ML20095K704

Final Deficiency Rept Re Damage to Conax Cable Penetrations Through Containment Wall.Initially Reported on 840328. Measures Taken to Preclude Recurrence of Similar Damage/ Deficiencies During Replacement Operations

ML20095K704
Person / Time
Site:	Clinton
Issue date:	08/15/1984
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-10186, NUDOCS 8408300022
Download: ML20095K704 (4)

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g 1605-L IUIN0lB POWER OOMPANY jg U-10186 I CLINTON POWER STAtlON, P.O. 801 678. CLINTON. ILLINOl$ 61727

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August 15, 1984

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Docket No. 50-461 / J'-

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Mr. James G. Keppler

Regional Administrator -

' Region III U.S. Nuclear Regulatory Comission 799 Roosevelt Road ,

Glen Ell n, Illinois 60137  : ,

Subjact: , 10CFR50.55(e) Deficiency 55-84-06:

Damage to Conax Penetrations

Dear Mrc eppler:

On March 28','1984, Illinois Power Com1any notified Mr. F. Jablonski, NRC Region III, (ref: I? memorandum Y-20509 dated March 28, 1984) of a potentially reportable deficiency concerning damage to Conax cable, penetrations through the containment wall. This initial notificatio'n was followed by one (1) interim repSrt (reft IP letter U-10148, D. P. Hall to J. G. Keppler dated April 27, 1984). Illinois Power's investigation of'the above issue is, complete and has determined that this' issue repres6nts"a reportable deficiency under the provision of 10CFR50.55(e). This letter is submitted as a final report regarding this repori:able deficiency. ,

" Statement of. Reportable Deficien'cy

- p Inspection of control and instrumentaElon (C&I) type, as t well as low voltage power type cable penetration assemblies identified damage to termination components consisting of:

terminal blocks, terminal block cages, feedthrough power conductors, termination enc 1'osures, wire terminations, integration valve, and material corrosion. An evaluation of these items was performed to determine the effects on the integrity of the cabic connections and penetration assemblics and the significance to the' spfety of operation of CPS.

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Mrc James G. Kepplar Paga 2 August 15, 1984

Background

The penetration assemblics were inspected and shipped from the Conax facility in late 1930 and installed, by Baldwin Associates, in early 1981. The assemblies were inspected and shipped in special packing cases and were installed without protective enclosures over the termination cages. In mid-1981, the enclosure covers were installed over the termination cages, but did not fit properly over the terminal cage. An inspection of one of the installed penetration assemblies led to the discovery of bent terminal studs and broken barriers on terminal blocks. As a result, IP decided to perform a preliminary inspection of all NSSS and BOP control and instrumentation penetration assemblies for possible damage.

Investigation Results Illinois Power prepared and implemented an investigation plan to determine the extent of this problem at CPS. The investigation plan included:

1. A review was made of all Nonconformance Reports (NCRs) written against Conax penetrations to classify the reported damage into specific areas for IE and non-IE applications.

The effect on safety for cach type damage was evaluated.

2. A review of the Conax Installation Instruction Manual and Baldwin Associates installation and inspection procedures was performed to determine adequacy and compliance.

3. The Baldwin Associates work travelers were reviewed to verify that the vendor's recommended procedures were folloued.

4. The Conax Corporation was consulted to determine the effect of the damage to the penetration assemblics and proper means of correcting the damage.

5. The Baldwin Associates procedures for inspection and termination of field cables to the pencerations were reviewed to determine quality hold points prior to connecting cables.

6. Field verification methods for assurance of equipment integrity were evaluated with respect to identifying damage prior to turnover of the penetration assembly.

During the investigation, all installed C&I type Conax penetrations were inspected for damage. As a result of all NCRs written against the Conax ponctration assemblics, 23 types of damage /dediciencies were identified. The identified damage /

deficiencies were categorized into seven (7) categories as follows:

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c a, 7- jllr. Jemes.G.EK%ppler - Paga i3 ' August 15,-1984

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21. Terminal Blocks

2. . Terminal? Block Cages

3. Feedthrough-Power. Conductors

4. . Termination Enclosures

5. Wire Terminations

-6. -Inte ration Valve-

.7. Nozz e Flange. Corrosion Nonconformance' Reports (NCRs) were generated for all l identified-damage / deficiencies.. The NCRs are being resolved in l

accordance~withyapproved site. procedures'.

Investigation Analysis Electric penetration assemblies provide a means for carrying electrical. circuits through apertures of the Reactor Building, whileLmaintaining the integrity.of the pressure barrier. The~

penetration assemblies prevent radioactive leakage outside the containment. A portion of these electrical-circuits is provided to ensure.the. safe, shutdown capability of the reactor. In' order to-determine the appropriate corrective action to ime taken, all identified damage / deficiencies, as well as the cause of the-identified damage / deficiencies, were analyzed.

The majority of deficiencies identified were incidental to the main problem of da~maged terminal blocks on the C&I penetration assemblies. These problems were caused primarily by improper-fitting of the penetration enclosures and use of the assembly terminal block cages as a' stepping support by construction craft personnel-during construction. activities associated with cable tray installation. The cable tray installations-have b~ con completed and all penetration enclosures have been properly installed to preclude recurrence of these -

problems.

Corrective Action All control & instrumentation (C&I) and low voltage power penetrations are currently installed and there are no other electrical penetration assemblies to be procured. Appropriate measures are being taken.to-improve existing procedures to preclude recurrence of similar damage / deficiencies during future replacement operations. ._

A t'otal of 118 NCRs were written against installed Conax penetrations. Of the 118 NCRscwritten, 81 are closed and the remaining NCRs are currently in the process of being worked.

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l Mr.bJcnes G. K:pplor:

Page 4 August. 15,.1984-

.. The penetration assemblies ~are inspected utilizing the

-inspection procedure of the quality control-instruction for-electrical equipment. Since the penetration assembly is a

-  ; combination of electrical-and pneumatic (sealant) equipment, a ,

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specific inspection checklist will be issued to combine the pertinent requirements of the, quality; control instructions for electrical equipment and electrical cables'and include checkpoint

• indications relative.to the penetration itself (welding, electrical and mechanical 1 components, corrosion, etc.). This

-inspection checklistuwill be performed prior to the turnover'of the penetration assemblies.- In addition,.IP Startup. testing will.

-be performed on these assemblies following turnover.

Safety Implications / Significance' .

, .. Illinois Power has evaluated the various types.of

. damage / deficiencies for safety significance to'the safe operation of CPS.- Our evaluation has determined that1the damage to the terminal-blocks, were it to have remained. uncorrected,~could have affected adversely'the safety of operation of CPS. .On this basis, the issue is considered to be reportable under the provisions of 10CFR50.55(e).

We trust that this final report provides you sufficient information to perform a general assessment.of_this reportable deficiency and adequately describes our overall approach to

. resolve the problem. i Sincerely yours,

. .. Hall Vice President RLC/ lag (NRC2) cc: -NRC Resident Office, V-690

' Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety

.INPO Records Center 1

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