ML20198T084
| ML20198T084 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/30/1986 |
| From: | Beck J, Mallanda J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20198T043 | List: |
| References | |
| NUDOCS 8606110291 | |
| Download: ML20198T084 (11) | |
Text
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7.oss(e)
O COMANCHE PEAK RESPONSE TEAM RE'SULTS REPORT ISAP:
I.a.3
Title:
Butt-Splice Qualification REVISION 1 j
4m e n
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saue Coordinator Dpe
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i d1kM 4/n/r4 oaa 71e.1epe.eer Qn a. L 1/3/n l
Johd/W. Beck Chairman CPRT-SRT Date
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0606110291 860606 I'
PDH ADOCK 05000445 l
A PDR I
Revision:
1 Pags 1 of 10 RESULTS REPORT
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J ISAP I.a.3 Butt-Splice Qualification
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7, Pages J-28 and J-29)*
"The practice of butt-splicing cables in panels was allowed on a limited basis, as specified in Section 8.1.5.2.4 of Amendment 44 to the Final Safety Analysis Report (FSAR). The NRC staff reviewed Texas Utilities Electric Company's (TUEC's) justification for permitting' butt-spl. ices inside pancis (correspondence from M.
Srinivascn, NRC Power Systems Branch to B. J. Youngblood, NRC Licensing Branch, July 30, 1984), and concluded that the practice is acceptable on a limited basis, subject to the following conditions:
That adequate provisions be included in the installation procedures to verify operability of those circuits for which splices are being used.
That the wire splices used are qualified for anticipated service conditions, and
\\s That splices are staggered within the panel so that they are not adjacent to each other in the same wire bundle and pressing against one another.
i "The TRT inspected butt splices in safety-related panels...
l "The TRT found the splices to be in conformance with all procedural-requirements set forth by TUGC0 which did not include the three conditions for acceptability stated above, which the NRC considers f
to be important to assure the adequacy of these splices..."
2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7. Item 6.(b), Page J-31)*
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"TUEC shall accomplish the following actions prior to fuel loadt Develop adequate installation and inspection procedures to reinspect all existing butt-splices to ensure (1) the operability 2
of those circuits which contain butt-splices in panels, (2) that 1
l the wire splicing materials and methods used are qualified for anticipated service conditions, and (3) that splices are staggered within the panel so that they are not adjacent to each other in the j
same bundle."
d NRC concerns involving the inspections of butt-splices are j
presented and addressed in ISAP I.a.2, " Inspection Reports on Butt Splices" 1
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1 Page 2 of 10 RESULTS REPORT
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ISAP I.a.3 (Cont'd)
3.0 BACKGROUND
The following information should be considered in addressing the issue identified by the NRC:
The type of butt-splice used by TUGC0 in control panels at Comanche Peak Steam Electric Station (CPSES) is the AMP Pre-Insulated Environmental Seal (PIES) splice.
It is used in these panels when conductors are not long enough to reach their termination. points-(due to design changes, equipment repair, etc.), ano it is not judged reasonable to pull a new field cable.
Most of the existing AMP PIES splices in the Unit I control panels had been installed by craft personnel from late 1982 through mid-1983.
FSAR Amendment 44 was issued in October 1983 to encompass the use of these splices in panels. The NRC evaluation, "The f-'s Safety Evaluation Of Field Splices Inside Control Panels",
(
)
dated September 14, 1984, set forth the guidance on staggering N- '
of these splices in panels. Thus, this guidance from the NRC was received by TUGC0 after the installation of the subject splices.
During plant preoperational and startup testing, all electrical circuits are required to be tested in accordance with Startup Administrative Procedures SAP-6, " Control of Work l
on Station Components After Release from Construction to TUCC0"; SAP-22 " Retest Control"; and XCP-EE8, " Control Circuit Functional Testing". These tests provide the necessary verification that the spliced circuits are functional.
