ML20101B632

Final Deficiency Rept 55-84-16 Re Internal Wiring Workmanship Defects in Electrical Panels in Hpcs.Initially Reported on 840720.GE Will Require Future Suppliers to Submit Installation/Insp Procedures

ML20101B632
Person / Time
Site:	Clinton
Issue date:	12/06/1984
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-84-16, U-10227, NUDOCS 8412200417
Download: ML20101B632 (7)

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'lli/N018 POWER COMPANY .U-10227 <

CLINTON POWER STATION, P.O. SON 678. CLINTON, ILLINOls 61727 December 6, 1984 Dock'et No . 461' '

Mr. James G. Keppler .

' Regional Administrator .;

Region :III  ;

.U.S. Nuclear Regulatory Commission  :

799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

10CFR50.55(e) Deficiency 55-84-16  :

Internal Wiring. Workmanship Deficiencies in Electrical Panels-(HPCS-DG)

Dear Mr. Keppler:

On July 20, 1984, Illinois Power Company notified Mr. F..

Jablonski, NRC Region III, (Ref: IP Memorandum Y-20704, dated July 20, 1984) of a potentially reportable deficiency concerning.

general workmanship discrepancies in the wiring'of' electrical control panels for the High Pressure Core Spray (HPCS) Diesel ..'

Generator (DG). This initial notification was followed by one (1) interim report (ref:~ IP letter U-10193, D. P. Hall to J. G.

Keppler dated August 17, 1984). Illinois Power's investigation of the above matter is complete and has determined that the' issue  ;

represents a reportable deficiency under the provisions of 10CFR50.55(e). This letter is submitted as a final report regarding this reportable deficiency. Attachment A provides the details of.our investigation.

We trust that this final report provides sufficient information to perform a general assessment of this reportable deficiency and adequately describes our overall approach to resolve this problem.  ;

Sincerely yours, 8412200417 841206 PDR ADOCM 0S000461 S pon D. . Hall Vice President RLC/cah (NRC2)

Attachment -

cc: NRC Resident Office -

Director, Office'of I&E, US NRC, Washington, DC 20555 Illinois Department.of Nuclear Safety b

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l ATTACHMENT A.

Illinois Power: Company Clinton Power Station Docket-No.J50-461-10CFR50.55(e) Deficiency 55-84-16 Internal Wiring Workmanship Deficiencies in : Electrical Panels (HPCS-DG)

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Fina1 Report Statement of Reportable Deficiency / Background An inspection of 'the vendor wiring in the High-Pressure Core Spray.(HPCS) electrical panel lE22-S001-B for Diesel Generator (DG) Division III' was performed as a result of generic problem information obtained by the NRC from other power reactors and forwarded to Clinton Power Station-(CPS) for information and

" follow-through" action (NRC Open Item 83-09-01).

Odr' inspection of the HPCS electrical panels has identified a significant number of internal wiring workmanship deficiencies.

The identified deficiencies were documented on Nonconformance Reports (NCRs) No. 14165 and No. 16984.

Investigation Results Illinois Power (IP) prepared and implemented an investigation plan to determine the extent of this problem at CPS. The investigation plan included:

1. A review and evaluation of background facts concerning the internal wiring deficiencies was conducted to determine if poor workmanship was performed at the factory prior to shipping or was performed at CPS during equipment installation / modification.

2. A review was conducted of CPS receiving inspection procedures as well as the panel installation procedures to determine what work, if any, was performed on the subject panels subsequent to the receiving inspection.

3. Baldwin Associates' (BA) procedures for field modifications and inspection of the control panels were reviewed to determine quality hold points prior to traveler completion.

. 4. Field testing methods utilized to verify equipment and circuit integrity were reviewed with respect to identifying internal wiring deficiencies prior to energizing.

5. Illinois Power evaluated the effect of the problem with respect to other equipment supplied by the same supplier / manufacturer.

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ATTACHMENT A (continued)

In order to' determine the extent bf the nonconformances in the DivisionLIII, Diesel. Generator unit the following panels were inspected:

- control panel lE22-S001-B

-CT & PT panel 1E22-S001-C

- control panel IE22-S001-G (air compressor)

- skid mounted metering panel 1E22-S001-A

- skid mounted instrumentation (pressure switches)

- battery charger The inspections determined that all panels have similar deficiencies in regard to the wiring and terminations. Wiring and terminations in the battery charger were satisfactory.

During the investigation the following was determined: The manufacturer Stewart & Stevenson Services (S&S) did not have or use a wiring installation procedure or inspection criteria for electrical panels supplied with the Division III Diesel Generator p Unit. There were no quality control hold points for inspection.

General Electric purchasing specification did not require or-did not impose any electrical wiring workmanship instructions to be followed during the manufacturing and shipping of the electrical panels.

Field Disposition Instruction (FDI)/ Field Deviation Disposition Request (FDDR) are GE documents issued when modifications / repairs are required by GE, BA or IP on GE supplied equipment. A review of the FDIs/FDDRs, related to the control panels provided with Division III diesel generator, has shown that none of the changes were implemented before July 24, 1984.

Therefore, the deficiencies do not pertain to any field work performed by Baldwin Associates (BA). The panels were installed by BA in July 1981 and turned over to IP Startup on October 10, 1984. Circuit check and testing had not been initiated by IP Startup prior to the turnover.

The following types of deficiencies were identified as a result of the panel inspections:

1. Improperly terminated lugs:

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a. Wires pulled out of lugs due to improper crimping,

b. Broken or missing strands of wire, Page 2 of 6

ATTACHMENT A (continued)

c. Wire insulation not inserted into the ferrule of the lug,

d. Improper insertion of the wire into the lug.

