ML20212J849
| ML20212J849 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/19/1987 |
| From: | Murphy M, Russell J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20212J703 | List: |
| References | |
| 302.01-SQN, 302.01-SQN-R03, 302.01-SQN-R3, NUDOCS 8701280326 | |
| Download: ML20212J849 (10) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 302.01-SQN SPECIAL PROGRAM REPO?,T TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER:
3 i
TITLE:
Possible Lack of Watertight Conduit and Connections REASON FOR REVISION:
To incorporate SRP and TAS comments and SQN Corrective Action Revision 1 Response; CATD 30201-SQ:i-02 and to incorporate ESCP Report 302.01 SQN CATD Number 30201-SQN-01, open items.
To incorporate SQN Corrective Action Plan Response CATD 30201-SQN-01. Revision 2 To incorporate SRP comments.
Revision 3 PREPARATION PREPARED BY:
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DATE REVIEWS PEER:
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CONCURRENCES CEG-H:
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- DATE APPROVED BY:
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/S ECSP MAdAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
1280326 870120 ADOCK 05000327 p
f TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT Ek LOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Electrical and Consnunications Element:
Possible Lack of Watertight Conduit and Connections Report Number: 302.01 - SQN - Revision 3 NAS-85-002 MRS-85-005 TAK-85-001 0
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A W. R. Lagergren Date 1776T
Rsvision 3 I.
Possible Lack of Water Tight Conduit This report evaluates three concerns involving the use of Raychem heat shrinkable tubing for covering cable terminations and splices at Sequoyah Nuclear Plant (SQN). These concerns address both a specific installation deficiency for a solenoid valve termination and overall procedural inadequacies for selection and use of Raychem heat shrinkable tubing for Class IE applications and harsh environment areas.
II.
Specific Evaluation Methodology The first concern evaluated was on procedure inadequacies for selection of the correct application and installation process of Raychem heat shrinkable tubing on terminations and splices at SQN.
TAK-85-001 Guidelines for use of Raychem (coating) on Class IE work are unclear and instructions not consistent.
The specific evaluation methodology used for this concern was to initially review Specification G-38, " General Construction Specification for Installing Insulated Cable, and Applicable Vendor Manuals," then compare them to the station procedure, NA&I-7, for compliance. N&AI-7, " Cable Terminations, Splicing, and Repairing of I
Damaged Cables," was also evaluated for ease of use by electricians without requiring assistance of engineering for normal applications.
Four personal and two telecon interviews were conducted with engineers and supervisors in both maintenance and modifications, quality control personnel, training department personnel involved in the training of N&AI-7, and electrical maintenance personnel. Along with the interviews, a document search was conducted looking for any improper installations caused by procedure inadequacies.
Included in the methodology was a review of industry problems related to the application of Raychem heat shrinkable tubing and how those problems compare to the concerns at SQN.
l Two additional concerns were addressed regarding cable terminations for a specific installation:
NAS-85-002 Adequacy of Raychem on 2-FCV-43-77.
NRS-85-005
. FSV-43-77 did not have the proper Raychem application.
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4 Rsvision 3 Th'e two concerns were evaluated as one issue.
Upon investigation of these concerns by research of-applicable maintenance work request, interviews with personnel in Electrical Maintenance and Electrical Modifications sections and actual inspection of the valves, it has been determined that these two concerns are actually one incident cited by the two sections. The only difference in the concerns was the valve nomenclature--FCV versus FSV. The function of the electric solenoid i
valve, FSV, is an integral part of the air-operated control valve, FCV; and the only terminations in question were the solenoid electrical connections.
These concerns were evaluated to ensure this specific concern was not a generic problem caused by the generic concern about procedural 4
inadequacies.
The specific evaluation methodology used for these concerns was to review the sensitive file for technical information retrieved from a previous investigation.
This information referenced specific maintenance work requests which provided documentation for both the initial work and the rework. From this documentation, a chronology of events was established from the initial work request for replacing the solenoid valve with an environmentally qualified valve to the retermination of the solenoid because of the initial improper installation of Raychem.
