ML20236D651

Safety Insp Rept 50-461/89-06 on 890206-0303.Violation Noted:Failure to Perform Adquate Corrective Action on Kynar Butt Splices & Junction Boxes.Major Areas Inspected:Lers,Reg Guide 1.97 Commitments & Torque Switches

ML20236D651
Person / Time
Site:	Clinton
Issue date:	03/16/1989
From:	Gardner R, Gautam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236D644	List: ML20236D642 ML20236D651
References
RTR-REGGD-01.097, RTR-REGGD-1.097 50-461-89-06, 50-461-89-6, NUDOCS 8903230205
Download: ML20236D651 (22)

See also: IR 05000461/1989006

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'U.S. NUCLEAR REGULATORY COMMISSION I

REGION III

Report No. 50-461/89006(DRS)

Docket No. 50-461 License No. NPF-62 'k

Licensee: Illinois Power Company

500 South 27th Street

Decatur, IL 62525

Facility Name: Clinton Power Station -

Inspection At: Clinton, IL 61727

Glen Ellyn, IL 60137

Inspection Conducted: February 6 through March 3,1989 (Clinton) q

Inspector: A. S. Gautam

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Also contributing to this report is: '

R. Larson, Idaho National  !

i Engineering Laboratories

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l Approved By: R. N. Gardner, Chief /d N I

l Plant Systems Section Date i

Inspection Summary

Inspection on February 6 through March 3, 1989 (Report No. 50-461/89006(DRS))

Areas Inspected: Routine, announced safety inspection of licensee actions

on previously identified findings, Licensee Event Reports (LERs), Regulatory

Guide 1.97 commitments, and torque switches (Modules 92701 and 92702).

Results: Of the areas inspected, one apparent violation was identified

(failure to perform adequate corrective actions - Paragraph 3).

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DETAILS-

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1. Persons Contacted

a. Illinois Power Company (IPCo)_

• D. P.-Hall,-Vice President

J. S. Perry, Assistant Vice President '

• R. D. Freeman, Manager, NSED l

J. G. Cook, Manager, Nuclear Planning and Support j

• J. Greenwood, Manager, Power _ Supply .j

R. E. Campbell, Manager, QA )

• J. W- Wilson, Manager, CPS j

R. E. Wyatt, Manager, Nuclear Training. j

D. L. Holtzcher Acting Manager, Licensing and Safety i

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J.D. Weaver, Director, Licensing '

• E. R. Bush, Director, Nuclear Program Scheduling

• E. P. Vaughan, Director, Operations and Maintenance .

• M. C. Hallon, Acting Director, Nuclear Programs W

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M. E. D' Haem, Supervisor, Engineering I

W. S. Iliff, Supervisor, Licensing Administration

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l *K. A. Baker,' Supervisor, I&E. Interface l

• S. L. Clary, Supervisor, Procurement

• K. Graff, Director, Operations Monitoring

• F. C. Edler, Director, Training. 1

P. Thompson, Supervisor, Elactrical Systems a

T. Butera, QC Engineer J

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( b. U.S. Nuclear Regulatory Commission (USNRC) l

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P. L. Hiland, Senior Resident Inspector a

• S. P. Ray, Resident Inspector

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• Denotes those attending the site exit interview on February 10, 1989.

2. Licensee Action on Previously Identified Findings

a. (Closed) Violation (50-461/87026-03a(DRS)): This item addressed l

l the incorrect qualified life of ASCO solenoid valve ORA 027.

l The calculated qualified life was ' originally based on the valve

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being energized for less than one hour a month while actual

plant conditions required the valve to be continuously energized.

Subsequent to the inspection, the licensee revised their EQ binder

(EQ-CLO24) to reflect the correct qualified life of 9.13 years. The

licensee has also completed further actions to prevent recurrence of

this finding by reviewing all appropriate solenoid valtes in regard

to their qualified life, and have reported' full compliance. No

further concerns were identified.

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b. (Closed) Violation (50-461/87026-03b(DRS)): This item addressed a 1

junction box containing terminal blocks tfut having no weep hole

for removal of accumulated water and condensed moisture during

an accident. Corrective hction for this item is discussed under

Section.2.f of this report.

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c. (Closed)-Violation (50-461/87026-03c(DRS)): (This item addressed l

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an oilplug

drain leakoffound on the

the Low motor Core

Pressure caseSpray

under, Motor IE21-C001. Thethe-upper moto

licensee performed an inspection on August 26, 1987, and reported i

that oil had not leaked from the drain plug. The inspector determined ,

that the oil previously found on'the floor was in fact a housekeeping  !

deficiency that has'since boco corrected. No'further concerns were

identified.

d.

