ML20206L425

Insp Repts 50-277/88-38 & 50-278/88-38 on 880926-30. Violations Noted.Major Areas Inspected:Licensee Corrective Actions for Previous Environ Qualification (EQ) Findings & Licensee EQ Documentation Re Cable Splices Qualificability

ML20206L425
Person / Time
Site:	Peach Bottom
Issue date:	11/01/1988
From:	Anderson C, Cheung L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206L417	List: ML20206L412 ML20206L418 ML20206L425
References
50-277-88-38, 50-278-88-38, NUDOCS 8811290567
Download: ML20206L425 (9)

See also: IR 05000277/1988038

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-277/88-38

Report Nos. 50-278/88-38

50-277

Docket Nos. 50-278

DPR-44

License Nos. OPR-56 Priority --

Category C_

Licensee: Philadelphia Electric Company

P.O. Box 7520

Philadelphia, Pennsylvania 19101

Facility Name: Peach Bottom Atomic Power Station, Unit 2 and 3

Inspection At: Delta, Pennsylanvia

Inspection Conducted: September 26-30, 1988

Inspectors: W d-or Engineer

Leonard Cheung, Senior Re date

Approved by: / // ' f I

C. J// Andarson, Chief date

Plan't Systems Section, EB/ ORS

Inspection Summary: Inspection on September 26-30, 1988, Combined Inspection

Report Nos. 50-277/88 9 and 50-278/88-38

Areas Inspected: Special announced inspection to review the licensee's

corrective actions for previously ident'fied environmental qualification (EQ)

findings and to review the licensee's EQ documentation to determine the

qualifiability of the deficient cable splices identified by the licensee.

Results: A) The following violations were identified (three were identified

by the licensee, one example was identified by the NRC):

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Identified Discussed in

Violation By Paragraph .Itam Number

1. Wire crimps in NRC 2.4 00-277/88-38-01;

Limitorque Valve 50-278/88-38-01

Actuators

2. Raychem Cable Licensee 3.1 50-277/88-38 02;

Splices 50-278/88-38-02

3. Ideal Wirenuts Licensee 3.2 50-277/88-38-03;

50-278/88-38-03

4. Amp Butt Splices Licensee 3.3 50-277/88-38-04;

50-277/88-38-04

B) Four unresolved items were closed.

Item No. Title Status

50-277/87-18-01 Identification of RG1.97 instrument Closed

50-278/87-18-01 in control room.

50-277/87-18-03 Raychem cable splice on braided cable Closed

50-278/87-18-03

50-277/87-18-05 Qualification of Rockbestos Closed

50-278/87-18-05 coaxial cables

50-277/87-18-07 Qualification of wire crimp Closed

50-278/87-18-07 in Limitorque valve actuators

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Details

Persons Contacted

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. 1.1 Philadelphia Electric Company (PECO)

D. Ahmuty, Training Records

R. Artus, Requalification Instructor,

• W. Birely, Peach Bottom Licensing Branch

• C. Boyce, Peach Bottom Licensing Branch

• 0.-Brown, Peach Bottom Material Superintendent

a *W. Clune, Engineering Service Section/PECO

• J. Evans, Nuclear Quality Assurance

K. Flaming, Peach Bottom Field Engirwer

• F. Lear, Peach Bottom Licensing Branch

G. Lengyel, Peach Bottom Maintenance Engineer

, "M. Lohr, Engineering Service Section/PECO

!- L. MacEntee,

R. Maldonado, Reactor Operator, Peach Bottom

• M. McKenna, Peach Bottom Lead Project Engineer

• R. Ogitis,' Instrument System Ergineer

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• R. Rock, Engineering Service Section, PCDB

1 *D. Thompson, Jr. Engineering Service Section/PEC

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1.2 Consultants

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• G. Chew, DiBenedeto Associates, Inc.

• S. Dasgupta, Gilbert Associates

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l 1.3 United States' Nuclear Regulatory Commission

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T. Johnson, $enior Resident Inspector

L. M/ers, Resident In pactor

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• Denotes those present at the exit meeting on September 30, 1988 at the

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Corporate Office.

