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{{#Wiki_filter:CATEGORY1yREGULATORY INFORMATION DISTRIBUTION SYSTEM(RIDS)ACCESSION NBR:9804130248 DOC.DATE:
{{#Wiki_filter:CATEGORY 1y REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9804130248 DOC.DATE: 98/04/06 NOTARIZED:
98/04/06NOTARIZED:
NO" DOCKET 0 FACXL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 AUTH.N~E.AUTHOR AFFILIATION FINXSSI,M.
NO"DOCKET0FACXL:50-315 DonaldC.CookNuclearPowerPlant,Unit1,IndianaM05000315AUTH.N~E.AUTHORAFFILIATION FINXSSI,M.
Indiana Michigan Power Co.SAMPSON,J.R.
IndianaMichiganPowerCo.SAMPSON,J.R.
Indiana Michigan Power Co.RECIP.NAME RECIPIENT AFFXLIATZON
IndianaMichiganPowerCo.RECIP.NAME RECIPIENT AFFXLIATZON


==SUBJECT:==
==SUBJECT:==
LER98-013-00:on 980306,discovered improperspliceconfigurations forPORVlimitswitches.
LER 98-013-00:on 980306,discovered improper splice configurations for PORV limit switches.Caused by inadequate guidance in installation documents.
Causedbyinadequate guidanceininstallation documents.
Document are being revised Ec breakout boots will be installed.W/980406 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: E RECIPIENT ID CODE/NAME PD3-3 PD INTERNAL: ZLE EELB NRR/DRCH/HHFB.
DocumentarebeingrevisedEcbreakoutbootswillbeinstalled.W/980406 ltr.DISTRIBUTION CODE:IE22TCOPIESRECEIVED:LTR ENCLSIZE:TITLE:50.73/50.9 LicenseeEventReport(LER),IncidentRpt,etc.NOTES:ERECIPIENT IDCODE/NAME PD3-3PDINTERNAL:
NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN3 FILE 01 EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1, 1 1 1 1 1 1 1 1 1 1 1 1 1 1'1 1 1 RECIPIENT ID CODE/NAME STANG, J AEOD/S PD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EXB LITCO BRYCE,J H NOAC QUEENER,DS NUDOCS FULL TXT COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1"1.1 1'1 1 1 1 1 1 1 1 Y'()U NOTE TO ALL"RIDS" RECIPIENTS:
ZLEEELBNRR/DRCH/HHFB.
PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 FULL TEXT CONVERSXON REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24 Indiana Michigan Power Company CcuNcc ear P~zc!Or.e Cxk Pzce Bagman.Ml 490C6 INDIANA NICHIGAItI POWER April 6, 1998 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Operating Licenses DPR-58 Docket No.50-315 Document Control Manager: d Ihh'bllhdbpldgdh 0.did~i~h Ill lg 0 1 big b lgd.'8-013-00 Sincerely, J.R.Sampson Site Vice President Imbd Attachment A.B.Beach, Region III E.E.Fitzpatrick P.A.Barrett S.J.Brewer R.Whale D.Hahn Records Center, INPO NRC Resident Inspector 9804130248 980406 PDR ADOCK 05000315 PDR HRC FORH 366 (5-92).NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)ROVED BY OMB NO.3150-0104 EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COHPLY IIITH THI INFORMATION COLLECTION REQUEST: 50.0 HRS.FORVAR COMMENTS REGARDING BURDEH ESTIMATE TO TH INFORMATION AND RECORDS MANAGEMENT BRANCH (MNB 7714), U.S.NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555.0001, AND TO THE PAPERNOR REDUCTION PROJECT (3150-0104), OFFICE 0 MAHAGEHENT AND BUDGET'WASHINGTON DC 20503.FACILITY HAME (1)Donald C.Cook Nuclear Plant-Unit 1 DOCKET NUMBER (2)50.315 Page 1 of4 TITLE (4)Improper Splice Configurations for Power Operated Relief Valve Limit Switches Results in Unanalyzed Condition EVENT DATE 5 LER NUMBER 6 REPORT DATE 7 O'THER FACILITIES INVOLVED 8 MONTH 03 DAY YEAR 06 98 YEAR 98 SEQUENTIAL NUHBER 013 REVI S ION NUMBER 00 HONTM 04 DAY 06 FACILIT'Y NAHE Cook Unit 2 FACILITY HAHE DOCKET NUMBER 50-316 DOCKET NUHBER OPERATING MODE (9)PONER LEVEL (10)0 TH S REPORT IS SUBMITTED PURSUANT 20.2201(b) 20.2203 a 20.2203(a)(2)(i)
NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN3FILE01EXTERNAL:
TO THE REQUIREMENTS OF 10 CFR 20.2203(a)(3)(s) 20.2203 a 3 ii 20.2203(a)(4)
LSTLOBBYWARDNOACPOORE,W.NRCPDRCOPIESLTTRENCL112211,11111111111111'111RECIPIENT IDCODE/NAME STANG,JAEOD/SPD/RRABNRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EXB LITCOBRYCE,JHNOACQUEENER,DS NUDOCSFULLTXTCOPIESLTTRENCL11111111111"1.11'11111111Y'()UNOTETOALL"RIDS"RECIPIENTS:
Check one or more 11 73.71 (b)73.71o 50'3(a)(2)(iii) 50.73 a 2 iv OTHER 50.73(a)(2)(v) 20.2203 a 2 ii 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(2)(v)
PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATION REMOVEDFROMDISTRIBUTION LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION, CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION 415-2083FULLTEXTCONVERSXON REQUIREDTOTALNUMBEROFCOPIESREQUIRED:
X 50.36 c 1 50.36(c)(2) 50.73(a)(2)(i) 50.73(a)(2)(ii) 50.73 a 2 vii 50.73(a)(2)(vfii)(A) 50.73(a)(2)(viii)(B) 50.73(a)(2)(x)(Specify in Abstract beloM and in Text, NRC Form 366A)NAME LICENSEE CONTAC1'OR THIS LER 12 TELEPHONE NUMBER (Include Area Code)Mr.Mike Finissi, Electrical Systems Manager 616/465-5901, x2830 COMPL ETE ONE LINE FOR EACH COMPONEHT FA LURE DESCR NIS REPORT ISED IN T CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO HPRDS CAUSE SYSTEM COMPOHENT MANUFACTURER REPORTABLE TO NPRDS SUPPLEMENTAL REPORT EXPECTED 14 X YES (If yes, complete EXPECTED SUBMISSION DAlE).NO EXPECTED'UBMISSIOH DATE (15)HONTH DAY YEAR 04 17 98 ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)(16)On March 61998, with Unit 1 and 2 in cold shutdown, it was determined that the splices for the limit switches on the Unit 1 Power Operated Relief Valves (PORVs)were installed without the"breakout boot required for Environmental Qualification (EQ).The valves were declared inoperable, and an ENS notification was made at 1829 hours EST under 10CFR50.72(a)(2)(i) for an unanalyzed condition.