Several interviews were conducted with the principals of this problem to ensure the documentation was' accurate and any additional information that could clarify the concerns. Procedure M&AI-7, was reviewed to ensure the work and its documentation was in compliance to station procedures. Additionally, a search was conducted j
for documentation of similar problems in the application of Raychem at SQN. This was followed by a visual inspection of recently terminated connections and splices that had Raychem applied. This representative sample was selected by the evaluator and inspected by the evaluator. an i
electrical maintenance engineer, and quality control.
During this evaluation, a concern was raised regarding the adequacy of documencation in work packages to ensure the material used in the installation of Raychem could be traced back to the original purchase order. A representative sample of work packages using Raychem was thoroughly reviewed for traceability of material.
i III.
Findings Raychem type N heat shrinkable products are the only approved product for insulating splices and terminations in harsh environments for Class IE category A and B equipment (Appendix E of NUREG 0588) and certain non-Class IE. equipment whose failure because of postulated environmental conditions could prevent the satisfactory accomplishment i
of safety functions by safety-related equipment (10 CFR 50.49).
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Ravision 3 9
TAK-85-001 Procedure M&AI-7 is a very complex procedure and difficult to use by the worker in the field. This is a commonly shared view based on interviews with electrical maintenance, quality control, and training personnel. This procedure was developed by Electrical Modifications from a corporate specification, G-38, " General Construction Specification for Installing Insulated Cable," and Raychem manuals.
The information required to select and apply Raychem properly is found in several sections and tables throughout this 45-page procedure.
Electrical Maintenance Section has indice.ted that selection of the proper application is confusing, difficult and time-consuming. Because of this, Electrical Maintenance Section engineers are not only assisting in special applications of Raychem but for standard applications as well.
Electrical Modification personnel do not indicate the same degree of difficulty W*th this procedure. However, they use this procedure in a manner different from Electrical Maintenance. Modifications engineers are initially involved in the preparation of the modification package and specify the correct application of Raychem and the material to be used. The electricians need the procedure primarily for the installation instructions, which are basically a duplication of the Raychem installation manuals.
MRS-85-005 and MAS-85-002 2-FSV-43-77 was replaced on October 5, 1985, to comply with the environmental qualification requirements. The initial installation of the Raychem on October 5, 1985, was satisfactorily inspected to comply with M&AI-7 and the sketch attached to the work request. However, when the cables were terminated and insulated with Raychem, the sleeve was too short. It was not until December 10, 1985, that a question was raised regarding the termination of this solenoid valve. The concern was initially raised by Electrical Modifications and passed along to Electrical Maintenance by way of memorandums. This was visually found and documented on Work Request (WR) 102030 dated January 5, 1986, and corrected on WR 102031 dated January 7, 1986.
Electrical Maintenance resolved the deficiency to the satisfaction of both sections by roterminating and insulating the termination to comply with the sketch and M&AI-7. This specific finding was not caused by inadequacies of M&AI-7 but by improper conformance with the attached sketch.
The NRC has issued # IE Information Notice 86-53, " Improper Installation of Heat Shrinkable Tubing," alerting licensees of potential safety problems because of improper installation. They referenced several plants including Watts Bar (ONP) and Bellefonte (BLN) Nuclear Plants. Because of the combination of this NRC information notice and the specific concerns of Raychem, a visual inspection was performed at SQN on a representative sample of recently performed terminations and splices.
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Rsvision 3 The inspection found a Raychem application on an environmentally qualified motor operator, 2 MV0P-063-04B, to be deficient. Procedure M&AI-7 requires a splice to have a 2-inch overlap from the bared wires. The overlap was found to be only 1-1/2 inches. However, this should not be construed as a total inspection to ensure SQN is in compliance with this notice since only a random sample was inspected only for overlap requirements. The ECTG-Construction Section review":d the applicable WBN noncompliance reports for opplicability to SQN and found them to be unique to WBN.
While reviewing work packages, a documentation concern was discovered.
I Standard Practice SQA 45, Quality Control of Material and Parts and l
Services require that traceability shall be maintained on all CSSC l
items to the original procurement document. To provide this I
traceability, a ecpy of the transfer document (Form 575) will be given IR3 to the craftsman or engineer for inclusion in the work package.
l Standard Practice SQM 2, requires the 575 form, Material Procurement, l
"shall be attached to the work package for qualified equipment unless I
waived by the section supervisor."
l The review of the representative sample of work packages for adequate documentation found the following:
a.
