ML20154S205

Insp Rept 50-461/88-10 on 880225-0331.Potential Violations Noted.Major Areas Inspected:Environ Qualification of Electric Equipment within Scope of 10CFR50.49 & Review of Licensee Action on Previously Identified Findings

ML20154S205
Person / Time
Site:	Clinton
Issue date:	04/19/1988
From:	Gardner R, Gautam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154S201	List: IR 05000461/1988010 ML20154S198 ML20154S205
References
50-461-88-10, IEIN-83-37, IEIN-85-039, NUDOCS 8806080421
Download: ML20154S205 (6)

See also: IR 05000461/1988010

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/88010(DRS)

Docket No. 50-461 Operating License No. NPF-62

Licensee: Illinois Power Company

500 South 27th Street

Decatur, IL 62525

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Facility Name: > ' ton Nuclear Station

Inspection At: Glen Ellyn, Illinois

Inspection Conducted: February 25 through March 31, 1988

Inspector:

$YY Anil S. Gautam

'h *" plgg

Reactor Inspector, Region III Date

Also participating in the inspection and contributing to the report was:

M. Kopp

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Approved By: Ronald N. Gardner, Chief hll/ / N

Plant Systems Section, Region III Date'

Inspection Summary

Inspection on February 25 through March 31, 1988 (Report No. 50-461/88010(DRS))

Areas Inspected: Special safety inspection of the environmental qualification

(EQ) of electric equipment within the scope of 10 CFR 50.49. The inspection

included a review of licensee action on previously identified findings.

Results: Previously identified EQ deficiencies were determined to be

potential violations of 10 CFR 50.49.

8806080421 880420

PDR ADOCK 05000461

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DETAILS

1. Persons Contacted

a. Illinois Power Company (IPCo)

W. C. Gerstner, Executive Vice President

F. A. Spangenberg, Manager, Licenst g and Safety

R. D.. Freeman, Manager, NSED

R. E. Campbell, Manager, QA

J. D. Weaver, Director, Licensing

M. E. D' Haem, Supervising specialist, EQ

S. A. 7abel, Attorney

W. E. Baer, Attorney

b. Nuclear Regulatory Commission (NRC)

C. J. Paperiello, Deputy Regional Administrator

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H. J. Miller, Director, Division of Reactor Safety

J. A. Grobe, Director, Enforcement Staff

R. C. Knop, Chief, Reactor Projects Branch 3

R. N. Gardner, Chief, Plant Systems Section

R. W. Cooper, Chief, Reactor Projects Section 3B

S. P. Ray, Resident inspector, Clinton

M. J. Kopp, Reactor Inspector, Plant Systems Section

C. D. Anderson, Enforcement Specialist

Z. Falevits, Reactor Inspector, Plant Systems Section

2. Previously Identified Findings

a. (Closed) Unresolved Item (50-4ol/87026-02(DRS))

This item addressed AMP KYNAR splices used in Limitorque actuators.

During examination of Limitorque Actuator E51-F010 in the auxiliary

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building),

Fluoride buttthesplices

inspectors observed

on 480V the use

motor leads. Theof AMP KYNAR

licensee (Polyvinylidene

confirmed

that these splices had been used in various instances inside and

outside the containment in instrument, control, and power circuits,

and that plant specification K-2999 allowed the use of these splices

l when leads were found too short to terminate. The licensee's EQ

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files, however, did not have adequate documentation to qualify these

splices, in that plant specific configurations were not tested in

postulated accident environments.

Subsequent to the inspection, the licensee conducted two tests at

Wyle Laboratories, Report No. 17955-1, dated January 29, 1988, to

demonstrate that the KYNAR AMP butt splices were qualifiable to

postulated accident environments at the Clinton Station. During

the first test, six specimens were irradiated and thermally aged

for a 40 year qualified life to simulate an ambient temperature of

125'F.