4.0 CPRT ACTION PLAN 4.1 Scope And Methodology The objectives of this action plan were to revise craft construction and QC inspection procedures:
(1) to assure that continuity checks are made at the time of installation of all butt-spliced Class IE essential and associated circuits in control panels, and (2) to assure that Class IE cables containing butt splices in these panels are bundled such that the splices are staggered or separated to comply with the NRC guidance.
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1 Pcgs 3 of 10 RESULTS REPORT ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
A further objective of'this action plan was to review the qualification data for AMP PIES splices to assure that they are qualified for the expected service conditions at CPSES.
These splices are the only insulated splices authorized for Class 1E circuits at CPSES. Uninsulated butt-splices are l
covered by RayChem heat-shrinkable material, which is environmentally qualified for Class lE applications.
(Safety-related electrical equipment requiring application of this material is the' subject of ISAP 1.a.1, " Heat Shrinkable Insulation Sleeves.")
i The following tasks were implemented to achieve the above objectives:
Procedure revisions
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Craft and inspector training D
Review of qualification data l
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4.1.1 Procedure Revisions The following specific subtasks were completed:
Construction procedure EEI-8. " Class IE and non-Class IE Cable Terminations" was revised to include a continuity check of all circuits in control panels in which splices are placed and to require that splices are staggered or separated to comply with the NRC guidance.
Inspection procedure QI-QP-11.3-28. " Class IE Terminations" was revised to add the attributes necessary to ensure that continuity checks of butt-spliced Class IE essential and associated circuits in control panels are made, and that these splices are staggered or separated.
i 4.1.2 Craft and Inspector Training
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The following subtasks were implemented:
Craft personnel were trained using the revised procedures.
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1 Fegs 4 of 10 RESULTS REPORT 0
ISAP I.a.3 (Cont'd) j 4.0 CPRT ACTION PLAN (Cont'd)
Inspectors were trained and certified to the revised procedures.
I 4.1.3 Qualification Data A qualification data package, based on site specific requirements and previously existing vendor documentation was assembled for the AMP PIES splices.
TUGC0 reviewed and approved this package as required by 10CFR$0.49. A third-party engineering review of the _
qualification data package was conducted.
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4.1.4 Use of Results Results of the actions under this plan were to be ovaluated to establish root causes and to identify appropriate corrective action, if required.
O, 4.1.5 Related Activities i'V In accordance with ISAP I.a.2, " Inspection Reports on Butt-Splices," all Class 1E cables found to contain AMP PIES splices will be inspected for any such splices i
that are not staggered or separated.
Upon completion i
of these inspection activities, and any required rework, CPRT will have ensured that all such splices in safety-related cables are staggered or separated. The results of these activities will be presented in the Results Report for ISAP I.a.2.
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I 4.2 Participante Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective work scope.
4.2.1 TUCCO Comanche Peak Project 4.2.1.1 Revised construction and inspection procedures. Trained craft and inspection personnel.
l 4.2.1.2 Processed NCRs that were generated due to this action plan. As discussed in Section 5, none was generated.
g 4.2.1.3 Prepared qualification data package.
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N ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.4 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Reviewed the revised inspection and construction procedures to ensure that requirements for continuity checks and staggered or separated splices were included.
4.2.2.2 Reviewed the training documentation to ensure that adequate training of craft and inspection personnel was performed.
4.2.2.3 Review NCRs that were generated due to this action plan. As discussed in Section 5, none was generated.
4.2.2.4 Performed root cause, generic implications and safety significance evaluations, if necessary.
4.2.2.5 Personnel (prior to October 18, 1985)
Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe. Issue Coordinator 4.2.2.6 Personnel (starting October 18, 1985)
Mr. J. J. M411anda, Review Team Leader Mr. J. R. Pearson, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser Mr. E. P. Stroupe. Third-Party Adviser 4.2.3 Third-Party Adviser 4.2.3.1 Reviewed the qualification data package to ensure that the A"P PIES splices are qualified for the expected service conditions at CPSES.