LTTR24ENCL24 IndianaMichiganPowerCompanyCcuNccearP~zc!Or.eCxkPzceBagman.Ml490C6INDIANANICHIGAItI POWERApril6,1998UnitedStatesNuclearRegulatory Commission DocumentControlDeskWashington, DC20555Operating LicensesDPR-58DocketNo.50-315DocumentControlManager:dIhh'bllhdbpldgdh 0.did~i~hIlllg01bigblgd.'8-013-00 Sincerely, J.R.SampsonSiteVicePresident ImbdAttachment A.B.Beach,RegionIIIE.E.Fitzpatrick P.A.BarrettS.J.BrewerR.WhaleD.HahnRecordsCenter,INPONRCResidentInspector 9804130248 980406PDRADOCK05000315PDR HRCFORH366(5-92).NUCLEARREGULATORY COMMISSION LICENSEEEVENTREPORT(LER)ROVEDBYOMBNO.3150-0104 EXPIRES5/31/95ESTIMATED BURDENPERRESPONSETOCOHPLYIIITHTHIINFORMATION COLLECTION REQUEST:50.0HRS.FORVARCOMMENTSREGARDING BURDEHESTIMATETOTHINFORMATION ANDRECORDSMANAGEMENT BRANCH(MNB7714),U.S.NUCLEARREGULATORY COMMISSION, WASHINGTON, DC20555.0001, ANDTOTHEPAPERNORREDUCTION PROJECT(3150-0104),
Inspection of the PORV limit switches for Unit 2 identified that although the breakout boot was installed, a problem with the length of the splice overlap existed at a different splice location.This discrepancy resulted in the valves being declared inoperable, and an update to the original notiTication was made on March 7, 1998, at 0615 hours EST.This LER is therefore submitted in accordance with 10CFR50.72(a)(2)(ii) for both units.The root cause for the lack of breakout boots was determined to be inadequate guidance in the installation documents.
OFFICE0MAHAGEHENT ANDBUDGET'WASHINGTON DC20503.FACILITYHAME(1)DonaldC.CookNuclearPlant-Unit1DOCKETNUMBER(2)50.315Page1of4TITLE(4)ImproperSpliceConfigurations forPowerOperatedReliefValveLimitSwitchesResultsinUnanalyzed Condition EVENTDATE5LERNUMBER6REPORTDATE7O'THERFACILITIES INVOLVED8MONTH03DAYYEAR0698YEAR98SEQUENTIAL NUHBER013REVISIONNUMBER00HONTM04DAY06FACILIT'Y NAHECookUnit2FACILITYHAHEDOCKETNUMBER50-316DOCKETNUHBEROPERATING MODE(9)PONERLEVEL(10)0THSREPORTISSUBMITTED PURSUANT20.2201(b) 20.2203a20.2203(a)(2)(i)
These documents are currently being revised, and once the revisions are complete, the breakout boots will be installed.
TOTHEREQUIREMENTS OF10CFR20.2203(a)(3)(s) 20.2203a3ii20.2203(a)(4)
The root cause for the improper splice overlap length is still under investigation.
Checkoneormore1173.71(b)73.71o50'3(a)(2)(iii) 50.73a2ivOTHER50.73(a)(2)(v) 20.2203a2ii20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(2)(v)
An evaluation of the existing configurations was performed.
X50.36c150.36(c)(2) 50.73(a)(2)(i) 50.73(a)(2)(ii) 50.73a2vii50.73(a)(2)(vfii)(A) 50.73(a)(2)(viii)(B) 50.73(a)(2)(x)
It was determined that although the installed configuration did not meet the EQ requirements, the configuration used would have functioned adequately during accident and post-accident conditions.
(SpecifyinAbstractbeloMandinText,NRCForm366A)NAMELICENSEECONTAC1'OR THISLER12TELEPHONE NUMBER(IncludeAreaCode)Mr.MikeFinissi,Electrical SystemsManager616/465-5901, x2830COMPLETEONELINEFOREACHCOMPONEHT FALUREDESCRNISREPORTISEDINTCAUSESYSTEMCOMPONENT MANUFACTURER REPORTABLE TOHPRDSCAUSESYSTEMCOMPOHENT MANUFACTURER REPORTABLE TONPRDSSUPPLEMENTAL REPORTEXPECTED14XYES(Ifyes,completeEXPECTEDSUBMISSION DAlE).NOEXPECTED'UBMISSIOH DATE(15)HONTHDAYYEAR041798ABSTRACT(Limitto1400spaces,i.e.,approximately 15single-spaced typewritten lines)(16)OnMarch61998,withUnit1and2incoldshutdown, itwasdetermined thatthesplicesforthelimitswitchesontheUnit1PowerOperatedReliefValves(PORVs)wereinstalled withoutthe"breakout bootrequiredforEnvironmental Qualification (EQ).Thevalvesweredeclaredinoperable, andanENSnotification wasmadeat1829hoursESTunder10CFR50.72(a)(2)(i) foranunanalyzed condition.
It is therefore concluded that the event had minimal safety significance and the health and safety of the public were not endangered.
Inspection ofthePORVlimitswitchesforUnit2identified thatalthoughthebreakoutbootwasinstalled, aproblemwiththelengthofthespliceoverlapexistedatadifferent splicelocation.
An update to this LER is expected to be submitted by April 17, 1998.
Thisdiscrepancy resultedinthevalvesbeingdeclaredinoperable, andanupdatetotheoriginalnotiTication wasmadeonMarch7,1998,at0615hoursEST.ThisLERistherefore submitted inaccordance with10CFR50.72(a)(2)(ii) forbothunits.Therootcauseforthelackofbreakoutbootswasdetermined tobeinadequate guidanceintheinstallation documents.
HRC FORM 366A.HUCLEAR REGULATORY COMMISSION LICENSEE EVENT CONTINUATION ROVED BY OMB NO.3150 0104 EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTIOH REQUEST: 50'HRS.FORWARD COMMENTS REGARDING BURDEH ESTIMATE'TO THE INFORMATION AHD RECORDS MANAGEMENT BRANCH (MHBB 7714), U.S.NUCLEAR REGULATORY COMMISSION,'WASHIHGTOH, DC 20555-0001, AHD TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET WASHINGTON DC 20503.FACILITY NAME 1 Cook Nuclear Plant-Unit 1 TEXT (if core space is required.use additional NRC Forrs 366A's)<17)DOCKET NUMBER 2 50-315 YEAR 98 LER NUMBER 6 SEQUEHT IAL REVI SION 013-00 PAGE 3 2 OF 4 C di n riort E e Unit 1 was in Mode 5, Cold Shutdown Unit 2 was in Mode 5, Cold Shutdown On March 6, 1998, while planning a job order on the Unit 1 Power Operated Relief Valves (PORVs), a potential discrepancy was noted between actual installation configuration and the required Environmental Qualification (EQ)configuration.
Thesedocuments arecurrently beingrevised,andoncetherevisions arecomplete, thebreakoutbootswillbeinstalled.
It was decided that a walkdown of the Unit 1 PORVs should be performed to confirm the installed configuration.
Therootcausefortheimproperspliceoverlaplengthisstillunderinvestigation.
The walkdown revealed that a single Raychem splice was used for 1-NRV-152 and 1-NRV-153 instead of the required EQ"breakout boot" as described in DCC Specification DCC-PS@30-QCN.
Anevaluation oftheexistingconfigurations wasperformed.
A breakout boot is used to splice a pair of leads to a single field cable, and physically resembles the letter"Y" or a pair of pants.It could not be determined when the improper splices were installed, but it was conservatively assumed that the improper splices had been installed while the unit was operating.