(Closed) Violation (50-461/87026-03d(DRSQ: This item addressed

deficied".:ies found on the Fuel Pool Cn : Ing Pumo 1FC02PA. Deficiencies

includnd a missing bolt on the motor cuanection box, rust on the

motor connection box-sealing surface, a broken thermocouple connection

box cover with no gasket, indeterminate oil'in the pump inboard k

bearing, and a pool of oil under the pump outboard bearing. Subsequent

to the inspection the licensee took immediate corrective action and

completed repairs. l

The inspector reviewed corrective actions taken to prevent the

recurrence of any such maintenance' deficiencies. The licensee

provided records of their preventive maintenance program that

periodically (about every 18 months) requires appropriate activities

to be performed to preserve the qualification of the equipment. The

licensee also provided details of surveillance regularly performed

by plant operators and by quality assurance inspectors. However,

during a brief plant walkdown, the NRC inspector noted a rusty

Limitorque valve stem, a leaky valve, a corroded pipe and a

housekeeping deficiency which had not yet been identified by the

plant's surveillance program. The inspectors had no immediate

safety concerns regarding these deficiencies and the licensee took

immediate corrective action. The licensee was. informed that implemen-

tation of their maintenance and surveillance programs would be further

reviewed during an upcoming Region III maintenance inspection. No

further concerns were identified,

e. (Closed) Violation (50-461/88010-03(DRS)) and Unresolved Item  :

(50-461/87026-01(DRS)): These items identified the lack of

environmental qualification documentation-for two hundred and  !

seventy Thomas and Betts nylon wire caps installed on the 480 V motor

leads of Limitorque operators. Subsequent to this finding, the

8icensee performed a LOCA~ test at Wyle (January 29, 1988) where

it was determined that these wire caps were qualified'for 9.9 years.

The licensee reported reworking t,ome of the wire caps with qualified

Okonite tape and scheduling replacement of others prior to the end

of their qualified life.

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The inspector reviewed corrective steps taken by the licensee.to

prevent recurrence of such a deficiency. The' NRC had identified.

the wire ~ caps as. unqualified.because there was no evidence.in the

licensee's EQ files that these' components were tested along with'

Limitorque actuators. The licensee has now implemented checklist

NF-208 for future EQ reviews which requires the reviewer to" ensure

that the tested equipment _.is identical to the installed ' equipment -

and.thet the equipment has been tested in its installed configuration.-

The licensee also indicated that reviews'are being conducted of

significant event reports submitted by.'the Institute of Nuclear Power

Operations, and .that IPCo is tracking various other . industry. EQ

information and data so as to be' aware of any potential impact'

on the EQ of the equipment at Clinton. No further concerns were

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f. (Closed) Violation ^(50-461/88010-02(DRS)); LER 87-066-00: This:

item addressed the lack of weep holes in EQ junction boxes. These  !

weep holes are required to drain accumulated water;so as:to prevent 1

shorting of electrical circuits in the junction box enclosures. l

Subsequent to this NRC finding, the licensee reported installing-

weep holes in one hundred and fifty six_ junction boxes. .This work

was reported to be complete on November 12,g1987.

The inspector reviewed corrective steps taken to prevent recurrence.  :;

The root cause of this deficiency was defined by the licensee as sr '

unclear installation specification for the junction boxes by the

architect / engineer Sargent & Lundy (5&L).. Consequently, Engineering  !

Change Notices were issued to correct drawings for this requirement I

and S&L specifications were reviewed to identify other discrepancies. J

The licensee indicated that a training program was implemented to

ensure that " appropriate personnel responsible for reviewing

nor.conformance documents and defining corrective actions are )

aware of the need to look for possible generic' implications of-

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problems and take a broad view of remedial actions for hardware

deficiencies."

