ML20207R727
| ML20207R727 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/11/1987 |
| From: | Josiger W POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IP3-JAS-025B, IP3-JAS-25B, IP3-WAJ-019Z, IP3-WAJ-19Z, NUDOCS 8703180071 | |
| Download: ML20207R727 (4) | |
Text
L Indian Point 3 Nuclear Power Plant P.O. Box 215 Buchanan, NewWrk 10511 914 739.8200
- > NewYorkPbwer tsf Authority March 11, 1987 IP3-WAJ-019Z IP3-JAS-025B Docket No. 50-286 License No. DPR-64 Mr. Stewart D. Ebneter, Director Division of Reactor Safety U.S. Nuclcar Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406
Subject:
Inspection No. 50-286/86-24
Dear Mr. Ebneter:
This letter provides the Authority's response to your Inspection Report No. 50-286/86-24 dated February 10, 1987 and received at this office February 17, 1987.
Attachment I to this letter addresses the concerns cited in Appendix A, Notice of Violation, of the Inspection Report.
Should you or your staff have any questions concerning this matter, please contact Mr. M. P. Cass of my staff.
Sincerely, f6
-/
Wylam. Josi er b
Resident Mana r Indian int Unit 3 Nuclear Power Plant WAJ-
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<3 cc: Nuclear Regulatory _ Commission (original)
Document Control Desk Washington, D.C.
20555 U.S. Nuclear Regulatory Commission 631 Park, Avenue King of._ Prussia, PA 19406 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 215 Buchanan, NY' 10;11
ATTACHMENT I VIOLATION A)
The installation instructions for Raychem cable splices prescribed in Work Request No. 8918 dated August 27, 1986, step #7 states that " shrink tubing on splice connection making sure that the minimum covering on insulation is at least 2 inches."
Contrary to the above, on December 17, 1986, while in the Pipe Pene-I tration area, the inspector identified four splices associated with transmitters PT-949A and B, with seal length (covering the cable insul-ation) less than 2 inches.
B)
Raychem Installation instruction for WCSF-N splices requires the minimum bending radius of the in-line tube splices to be 5 times the outside I
diameter.
10 CFR 50 Appendix B, Criterion V states in part, that " Activities affecting quality shall be prescribed by documented instruction, proced-ures,.,... and shall be accomplished in accordance with these instructions Contrary to the above, on December 17, 1986, the inspector identified that 1) the installation instruction used by the licensee to install Raychem WCSF-N splices do not prescribe the minimum bending radius requirements and 2) there are three in-line tubing splices (one for transmitter PT-948C and two for PT-948A) bent with a radius much less than 5 outside diameters.
RESPONSE
The Authority has reviewed the violation and associated issues presented in Inspection 86-24 and acknowledges the violation as presented.
Both aspects of the violation can be attributed to either a failure to follow written /
classroom instructions or deficient work practices.
Regarding the splice overlap deficiency, written instructions were provided with the work request which installed the splices. While the NRC inspector commented in Inspection Report 86-24 that the instructions may have been misleading or confusing, the instructions coupled with the training that had been provided at that time should have resulted in an appropriate splice being installed.
Regarding the issue of minimum bend radius, while written instructions concerning this item were not provided, the topic of appropriate bend radius has been addressed in classroom training and is considered in the realm of a craftsmen working level of knowledge.
In both cases the deficient splices were not detected by the job supervisor or the assigned QC Inspector. These failures indicate the need for additional training and increased detail in installation instructions.
1 As a result of the identified deficiencies, appropriate Authority electrical maintenance workers and foremen have been extensively retrained on the use of Raychem splices, including minimum bend radius.
Included in these classes were the appropriate Authority's site electrical QC inspectors. The QC inspector who performed the inspection on the Raychem cable splices had not undergone formal training on this item.
A detailed procudure addressing the applications and installation of Raychem splices has been written and is currently undergoing site review. This procedure includes guidance provided by the Raychem product guide noted in the violation. Specifically, the procedure will specify a splice seal length overlap of not less than 2 inches and a bend radius of not less than 5 times the cable diameter. This new procedure will be used as a reference document for preparation of Work Requests and will result in greater detail in step list instructions. This procedure is expected to be approved for use no later than April 15, 1987.
The Raychem splices identified with seal length overlap less than 2 inches and the Raychem splices found with a bend radius less than 5 times the cable diameter were associated with the containment pressure transmitters.
Testing performed by Wyle Laboratories has demonstrated the qualification of Raychem heat shrink tubing with two sharp 180* bends (specimens bent at the splice into the tightest collapsed "s" curve physically possible) and 1/8 inch overlap onto the cable insulation. The specimens were qualified to a LOCA test profile which bounds the IP3 LOCA containment response. This testing has been confirmed by a number of industry tests including those conducted by Commonwealth Edison Co. and TVA. The Nuclear Utility Group on Equipment Qualifications, of which the Authority is a member, is presently finalizing summaries of these tests for the NRC Staff. Furthermore, these transmitters are located outside containment in the pipe penetration area and required to function in a harsh environment consisting of high radiation, only. They are not exposed to environmental conditions for which splice overlap and bend radius considerations are critical. Based on the above, the Authority considers it unnecessary to modify the Raychem splice installations referred to in the Notice of Violation.