Only 7 of the 26 work packages reviewed had the material form, 575 attached. Only 4 packages were not 10 CFR 50.49 packages. No waivers were documented.
b.
All packages did reference the 575 form for traceability to original purchase order. However, 6 packages referenced the wrong number. This was a result of the worker incorrectly writing down the wrong number of the 575 form because of its number being illegible. The only way traceability was ensured was to verify that similar work packages that referenced this 575 form had the form attached. Other information on the attached 575 form identified the original purchase order and specifications.
If similar packages referencing the same form were not performed, traceability could not be ensured.
c.
The 575 forms attached to the work packages do not reflect the I
equipment it was used on.
The information on the top of Form 575 l
(description, system, MR, account number) lists only the equipment I
it was to be used on when removing it from Power Stores to transfer IR3 it to another centro 11ed location. When the item is removed from l
that location, the form is not changed to record the equipment it I
is to be used on.
If the form is misplaced, traceability may be I
indeterminant.
I d.
If a sketch was not attached, it could not be confirmed how many I
splices were performed for the configuration of the splice in a I
work package. Documentation did not specify how many splices were I
performed or what material was used for each splice. Only by a lR3 thorough review of the work package and visual inspection in the l
field could an actual assessment be made to determine how many l
splices were installed.
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Rzvlsion 3 Two recent Corrective Action Reports were reviewed for applicability to these concerns. CAR-86-03-15 identified a specific problem where an engineer incorrectly designed a splice within the limits of the standard design drawings. He received oral approval from corporate and proceeded with issuance of workplan. This splice had to be respliced to the requirements of M&AI-7.
CAR-86-040 identified a failure of several environmental equipment solenoids not having the approved Raychem on their terminations. This was due to a programmatic problem and not caused i by a violation of M&AI-7.
Neither CAR substantiates or dispels lR3 the subject concerns.
I Conclusions 1.
Concern TAK-85-001 is a valid concern. M&AI-7 is unclear when trying to specify the correct application of heat shrink insulation on a splice. The modification procedure attempts to satisfy all modification and maintenance problems with terminations, splicing, and repairing and include all vendor information from technical manuals.
However, since no programmatic or physical discrepancies could be found as a result of this investigation, the concern is not considered to have a safety impact on the plant although engineering time used for identifying standard splices is excessive mainly because the modification procedure is very compler.
Therefore, this concern has no safety significant impact.
2.
Concerns MRS-85-005 and NAS-85-002 were determined to be valid as documented in WRs referenced in the findings. However, the concern was satisfactorily resolved when the termination was corrected on a subsequent WRs. Since the plant was shutdown during the duration of this concern, and subsequent corrective action has been completed, no safety-related requirements have been compromised for this case.
3.
The visual inspection of the representative sample of Raychem installations found evidence of another deficient application which had originally passed QC inspection. Because of the results of this inspection, a generic problem could not be ruled out. This additional finding is a safety-related issue.
4.
The material control aspect of this concern is adequate in that the l
Material Control Program as specified in SQM 2 and SQA 45 meets the l
requirements for 10 CFR 50.49.
However, implementation of the l
program itself has been diluted by plant personnel who have not lR3 strictly followed the procedural requirements regarding use of the l
Requisition Form 575. The program requires that the Requisition l
Form 575 be attached to all 10 CFR 50.49 equipment work packages and I
should be attached to all safety-related work packages to ensure traceability.
It should further be noted that a traceability could be lost if each requisition is not identified to the equipment which it was used. Presently plant personnel do not indicate on Form 575 the equipment it is to be used on.
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R1 vision 3 IV.
Root Cause The procedure for using Raychem heat shrinkable tubing is too complex.
The application of Raychem by its nature, has many different configurations.
For the many wire sizes, different terminations, and splices in a nuclear plant, there must be a suitable Raychem kit to conform to the unique configurations. Training is necessary to ensure compliance to this procedure and to ensure that all electriciana apply and install the Raychem heat shrinkable tubing properly and consistently.
V.
Generic Applicability Concern TAK-85-001 should be considered generic to all sites because of the compliance to specification G-38 not being unique to SQN.