During this review the inspector identified certain deficiencies

in the licensee's corrective action and determined that full

compliance has apparently not yet been achieved. Deficiencies regarding

inadequate corrective action shall be tracked as a separate item and

are described in Section 3.b of this report.

g. (Closed) Violation 50-461/88010-01(DRS)); Unresolved Item

(50-461/87026-02(DRS)): This item addressed unqualified AMP Kynar

electrical butt splices found to be installed on EQ valve' actuators, >

solenoid valves and electrical junction boxes affecting multiple

safety systems. Subsequent to this finding, these splices failed a >

LOCA test conducted by the licensee at Wyle Labs on October 9 *

through November 19, 1987. Upon learning of these test results,

the licensee immediately located these installed splices in the  :

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plant and reported to the'NRC that '196 Kynar. splices had 'been il

reworked with. qualified tape or Raychem tubing.' This work was' am

reported to be complete on November 18, 1987.-

The inspector reviewed corrective steps taken.by the licensee.to . ;

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prevent recurrence of such a deficiency. The NRC had~ identified thel 'V

Kynar splicesf as unqualified because there was no evidence in,the: 4

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licensee's EQ files that these components'were. tested in their a

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installed configuration. The licensee has now implemented checklist = )

NF-208 which requires the reviewer to ensure that the installed  ;

equipment is identical to the tested' equipment and that the. equipment  :"

has been tested in its installed configuration. The licensee also  :

indicated.that reviews are being conducted of significant event 3 1

reports submitted by the Institute of Nuclear Power Operations ~and- 1I

that IPC is tracking various other industry EQ information and data

so.as'to be aware of any potential impact on the EQ of the equipment l

at Clinton~.

During this current review, the NRC inspector reviewed several licensee 1

identified deficiencies.in the corrective action process. Based on- .

l details described in Section 3;a of this report, full compliance has '

lL apparently not yet been achieved. Deficiencies regarding inadequate

corrective action shall be tracked as a separate item.

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h. (Closed) Open Item (50-461/87026-04(D'RS)): .This item addressed.

the inappropriate location of a "T" drain-in Limitorque actuator

1SX095A such that the "T" drain would not provide drainage.during'an. '

accident. The licensee stated that actuators'1SX095A and B were part

of the' combustible gas control system room _ coolers and that this

system is no' longer required to perform any safety function during

.an accident; thus the actuators are being removed from the EQ list.' q

The NRC inspector noted that the rooms associated with these coolers

are now adequately ventilated by.the containment and that;no. associated

EQ equipment or operator action would be compromised. No further-

concerns were' identified.

3. Licensee Corrective Action on Kynar Splices and Junction Boxes

During the periods of August 17 through October 12, 1987, and February 25

through March 31, 1988, Region III conducted inspections to verify the

environmental qualification (EQ) of electrical equipment at the.Clinton

Station (Inspection Reports No. 50-461/87026(DRS) and No. '50-461/88010(DRS)).

As a result of these inspections, a $75,000 civil penalty was imposed

on Illinois Power Company (IPCo) on June 1, 1988. The' Notice of Violation

(NOV) that accompanied the civil penalty identified.the following two

deficiencies:

10 CFR 50.49(f) requires, in part, that each item of electric equipment

important to safety be qualified by. testing.and/or analysis under

postulated environmental conditions.

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' Contrary to the above, as of August 19, 1987, the_following equipment

important to safety was not qualified by appropriate testing and/or

analysis which reflected the= installed configuration:

• One hundred and ninety-six' AMP-Kynar electrical butt splices 1

installed in valve actuators, solenoid valves and electrical '

junction boxes affecting multiple safety systems,

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• One hundred and fifty-six junction boxes without drainage openings

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(weep' holes) affecting multiple safety systems.

As a result of this violation, the licensee was required to take

corrective steps and' report the results achieved. On June 29,.1988,.

IPC submitted a response to the NOV (DPM-0621-88) stating that the-

following steps had been taken to correct the problem:

Kynar Splices:

"Upon learning of these test results on November 10, 1987, while CPS ,

was in cold shutdown, IP immediately initiated a walkdown of electrical .l

devices in areas where 100% humidity could occur. During this walkdown, l

196 AMP Kynar butt splices in these areas were located. Each of these l

was reworked using qualified tape or Raychem tubing, resulting~ in a. J

configuration that the NRC agrees is qualified. .See NRC Inspection-

Report No. 88010,-Item 88010-01. The walkdown and rework of..all butt

splices in high humidity areas was completed on November 18, 1987,

prior to the time power ascension from the shutdown commenced." ,

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Junction Boxes: -

"This problem was identified as a generic condition on November 5,  !

