified nonconforming splices located in penetrations were qualified without rework, 2) document reviews did not identify any additional nonconformances and 3) field inspection results provided assurance that splices were installed in accordance with environmental qualification requirements. Additional information on the penetrations inspections is included in Attachment I.

The junction boxes contained a total of 1548 splices of which 987 splices were inspected. This figure represents all in-line splices and five "Y" and "V" type splices. A total of 561 "Y" and "V" type splices have not been inspected because 1) documentation does not show that a nonconformance exists in "Y" and "V" type splices and, 2) inspection of these splicos involves cutting the insulating material (destroying the splice). All junction box splices identified as nonconforming have been reworked and now comply with procedural and environmental requireme'ts. Additional information on the junction box inspectic 4 is included in Attachment II.

In addition to the inspections of PO-3 and RF-2 splices, a documentation review of splice installations performed during the first refueling outage (RF-1) was conducted. This review showed that either the Raychem work wae accomplished in accordance with detailed instructions or that the material used was not subject to errors similar to those noted from pO-3 and RF-2. Therefore, splices made during RF-1 are acceptable.

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Based on evaluation methodology, inspection results and field configuration, electrical splices in both penetrations and junct.on boxes meet thii Equipment Qualification requirements necessary for the safe operation of Clinton Power Station.

Sincerely yourn, U~

G S. Per Vice Presi' dent JDP/alh Attachments: Attachment I Electrical Penetrations Attachment II Junction Boxes cc: NRC Clinton Licensing Project Manager NRC Resident Office ,

Illinois Department of Nuclear Safety l

. j Attachment I - Electrical Penetrations Hackaround To fu.'.y 3ealuate the generic implications associated with the incor1 3 g selection and installation of Raychem insulated splice materials, an Inspection Plan was developed. The Inspection Plan required a complete review of documentation for electrical penetrations upgraded during Planned = Outage 3 (PO-3) and during the second refueling outage (RF-2). Additionally, the plan provided provisions to field inspect all accessible splices. The inspections were performed to demonstrate the accuracy of documentation reviews. Decision points were specified in the plan to adjust the scope based on interim inspection results. >

Physical inspections were limited to those splices which could be -

accessed without causing damage to surrounding splices.

Additionally "Y" and "V" type splices were excluded from inspection since inspection would have resulted in splice destruction. During the implementation of the penetration portion of the plan, 788 of the penetration splices were inspected.

Penetration ConficuratiDD Three types of splices were installed-in the electrical penetrations in-line splices (Figure 1) ,- three-wire "Y" - ty pe r splices (Figure 2) and three-wire "V" type splicos (Figure 3).

All Raychem insulation installations at Clinton Power Statir>n are performed in accordance with_ CPS 8492.01, CABLE TERMI!1ATIOS AND REPAIR. The assembly method for the three types of spl30es is similar. Wires are shimmed as necessary to moet the use range of the outer sleeve on in-line splices, or the kit breakout legs on i "Y" and "V" type splices.

Results of Documentation Review / Field'Insfiections Documentation review of Maintenance Work Pequests (MWRs) identified 31 splicos as suspect because .t he documents did not explicitly show that procedural requirements had been met.

Specifically,. splices were considered to be suspect when incomplete or incorrect parts were listed an the MWR, - Field

inspections verified that 28 splicts had ..ot been installed in - -

accordance with procedural requiremaats. This population included'20 of the original 31 splices identified as suspect as well as eight additional' splices. A total of 788 penetration splices were field inspected.

. Attachment to U-001800 All 28 of the nonconforming splices were located in one of two penetrations (IEE20E and 1EE21E) which woro worked during Po-3.

All other field inspections verified acceptablo splico installation. This inspection encompassed 241 of the 477 splicos completed during Po-3 and 547 of 2053 completed during RF-2. The inspection of splicos in penetrations worked during RF-2 identified no nonconforming Raychem installations. In addition, no additional nonconforming conditions were identified by the document reviews. Inspection results, listed by penetration, are provided in Table 1.

