IR 05000461/1986071

Insp Rept 50-461/86-71 on 861028-1105.No Violations or Deviations Noted.Major Areas Inspected:Followup on Allegations & 10CFR50.55(e) Raychem Splices & Training

ML20214T909
Person / Time
Site:	Clinton
Issue date:	11/25/1986
From:	Falevits Z, Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214T867	List: IR 05000461/1986071 ML20214T864
References
50-461-86-71, IEIN-86-053, IEIN-86-53, NUDOCS 8612090052
Download: ML20214T909 (8)

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U.S. NUCLEAR REGULATORY COMISSION

REGION III

Report No. 50-461/86071(DRS)

Docket No. 50-461- License No. NPF-55 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear. Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspect a Conducted: October 28 through November 5, 1986

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Inspector: Zelig Falevits Date bam N*

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- Approved By: James W. Muffett,. Chief GG Plant Systems Section Date Inspection Summary Inspection on October 28 through November 5, 1986 (Report No. 50-461/86071(DRS))

Areas Inspected: Special, unannounced inspection to followup on allegations, followup on 10 CFR 50.55(e) Raychem Splices, and training. (09914,990208)

Results: Of the areas inspected, no violations or deviations were identifie DR ADOCK 0500 1

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DETAILS Persons Contacted Illinois Power Company

• C. Gerstner, Executive Vice President

• R. E. Cambell, Manager, QA

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• F. A. Spangenberg, Manager, Licensing and Safety

• H. R. Lane, Manager, Schedule and Outage

• J. D. Weaver, Director, Licensing

• J. S. Perry, Manager, Nuclear Program Coordination

• E. W. Kant, Assistant Manager, NSED

• Connell, Manager, NP&S

• E. A. Till, Director, Nuclear Training

• J. A. Brownell, Licensing Specialist T. Buteria, Instructor, Training Sargent & Lundy Engineers

• D. K. Schepfer, Project Manager Sunland/Wipco ,

• J. G,'eenwood, Manager, Power Supply

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NRC

• P. Hiland, Resident Inspector

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• Denotes those attending the exit meeting held October 30, 198 . Followup on Allega_tions (RIII-86-A-0169 Closed)

Allegation In a letter to the NRC dated October 6,1986, an individual expressed concerns pertaining to: (a) incorrect presentation of the termination

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information (terminal board point numbers and wire numbers) depicted on the schematic diagrams as compared to the wiring diagrams; and (b) the inadequacy of the configuration control programatic policy used at Clinton in regards to schematic and wiring drawings. The inspector conducted an in depth design review and field inspection to address the allegers concern In addition, the inspector interviewed licensee's technical perscnnel involved with the use of thcse drawing _, - - _ _

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a. Termination Information on Schematic Diagrams (1) Review (a) The following electrical circuits (alluded to in the allegation) were reviewed against the latest connection diagrams and applicable wire lists: (1) Leak Detection Drywell Isolation Valves No. 1E31-F018, 1E31-F015, and 1E31-F017 as depicted on schematic diagram No. E02-1LD99-007, Revision C; and (2) Drywell and Containment Area Drain Sumps as depicted on schematic diagram No. E02-1LD99-109, Revision G. (Note that this is a non safety circuit).

During this review the following related design documents were examined:

• Connection Diagram No. E03-IP632, Sheet No. 11, Revision * Connection Diagram No. E03-1P7018, Sheet No. 1, Revision * Connection Diagram No. E03-1P7158, Sheet No. 1, Revision * Connection Diagram No. E03-1P742E, Sheet No. 1, Revision * Condition Report (CR) No. 1-85-10-091, dated October 17, 198 * Condition Report No. 1-85-10-095, dated March 19, 198 * Field Engineering Change Notice (FECN) No. 14391, dated December 20, 198 * Field Engineering Notice No. 13160, dated November 18, 198 * Field Engineering Notice No. 13158, dated November 15, 198 * Field Engineering Notice No. 14036, dated February 14, 198 * Field Engineering Notice No. 12329, dated September 28, 198 * Field Problem Report (FPR) No. 8070, dated January 21,_