1987, while the plant was in cold shutdown. IP ordered that the j

plant remain in cold shutdown until all of the junction boxes were i

repaired. A walkdown was conducted to identify:all junction boxes l

lacking required weep holes. A total of 156 boxes.were identified as l

lacking weep holes. These were reworked by drilling a drain hole in i

each box. This work was completed on November 12, 1987, prior to .!

initiating power ascension from the shutdown." i

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Summary of NRC Findings l

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a. KYNAR Butt Splices: l

In December 1988, during routine maintenance activities, the licensee j

identified two Limitorque operators containing unqualified AMP KYNAR  !

butt splices. These valves were included in the population'of

devices walked down by the licensee in 1987. Subsequently, the

licensee initiated a complete walkdown of all EQ devices having

KYNAR butt splices and has identified a current total of six 1

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unqualified KYNAR' butt splices inifive.Limitorque operators. As

a result, these five 10 CFR 50.49 designated valves were inoperable

during plant operation.

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In determining-the: root cause of the inadequate inspections

conducted in 1987, the licensee determined that planning that o I

occurred prior to the first walkdown inspections in 1987'was

incomplete.. The NRC: inspector determined that in regard to these 1li

1987 inspections,'the IPC administrative controls and measures were

inadequate in the areas of planning, training of inspectors, quality.

controls,-documentation, communication, accountability, and

conformance to inspection procedures. Consequently, there was

a certain degree of confusion and some errors made during.the

licensee's inspection process.

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b. Junction Boxes:

During this current review, the NRC inspector identified missing

weep holes in six-boxes installed inside the Unit 1 containment and

in high energy line break areas. The licensee later confirmed that

fifteen 10 CFR 50.49 designated EQ. junction boxes did not have weep

holes for' drainage of accumulated water. -The licensee' indicated that.

weep holes were only -installed in boxes having terminal blocks, and

the contents of the six boxes were qualified for submergence.

All fifteen boxes are inside the containment or-high energy line

break areas (HELB) and are exposed to spray during an accident. Since

the' box is not sealed, water is postulated to pour into the box from-

top and side conduit entries and from unsealed covers. Moisture is

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also introduced during the~ accident through the box cover to condense

f and accumulate in the box. The inspector. requested the licensee.to

verify whether the contents of the boxes without weep holes'were

qualified for submergence. The following items in the boxes were

identified as requiring qualification'for' submergence:

• Raychem splices.

• Okonite Wire, Single Conductor No. 16 19X with 0.015" Okozel

(Tetzel 280) insulation (Instrumentation Cable; Okonite Report

No. SL-IP-1081 dated October 29,1981).

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• Conax Electrical Conductor Seal Assembly (ECSA) with Kapton i

insulated leads (Conax Report IPS-1079, Revision D, May 21,

1984).

• Okonite T-95 and T-35 splicing _ tapes (0konite ' aport No.

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The Raychem splices were found adequately tested for submergence,.

however, the inspector noted that based on the. documentation in the

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licensee's EQ files, the'0konite wire, Kapton' leads and Okonite tapes.

were not qualified'for submergence. The inspector also noted that-

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the summary sheets in the EQ files for Okonite cable and tapes.

stated " Submergence - N/A" and that~there was no apparent evaluation-

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for submergence in these files. .

Subsequent to the NRC concerns identified in Paragraphs 3a and 3b of l

this report, the licensee provided additional documentation in an '

attempt to establish qualification of the Kapton leads, the Okonite

cable, and the Okonite tape for post LOCA submergence.' In regard to

the ECSA Kapton leads, the licensee submitted Conax Report IPS-1079,

Revision D, May 21, 1984 and Conax Installation Manual -IPS-725,

Revision G, February 15, 1985 to address submergence. . The. inspector

noted that in the Conax test, Kapton leads were encased in a tight

polyolefin tube and then inserted in a flex' conduit before being

immersed in water. It was'not clear.whether the. pigtails were wet l

in such a configuration. This is significant;because the Kapton leads I

insta11ed'in the plant have no polyolefin tube or flex conduit in the

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postulated' submerged condition in the field. Further, one of two

samples failed the test requiring modification of the, test. circuit

for.the second sample. It was~not clear how the' measurements were

taken and whether they were taken while the leads were submerged.

Based on a lack of adequate test documentation,'the NRC inspector-

, concluded that the Kapton' leads were unqualified for submergence and'

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that their appropriate junction box enclosures required weep holes.

