ML20154S205
| 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: |
| References | |
| 50-461-88-10, IEIN-83-37, IEIN-85-039, NUDOCS 8806080421 | |
| Download: ML20154S205 (6) | |
See also: IR 05000461/1988010
Text
.
.
'
.
.
.
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
Facility Name:
"
' ton Nuclear Station
>
Inspection At:
Glen Ellyn, Illinois
Inspection Conducted:
February 25 through March 31, 1988
$YY
'h *"
plgg
Inspector:
Anil S. Gautam
Reactor Inspector, Region III
Date
Also participating in the inspection and contributing to the report was:
M. Kopp
\\b
/
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
ADOCK 05000461
Q
.
.
.. ..
.
.
.
- - _ _ _ _ _
.
.
'
.
.
.
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
.
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
building), the inspectors observed the use of AMP KYNAR (Polyvinylidene
Fluoride butt splices on 480V motor leads. The licensee confirmed
l
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
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.
l
2
_-_
_
-
-
.
.
.-
.
.
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.
1
3
.
o
.
,
.
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
-
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.
4
. - _
. .
-
_-
. - _ -
.
.
'
.
.
.
.
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
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
l
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.
[
!
5
- .
, _ _ _._ _ _
.
..
..
.
.
.
.
.
,
.
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,
t
I
l
l
l
6
!