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The specimens were then exposed to a loss of coolant accident

(LOCA) environment of elevated temperature, pressure, steam, and

demineralized water spray. During the LOCA portion of the test,

five of the six specimens energized by 528VAC,132VAC, and 132VDC

circuits shorted to ground; thereby failing the test. Failures

were attributed to insulation degradation due to aging.

The licensee performed a second test on samples aged for an eight

year qualified life. Six samples were exposed to a LOCA environment

without any spray. One of the six specimens failed during the first

six minutes of the LOCA exposure. Two other specimens failed after

17 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of testing, respectively. The licensee discontinued

the test and concluded that the splices had failed to perform under

conditions tested.

Subsequent to this test the licensee reviewed appropriate equipment -

and identified 196 AMP butt splices in valve actuators, solenoid

valve leads, and in one junction box. These splices have since been

replaced at the Clinton Station with qualified tape or Raychem tubing.

This item was previously identified as a Potentially Enforceable

Unresolved item, and has now been detennined to be an apparent

violation of 10 CFR 50.49 (50-461/88010-01(DRS)).

b. Licensee Event Report 87-066

During the EQ inspection, junction Box IJB673 was observed to have

a top conduit entry and contain a Marathon terminal block; however,

there were no provisions for moisture removal during an accident

(no weep holes). The licensee confirmed the box was in a high

er.ergy line break (HELB) environment and issued Condition Report

No. 1-87-08-081 to install weep holes in the box. The licensee also

stated that ASCO Solenoid Valve 1E12-F0658, which is energized from

this terminal block, would ha ve failed to an accident safe position

if the terminal block was compromised during an accident. At the

conclusion of the inspection, the licensee indicated that this was

an isolated deficiency. Based on this information, this item was

cited as part of a Severity Level V violation in the NRC EQ

Inspection Report 50-461/87026(DRS).

Subsequent to the EQ inspection, Nuclear Station Engineering

Department (NSED) received a copy of a letter written by General

Electric (GE) to Sargent and Lundy (S&L) discussing electrical boxes

that failed EQ testing. Based on this letter, NSED re-reviewed a

Nonconforming Material Repos't (NCMR) written on September 16, 1986,

dealing with standing liquid in a 1E junction box causing corrosion

of terminals. Previously identified remedial corrective action for

the NCMR had failed to identify the lack of the required drainage

opening. No generic corrective action was specified for the NCMR

as the condition was identified during a generic walkdown for a

class 1E cable splice insulation deficiency.

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NSED also re-reviewed the Condition Report written on the junction box

deficiency identified during the EQ inspection. Based on all of this

information, a limited plant inspection was performed by the licensee

on November 5, 1987. During this inspection one hundred fif ty-six

junction boxes were identified as lacking the required drainage

openings. These boxes were subsequently reworked by drilling a

drain hole in each box. The rework was completed in the field by

November 13, 1987, prior to starting up from the outage. Licensee

Event Report 87-066 was initiated to report this event in accordance

with 10 CFR 50.73(a)(2)(ii) and 10 CFR 50.73(a)(2)(v).

This deficiency is considered an apparent violation of 10 CFR 50.49

(50-461/88010-02(DRS)).

c. (Closed) Unresolved Item (50-461/87026-01(DRS))

This item addressed the use of nylon wire caps in Limitorque

actuators. Limitorque Actuator 1CC072 was examined by the inspectors

in the auxiliary building. The inspectors noted the use of three

nylon wire caps to terminate six of the nine 480V motor leads and

subsequently confirmed that nylon wire caps had been installed in

approximately ninety dual voltage 10 CFR 50.49 designated Limitorque

actuators in the auxiliary and fu ' buildings.

The licensee stated that Limitorque Test Reports No. 600376A and

No. 8003 demonstrated equipment qualification, and that a Limitorque

letter dated August 20, 1987, confirmed that the suspect caps were

used during these tests. The inspectors, however, found no evidence

in the reports of the wire caps being tested. The licensee could

not provide additional information. The inspectors informed the

licensee that Limitorque actuators containing these wire caps were

unqualified based on inadequate qualification documentation.