Itwasdetermined thatalthoughtheinstalled configuration didnotmeettheEQrequirements, theconfiguration usedwouldhavefunctioned adequately duringaccidentandpost-accident conditions.
The valves were subsequently declared inoperable.
Itistherefore concluded thattheeventhadminimalsafetysignificance andthehealthandsafetyofthepublicwerenotendangered.
A walkdown of the Unit 2 PORVs was conducted early on March 7, 1998.This walkdown revealed that the breakout boots were properly installed, however, the Raychem splices for a different splice of a single conductor to another single conductor did not have the EQ required overlap length of 2 inches.These valves, 2-NRV-151, 2-NRV-152 and 2-NRV-153, were also declared inoperable.
AnupdatetothisLERisexpectedtobesubmitted byApril17,1998.
Subsequent to the discovery of the problems with the PORVs, the lack of a breakout boot was also identified on the splices for 1-NSO-21 and 1-NSO-22, the Unit 1 reactor vessel head vent valves.j The root cause of this event v7as inadequate written guidance for the installation of the required EQ breakout boot splices.The splices are to be installed in accordance with the Electrical Design Standard (EDS)for the particular installation.
HRCFORM366A.HUCLEARREGULATORY COMMISSION LICENSEEEVENTCONTINUATION ROVEDBYOMBNO.31500104EXPIRES5/31/95ESTIMATED BURDENPERRESPONSETOCOMPLYWITHTHISINFORMATION COLLECTIOH REQUEST:50'HRS.FORWARDCOMMENTSREGARDING BURDEHESTIMATE'TO THEINFORMATION AHDRECORDSMANAGEMENT BRANCH(MHBB7714),U.S.NUCLEARREGULATORY COMMISSION,
In the case of the PORVs, EDS 335 contains illustrated installation details for the limit switches themselves and includes a reference to DCC Specification DCC-PS430-QCN for the actual splice configuration.
'WASHIHGTOH, DC20555-0001, AHDTOTHEPAPERWORK REDUCTION PROJECT(3150-0104),
DCC-PS%30-QCN describes the process for assembling a qualified splice, but does not contain any illustration to assist in that assembly.The root cause for the improper splice overlap lengths for the Unit 2 PORVs is still under investigation.
OFFICEOFMANAGEMENT ANDBUDGETWASHINGTON DC20503.FACILITYNAME1CookNuclearPlant-Unit1TEXT(ifcorespaceisrequired.
The investigation is expected to be complete by April 13, 1998.This event was reported via ENS on March 6, 1998 in accordance with 10CFR50.72(a)(2)(i), as an unanalyzed condition on Unit 1.The notification was updated on March 7, 1998 to include the Unit 2 PORVs.This LER is therefore submitted in accordance with 10CFR50.73(a)(2)(ii)(B), as an event which was found while shutdown, which if found while the reactor was operating, would have constituted an unanalyzed condition.
useadditional NRCForrs366A's)<17)DOCKETNUMBER250-315YEAR98LERNUMBER6SEQUEHTIALREVISION013-00PAGE32OF4CdinriortEeUnit1wasinMode5,ColdShutdownUnit2wasinMode5,ColdShutdownOnMarch6,1998,whileplanningajoborderontheUnit1PowerOperatedReliefValves(PORVs),apotential discrepancy wasnotedbetweenactualinstallation configuration andtherequiredEnvironmental Qualification (EQ)configuration.
NRC FORM 366A~NUCLEAR REGULATORY COMMISSIOH LICENSEE EVENT CONTINUATION ROVED BY OMB NO.3150.0104 EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS IHFORHATIOH COLLECTION REQUEST: 50.0 MRS.FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S.NUCLEAR REGULATORY COMMISSION/
ItwasdecidedthatawalkdownoftheUnit1PORVsshouldbeperformed toconfirmtheinstalled configuration.
WASHINGTOH, DC 20555-0001, AHD TO THE PAPERWORK REDUCTIOH PROJECT (3150 0104), OFFICE OF MANAGEMENT AND BUDGET WASHINGTON DC 20503.FACILITY NAHE 1 Cook Nuclear Plant-Unit 1 TEXT (if acre space is required.use additional NRC Fom 366A's)(IT)DOCKET NUMBER 2 50-315 YEAR 98 LER NUMBER 6 SEQUENTIAL REVISION 013-'0 PAGE 3 3OF4 na I ve cont'd An Engineering evaluation of the installed configurations was performed.
ThewalkdownrevealedthatasingleRaychemsplicewasusedfor1-NRV-152 and1-NRV-153 insteadoftherequiredEQ"breakout boot"asdescribed inDCCSpecification DCC-PS@30-QCN.
The first issue addressed was the lack of a breakout boot for the single conductor to two conductor splice.The breakout boot is designed to provide a seal where the two conductors leave the single conductor.
Abreakoutbootisusedtospliceapairofleadstoasinglefieldcable,andphysically resembles theletter"Y"orapairofpants.Itcouldnotbedetermined whentheimproperspliceswereinstalled, butitwasconservatively assumedthattheimproperspliceshadbeeninstalled whiletheunitwasoperating.
Raychem had qualified the breakout boots for installations exposed to direct steam impingement.
Thevalvesweresubsequently declaredinoperable.
Instead of using a breakout boot for the 1-NRV-152 and 1-NRV-153 applications, each of the three individual conductors were insulated with Raychem WCSF heat shrink tubing.Then the entire assembly was covered with a piece of the same tubing.Raychem manufactures the WCSF tubing with a pre-coated adhesive whose function is to provide an environmental seal for isolating the active electrical component from moisture.The entire WCSF sleeve is then heat shrunk to seal against the conductor.
AwalkdownoftheUnit2PORVswasconducted earlyonMarch7,1998.Thiswalkdownrevealedthatthebreakoutbootswereproperlyinstalled, however,theRaychemsplicesforadifferent spliceofasingleconductor toanothersingleconductor didnothavetheEQrequiredoverlaplengthof2inches.Thesevalves,2-NRV-151, 2-NRV-152 and2-NRV-153, werealsodeclaredinoperable.
The adhesive flows to conform to the shape of the conductor.
Subsequent tothediscovery oftheproblemswiththePORVs,thelackofabreakoutbootwasalsoidentified onthesplicesfor1-NSO-21and1-NSO-22, theUnit1reactorvesselheadventvalves.jTherootcauseofthiseventv7asinadequate writtenguidancefortheinstallation oftherequiredEQbreakoutbootsplices.Thesplicesaretobeinstalled inaccordance withtheElectrical DesignStandard(EDS)fortheparticular installation.