2. Broken wire

3. Loose wires Applicab_le Requirements The installation / inspection procedures at Clinton Power Station are governed by Sargent & Lundy specification K-2999

" Electrical Installations", and by Baldwin Associates Procedural Manuals: BAP 2.10 " Equipment Installation", and BAP-3.3.3 " Cable Terminations". The receiving inspection was performed dLn accordance with S&S Manual VPF 5257-51(1), Section 2 paragraph 2.6.d.

The control panels provided with division III diesel generator unit (HPCS) are required to meet the GE installation and inspection procedure applied to GE equipment: IIGA-024

" Visual Inspection for FDI/FDDR changes to CID Panels", IIGA-026

" Wire check for FDI/FDDR changes to CID Panels and Cables", and GE Manufacturing Standard Practice - document MSP #14.003 " Wire Termination-Application".

Root Cause This investigation determined that the root cause of the deficiencies described in the previous paragraph were due to one or more of the following items:

- poor workmanship performed by the manufacturer

- lack of S&S quality assurance procedures during the manufacturing

- no quality requirements for panel wiring imposed by GE on S&S

- inadequate inspection at the manufacturer facility by S&S or GE Similar Concerns In order to determine the extent of similar deficiencies on other equipment manufactured / supplied by Stewart & Stevenson Services the receiving documents provided with Division I and II Emergency Diesel Generator Units were reviewed. These units were purchased by Baldwin Associates under Sargent & Lundy specifica-tion K-2861.

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ATTACHMENT A ,

(continued)

A review of.the receiving; reports determined that the internal wiring related to the-control panels is in a condition:

similar:to that of the control. panels provided by S&S for Division III diesel generator.

It was determined-that the periodicisurveillance inspections performed by BA at the manufacturer's_ facility, ended with numerous Deviation and Deficiency Reports (DDRs) related -tx> the internal wiring and terminations.- BA, also determined that S&S -

Quality Assurance Program.is lacking enforcement tx) ensure compliance with their contractual obligations. However, these items were left outstanding by S&S and BA inspectors at-final inspection, and the equipment was released for shipment with these deficiencies. The receiving inspection performed at the CPS site by BAQA personnel,_ identified the same deficiencies related to wiring and terminations.- These nonconformances were summarized in Deviation Report (DR) f4501. NCR #10012'of April.

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20, 1983 (still open) was issued to correct these deficiencies.

The root cause of the'nonconformances for Division I and II diesel generators lies in the lack of a specific quality assurance program by S&S for the installation and inspection'of internal wiring and terminations. .

Corrective Action To preclude recurrence of similar problems, GE will require  !

future suppliers to submit installation / inspection procedures, ap )licable to wiring and terminations for approval, prior tx>

fairication. All equipment to be supplied for Division I, II and III diesel generators for CPS is on site. The following corrective actions will be taken to make the equipment acceptable for use at CPS:

1. Division III (HPCS) Diesel Generator Unit The equipment provided with division III (HPCS) diesel generator unit is installed. The deficiencies identified-by NCR #16984 and an earlier NCR #14165 were incorporated into FDDR #2255 and FDDR #2312. GE performed a detailed inspection of the wiring in the control panels and the identified nonconformances were reworked by completion of FDDRs No. 2255 and 2312. The skid mounted instrumentation (pressure switches), have not yet been inspected by GE. It is anticipated-that this activity will be completed by November 30, 1984.

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LATTACHMENT'A

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2. Division I and'II' Diesel Generator Units The control panels: provided with Division I and II diesel' generators are not installed. The deficiencies identified by NCR #10012 will'be reworked prior to installation. An additional inspection (above the receiving ins 3ection) of g

- wiring and-terminations per'BA procedure _will be performed on the control wiring related to Divisions I and II diesel generators. Identified deficiencies will be documented by NCRs.and resolved in accordance with approved site procedures. It is anticipated that this activity will'be completed by December 31, 1984.

Safety Significance I

The HPCS Diesel Generator Unit-is qualified as class 1E equi ? ment and has a major role in maintaining the safety-function-of the nuclear plant. The subject control panels ensure automatic startup and shutdown of the HPCS diesel generator when the normal AC power supply system-is not available.

A sample of 20% of the wires with deficiencies from the HPCS ,

DG were randomly selected for circuit analysis by S&L engineers.

It was determined that some of the wiring deficiences could prevent the proper function of the emergency power supply system.

As an example, wire #149 identified by NCR #14165 (wire pulled out of the termination lug at switch S-26) could cause a false "NOT READY FOR AUTO START signal thereby misleading the operator. The failure of improperly crimped wire (improper insertion into the lug) on terminal #5 of relay K-15 could cause deenergization of relay K-18 which starts cooling water pumps, and consequently the failure of the generator after 30 seconds.

The same type of deficient termination could cause deenergization of relay K-32 (field flashing relay) and therefore not energize the exciter field to produce voltage output at generator terminals.

Although HPCS is not the prime nor the ultimate resource in ensuring the safe shutdown of the reactor, it is an integral part of the safety provisions of the plant. The inability of the HPCS System to function,"when required, reduces the safety provisions of the plant and therefore, the nonconformances are considered significant per 10CFR50.55(e).

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ATTACHMENT A (continued)

Additionally, by analogy, the deficiencies identified with the wiring and terminations in the control panels-provided with Division I and II diesel generator could potentially compound the situation by causing failure of the emergency power supply system.

Illinois. Power Company has reviewed and evaluated the findings of'this investigation and has determined that the l identified deficiencies are significant and had these I deficiencies gone uncorrected they could have adversely affected the safety of operations of the Clinton Power Station. On this basis, this matter is considered to be reportable under the provisions of 10CFR50.55(e).

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