Subsequent to the inspection, the licensee conducted two tests at

Wyle Laboratories, Report No. 17955-1, dated January 29, 1988, to

demonstrate that the nylon wire caps weie qualifiable to postulated

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accident environments at the Clinton Staon. During the first test,

six specimens were irradiated and thermally aged to simulate an eight

year qualified life at 125 F ambient temperature and exposed to a

LOCA environment of elevated temperature and steam. Specimens were

mounted in appropriate configurations with an applied phase to phase

voltage of 537 VAC, thereby simulating plant applications. No failures

were observed.

The licensee performed a second test where twelve specimens were

irradiated and thermally aged. Six specimens were aged to simulate

125 F for a 40 year life, and six specimens were aged to simulate

150 F for an eight year life. At the 22 hour2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> point of the test,

three specimens aged to simulate 125 F and two specimens aged to

simulate 150 F failed and were found shorted to ground. The test

was discontinued.

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The licensee has re-evaluated the environmental zones in which these

wire caps are installed and has determined that the wire caps will

be exposed to an ambient temperature of 122 F. EQ files are being

revised accordingly. The licensee concluded that the nylon caps were

qualified for at least a 9.9 year qualified life (as opposed to the

40 year life documented in the EQ files) based on the success of the

first test. The nylon wire caps will be replaced prior to the end of

their qualitied life.

This item was previously identified as a Potentially Enforceable

Unresolved Item, and has now been determined to be an apparent

violation of 10 CFR 50.49 (50-461/88010-03(DRS)).

3. Enforcement Conference on EQ Findings

On March 31, 1988, an enforcement conference was held in Region III in ,

regard to NRC findings identified during the August 17 through October 13,

1987 and February 25 through March 31,198810 CFR 50.49 EQ inspections.

The licensee acknowledged and agreed with the NRC findings, and presented

the following arguments:

a. With regard to the use of nylon wire caps in Limitorque valve  :

actuators, the licensee stated that it had been their understanding

that Limitorque had tested these caps during the qualification

testing of the actuators. The NRC, however, determined that the

licensee had no evidence to substantiate this claim, and that any

licensee communications with Limitorque regarding these caps took

place after the NRC finding. The licensee also stated that failures

in the field would have been prevented, as the licensee found no

contact of the wire caps to the metal enclosures in the field. The

NRC rejected this argument as the numerous wire leads having wire

i caps were not, and are not required to be secured in the field, and

may easily touch each other er the enclosure during operation or

maintenance,

b. With regard to the KYNAR AMP splices, the licensee stated that even

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though they had not originally tested the splices in a configuration

consistent with the plant application, their original testing had

been consistent with industry practices. The NRC rejected this

response as the Clinton Station is required to meet the latest

industry standards for testing as outlined in NUREG 0588, Category I ,

and in IEEE 323-1974. Both documents refer to the use of proper ,

configuration and mounting of tested components. In addition, IE

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Information Notice No. 85-39 addresses the need for a similarity of

the tested configuration of equipment to the configuration installed

in the plant.

c. With regard to the lack of junction box weep holes, the licensee

stated that based on their review of plant engineering specifications

no other such installation deficiency was found for installed

equipment. As a basis for enforcement of this item, the NRC has

noted that IE Information Notice 84-57 did address the need for weep  ;

holes in junction boxes to prevent failures due to moisture intrusion. [

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The licensee did not provide any new or revised information during

the enforcement conference to mitigate the findings but confirmed that

adequate corrective and remedial action had been implemented. A review

of the licensee's corrective action will be performed during a followup

NRC inspection.

4. Exit Interview

The Region III inspectors met with the licensee's representatives

(denoted under Paragraph 1) during an enforcement conference on March 31,

1988 and discussed their findings. The inspectors summarized the

purpose and findings of the inspection and the licensee acknowledged

this information,

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