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In regard to the Okonite cable and tapes, the licensee submitted 'i

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Okonite test reports SL-IP-1081, October 29, 1981 and NQRN-3 which

indicated that a voltage withstand test.at 80 volts / mil was performed ,

on post LOCA test samples immersed in tap water for'five minutes. The  !

inspector informed the licensee that to demonstrate qualification for .

submergence, the~ specimens must be submerged during the test for the-  !

duration required during and after an accident. The licensee also

provided a water absorption test for both Okonite: cable and tapes;

however, this test did not subject the samples'to thermal or~ radiation

aging prior to submergence. Based'on a lack of adequate test

documentation, the NRC inspector concluded that the Okonite cable

and tapes were unqualified for submergence, and that'their appropriate

junction box enclosures required weep holes. Subsequent to these

findings, the licensee immediately installed weep holes in the boxes

to mitigate any immediate safety concerns.

10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" requires, ,

in part, that measures be established to assure that conditions  !

adverse to quality such as defective material and equipment are (

promptly identified and corrected. In the case of significant

l conditions adverse to quality the measures shall assure that the

! cause of the condition is determined and corrective action taken to

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preclude rep'etition. The identification of the significant condition

adverse to' quality, the cause of the condition, and the corrective

action taken shall be documented and reported to appropriate levels

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of management. Based on the NRC review, the licensee failed to l

perform adequate corrective action in repairing the previously '

identified unqualified Kynar electrical butt splices and junction

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boxes without weep holes. This was evidenced by the licensee's

, failure to ensure that corrective actions-taken included; adequate ~ ^

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design control _(weep holes), document control, quality control, t'

and conformance to inspection procedures. The li.censee's failure to ~[

perform adequate corrective action is' considered an apparent ~ violation f

of 10 CFR 50,' Appendix B, Criterion XVI '(50-461/89006-01(DRS)).

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4. Regulatory Guide 1.97 Commitments > l

The. Clinton' Station . Regulatory Guide (RG) 1.97 SER identified two  !

outstanding commitments in regard to_the neutron flux detectors and:

the reactor pressure vessel water level _' fuel zone range indicators.

a. The licensee is committed to upgrade their neutron flux detectors to'

the requirements of RG 1.97, Category 1. _ The inspector informed the

. licensee-that systems were currently available for such applications,

and that.the licensee was required by RG 1.97 to initiate' reviews of.

these systems. The licensee stated that they were currently in the

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process of reviewing available systems and-shall-inform the NRC of '

their progress in thir area.

b. The licensee is committed to provide Class 1E power to reactor-

water level fuel zone range' indicator 821-R610 (Division 2) and

recorder B21-R615 (Division 1). The inspector.' reviewed appropriate

i schematics for independence of power supplies and appropriate

isolation.

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No concerns were identified.

5. Replacement of Limitorque Melamine Torque Switches

A 10 CFR 21 report issued by Limitorque alerted the industry to potential

functional failures of Melamine torque' switches : installed in certain

actuators. According to the. report, the' Melamine shafts of-these torque i

switches are very susceptible to high temperatures and may have become

slightly warped during production. This could cause these shafts to'bre'ak

during operation. The licensee took immediate corrective' action'and

replaced all appropriate EQ valve torque switches with qualified Fiberite

torque switches.

No further concerns were identified. j

6. Mixed Lubricants in Limitorque Actuators

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On February 6, 1987, the licensee identified mixed lubricants in a

Limitorque actuator limit switch gear box. The mixture was apparently

50% Beacon 325 and 50% Mobil 28. These lubricants are not compatible.

The licensee subsequently . issued Special Procedure 8451.01 (current

Revision:17) to ensure mixing would not occur in the future. The-licensee

also checked all appropriate valves for mixing and replaced lubricants

where necessary.

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0n September 15, 1987, the licensee issued Condition'ReportLCR 1-87-09-053,

Revision 0, regarding valves 1FP051 and 1FP054 because maintenance found

Exxon Nebula in these valves while the preventive maintenance document i;

required Sun Oil EP-50. .The licensee reported,"however, that'there was :

no mixing of lubricants and that Exxon Nebula is.a qualified grease. A.

similar' concern was identified on November 18, 1988 regarding; valve 1FC036;. l

however, there was no mixing of lubricants. reported.

No further concerns were identified.

7. Exit Interview

The Region III inspector met with the licensee's representatives (denoted

in Paragraph 1) during a site exit on February 10,~1989. The inspector

i summarized the purpose and findings of the' inspection and the licensee

acknowledged this information. The licensee did not identify any

documents / processes reviewed during the inspection as proprietary. i

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