VI.
References 1.
10 CFR 50.49(b)(2) Equipment Qualification Section 2.
IEEE Standard 383-1974 Class IE Cable, Splices, and Connections 3.
IEEE Standsed 323-1983 Class IE Qualifications 4.
IEEE 336-1985," Installation, Inspection, and Testing for Power, Instrumentation, and Control Equipment, 4-85" 5.
M&AI-7." Modification and Additions Instruction on Cable Terminations, Splicing, and Repairing of Damaged Cable" 6.
Raychem Vendor Manual;
" Instruction for In-Line Splice Application Guide, 825348-2720," Revision 1. August 1983 7.
Raychem Vendor Manual:
" Installation Instructions WCSF-N Heavy Wall Flame Retarded Nuclear Cable Sleeves 825348-2721," dated March 1985 8.
Raychem Nuclear Motor Connection Kit Ins'tallation Instructions, 825348-2705 dated August 1980 9.
IE NRC Information Notice 85-53; " Improper Installation of Heat Shrinkable Tubing," dated June 26, 1986 10.
SQM-2 Standard Practice, Revision 18 11.
SQA 45 Standard Practice, Quality Control of Material and Parts I
and Services, Revision 21 (R3 Page 6 of 7
Rsvision 3 VII.
Immediate and Long-Term Corrective Actions SQN Corrective Action Plan Response 1.
In response to IE Information Notice 86-53 and the Environmental Qualification program, Sequoyah will have.an inspection program for Raychem applications. This work activity can be found in the unit 2 Project /2 network as zone 3144. The present duration is indeterminate until the program is defined by the Division of Nuclear Engineering.
(CATD 30201-SQN-02)
- 2. & 3.
SQM-2 and AI-19 are quite specific in the requirements of material traceability, including 10CFR50.49 equipment. The procedures comply with the requirements of SQA-173, " Environmental Qualification Program."
Training classes will be conducted to reempahsize the requirements of AI-19 and SQM-2 for material traceability. These classes should be completed by December 12, 1986 (CATD 30201-SQN-01).
4.
Section 7.0 of M&AI-7 describes Raychem installation instructions.
M&AI-7 is indexed to describe splices and terminations of various sizes and types of cables. These sections reference applicable standard drawings to be followed.
It is not practical to have one procedure.to describe the splice or termination and another procedure to execute the splice cr termination.
5.
Electrical Maintenance will review M&AI-7 and propose improvements to the procedure. The Electrical Maintenance Supervisor expects to complete this review by January 30, 1987.
If revisions to the procedure are necessary, this should be completed by March 30, 1987 (CATD 30201-SQN-01).
Page 7 of 7
D TENNESSEE VALLEY AUTHORITY' PAGE-F l i l F! !H I
- FCPSl?0J-ECPS121C OFFICE OF NUCLEAR PONER RUN TIME -
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- RLOULST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUsl DATE g
uni - 1555 - Ri!!1 LIST OF EMPLOYEE CONCERN INFORMATION CATLGORY: OP PLAtlT OPER. SUPPORT SUBCATEGORY: 30201 POSSIBLE LACK OF HATERTIGHT CONDUIT AND CONNECTION KEYHORD A S
GENERIC g
H APPL QTC/N3RS P
KEYHORD B C0flCERii SUB R PLT BBSH INVESTIGATION S
CONCERN KEYHORD C NUf13ER CAT CAT D LOC FLQB REPORT R
DESCRIPTION KEYHORD MAS-35-002 OP 30201 N SQ!!
NNNN NS ADEQUACY OF RAYCHEM ON 2-FCV-43-77 K-FORM 2
9 MRS-85-005 OP 30201 N SQN NNNN SS 2-FSV-43-77 DID NOT HAVE THE PROPER K-FORM RAYCHEM APPLICATION D
TAK-ES-001 OP 30201 N SQtt YYYY NS GUIDEL!NES FOR USE OF RAYCHEM (COATI REPORT NG) ON CLASS IE HORK ARE UllCLEAR AND g
INSTRUCTIONS NOT CONSISTENT.
3 C0t4CERtiS FOR CATEGORY OP SUDCATEGORY 30201 p
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