ML20215C136
| ML20215C136 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/17/1987 |
| From: | HOUSTON LIGHTING & POWER CO. |
| To: | NRC |
| References | |
| NUDOCS 8706170594 | |
| Download: ML20215C136 (1) | |
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ERRATA--
l Replacement.for ST-ilL AE-2239.
Previously mailed letter contained as an attachment the " Third Interim Report Concerning Electrical Splices Using i
Raychem 11 eat Shrink", instead of the Final Report as attached hereto, i
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I 8706170594 870617 I
.PDR. ADOCK 05000498 :
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The Light company H-n ugMng u-m nox 1700 nouston, Texas 77001 (713) 228 9211 June 10, 1987 ST-HL-AE-2239 File No.: G4.02 i
10CFR50 l
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Raychem Splices
References:
1.
Letter ST-HL-AE-2242, dated June 10, 1987 2.
Letter ST-HL-AE-2235, dated June 8, 1987 In the Safety Evaluation Report Supplement (SSER) No. 3, it is stated on page 8-2 concerning Raychem splices, "...the staff requires the applicant to perform a visual inspection of all penetration splices located inside and outside the containment and to rework all splices that do not conform with the vendor's installation instructions".
In addition to the penetration splices, the remaining safety-related Raychem splices have been inspected except for thirty-seven (37) termination ends. As discussed in Reference 1 (attached), thirty-six (36) of these 37 termination ends have been spliced between an environmental seal (Electrical Conduit Seal Assembly-ECSA) and the instrument being sealed, and one (1) termination end is a splice to a solenoid operated damper, located in a mild environment, which is not readily accessible.
In all 37 cases, the Raychem splice's only required function is to provide electrical insulation, not an environmental seal.
Based on a review of the Class 1E termination cards and test data discussed below, these 37 termination ends have been accepted as-is.
As also discussed in Reference 1, splices which did not meet the Raychem installation requirements were evaluated for acceptability based on test data.
As discussed in Reference 2, splices found to be acceptable using the test data were not reworked to conform with Raychem installation instructions.
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SO 8706/7 6,y
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Houston Lighting & Power Company 987 1
ST-HL-AE-2239 t
File No.: G4.02 Page 2 i
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' Based on this information, we request the SER section quoted above be.
restated to correctly reflect the actual program being performed at STP to-address the Raychem splice issue.
l If you should have any questions on this matter, please contact Mr.
M. E. Powell at (713) 993-1328.
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M. R. W senburg Manager, Engine ing an Licensing RLP/yd j
Attachment:
Final Report Concerning Electrical Splices Using Raychem Heat Shrink i
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ST-HL-AE-2239 File No.: G4.02-Page 3 cc:
Regional Administrator, Region IV M.B. Lee /J.E. Malaski Nuclear Regulatory Commission City of Austin.
611 Ryan: Plaza Drive, Suite 1000 P.O. Box 1088
- Arlington, TX 76011 Austin, TX 78767-8814 i
N. Prasad Kadambi, Project Manager A. von Rosenberg/M.T. Hardt i
U.S. Nuclear Regulatory Commission City Public Service Board 7920 Norfolk Avenue P.O. Box 1771 i
Bethesda, MD 20814.
San Antonio, TX 78296 Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards-i U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission l
7920 Norfolk Avenue 1717 H Street Bethesda, MD 20814 Washington, DC 20555 Dan'R. Carpenter
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Senior Resident Inspector / Operations c/o U.S. Nuclear Regulatory
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Commission P.O. Box 910 1
Bay City, TX 77414 i
Claude E. Johnson Senior. Resident Inspector / Construction c/o U.S. Nuclear Regulatory
. Commission
'P.O. Box 910' Bay City, TX 77414 M.D. Schwarz, Jr., Esquire Baker & Botts One Shell Plaza Houston, TX 77002 J.R. Newman, Esquire Newman & Holtzinger, P.C.
'1615 L Street, N.W.
Washington, DC 20036
.T.V. Shockley/R.L. Range Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403 j
e ATTACHMENT ST HL-AE. sag}
I 0F5 PAGE The Light Company n-,,, ugi,n,,g a,,m m n.,um n->,i.was, moi m5msmn 1
June 10, 1987 1
ST-HL-AE-2242 File No.: G12.364, G2.2 10CFR50.55(e)
I U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 l
South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Final Report Concerning Electrical Splices Using Raychem Heat Shrink r
On February 19, 1987, Houston Lighting & Power Company notified your office pursuant to 10CFR50.55(e) of an item concerning electrical splices using Raychem heat shrink insulation material.
Enclosed is our Final Report on this item.
If you should have any questions on this matter, please contact Mr.
C. A. Ayala at (512) 972-8628.
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!wJ s-H. Goldberg Group Vice President, Nuclear CAA/hg Attachments:
Final Report Concerning Electrical Splices Using Raychem Heat Shrink 2706/7 63 L4/NRC/es/hg-0
.sa ATTACHM Raf
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H ST-HL-AE-2242.
c Hou$ ton'11ghting & Power Cornpany Pile No.: C12.364, C2.2 1
Page 2-
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~ Regibna1' Administrator,J Region IV.
M.B. Lee /J.E. Malaskt
' Nuclear Regulatory Conni.ssion City of Austin
'611.Ryan Plaza Drive, Suite 1000 P.O. Box 1088 Arlington,'TX. 76011 Austin, TX 78767-8814 N. : Prasad Kadambi, Project Menager M.T. Hardt/A. von Rosenberg U.S. Nuclear Regulatory Commission City Public Service Board 7920 Norfolk Avenue P.O. Box 1771
.Bathesda, MD 20814-San Antonic, TX 78296 Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission.