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198 * Field Problem Report No. 7519, dated December 10, 198 * Field Problem Report No. 7254, dated November 21, 198 * Field Problem Report No. 6912, dated October 24, 198 * General Electric No. FDDR LH1-3400, dated November 7, 198 * General Electric Panel Module Wire List Drawing No. 287A5650, Sheet No. 75, Revision 1 * General Electric Panel Module Wire List Drawing No. 287A5659, Sheet No. 116, Revision 1 * General Electric Panel Module Wire List Drawing No. 287A5669, Sheet No. 507, Revision 1 * General Electric Panel Module Wire List Drawing No. 287A5670, Sheet No. 425, Revision 1 . __ - __ - _

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• General Electric Panel Module Wire List Drawing No. 287A5670, Sheet 421, Revision 1 * Drawing No. E03-1P601-226, Revision (b) The design review indicated that the circuitry depicted on schematic diagram No. E02-1LD99-007, Revision C, was revised by FECN 14036 on February 14, 1986, to incorporate an FPR-8070 concern. The leak Detection Drywell Isolation Valve Logic was fcund to be deficient in that these valves will automatically reopen when the isolation signal to their circuitry is rese The valves are required to remain closed after a safety signal is received until they are manually reset by the operator. During the incorporation of this modification, the licensee has changed the circuit logic by adding a latching relay to keep the circuit " sealed in" on ESF signal actuatio Subsequently, FECN-14391 was issued on March 27, 1986, this.FECN superseded FECN-14036 due to an identified discrepancy between FECN-9843 and FECN-14036. FECN-14019 was issued on February 13, 1986, to revise the logic diagrams associated with the above modification. On February 19, 1986, FECN-14083 was issued to revise the logic depicted in FECN-14019 and therefore suspended FECN-14019. No deficiencies were identified in the methodology used by the licensee to identify the termination information on schematic diagram No. E02-1LD99-077; however, the inspector identified the following deficiencies on schematic drawing No. E02-1LD99-007: Cable designated as VG99-087 should be VG99-02 . Cable designated as VG99-013 should be VG99-011, 4 Cable designated as VG99-013 should be VG99-00 . DTF was not written to revise Panel Module Wire Lists associated with this modification to indicate that spare conductors of G. E. cables have been use (c) Review of circuitry depicted on schematic diagram No. E02-1LD99-109, Revision G, indicated that on October 24, 1985, FPR-6912 was issued to add a missing connection and cable between panel No. H13-P701B and panel No. H13-P715B as per G. E. No. FDDR LH1-3400, Revision 0. On November 15, 1985, FECN-13158 was issued to implement the missing connection as stated in FPR-6912. Subsequently, FPR-7254 was issued on November 21, 1985, indicating that FPR-6912 did not correct the missing connection problem. On December 20, 1985, FECN-13547 was issued to revise the missing connection added per FECN-13158 and therefore superseding FECN-13158. The inspector reviewed the applicable drawings. No deficiency was identified with the methodology used by the licensee to depict the termination on schematic diagram No. E02-1LD99-109, Revision _ _ _ _ _ , ._ . -. .

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-During this review.the inspector noted that FECN-1439 was not posted against controlle'd_ drawing No. E03-1P741E-002, Revision N, as required by the procedure. _Also, FECN-14036-was still. posted against the drawing even'though it had been-

. supersede (2) Conclusion The inspector reached the conclusion that although many design

. change notices have_been issued to correct the various noted design errors; the-schematic diagrams delineated the intended

' design which is'to logically indicate'the operation of the-

-particular. circuit or system. The schematic diagrams are no intended to indicate the actual ~ point to point wirings of the

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. circuit or components, this'.is. accomplished by_the wiring or