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,C ISAP I.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3.2 Personnel Mr. L. D. Bates Electrical Engineering Adviser 4.3 Qualification of Personnel Third-party participants in the implementation of this action plan met the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures.
Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel were governed by the applicable principles of Section III.K. " Assurance of CPRT Program Quality", of the CPRT Program Plan.
L 4.4 Procedures Not applicable.
4.5 Acceptance Criteria 4.5.1 The acceptance criteria for the qualification data package were that it provided justification for the use of AMP PIES splices for their specified service conditions; and siet the applicable TUCCO procedural requirements, the applicable IEEE standards for environmental qualification and the requirements of NUREG 0588, Category 1. " Environmental Qualification of Safety-Related Electrical Equipnent." 'Ihird-party engineering review and concurrence was required.
4.5.2 The applicable IEEE Standards applied were IEEE 323-1974, "1EEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations" IEEE 383a1974, "IEEE Standacd for Type Test of Class IE Electric Cables. Field Splices n
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and Connections for Nuclear Power Generating C#
Stations"
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1 Pege 7 of 10
'~w RESULTS REPORT
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ISAP I.a.3 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'dl IEEE 344-1975, "IEEE Recommended Practices for Seismic Qualification of Class IE Equipment for Nuclear Power Generating Stations" 4.6 Decision Criteria i
4.6.1 If it had been determined that the splices were not qualified for their service conditions, they would have been replaced with qualified splices. As discussed in Section 5, this was not necessary.
5.0 DISCUSSION OF RESULTS l
i The following discussions are limited to the results of tasks performed in accomplishing the objectives of this action plan.
4 (All hardware reinspection and documentation review findings related to AMP Pre-Insulated Environmental Seal (PIES) splices will l
be discussed in the Results Report for ISAP I.a.2.)
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Procedures QI-QP-11.3-28 " Class 1E Terminations" and EEI-8 " Class IE and Non-Class 1E Terminations" are referred to as the QC i
(inspection) and craft (installation) procedures, respectively, in the following discussion.
a 5.1 Summary of Implementation l
1 The activities performed under this ISAP consisted oft (1) l revising craft and QC procedures to ensure that all j
installation requirements are clarified and to include the J
additional NRC guidance (i.e., staggering / separation requirements and continuity checks following installation of AMP PIES splices), (2) providing training of craft and QC j
,i personnel to the revised procedures and (3) preparing and reviewing qualification data for'the AMP PIES splices.
5.2 Procedure Revisions 1
The procedures were revised to reflect the NRC guidance for the AMP PIES splices in control panels.
Specifically:
7 Continuity checks are procedurally required on all l
Class IE conductors. However, craft and QC procedures have been revised to ensure that continuity checks are i
performed at the time of installation of the subject i
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splices.
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v' ISAP I.a.3 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd)
Craft and QC procedures have been revised to require that the AMP PIES splices be staggered or separated.
Quality Control " hold points" have been incorporated into the craft procedure, and the QC procedure has been revised to clearly state the attributes that the inspector must verify or witness, as appropriate.
In the past, installation of AMP PIES splices was limited to areas outside the containment building (see drawing 2323-El-1701, Details 18, 18B and 18C).
The current QC procedure further limits the installation of these splices by prohibiting their use in harsh environmental areas, unless authorized by Design Change Authorization, even though qualification has been established for all service conditions at f 's CPSES (see Section 5.4).
l The revised procedures have been reviewed by third-party Electrical v
Review Team personnel and found to be acceptable.
5.3 Craft and Inspector Training Training of craft and QC inspection personnel to the revised procedures was conducted in accordance with applicable site proceduren.
Lesson plans for the revised QC procedure training have been reviewed by third-party Electrical Review Team personnel.
