ML20235U342

Responds to NRC Notice of Violation Re Violations Noted in Insp Repts 50-295/86-16 & 50-304/86-15.Corrective Action: Sample Splice Representatives Submitted for Qualification Testing at Lab Under Direction of Util Engineering Dept

ML20235U342
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/22/1987
From:	Butterfield L COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
3370K, NUDOCS 8710140043
Download: ML20235U342 (3)

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~ [N ' Commonwealth Edison a r" ' .8 i- 'l i ) ' Oni First Nrtiond Plazt, Chicago, Illinois

.I U Address R; ply to: Post Offics Box 767 Chicago, Illinois 60690 0767 July 22, 1987 Mr. A. Bert Davis Regional Administrator U.S.' Nuclear Regulatory Commission Region III 799 Roosevelt, Road Glen Ellyn, IL 60137

Subject:

Zion Nuclear Power Station Units 1 and 2 Response to Inspection Report Nos.

50-295/86-16 and 50-304/86-15 NRC Docket No. 50-295 and 50-304 References (a): August 7, 1986 letter from J.J. Harrison to Cordell Reed (b): June 15, 1987 letter from J.J. Harrison-to Cordell Reed

Dear Mr. Davis:

This letter is in response to the inspection conducted by A.S. Gautam and others of your office on July 9, 10, and 29, 1986, of ..

activities at Zion Nuclear Power Station. Reference (a) transmitted the subject Inspection Reports, which included a discussion on Raychem splices.

Reference (b') indicated that Commonwealth Edison's use of Raychem' Splices appeared to be in noncompliance with NRC requirements. Commonwealth Edison Company's response to tais violation is provided in the Attachment to this letter. A 7 day extension was obtained from J.J. Harrison by telecon on July 13, 1987.

If you have any further questions on this matter, please direct them to this office.

Very truly yours, N

L.D.Butterfkeld Nuclear.. Licensing Manager Cs l i

Attachment cc: NRC Resident Inspector - Zion J. A. Norris.- NRR 4

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"- ATTACHMENT ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION l

ITEM OF NONCOMPLIANCE As a result of the inspection conducted on July 9, 10, and 29, 1986 and in accordance with 10 CFR part 2, Appendix C - General Statement of 4 Policy and procedure for NRC Enforcement. Actions (1985), the following violation'was identified:

10 CFR 50.49 Paragraph'(f) requires each item of electrical equipment important to safety to be qualified by testing and/or analysis.

Contrary to the above, Raychem Heat Shrinkable Tubing (HST) used in 10 CFR 50.49 designated applications was installed in unqualified configurations. Deficiencies included 1) improper seal lengths relative to qualified configurations; 2) fiberglass braid material not stripped back from under the splice; and 3) the HST found exceeding specified bend radius.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Sample splices representative of those splices that were not qualified by reason of improper seal length, excessive bend radius, or lack of fiberglass stripping were prepared at Zion Station. These samples were submitted for qualification testing at Wyle laboratories under the direction of Commonwealth Edison's Station Nuclear Engineering Department. The test conditions were selected to fully envelope the required environmental conditions as referenced in 10 CFR 50.49. All test results were satisfactory.

Visual inspections on both units were performed on all E.Q. splices that were specified to utilize the Raychem HST. All HST splices that were originally considered to be unqualified and that were not subsequently qualified by the testing program discussed above have been replaced on Unit 1. The required replacement of splices on Unit 2 will be complete prior to the completion of the current refueling outage.

All Commonwealth Edison Personnel involved in E.Q. heat shrink tubing splice installation at Zion Station have been given special training in splice installation by the splice manufacturers' certified representative. This training is a videotape presentation made by Commonwealth Edison specifically for Zion Station.

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The Zion Station Quality Control Department has implemented a required review of the future installation of all splices having stub connections. In addition, the QC department is documenting all' future inspections of splice connections.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION All Commonwealth Edison personnel performing E.Q. heat shrink tubing splice installation at Zion Station will receive training prior to their initial splice installation. Retraining will be provided at an interval no greater than every two years.

.The special procedure used to inspect the existing splices will be converted into a permanent inspection procedure for use-on all-future

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Environmentally Qualified heat shrink tubing splice installations.

DATE WHEN FULL COMPLIANCE WILL BE MET' All necessary inspections and splice replacements will be. completed on Unit 2 by the end of the current refueling outage.

All associated procedure changes will be completed by.

October 1, 1987.

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