For this particular installation, it also flowed between the two conductors to provide the sealing function normally performed by the breakout boot..The primary failure mechanism to be considered is moisture collection inside the Raychem splice on the conductor to form a low resistance path to ground.The possibility of a short circuit is a function of the length of this path, the circuit voltage and the resistance of the path.In order to develop a low resistance path to ground it would be necessary for moisture to penetrate the Raychem splice underneath the outer tubing.While a qualified assembly would have a breakout boot,'an analysis of the existing configuration shows that it also would provide protection from moisture intrusion.
InthecaseofthePORVs,EDS335containsillustrated installation detailsforthelimitswitchesthemselves andincludesareference toDCCSpecification DCC-PS430-QCN fortheactualspliceconfiguration.
The breakout boot was qualified against direct spray impingement on the splice for a 1000 volt circuit.For the existing configuration in a 250 volt DC circuit, protection against direct steam impingement is not required as these splices are located inside terminal boxes.Without direct spray impingement, it is considered unlikely that moisture would penetrated the installed splice configuration, and the physical creep distance requirements for the 250 volt DC circuit are less than required for a 1000 volt circuit.The second issue considered was that of the proper size of overlap for Raychem WCSF-N material used for conductor to conductor splices.The current Raychem installation practices requires that for a Loss of Coolant Accident (LOCA)application, the WCSF tubing is 6 inches long in order to provide 2 inches of overlap.This 2 inch length was chosen by Raychem to insure successful completion of the LOCA testing for 1000 volt applications directly exposed to steam.However, varieties of overlap lengths, some as short as one eight inch have been acceptably qualified by industry testing.The Nuclear Utility Group on Equipment Qualification prepared a report on industry testing of short Raychem splices, which was issued on May 22, 1987, and is the basis for the industry acceptance of the shorter Raychem splice.At this time these tests are under review so that a direct comparison can be made of the test parameters versus the accident profile for Cook.Additionally, as with the quaiifiied breakout boot configuration, the application for which the shorter splice length exists is a 250 vDC circuit installed inside terminal boxes, as opposed to the tested 1000 volt configuration exposed to direct steam impingement.
DCC-PS%30-QCN describes theprocessforassembling aqualified splice,butdoesnotcontainanyillustration toassistinthatassembly.
In conclusion, it was determined that although the installed splices do not meet the EQ requirements for breakout boot and splice, overlap length, it is considered likely that the installed configuration would have performed adequately in a LOCA or post-LOCA environment.
TherootcausefortheimproperspliceoverlaplengthsfortheUnit2PORVsisstillunderinvestigation.
Therefore, this event is considered to be of minimal safety significance as the health and safety of the public was not jeopardized.
Theinvestigation isexpectedtobecompletebyApril13,1998.ThiseventwasreportedviaENSonMarch6,1998inaccordance with10CFR50.72(a)(2)(i),
HRC FORM 366A.NUCLEAR REGULATORY COMHISSIOH LICENSEE EVENT CONTINUATION OVED BY OMB NO.3150-0104 EXP I RES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COHPLY WITH THIS INFORMATION COLLECTION REOUESTs 50.0 HRS.FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE IHFORHATIOH AND RECORDS MANAGEHENT BRANCH (MNBB 7714), U.S.NUCLEAR REGULATORY COMHISSION, liASHIHGTOH, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF HANAGEMEHT AND BUDGET IJASHINGTON DC 20503.FACILITY NAME 1 DOCKET NUHBER 2 YEAR LER NUMBER 6 SEQUENTIAL REVISION PAGE 3 Cook Nuclear Plant-Unit 1 TEXT (ir nore space is required.use additional NRC Fora 366A's)(17)50-315 98 013 00 4OF4~*EDS 335 will be revised to reference EDS 620, instead of the DCC Specification.
asanunanalyzed condition onUnit1.Thenotification wasupdatedonMarch7,1998toincludetheUnit2PORVs.ThisLERistherefore submitted inaccordance with10CFR50.73(a)(2)(ii)(B),
EDS 620 will illustrate the required configuration for a multiple cable splice using the breakout boot.Once these revisions are completed, the breakout boots will be installed in accordance with the EDS.Action requests have already been prepared for installation of the breakout boots on both the affected PORVs and reactor vessel head vent valves.Corrective actions will be taken as appropriate for the splice overlap length problem once the root cause has been determined.
asaneventwhichwasfoundwhileshutdown, whichiffoundwhilethereactorwasoperating, wouldhaveconstituted anunanalyzed condition.
This LER will be updated at that time to reflect those actions.In response to a number of EQ discrepancies that have been identified during the restart readiness reviews currently underway, a Project Team has been assembled to assess the EQ process.This team is composed of members from EQ and Design Engineering, Maintenance Training, Maintenance Planning and Maintenance procedure writers, Quality Control, and Procurement.
NRCFORM366A~NUCLEARREGULATORY COMMISSIOH LICENSEEEVENTCONTINUATION ROVEDBYOMBNO.3150.0104 EXPIRES5/31/95ESTIMATED BURDENPERRESPONSETOCOMPLYWITHTHISIHFORHATIOH COLLECTION REQUEST:50.0MRS.FORWARDCOMMENTSREGARDING BURDENESTIMATETOTHEINFORMATION ANDRECORDSMANAGEMENT BRANCH(MNBB7714),U.S.NUCLEARREGULATORY COMMISSION/
The team will review and assess the EQ process for adequate knowledge and training on installation practices for each discipline.
WASHINGTOH, DC20555-0001, AHDTOTHEPAPERWORK REDUCTIOH PROJECT(31500104),OFFICEOFMANAGEMENT ANDBUDGETWASHINGTON DC20503.FACILITYNAHE1CookNuclearPlant-Unit1TEXT(ifacrespaceisrequired.