The errors identified in penetrations 1EE20E and 1EE21E were:

1) A WCSF-70-N shim versus a WCSF-115-N shim was installed on a 19/25 wire. The 19/25 wire diameter exceeded procedural requirements for a WCSF-70-N shim. This error occurred seven timos on one cable.

2) A WCSF-70-N shim was installed under a WCSF-115-N alcove. The diametar of the WCSF-70-N shim and the wire exceeded procedural requirements for a WCSF-115-N sleevo. This error occurred 21 times on six cables all installed by the same crow.

All nonconforming splices woro reworked to meet the procedural requirements. However, this rework was not required to fulfill the environmental qualification for the splices.

Evaluation of Errors Found The IP evaluation of the procedural noncompliancos identified included an evaluation of the offects on operability and the reasons for limiting the inspection scope.

Effects on ODerability IP ovaluated the procedural errors made against the Equipment Qualification (EQ) requirements for the installed location of the penetration splices. This evaluation determined that the identified nonconforming splices installed met the EQ requirements based on their location. Therefore, although the splicos were reworked to meet procedural requ.tements, this rework was not necessary to fulfill the environmental qualification of the splices.

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. Attachment to U-601800

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e Reasons for Limitino Inspection Scope The final scope of the inspection plan did not include field

-inspections of the following:

1199 inaccessible splices in penetrations 1EE23E, t 1EE18E, IEE19E, IEE34E and 1EE22E.

512 in-line splices in instrumentation penetrations 1EE33E and 1EE28E 31 "Y" and "V" type splices These splices were not included in the inspection plan and they are. considered acceptable for the following reasons:

t Inaccessible Sollegg 1). All nonconforming splicas found in penetrations '

1EE20E and 1EE21E, were environmentally qualified without rework.

2) Document reviews did not identify any additional nonconformances.

3) Field inspections of-accessible splices in these penetrations (IEE23E, IEE18E, IEE19E, IEE34E and 1EE22E) did not identify any nonconformances.

4)- Inspection of other splices installed by the craftsmen who made the nonconforming splices identified no other nonconformances. This inspection included a review cf splice ,

configurations similar to the cres identified as l nonconforming. >

.RF-2 Instrument Penetrations 1EE33E and 1EE28E

1) No nonconformances were identified in any of the l 547~RF-2 penetration splices inspected.

2) All nonconforming splices located in penetrations

-(1EE20E and 1EE21E) were environmentally qualified r

without= rework, i

3) With few exceptions, the wire sizes'found in those two penetrations are not-the same as found in IEE20E and 1EE21E. As such, these splices are not subject to the types of errors previously found

'and identified in the root cause.

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, 1 Attachment to U-601800 "Y" and "V" Type Solices

1) Document reviews did not identify any "Y" and "V" type splice nonconformances in the penetrations.

2) Documentation assessment identified that installation defects similar to those made to in-line splicos could not exist.

3) Inspection of these splices involves destroying the splice.

Conclusion Documentation of splice installation for electrical penetrations shows that no additional nonconforming splices exist. Although, all splices identified as nonconforming have been reworked, these splices were environmentally qualified without rework.

Therefore, Illinois Power Company has a high level of confidence, based on the document review and on field inspection results, that penetration splices installed at Clinton Power Station meet both procedural and environmental requirements.

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4-TABLE I ELECTRICAL PENETRATION (12) INSPECTION RESULTS ~

- 1 j SUSPECT SPLICES INCORRECTLY _

NUMBER FROM PAPER SPLICES INSTALLED OF SPLICES REVIEW INSPECTED (PER PROCEDURE) DISPOSITION PO-3 (6) 477 22 241 (50%) 28 30* REWORKED 1EE20E 39 10 39 (100%) 16 18* REWORKED