-. connection diagram The schematic diagrams and.the connection diagrams need to always be electrically equivalent, that is,'the schematic diagrams are correctly. translated into wiring diagrams which reflect the as-built configuration of the. plant. Durin the review of the schematics noted above, the. inspector did not observe an deficiency with the terminations depicted on the i _ drawing,.therefore this' portion of the allegation could not be substantiated, therefore it is considered close i The-deficiencies observed during this review as noted in

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Sections 2.a.(1) and (2) are considered an open ite (461/86071-01(DRS))

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b. Configuration Control Program Policy j (1)_ Review This portion of the allegation addressed the allegers concern that motor power connections may be modified as required to obtain proper motor rotation without revising the wiring diagrams i in FECN 12329, dated September.28,- 1985, which. adds this j requirement-to_ Specification No. K2999, Article No. 702.12a,

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Amendment 1 This issue is described in Condition Report No. 1-85-10-091,

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dated October 17, 1985. The specific concern is that the power cable color coding does not match the "as-built" configuration for motor feed cables. Review of this issue revealed that Nuclear Station Engineering Department (NSED) recommended to CPS-management that wiring diagrams should be revised in 1987, and allow an interim exception to CNP 2.06, Paragraph 2.3 wnich states that the manager of NSED will establish and maintain control of the CPS design to ensure that CPS design documents define the approved configuratio ,

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The power cables color coding was removed from all electrical wiring diagrams on October 16, 1986. The licensee stated that this action will eliminate the disagreement between design drawings and the "as-built" configuration. The inspector questioned licensee's engineers as to the administrative controls in place to control activities relating to the determination and retermination of motor power cables. The licensee stated that motor rotation will be verified as it has been in the past through job steps in the applicable Maintenar.ce Work Request (MWR); the licensee noted that this method of controls is preferable to creating a maintenance procedure. Documented evidence requiring that a motor rotation be performed after determination and retermination of power cables was not available for review. The licensee stated that normal practice was to require maintenance pe~sonnel to either check motor rotation or require cable leads to oe tagged per CPS form No. 8801.017001

" wire or component Removal / Jumper Installation."

The inspector conducted a field inspection to determine if the there are adequate administrative controls applicable to determination and retermination of power cables. The inspector

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examined MWR C35640 which included form No. 8801.01F001 documenting the sign off of the craftsman who determinated and reterminated the power cable leads, and the QC inspector who verified the retermination of the leads. The cable color coding was denoted on form No. 8801.01F00 (2) Conclusion All of the issues above have also been reviewed by another NRC inspection team. (See Report No. 461/86053(DRS)). The inspector reached the conclusion that the as-built configuration of the power cables is not maintained due to the fact that all color codes were removed from the connection diagrams; however, the administrative controls in use for this activity may eliminate confusion and personnel errors if applicable procedures are closely followed. This concern will be followed in the normal practice used to close concerns developed by the previously mentioned inspection report and is therefore close . Followup on 10 CFR 50.55(e) (Raychem Heat Shrink Splice _s_)

IE Information Notice No. 86-53, as issued on June 26, 1986, to alert licensee's of a potentially generic safety problem involving improper installation of heat shrinkable tubing manufactured by Raychem, which is employed as a covering of electrical splices and terminations. The licensee had conducted a sample inspection on Raychem splices and determined that non qualified configurations existed at Clinton. This is documented in CR-1-86-08-125, dated August 21, 1986, and in 10 CFR 50.55(e)

Referral No. 86-RE37, dated August 25, 198 ,

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a. ; Observation of Field Inspection Activities The inspector observed the licensee's inspection activities in

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progress associated _with the drywell H2 Ignitors. .This inspection was conducted.to assess the effectiveness of the licensee's Raychem splice inspection program. The inspector reviewed the.following documents used by the licensee's inspection team:

• MWR No. C31421, dated October 12, 198 * FECNs-15339, 15334, and 1534 * Acceptance Criteria Procedure No. 8492.01, Revision '