The amount, content and frequency of training given to each discipline will be evaluated, as will the documents used for installation.
useadditional NRCFom366A's)(IT)DOCKETNUMBER250-315YEAR98LERNUMBER6SEQUENTIAL REVISION013-'0PAGE33OF4naIvecont'dAnEngineering evaluation oftheinstalled configurations wasperformed.
The team is expected to complete their charter within 6 months, and appropriate actions will be taken to implement solutions to the problems they identify.This information will be provided to the NRC once the long term actions have been determined.
Thefirstissueaddressed wasthelackofabreakoutbootforthesingleconductor totwoconductor splice.Thebreakoutbootisdesignedtoprovideasealwherethetwoconductors leavethesingleconductor.
Not Applicable ifi on vl 315/97-006-01
Raychemhadqualified thebreakoutbootsforinstallations exposedtodirectsteamimpingement.
, 316/97-00640 Ev}}
Insteadofusingabreakoutbootforthe1-NRV-152 and1-NRV-153 applications, eachofthethreeindividual conductors wereinsulated withRaychemWCSFheatshrinktubing.Thentheentireassemblywascoveredwithapieceofthesametubing.Raychemmanufactures theWCSFtubingwithapre-coated adhesivewhosefunctionistoprovideanenvironmental sealforisolating theactiveelectrical component frommoisture.
TheentireWCSFsleeveisthenheatshrunktosealagainsttheconductor.
Theadhesiveflowstoconformtotheshapeoftheconductor.
Forthisparticular installation, italsoflowedbetweenthetwoconductors toprovidethesealingfunctionnormallyperformed bythebreakoutboot..Theprimaryfailuremechanism tobeconsidered ismoisturecollection insidetheRaychemspliceontheconductor toformalowresistance pathtoground.Thepossibility ofashortcircuitisafunctionofthelengthofthispath,thecircuitvoltageandtheresistance ofthepath.Inordertodevelopalowresistance pathtogrounditwouldbenecessary formoisturetopenetrate theRaychemspliceunderneath theoutertubing.Whileaqualified assemblywouldhaveabreakoutboot,'ananalysisoftheexistingconfiguration showsthatitalsowouldprovideprotection frommoistureintrusion.
Thebreakoutbootwasqualified againstdirectsprayimpingement onthesplicefora1000voltcircuit.Fortheexistingconfiguration ina250voltDCcircuit,protection againstdirectsteamimpingement isnotrequiredasthesesplicesarelocatedinsideterminalboxes.Withoutdirectsprayimpingement, itisconsidered unlikelythatmoisturewouldpenetrated theinstalled spliceconfiguration, andthephysicalcreepdistancerequirements forthe250voltDCcircuitarelessthanrequiredfora1000voltcircuit.Thesecondissueconsidered wasthatofthepropersizeofoverlapforRaychemWCSF-Nmaterialusedforconductor toconductor splices.ThecurrentRaycheminstallation practices requiresthatforaLossofCoolantAccident(LOCA)application, theWCSFtubingis6incheslonginordertoprovide2inchesofoverlap.This2inchlengthwaschosenbyRaychemtoinsuresuccessful completion oftheLOCAtestingfor1000voltapplications directlyexposedtosteam.However,varieties ofoverlaplengths,someasshortasoneeightinchhavebeenacceptably qualified byindustrytesting.TheNuclearUtilityGrouponEquipment Qualification preparedareportonindustrytestingofshortRaychemsplices,whichwasissuedonMay22,1987,andisthebasisfortheindustryacceptance oftheshorterRaychemsplice.Atthistimethesetestsareunderreviewsothatadirectcomparison canbemadeofthetestparameters versustheaccidentprofileforCook.Additionally, aswiththequaiifiied breakoutbootconfiguration, theapplication forwhichtheshortersplicelengthexistsisa250vDCcircuitinstalled insideterminalboxes,asopposedtothetested1000voltconfiguration exposedtodirectsteamimpingement.
Inconclusion, itwasdetermined thatalthoughtheinstalled splicesdonotmeettheEQrequirements forbreakoutbootandsplice,overlaplength,itisconsidered likelythattheinstalled configuration wouldhaveperformed adequately inaLOCAorpost-LOCA environment.
Therefore, thiseventisconsidered tobeofminimalsafetysignificance asthehealthandsafetyofthepublicwasnotjeopardized.
HRCFORM366A.NUCLEARREGULATORY COMHISSIOH LICENSEEEVENTCONTINUATION OVEDBYOMBNO.3150-0104 EXPIRES5/31/95ESTIMATED BURDENPERRESPONSETOCOHPLYWITHTHISINFORMATION COLLECTION REOUESTs50.0HRS.FORWARDCOMMENTSREGARDING BURDENESTIMATETOTHEIHFORHATIOH ANDRECORDSMANAGEHENT BRANCH(MNBB7714),U.S.NUCLEARREGULATORY COMHISSION, liASHIHGTOH, DC20555-0001, ANDTOTHEPAPERWORK REDUCTION PROJECT(3150-0104),
OFFICEOFHANAGEMEHT ANDBUDGETIJASHINGTON DC20503.FACILITYNAME1DOCKETNUHBER2YEARLERNUMBER6SEQUENTIAL REVISIONPAGE3CookNuclearPlant-Unit1TEXT(irnorespaceisrequired.
useadditional NRCFora366A's)(17)50-31598013004OF4~*EDS335willberevisedtoreference EDS620,insteadoftheDCCSpecification.
EDS620willillustrate therequiredconfiguration foramultiplecablespliceusingthebreakoutboot.Oncetheserevisions arecompleted, thebreakoutbootswillbeinstalled inaccordance withtheEDS.Actionrequestshavealreadybeenpreparedforinstallation ofthebreakoutbootsonboththeaffectedPORVsandreactorvesselheadventvalves.Corrective actionswillbetakenasappropriate forthespliceoverlaplengthproblemoncetherootcausehasbeendetermined.
ThisLERwillbeupdatedatthattimetoreflectthoseactions.InresponsetoanumberofEQdiscrepancies thathavebeenidentified duringtherestartreadiness reviewscurrently
: underway, aProjectTeamhasbeenassembled toassesstheEQprocess.ThisteamiscomposedofmembersfromEQandDesignEngineering, Maintenance
: Training, Maintenance PlanningandMaintenance procedure writers,QualityControl,andProcurement.
TheteamwillreviewandassesstheEQprocessforadequateknowledge andtrainingoninstallation practices foreachdiscipline.
Theamount,contentandfrequency oftraininggiventoeachdiscipline willbeevaluated, aswillthedocuments usedforinstallation.
Theteamisexpectedtocompletetheircharterwithin6months,andappropriate actionswillbetakentoimplement solutions totheproblemstheyidentify.
Thisinformation willbeprovidedtotheNRConcethelongtermactionshavebeendetermined.
NotApplicable ifionvl315/97-006-01
,316/97-00640 Ev}}