! 1EE21E 27 12 27 (100%) 12 12 REWORKED

IEE23E 357 0 121 ( 34%) O N/A '

j 1EE25E 42 0 42 (100%) O N/A i 1EE32E 6 0 6 (100%) O N/A l

! 1EE35E 6 0 6 (100%) O N/A l

1 RF-2 (6) 2053 9 547 0 N/A 1EE18E 477 0 186 (39%) O N/A 4

i 1EE19E 528 0 156 (30%) O N/A 1EE34E 480 0 194.(40%) O N/A 1EE22E 42 9 11 (26%) O N/A 1EE33E 229 0 0 0 N/A 1EE28E 297 0 0 0 N/A

• 2 of the splices that wer reworked were later determined to have been acceptable per procedure ptior to the rework.

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, Attachment II JMnction Boxes Backatanad The Inspection Plan provided for a comploto review of all documentation associated with the installation of oplicos in junction boxos.

The 114 applicable junction boxes contained a total of 1548 oplicos including in-lino splicos, "Y" splicou and "V" splicos. The following provides a breakdown of typeo

. of Fplicos and total splicon for PO-3 and RF-2:

Junction Splings .

Outaaq Boxes In-ling "Y"/"V" IQIAL PO-3 6 11 162 173 RF-2 108 971 404 1375 Field inspection was performed on all in-lino aplicos ar.d on five of the "Y" "V" type splicos.

Junction Box ConfigurAtign Throo typos of oplicos were installed in the junction boxon: in-line aplicon (Figuro 1), three-wiro "Y" splicos (Figure 2), and throo and four-Wiro stub ("V")

pplicos (Figuro 3). All Raychem innulation installations at Clinton Power Station are performed in accordanco with CPS 8492.01, CABLE TERMINATION AND REPAIR. The assembly method for the throo types of splicon la almilar. Wirco are chimmed as necessary to moet the uso range of the outor aloevo on in-lino splicos, or the kit breakout legn on "Y"/"V" type splicos.

Reg.ults of Documentation Review /riold Insnoctions A review of documentation was performed for all 114 junction boxes, aix of which woro worked du.-ing 00-3 with the remaining 108 worked during RF-2.

As a result of the document review, a total of 37 aplicon woro identified as suspect. Specifically, splicos woro considorod to be suspect when incompleto or incorrect parts woro listed on the MWR. This population included a total of 32 in-lino splicos and five splicos having a "Y"/"V" configuration. Subsequently, all 37 splicos identified as suspect woro field inspected, including the fivo "Y"/"V" typo splicos (which required destructivo examinations).

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Attachment to U-601800 i

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Results of the field inspections performed showed that, L of the 37 splices identified as suspect, 21 splicos were confirmed to be nonconforming and 16 splicos were found

[ to be acceptable. The following provides a breakdown of those results:

Suspect Acceptable Honconforming Solices .. Solices solices In-line Splices 32 15 17 "Y"/"V" Splices 5 1 4 During the field inspection of suspect splices, a nonconforming condition was identified in two splicos not 1 previotbly identified as suspect. Therefore, the decision was made to inspect all in-line splices ,

contained in junction boxes. As a result of this decision, 987 splices were inspected. This number i included.the 37 splices previously identified as suspect.  !

< This inspection resulted in the identification of six additional nonconforming splices. Thus a total of 29 splices were identified as nonconforming and-were reworked. All in-line splices in junction boxes have been field inspected and reworked as necessary to meet Equipment Qualification requirements.

Inspection results show that junction boxes contain a '

total of 1548 splicos, 173 of which were installed during PO-3 with the remaining 1375 being installed in RF-2.

None of the in-line splices installed during PO-3 were found to be-nonconforming. Of the 1375 splices installed

, during RF-2, 971 in-line-splices were-inspected resulting in the confirmation that 17 suspect splices were installed incorre ly and that an additional 8 splicos thought to be acceptable were-found to be nonconforming.