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2.0 Review of Licensee's Corrective Actions _on Previously Identified

FQ Findings

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2.1 Closed (50-277/87-18-01; 50-278/87-18-01) pertaining to the

identification of RG 1.97 indicating instruments in the control

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room, and the licensee's commitment to train their control room

j operators to recognize the reliable instrumentation under the given

accident conditions. The licensee had undertaken several corrective

actions to resolve this deficiency.

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1) For the instrument identification part, the licensee: initiated

modification package #2132 on July 22, 1987, entitled "Control

Room Panels Human Factors Enhancements". The inspector reviewed

Revision 5 ci the "Construction Job riemorandum, Doc. #107 for

. - Modification Package #2132" dated February 24,1988. Job de-

scription No. 2 outlines the modification to provide identifica-

m' tion of RG 1.97 instrumentation in the control room. This part

of the modification requires each of the affected RG 1.97 indica-

ting instruments to be provided with a h" wide yellow sticker

attached to the face of the instrument. The inspector conducted

a walkdown in the control room for Unit 2 and Unit:3 to verify

the presence of this identification. There are about 25 instru-

ments belonging to this category in each Unit. The inspector

found that for Unit 2, the yellow sticker identification was

completed. There were about 4 instruments in Unit 3 that were

not yet completed. The licensee stated that the identification

for Unit 3 was scheduled to be completed before the end of

October 1988. The instruments included in this category consist

of torus water level instruments, drywell pressure, reactor

water level and pressure, neutron monitors and vent stack monitors.

2) For the training of control room operators, the licensee included

two lesson plans related to RG 1.97 instrumentation identification

into their requalification program for their control room operators:

a) Lesson Plan No.87-03B entitled "Environmental Qualification

for Control Room Operators" dated November 27, 1987; and, b) Lesson

Plan No.88-018 entitled "Review of Control Room Enhancements"

dated April 8, 1988. The inspector interviewed two control room

operators and reviewed six training records of Lesson Plan No.87-038. The inspector concluded that the training program for

the recognition of RG 1.97 instrumentation was adequately

implemented.

This item is closed.

2.2 closed (50-277/87-18-03; 50-278/87-18-03) pertaining to Raychem

cable splices on braided cables. On November 24, 1987, the licensee

started a 100% walkdo,<n of all Raychem spilcos on EQ components with

electrical pigtails. The results of this walkdown indicated that no

Raychem splices on impregnated braids were installed at Peach Bottom

2 and 3. However the licensee did identify other types of cable

splice deficiencies as described in Section 3.0.

This item (Raychem splice over braided cable) is considered closed.

2.3 Closed (50-277/87-18-05; 50-278/87-18-05) pertaining to the

qualification of Rockbestos coaxial cable (EQ file No. 43). The

inspector reviewed EQ file 43 and verified that the following

docun,ents were included in the file:

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1) Rockbestos test report #QR-6802 entitled "Report on

Qualification tests for Rockbestos Adverse Service Coaxial,

Twinaxial, and '-faxial Cable Generic Nuclear Incident for

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Class 1E Service it Nuclear Generating Stations" dated

March 12, 1986. This report documented the qualification test

of Rockbestos series 1E coaxial cable.-

2) Rockbestos document entitled "Analysis of Similarity between

Coaxial Insulation Types Polymer LO and Polymer LE" dated

July 15, 1986.

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3) SCEW sheet for cable 104 and cable 110 identifying that the

cables to be qualified are RSS-6-104/LD and RSS-6-110/LO

respectively (handwritten change).

This item is closed.  ;

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2.4 Closed (50-277/87-18-07; 50-278/87-18-07) pertaining to the  ;

qualification of wire crimps in Limitorque valve actuators. As a '

result of the Raychem cable splices walkdown, the licensee identified

additional wire crimps in their Limitorque valve actuators. The

licensee replaced all wire crimps at Peach Bottom Unit 2 with

qualified Raychem cable splices. For Peach Bottom Unit 3 the wire ,

crimp replacement (with Raychem splices) was still in progress. The

licensee committed to complete the cable splice replacement program

for Unit 3 before the end of March 1989 and before the scheduled

restart of Unit 3.

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For the replaced wire crimps, the licensee produced qualificattu

data to demonstrate their qualifiability during the inspection. The .t

licensee's qualification data included the following: '

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1. Evaluation of nylon insulated blind barrel crimp connectoi.s. on

230/460 volt dual voltag motor windings in Linitorque motor

operators, prepared by the licensee during the week of the

inspection.