Revision as of 06:12, 6 July 2018

LER 98-013-00:on 980306,discovered Improper Splice Configurations for PORV Limit Switches.Caused by Inadequate Guidance in Installation Documents.Document Are Being Revised & Breakout Boots Will Be installed.W/980406 Ltr
ML17334B712
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 04/06/1998
From: FINISSI M, SAMPSON J R
INDIANA MICHIGAN POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-98-013, LER-98-13, NUDOCS 9804130248
Download: ML17334B712 (6)


Text

CATEGORY 1y REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9804130248 DOC.DATE: 98/04/06 NOTARIZED:

NO" DOCKET 0 FACXL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 AUTH.N~E.AUTHOR AFFILIATION FINXSSI,M.

Indiana Michigan Power Co.SAMPSON,J.R.

Indiana Michigan Power Co.RECIP.NAME RECIPIENT AFFXLIATZON

SUBJECT:

LER 98-013-00:on 980306,discovered improper splice configurations for PORV limit switches.Caused by inadequate guidance in installation documents.

Document are being revised Ec breakout boots will be installed.W/980406 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: E RECIPIENT ID CODE/NAME PD3-3 PD INTERNAL: ZLE EELB NRR/DRCH/HHFB.

NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN3 FILE 01 EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1, 1 1 1 1 1 1 1 1 1 1 1 1 1 1'1 1 1 RECIPIENT ID CODE/NAME STANG, J AEOD/S PD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EXB LITCO BRYCE,J H NOAC QUEENER,DS NUDOCS FULL TXT COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1"1.1 1'1 1 1 1 1 1 1 1 Y'()U NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 FULL TEXT CONVERSXON REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24 Indiana Michigan Power Company CcuNcc ear P~zc!Or.e Cxk Pzce Bagman.Ml 490C6 INDIANA NICHIGAItI POWER April 6, 1998 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Operating Licenses DPR-58 Docket No.50-315 Document Control Manager: d Ihh'bllhdbpldgdh 0.did~i~h Ill lg 0 1 big b lgd.'8-013-00 Sincerely, J.R.Sampson Site Vice President Imbd Attachment A.B.Beach, Region III E.E.Fitzpatrick P.A.Barrett S.J.Brewer R.Whale D.Hahn Records Center, INPO NRC Resident Inspector 9804130248 980406 PDR ADOCK 05000315 PDR HRC FORH 366 (5-92).NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)ROVED BY OMB NO.3150-0104 EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COHPLY IIITH THI INFORMATION COLLECTION REQUEST: 50.0 HRS.FORVAR COMMENTS REGARDING BURDEH ESTIMATE TO TH INFORMATION AND RECORDS MANAGEMENT BRANCH (MNB 7714), U.S.NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555.0001, AND TO THE PAPERNOR REDUCTION PROJECT (3150-0104), OFFICE 0 MAHAGEHENT AND BUDGET'WASHINGTON DC 20503.FACILITY HAME (1)Donald C.Cook Nuclear Plant-Unit 1 DOCKET NUMBER (2)50.315 Page 1 of4 TITLE (4)Improper Splice Configurations for Power Operated Relief Valve Limit Switches Results in Unanalyzed Condition EVENT DATE 5 LER NUMBER 6 REPORT DATE 7 O'THER FACILITIES INVOLVED 8 MONTH 03 DAY YEAR 06 98 YEAR 98 SEQUENTIAL NUHBER 013 REVI S ION NUMBER 00 HONTM 04 DAY 06 FACILIT'Y NAHE Cook Unit 2 FACILITY HAHE DOCKET NUMBER 50-316 DOCKET NUHBER OPERATING MODE (9)PONER LEVEL (10)0 TH S REPORT IS SUBMITTED PURSUANT 20.2201(b) 20.2203 a 20.2203(a)(2)(i)