Of'the 566 "Y" and "V" type splices, five wore identified as suspect with field inspections confirming:that only 4 >

were actually nonconforming. All of the nonconforming "Y" and "V" type' splices were installed during RF-2. All splices identified as nonconforming have been reworked.-

Documentation reviews do not indicate that any additional suspect splices exist.

Evaluation of Errors Found A total of-29 nonconforming conditions were noted during the documentation review and field inspections of junction box splices. The following provides a description of splice nonconformances noted:

1) A WCSF-70-N shim versus a WCSF-115-N shim was '

installed on a wire. The wire diameter was too large for a WCSF-70-N shim. This error occurred 22

times.

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Attcchment to U-601800

2) A WCSF-70-H shim was installed under a WCSF-115-N sleeve. The diameter of the WCSF-70-H shim and the wire were too large for a WCSF-115-H sleeve. This error occurred two times.

3) The correct shims were utilized; however, the chims were inadvertently positioned on the opposite sido of the splice. This error occurred one tim".

4) A WCSF-115-N shim versus a WCSF-70-N shim was installed on a wire. The wire dicueter was too small for a WCSF-115-H shin. This error occurred two times.

5) A WCDF-70-N sleeve versus a WCSF-115-H sleeve was installed on a wiro. The sleeve was too small for the wire diameter and shim material used. This error occurred two times.

Since "Y" and "V" type splicos cannot be nondestructively inspected, en additional assessment was performed based on the types of e rors noted in the in-line splicos. To provide additional guidance during the aesessment of "Y" and "V" type splicos, a document review algorithm was utilized to assess each splice. The errors made in the electrical penetrations and in the junction boxes involved the incorrect use of Raychem WCSF-70-N and WCSF-115-N material. As such, the assessment considered: 1)

The splico material used to assemble the splice and whether or not the material listing included both WCSF-70 and WCSF-115 material, 2) if shims were required to make the splice. The need for shim material in configuring the splice or the absence of both WCSF-70-N and WCSF-115-N shim material provided additional assurance that installation defects similar to those made in the in-line splices could not exist. The algorithm utilized to perform this assessment is shown on Enclosure I to Attachment II.

This assessment resulted in the elimination of 549 of 566 of the "Y" type and "V" type splices due to splice configuration not being subject to these types of errors.

Additionally, five splices were previously identified as suspect and were reworked. A review of installation documentation for the remaining 12 splices does not indicate that any suspect splices exist. This adds additional confidence that "Y" type and "V" type splices are installed correctly.

Although IP has no indication that these spli:es are subject to failure, an evaluation was performed to examine the consequences of failure of the Raychem environmental seal for the remaining 12 multiconductor splices located in various safety related junction boxes.

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. Attachment to U-601800 )

Six of the splices are neutral returns on 120 volt alternating current (VAC) circuits. Based on Sargent &

Lundy (S&L) calculation 19-AI-75, it was concluded that a short between the splice and the junction box would not affect circuit operability. The 120 VAC neutral return is at the same ground potential as the junction box. A nhort may add an alternate return path but it would not cause the circuit to lose power or bypass any control contacts. The specific service of these six circuits ist

• *'o VAC neutral return for solenoids of 1FSV-VQ-027B/C and indicating lights.

120 VAC neutral return for solenoid of 1SA030 and limit switch contacts (two splicos).

120 VAC neutral return for solenoid and limit switch contacts of 1RF020.

120 VAC neutral return for solenoid and limit switch contacts of 1RF021.

120 VAC neutral return for solenoid and limit switch contacts of 1RE020.

Two of the splices are 120 VAC line feeds to limit switch contacts of valves 1B33-F020 and 1E12F075B. These valves are utilized to obtain water samples at the process sampling panel, 1PL33J. These valves are not used for post accident sampling. The normal position of these valves is closed. The safety function of those valves is to close during an accident. A short of the splice to the junction box would cause the five amp fuse feeding the circuit to open. Loss of this fuse would render both valves inoperable, along with valve 1E12-F075A. Since these valves are energized to open and fail closed, failure would be to the safe position. Therefore, a failure of either of these splicos would not affect the safe operation of the plant.