2. Containment and Safety Related Equipment Transient Temperature

j Analysis Foilowing a MSLB dated June 1975.

3. Wyle Test Report - 17955-1 dated January 29, 1988 for Clinton

Power Station (not available for review)

4. NP-1472 dated August 1985 "Radiation Data for Design and Qualification

of Nuclear Plant Equipment."

The inspector reviewed t 5 licensee's evaluation and agreed that the

replaced wire crimps we-e qualifiable. This unresolved item is

closed. However, t's a the qualification of these wire crimps was

not established befor a Noverr.ber 30, 1985, this item constitutes a

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violation of 10 CFR 50.49 paragraphs (f) and (g) which require that

each item of electrical equipment important to safety be qualified

and the qualification be completed at a time no later than

. November 30, 1985. (50-277/88-38-01; 50-278/88-38-01).

3.0 Review of Qualification Documents for Various Cable Splices

As part of the 1 %ensee's response to Information Notice 86-53, on

September 16, 1967, the licensee started a cable splice inspection

program for Unit 2 based on a selected sample of Raychem splices. (17

solenoid valves and 2 motors). The result of this inspection indicated

that splice deficiencies existed in the installed cable splices at Peach

Sottom 2. On November 24, 1987, the licensee initiated a 100*.' walkdown

of all cable splices on EQ components with electrical pigtails. As a

result of this inspection program, various splice deficiencies were

identified by the licensee. The licensee stated that, due the similar

design of both units, similar deficiencies would probably exist in

Unit 3. For Unit 2, all but several Scotch Tape Splices (see paragraph

3.3) were replaced with qualif'ed Raychem splices. For Unit 3 the

licensee decided to replace all these splices without performing an

inspection. At the time of this inspection, replacement of Unit 3 cable

splices was still in progress. The licensee's management committed to

complete Unit 3 cable splice replacement before the end of Marcr.1989

and befo e the scheduled restart of Unit 3.

The cable splice deficiencies identified by the licensee include: 1)

Raychem c3ble splices not meeting the qualification criteria; 2) Ideal

Wirenuts; 3) Arp butt splices; and, 4) Scotch tape splices. These

deficiencies see discussed individually as follows:

3.1 Raychem Cable Splices

The licensee identified that numerous Raychem splices did not moet

the qualification criteria. The deficient. splices were due to

a) insufficient seal length (less than 2"); and, b) too small a

bending radius (less than the minimum bend iadius criteria specified

by Raychem). The licensee replace these deficient splices with now

Raychem splices using qualified installation procedures. The licensee

used Wyle test report No. 17859-02B for Commonwealth Edison Company

entitled "Qualification test program on Raychem Nuclear cable

splices ..." dated March 11, 1987 to demonstrate the qualifiability

of the replaced cable splices. This report documented the qualifica-

tion test of Raychem splices with seal length as short as 1/8" and

with very tight bending radii. The inspector agreed that these

splices were qualifiable. However, because qualification of these

splices was not established before November 30, 1985, this constitutes

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a violation of 10 CFR 50.49 paragraphs (f) and (g) which require each

item of electrical equipment important to safety be qualified and the

qualification be conpleted at a time no later than November 30, 1985

(50-277/88-38-02; 50-278/88-38-02).

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3.2 Ideal Wirenuts

The licensee identified in Unit 2 that Ideal wirenuts were used to

connect Atkomatic colenoid valves to the field wire. These

Atkomatic soleno'd valves are located in the CAD (Containment

Atmosphere Dilution) analyzer racks outside the Drywell. These

wirenuts were subsequently replaced by qualified Raychem iplices.

The wors6 ::=a post 08E environmental conditions for the affected

analyzer racks are:

Temperature = 130 F

Pressure = Atmos

Re1 Humidity = 100%

Radiation (TID) = 1.60 x IOC Rads

Since this is a relatively mild environment, radiation is the only

parameter of concern. The licensee determined that the insulating

material for the wirenuts was polypropylene. The licensee determined

the radiation withstand capability for polypropylene from EPRI

NP-1558 to be 3 x 10' rads. The inspector agreed that the wirenuts

for this application were qualifiable. However, since the qualifica-

tion was not established before November 30, 1985, this item

constitutes a violation of 10 CFR 50.49 paragraphs (f) and (g)

, which require each item of electrical equipment important to safety

be qualified and the qualification be completed at a time no later

than November 30, 1985 (50-277/88-38-03; 50-178/88-38 03).