TO THE REQUIREMENTS OF 10 CFR 20.2203(a)(3)(s) 20.2203 a 3 ii 20.2203(a)(4)

Check one or more 11 73.71 (b)73.71o 50'3(a)(2)(iii) 50.73 a 2 iv OTHER 50.73(a)(2)(v) 20.2203 a 2 ii 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(2)(v)

X 50.36 c 1 50.36(c)(2) 50.73(a)(2)(i) 50.73(a)(2)(ii) 50.73 a 2 vii 50.73(a)(2)(vfii)(A) 50.73(a)(2)(viii)(B) 50.73(a)(2)(x)(Specify in Abstract beloM and in Text, NRC Form 366A)NAME LICENSEE CONTAC1'OR THIS LER 12 TELEPHONE NUMBER (Include Area Code)Mr.Mike Finissi, Electrical Systems Manager 616/465-5901, x2830 COMPL ETE ONE LINE FOR EACH COMPONEHT FA LURE DESCR NIS REPORT ISED IN T CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO HPRDS CAUSE SYSTEM COMPOHENT MANUFACTURER REPORTABLE TO NPRDS SUPPLEMENTAL REPORT EXPECTED 14 X YES (If yes, complete EXPECTED SUBMISSION DAlE).NO EXPECTED'UBMISSIOH DATE (15)HONTH DAY YEAR 04 17 98 ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)(16)On March 61998, with Unit 1 and 2 in cold shutdown, it was determined that the splices for the limit switches on the Unit 1 Power Operated Relief Valves (PORVs)were installed without the"breakout boot required for Environmental Qualification (EQ).The valves were declared inoperable, and an ENS notification was made at 1829 hours0.0212 days <br />0.508 hours <br />0.00302 weeks <br />6.959345e-4 months <br /> EST under 10CFR50.72(a)(2)(i) for an unanalyzed condition.

Inspection of the PORV limit switches for Unit 2 identified that although the breakout boot was installed, a problem with the length of the splice overlap existed at a different splice location.This discrepancy resulted in the valves being declared inoperable, and an update to the original notiTication was made on March 7, 1998, at 0615 hours0.00712 days <br />0.171 hours <br />0.00102 weeks <br />2.340075e-4 months <br /> EST.This LER is therefore submitted in accordance with 10CFR50.72(a)(2)(ii) for both units.The root cause for the lack of breakout boots was determined to be inadequate guidance in the installation documents.

These documents are currently being revised, and once the revisions are complete, the breakout boots will be installed.

The root cause for the improper splice overlap length is still under investigation.

An evaluation of the existing configurations was performed.

It was determined that although the installed configuration did not meet the EQ requirements, the configuration used would have functioned adequately during accident and post-accident conditions.

It is therefore concluded that the event had minimal safety significance and the health and safety of the public were not endangered.

An update to this LER is expected to be submitted by April 17, 1998.

HRC FORM 366A.HUCLEAR REGULATORY COMMISSION LICENSEE EVENT CONTINUATION ROVED BY OMB NO.3150 0104 EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTIOH REQUEST: 50'HRS.FORWARD COMMENTS REGARDING BURDEH ESTIMATE'TO THE INFORMATION AHD RECORDS MANAGEMENT BRANCH (MHBB 7714), U.S.NUCLEAR REGULATORY COMMISSION,'WASHIHGTOH, DC 20555-0001, AHD TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET WASHINGTON DC 20503.FACILITY NAME 1 Cook Nuclear Plant-Unit 1 TEXT (if core space is required.use additional NRC Forrs 366A's)<17)DOCKET NUMBER 2 50-315 YEAR 98 LER NUMBER 6 SEQUEHT IAL REVI SION 013-00 PAGE 3 2 OF 4 C di n riort E e Unit 1 was in Mode 5, Cold Shutdown Unit 2 was in Mode 5, Cold Shutdown On March 6, 1998, while planning a job order on the Unit 1 Power Operated Relief Valves (PORVs), a potential discrepancy was noted between actual installation configuration and the required Environmental Qualification (EQ)configuration.

It was decided that a walkdown of the Unit 1 PORVs should be performed to confirm the installed configuration.

The walkdown revealed that a single Raychem splice was used for 1-NRV-152 and 1-NRV-153 instead of the required EQ"breakout boot" as described in DCC Specification DCC-PS@30-QCN.

A breakout boot is used to splice a pair of leads to a single field cable, and physically resembles the letter"Y" or a pair of pants.It could not be determined when the improper splices were installed, but it was conservatively assumed that the improper splices had been installed while the unit was operating.

The valves were subsequently declared inoperable.

A walkdown of the Unit 2 PORVs was conducted early on March 7, 1998.This walkdown revealed that the breakout boots were properly installed, however, the Raychem splices for a different splice of a single conductor to another single conductor did not have the EQ required overlap length of 2 inches.These valves, 2-NRV-151, 2-NRV-152 and 2-NRV-153, were also declared inoperable.

Subsequent to the discovery of the problems with the PORVs, the lack of a breakout boot was also identified on the splices for 1-NSO-21 and 1-NSO-22, the Unit 1 reactor vessel head vent valves.j The root cause of this event v7as inadequate written guidance for the installation of the required EQ breakout boot splices.The splices are to be installed in accordance with the Electrical Design Standard (EDS)for the particular installation.

In the case of the PORVs, EDS 335 contains illustrated installation details for the limit switches themselves and includes a reference to DCC Specification DCC-PS430-QCN for the actual splice configuration.

DCC-PS%30-QCN describes the process for assembling a qualified splice, but does not contain any illustration to assist in that assembly.The root cause for the improper splice overlap lengths for the Unit 2 PORVs is still under investigation.