One of these splices is a 120 VAC line feed to the limit switch contacts of valve 1C41-F031, Standby Liquid Control (SLC) Test Tank Outlet. These contacts operate status lights. A short of the splice to the junction box would cause the one amp fuse to open and deenergize Division 1 status lights for the standby liquid control system. These lights provide position indication for two manually opened (normally locked closed) valves. Other status lights fed by this fuse provide the following system status:

4 SLC "A" Manually Out of Service.

Valve C41-F001A "In Test", " Power Loss" or

" overload ' rip".

, Attcchment to U-601800 4

Pump Motor C41-C001A " Power Loss" or " Overload Trip".

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Loss of Continuity to Squib Valvo "A".

Loss of those status lights does not provent system operation because control circuits are poworod from a 1 separate source. Annunciator windows in the same panol  !

will alarm on loss of power to the valve or pump motor ,or l upon trip of the Standby Liquid control Pump. Since i system operation is not affected and annunciation / alarm  !

of control circuits is available, the function of this I splico doos not affect the safe operation of the plant. I l

One of those splicos is a 125 volt direct current (VDC) l positive load to the limit switch contacts of manual 3y l operated valvo 1E12-F0518. These contacts are inputa to J optical isolators for process computer input signals. A short of this splice would put a ground on the positivo leg of the Division 2 DC Motor Control Centor. Since the DC system is not grounded by doolgn, the three amp fuso for this circuit would not open sinco a single ground '

would not create a fault path. Control room annunciation would identify the prosonce of a ground fault- sito procedures call for the ground to be found and eliminated. The optical isolator circuit and the Division 2 DC distribution is designed to continue to operate even with a single ground present.

The remaining two aplices are 120 VAC lino foo6. to the solenoid coils of 1FSV-VQO25C/D and 1FSV-VQO27B/C. Those solwnoids operato drywell isolation valvos IVQOO2 and IVQOOS. The solenoids are energized to open and fail closed. The valves also fail to the closed position, The normal position for those solenoids and valvos when the plant is operating is closed. With the control switch in the closed position, the contacts are open and the splices are isolated from the 120 VAC. Failure of the Raychem seal in this condition has no offect on the circuit.

Certain infrequent' operations utilize these valvos while tho. plant is operating. Thoso operations are of short duration, but if an accident were to occur during one of these times, the system would isolato. System isolation will isolate the splicos from the 120 VAC bus and put the circuit in a configuration where failure of the Raychem seal has no effect. Those valvos are normally utilized during modes 4 and 5. Operation of the Drywell Purgo (VQ) and Containment Building Ventilation (VR) systems j during modos 4 and 5 maintains the humidity at a low l level. Without the moisture to croato a leakage path j through the failed seal, the actual seal failure has no t

. Attachment to U-601800 effect on the system operation. The junction box containing these splices has a drainage opening, so standing watir from an earlier event is not a concern.

Accordingly, failure of the Raychem seal on these splices will not affect the operation of the Drywell Purge System or the plant. When the circuits are energized, there is no moisture for a leakage path. During accident conditioin, the circuits would not be energized.

As previously stated, IP has no indication that the remaining 12 splicos are subject to potential failure of the environmental seal; however, as demonstrated above, the failure of the Raychem seal on the remaining 12 splicon would not create a safety or operability concern at Clinton Power Station.

Conclu'J2D All in-line, "Y" type and "V" type splices identified as nonconforming have been reworked. All in-line splices have been inspected to ensure compliance with environmental design requirements. Documentation for all "Y" type and "V" type splices has been ovaluated to ensure suspect splices have baen identified and inspected as necessary.

Illinois Power Cempony has a high level of confidence, based on the document review and on field inspection results, that junction box splices at clinton Power Station are installed as required by environmental design.

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. ATTACHMENT II to U-601800 Enclosure Z

Document Algorithm e

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{ , U-601800 j

Typical Splice Configurations e

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