U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue 1717 li Street Bethesda, MD. 20814 Washington, DC 20555 Dan R. Carpenter Senior Resident Inspector / Operations 1
e/o U.SL Nuclear. Regulatory Commission P.O. Box:910 Bay City, TX 77414 a
Claude E. - Johnson U
Senior Resident Inspector / Construction c
c/o.U.S. Nuclear Regulatory Commisilon
~P.O. Box 910
' Bay City, TX 77414 3-
'M.D. Schwarz, Jr., Esquire Baket'6 Borts-One Shell Plaza'
!!autston, TX 77002 o
J.R/ Newman~, Esquire Newman'& Holrzinger, P.C.
1615 L Screet, N.W.
Wa shington, DC_ 20036 T.V..Shockley/R.L. Range Central Power & Light Company
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P.'O.
Box 21F.1 Corpus Christi,'TX 78403 1
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L4/NRC/es/hg-0 Revised 2/3/87 t
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n ATTACHMENT ST HL.AE =7;;t S$
PAGE S OFS 0 tachment ST-HL-AE-2242 I
File No.: G12.364, G2.2
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Page 1 of 3 l
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South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50 499
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Final Report Concerning j
Electrical Splices Using Raychem Heat Shrink j
i I. Summary On February 19, 1987, Houston Lighting & Power (HL&P) notified NRC Region IV, pursuant to 10CFR50.55(e), of a reportable item concerning safety related electrical splices using incorrectly installed Raychem heat shrink insulation material. This deficiency affects various safety related circuits.
If left uncorrected, the safe operation of the plant j
could have.been affected.
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1 II. Description of Deficiency During an NRC Electrical Audit, Raychem heat shrink material used for in-line splices was discovered to have been installed incorrectly.
Shims required by existing procedures which are necessary to assure proper installations were omitted.
Installations did not consistently follow vendor instructions. Additionally, site procedures did not require Raychem installations to be inspected for conformance with vendor instructions. Also Raychem's requirement for installing the heat shrink material with a " maximum bend radius of five times the outside diameter" of the cable was not included in the installation requirements.
The only bend radius requirement included was that the cable bend radius could not be violated.
As a result, there were some splices found with deficiencies.
Immediately afterward, a review of the Class 1E termination cards to determine the location and acceptability of safety related splices was conducted which identified numerous Raychem deficiencies which required further evaluation to determine acceptability.
During this evaluation, discrepancies were found between the as-built condition and the termination cards.
In addition, j
configurations were identified where non-qualified Raychem kits were l
installed in Class 1E applications.
III. Corrective Action An inspection has been completed to determine the total number of incorrectly installed splices.
Termination ends which did not meet installation requirements were identified as nonconforming.
These have been evaluated for acceptability based on test data from Commonwealth Edison (Wyle Test Reports #17859-02B & 02P) Toledo Edison (NTS Test Report #22414-87N), and the Tennessee Valley Authority (CCL Test Report 86 1995).
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XiTACHMENT ST HL AE4d, e
PAGE LJ OFJs Attachmant ST-HL-AE 2242 File No.: C12.364, C2.2 Page 2 of 3 l
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i Thirty-seven (37) termination ends were not physically inspected.
Thirty-six (36) of these termination ends have been spliced between an environmental seal (Electrical Conduit Seal Assembly-ECSA) and the instrument being sealed. These heat shrink installations are sealed from the environment such that the heat shrink material's only function is to provide electrical insulation for the splices. One (1).of the thirty-seven cables is spliced to a solenoid operated damper which is not accessible due to its location.
This splice is located in a mild environment, and, as such, the heat shrink material's only required function is to provide electrical insulation. Additionally, based on inspection records and test data, these termination ends have been dispositioned as acceptable as-is.
There are five (5) termination ends remaining which require rework. This rework is targeted for completion by fuel load.
As a result of the bend radius portion of the deficiency, a review of installation instructions for other commodities has been completed which determined that the vendors instructions were properly included in l
project documents. This review included the following:
A)
I & C -Flex Hoses, Tube Fittings (Parker Hannifin) b)
Civil Cadwelds, Maxi Bolts, Hilti Bolts,
& Coatings C)
Electrical-Crimped Terminations, Electrical Connectors No other conditions where vendor instructions were not incorporated into project documents were found.
IV. Recurrence Control 1)
Craft, Field Engineers, and Field Quality Control (FQC) personnel have been reinstructed on the use of Raychem material in accordance with project procedures and drawings.
2)
Site Standard Procedure 26 " Termination of Electrical Cable" has been revised to require that Class lE Raychem splices be installed and inspected to approved engineering details.
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4; ATTACHMENT ST HL AE tR6tb@
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PAGE 5 OF 6 Attachment ST-HL-AE-2242 File No.: G12.364, G2.2 Page 3 of 3 V. Safety Analysis
'The deficient. splices are in circuits for various safety related systems.
The potential exists that circuit malfunctions (shorts, grounds, or opens);could occur in a harsh environment and cause associated equipment or instrumentation failure.
For example, a failure of the Raychem heat shrink. insulation to maintain'the electrical integrity of the cables could result in malfunction of associated motor operated valves (MOVs).
Had these deficiencies remained uncorrected, failure of MOV's to operate properly could have affected safe operations of the plant. Therefore, HL&P has determined that this item is reportable pursuant to
=10CFR50.55(e).
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