3.3 Amp Butt Splices

The licensee identified in Unit 2 that Amp butt splicts were used in

the plant. These splices were subsequently replaced by qualified

Raychem splices. During the week of the inspection, the licensee

evaluated the qualifiability of the replaced Amp splices. These

splices were used for both control and instrumentation applications.

For control applications where leakcge current is not a serious

concern, the following components were affected:

Environmental conditions

SOV # Lo :ation Peak temperature / radiation

A0-2509 Rcom #508 120 F/2.75 x 10' rad

A0-2570 R;om #508 120 F/2.75 x 10' rad

SV-2978A f.oom #107 138 F/9.') x 10' rad

SV-2978E Acom #107 138 F/9.9 x 10' rad

SV-2671A Room #1 183 F/2.29 x 10' rad

SV-2671B Room #1 183 F/2.29 x 10' rad

SV-2671D Room #1 183*F/2.29 x 10' rad

SV-2671E Room #1 183 F/2.29 x 10' rad

OPIS-2-13-083 Room #8 123 F/2.99 x 10' rad

DPIS-2-13-084 Room #8 123*F/2.99 x 10' rad

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The licensee used Wyle test report No. 17866-02 dated January 29, 1987

to justify the temperature qualifit;ation of the replaced Amp butt

splices for control application. 'ihis test report documented a LOCA

test of four Amp splices for Fort it. Vrain. For the radiation quall-

fication, the licensee analyzed the splice material and determined

that the weakest material is nylon The licensee referenced EPRI

report No. NP-1472 which indicated that nylon can be qualified for a

radiation dose of 4 x 10' rads. Since a large margin exists between

this dose and the actual dose at the plant, the inspector agreed that

Amp splices for this application are qualifiable for the harsh tem-

perature and radiation environment.

The licensee reviewed the walkdown records and determined that only

1 transmitter used Amp butt splices. The affected transmitter is

LT-2-81238 "Torus Water Level", which is a Barton transmitter for RG

1.97 application. This transmitter is located outside the Drywell

(in Room #9). It is to be used for post LOCA operation. The trans-

mitter is subject to a peak temperature of 128 F and a radiation dose

of 2.99 x 10' rads. The inspector agreed that temperature is not a

qualification concern. The licensee used anaiysis as described above

for control applications to demonstrate the radiation qualification

for this transmitter. The inspector agreed that the replaced Amp

splices for both control and instrumentation application were quali-

fiable. However, since the qualification of these splices was not

established before November 30, 1985, this item constitutes a viola-

tion of 10 CFR 50.49 paragraphs (f) and (g) which require each item

of electrical equipment important to safety be qualified and the

qualification be completed at a time no later than November 30, 1985

(50-277/88-38-04; 50-278/88-38-04).

3.4 Scotch Tape Splices

The licensee identified that numerous Scotch tape splices were used

in various areas outside the Drywell. The licensee replaced all of

these splices with qualified Raychem splices except those used for

the following fan motors:

fan Location Environmental Condition

2EV24 Room 9 126*F peak /8x102 rad

2FV24 Room 9 126 F peak /8x102 rad

2GV24 Room 10 126*F peak /8x102 rad

2FV25 Room 4 128*F peak /5x10' rad

2EV25 Room 5 128*F peak /5x10' rad

0AV'O Room 33 105*F peak /2x108 rad

The licensee has an EQ file (Package No. 37) to demonstrate the

qualification of the Scotch tape splices. This EQ file contains

a Franklin test report No. F-C5022-2 entitled "Qualification Test of

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terminal blocks and splice - insulating assemblies in a simulated

loss-of-coolant accident environment - Phase B" dated November 1978.

The test speciment was tested to a peak temperature of 340 F and a

radiation dose of 1 x 10' rads. The inspector reviewed the EQ file

and did not identify any deficiencies.

4.0 Exit Meeting

The inspectors met with the licensee corporate personnel and the

representatives from both plants at the conclusion of the inspection on

September 30, 1988. The inspectors summarized the scope of the inspection

and the inspection findings.

At no time during this inspection was written material given to the

licensee.