• Termination card and QC termination check list for cables No. 1HG15Q, 1HG15P, 1HG15N, 1HG23N and 1HG15 *

The inspector interviewed the. licensee's QC inspector who indicated that he had started inspecting the H2 Ignitor' splices a day earlier, that so far he had inspected six 2/c tables (12 splices). The NRC inspector questioned the QC inspector whether he had documented all of his findings during this. inspectio The QC inspector stated that all six cables contained braiding underneath the shim which does not-comply with the manufacturers acceptance criteria. He further stated that in his opinion all splices (Total 12) involved with the six cables inspected had been improperly done and will need to be replaced. At the time of the discussion.the QC inspector have not documented his findings. The inspector _ expressed the-concern that the QC. inspector identified'this deficiency on the previous day; however, he did not document it on the inspection check lists. The QC inspector stated that he needed to discuss this finding with engineering before documenting it. In addition, the NRC' inspector noted that the inspection checklist used by the QC inspector to conduct this inspection contained a general acceptance criteria'of a very specific attribute. It did not contain inspection requirements of (1) minimum bend radius, (2) non qualified or braided jacketing materials in splice area, and (3) heat shrinkable materials used. This matter is considered unresolved (461/86071-02(DRS)). Review of QC Inspectors Training During the interview, the QC inspector indicated that prior to his job at Clinton (Joined Clinton Project on April 14,1986) he had received-some Raychem Heat Shrink splicing training; however, no documented evidence existed to indicate that he had received this training prior-to him joining the Clinton project. Records on file as denoted in the i QA Training Records Master List, dated June 26, 1986, indicated that on April 19, 1986 he had received minimal Raychem splices trainin . The inspector reviewed the training records to determine the specific

{1 Raychem splice training given to Level II QC inspectors. Lesson Plan i No. QAT-P-5350-10, Revision 0, Page 4 contained very limited training i- data pertaining to Raychem kit reflection, instructions, and approved cleaner for power cables, no training was found addressing control l

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cable In addition, training Lesson Plan No. QAT-P-5350-10, titled

" Introduction to Electrical Inspection Requirements for Maintenance and Test Activities" contained a vast amount of information on various electrical subjects such as: electrical termination, soldering, Torquing, maintenance megger test, maintenance ductor tests, system

cleanliness, conduct of maintenance, wire or component removal / jumper installation form, startup program, conduct of test, molded case circuit breaker / overload relay test, and functional test for motor operated valves. The inspector noted that on April 19, 1986 a short 30 minute training session was given to the QC inspector and seven other inspectors covering Lesson Plan No. QAT-P-5350-10. Furthermore, on the same date, the QC inspector received classroom instruction on the following Lesson Plans No. P-5350-3, P-5350-5, P-5350-7, P-5380-8, P-5820-1, and P-5820-2. Records indicated that the QC inspector was hired on April 14, 1986, and certified as a Level II electrical I inspector on April 25, 198 I On November 5, 1986 in a telephone conversation with the licensee's training instructor the inspector was informed that selection of craft personnel at Clinton is done through telephone interviews, review of resumes, and interview There is no requirement for documented evidence to indicate that the craftsman received specialized training prior to him or her joining Clinton. Neither is there a requirement for a test to be given to determine if the person is qualified to perform the specific work for which he was hire The resolution of concerns noted in Paragraphs 3.a and 3.b above is considered an unresolved item pending further evaluation by the licensee and review by NRC (461/86071-03(DRS)).

4. Open Items Open' items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involves some action on the part of'the NRC or licensee or both. Open items disclosed during this inspection are discussed in Paragraphs . Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. An unresolved item disclosed during this inspection is discussed in Paragraphs 3.a and . Exit Interview The Region III inspector met with licensee representatives (denoted under Paragraph 1) at the conclusion of the inspection on October 30, 1986. The inspector summarized the purpose and findings of the inspection. The licensee acknowledged this information. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents processes as proprietar .. . . . --- .- . - . _ _ _