Craft trcining was accomplished using the actual revised procedures. Third-party Electrical Review Team members also reviewed methods for tracking and ensuring proper training for both craft and QC personnel for the applicable procedure revisions for this ISAP. The methods and records of training were found to be acceptable.
5.4 Review of Qualification Data A qualification data package was assembled, reviewed and approved by TUCC0; and reviewed by the third-party electrical engineering adviser and the Electrical Review Team Leader (RTL). This review concluded that the AMP PIES splices are
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qualified for all expected service conditions at CPSES, and
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that adequate documentation had existed at AMP since at least 1982 to demonstrate qualification.
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RESULTS REPORT (V
ISAP I.a.3 (Cont'd) 5.0 DISCUSSION OF RESULTS (Cont'd)
Although qualification has thus been established CPRT found no evidence that TUCCO had previously reviewed the qualification data in accordance with 10CFR50.49 and applicable site procedures prior to installation of the splices. The details of the third-party review are discussed below.
5.4.1 As stated previously, the third-party adviser review concluded that the AMP PIES splices are qualified for the expected service conditions at CPSES. This determination was based upon a review of the AMP Qualification Test Report 110-11004, " AMP Insulated Terminals and Splices for Class IE, Inside Containment Service in Nuclear Power Generating Stations". This report shows that the CPSES plant-specific environmental and esismic parameters have been bounded by AMP'r. qualification testing. The Electrical RTL also reviewed the qualification data package and found it to be acceptable.
5.4.2 The TRT had questioned the qualification of AMP PIES splices. Although actions performed for this ISAP demonstrated that these splices are qualified for their intended service conditions, a remaining issue involves the potential use of components without a complete engineering review of applicable qualification documentation. The generic aspects of this concern are included in the program for DSAP XI, " Electrical /16C Systems and Components Discipline Specific Action Plan."
5.4.3 Since the AMP PIES splices have been shown to be qualified for the intended service condition, no safety-significant condition existed.
5.5 Non-conforming Hardware Conditions Since no non-conforming hardware conditions were identified by the activities performed for this action plan, no NCRs were generated.
5.6 Root Caune and cenerte Implicationn
'O Since no safety-significant deficiency was identified, no root cause or generic implications evaluation was performed.
In a related activity, however, DSAP XI will evaluate whether there are any programmatic deficiencies that involve qualification of site-initiated procurement of electrical components.
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ISAP I.a.3 (Cont'd)
6.0 CONCLUSION
S The AMP PIES splices are qualified for the expected service conditions at CPSES. Craft and QC procedures have been revised to specify both staggering / separation requirements and continuity checks at the time of installation of these splices in control panels. Craft and QC personnel have been trained to these revised procedures.
7.0 ONCOING ACTIVITIES The procedure revisions discussed above have incorporated the NRC guidelines on stagger / separation, and have required continuity checks at the time of installation, for AMP PIES splices in control panels. Though this resolves the issue identified by TRT, CPRT considers that the same procedures should be further revised to include the same requirements for all safety-related installations of AMP PIES oplices. These procedure changes have been recommended to, and accepted by TUGC0 for incorporation.
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Results of the actual reinspection and staggering / separation
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activities will be discussed in the Results Report for ISAP I.a.2.
A general evaluation of the engineering review of qualification of site-initiated electrical component procurements is being performed as part of DSAP XI.
8.0 ACTIONS TO PRECLUDE OCCURRENCE IN THE FUTURE A qualification data package for AMP PIES splices was assembled and reviewed. This review demonstrated that the subject splices are qualified for the expected service condition at CPSES. As such, no further corrective actions regarding qualifications are necessary for this ISAP. Any corrective actions of a programmatic nature determined necessary by the activities being performed as part of DSAP XI will be reported in the Results Report for that DSAP. The procedure revisions and associated training discussed above will provide assurance that all future AMP PIES splice installations will include the continuity check and stagger / separation requirements in accordance with the NRC guidelines.
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