The investigation is expected to be complete by April 13, 1998.This event was reported via ENS on March 6, 1998 in accordance with 10CFR50.72(a)(2)(i), as an unanalyzed condition on Unit 1.The notification was updated on March 7, 1998 to include the Unit 2 PORVs.This LER is therefore submitted in accordance with 10CFR50.73(a)(2)(ii)(B), as an event which was found while shutdown, which if found while the reactor was operating, would have constituted an unanalyzed condition.

NRC FORM 366A~NUCLEAR REGULATORY COMMISSIOH LICENSEE EVENT CONTINUATION ROVED BY OMB NO.3150.0104 EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS IHFORHATIOH COLLECTION REQUEST: 50.0 MRS.FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S.NUCLEAR REGULATORY COMMISSION/

WASHINGTOH, DC 20555-0001, AHD TO THE PAPERWORK REDUCTIOH PROJECT (3150 0104), OFFICE OF MANAGEMENT AND BUDGET WASHINGTON DC 20503.FACILITY NAHE 1 Cook Nuclear Plant-Unit 1 TEXT (if acre space is required.use additional NRC Fom 366A's)(IT)DOCKET NUMBER 2 50-315 YEAR 98 LER NUMBER 6 SEQUENTIAL REVISION 013-'0 PAGE 3 3OF4 na I ve cont'd An Engineering evaluation of the installed configurations was performed.

The first issue addressed was the lack of a breakout boot for the single conductor to two conductor splice.The breakout boot is designed to provide a seal where the two conductors leave the single conductor.

Raychem had qualified the breakout boots for installations exposed to direct steam impingement.

Instead of using a breakout boot for the 1-NRV-152 and 1-NRV-153 applications, each of the three individual conductors were insulated with Raychem WCSF heat shrink tubing.Then the entire assembly was covered with a piece of the same tubing.Raychem manufactures the WCSF tubing with a pre-coated adhesive whose function is to provide an environmental seal for isolating the active electrical component from moisture.The entire WCSF sleeve is then heat shrunk to seal against the conductor.

The adhesive flows to conform to the shape of the conductor.

For this particular installation, it also flowed between the two conductors to provide the sealing function normally performed by the breakout boot..The primary failure mechanism to be considered is moisture collection inside the Raychem splice on the conductor to form a low resistance path to ground.The possibility of a short circuit is a function of the length of this path, the circuit voltage and the resistance of the path.In order to develop a low resistance path to ground it would be necessary for moisture to penetrate the Raychem splice underneath the outer tubing.While a qualified assembly would have a breakout boot,'an analysis of the existing configuration shows that it also would provide protection from moisture intrusion.

The breakout boot was qualified against direct spray impingement on the splice for a 1000 volt circuit.For the existing configuration in a 250 volt DC circuit, protection against direct steam impingement is not required as these splices are located inside terminal boxes.Without direct spray impingement, it is considered unlikely that moisture would penetrated the installed splice configuration, and the physical creep distance requirements for the 250 volt DC circuit are less than required for a 1000 volt circuit.The second issue considered was that of the proper size of overlap for Raychem WCSF-N material used for conductor to conductor splices.The current Raychem installation practices requires that for a Loss of Coolant Accident (LOCA)application, the WCSF tubing is 6 inches long in order to provide 2 inches of overlap.This 2 inch length was chosen by Raychem to insure successful completion of the LOCA testing for 1000 volt applications directly exposed to steam.However, varieties of overlap lengths, some as short as one eight inch have been acceptably qualified by industry testing.The Nuclear Utility Group on Equipment Qualification prepared a report on industry testing of short Raychem splices, which was issued on May 22, 1987, and is the basis for the industry acceptance of the shorter Raychem splice.At this time these tests are under review so that a direct comparison can be made of the test parameters versus the accident profile for Cook.Additionally, as with the quaiifiied breakout boot configuration, the application for which the shorter splice length exists is a 250 vDC circuit installed inside terminal boxes, as opposed to the tested 1000 volt configuration exposed to direct steam impingement.

In conclusion, it was determined that although the installed splices do not meet the EQ requirements for breakout boot and splice, overlap length, it is considered likely that the installed configuration would have performed adequately in a LOCA or post-LOCA environment.

Therefore, this event is considered to be of minimal safety significance as the health and safety of the public was not jeopardized.

HRC FORM 366A.NUCLEAR REGULATORY COMHISSIOH LICENSEE EVENT CONTINUATION OVED BY OMB NO.3150-0104 EXP I RES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COHPLY WITH THIS INFORMATION COLLECTION REOUESTs 50.0 HRS.FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE IHFORHATIOH AND RECORDS MANAGEHENT BRANCH (MNBB 7714), U.S.NUCLEAR REGULATORY COMHISSION, liASHIHGTOH, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF HANAGEMEHT AND BUDGET IJASHINGTON DC 20503.FACILITY NAME 1 DOCKET NUHBER 2 YEAR LER NUMBER 6 SEQUENTIAL REVISION PAGE 3 Cook Nuclear Plant-Unit 1 TEXT (ir nore space is required.use additional NRC Fora 366A's)(17)50-315 98 013 00 4OF4~*EDS 335 will be revised to reference EDS 620, instead of the DCC Specification.

EDS 620 will illustrate the required configuration for a multiple cable splice using the breakout boot.Once these revisions are completed, the breakout boots will be installed in accordance with the EDS.Action requests have already been prepared for installation of the breakout boots on both the affected PORVs and reactor vessel head vent valves.Corrective actions will be taken as appropriate for the splice overlap length problem once the root cause has been determined.

This LER will be updated at that time to reflect those actions.In response to a number of EQ discrepancies that have been identified during the restart readiness reviews currently underway, a Project Team has been assembled to assess the EQ process.This team is composed of members from EQ and Design Engineering, Maintenance Training, Maintenance Planning and Maintenance procedure writers, Quality Control, and Procurement.

The team will review and assess the EQ process for adequate knowledge and training on installation practices for each discipline.

The amount, content and frequency of training given to each discipline will be evaluated, as will the documents used for installation.

The team is expected to complete their charter within 6 months, and appropriate actions will be taken to implement solutions to the problems they identify.This information will be provided to the NRC once the long term actions have been determined.

Not Applicable ifi on vl 315/97-006-01

, 316/97-00640 Ev