ML20209F533

Rev 1 to Issue Specific Action Plan I.a.2, Insp Repts on Butt-Splices

ML20209F533
Person / Time
Site:	Comanche Peak
Issue date:	04/01/1987
From:	Mallanda J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20209F518	List: ML20209F533 ML20209F553 ML20209F567 TXX-6425, Forwards Rev 1 to Issue Specific Action Plan I.a.2, Insp Repts on Butt-Splices, Rev 1 to Issue Specific Action Plan III.a.5, Preoperational Test Review & Approval of Results & Rev 1 to Issue Specific Action Plan Vi.A, Gap..
References
NUDOCS 8704300310
Download: ML20209F533 (35)

Text

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COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: I a.2

Title:

Inspection Reports on Butt-Splices REVISION 1 l

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cal Et& W. Beck, Chairman CPRT-SRT

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R 870427 A DO{05000445 PDR

R: vision: 1 Pag 2 1 of 34

.m RESULTS REPORT t \

(._ / ISAP I.a.2 Inspection Reports on Butt-Splices

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG 0797, Supplement j Number 7, Page J-29)

"...the TRT reviewed the QC Inspection Reports for 12 butt-splices and found the following:

Nine of these splices were documented on the inspection form designated in paragraph 3.3 of the procedure for post-installation inspections instead of on the correct form designated for witnessing-type inspections. It should be noted that all splices were required to be witnessed by QC personnel per paragraph 3.1.d of the procedure [QI-QP-11.3-28 Revision 21, " Class 1E Cable Terminations"].

Six of the nine incorrect forms contained handwritten notes by the inspector indicating that he had witnessed the splice; however, no reference was added to indicate that the installation of the heat-shrinkable sleeves was required to be witnessed.

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The remaining three of the nine incorrect forms did not indicate that the splices had been witnessed.

For three splices which were documented on the correct forms, the forms all contained an "N/A" (not applicable) handwritten by the inspector on the line indicating that the installation of the heat-shrinkable sleeve was witnessed."

2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement Number 7, Item 6.(d)(2) and (3), page J-31)

"TUEC shall accomplish the following actions prior to fuel load:

... ensure that ...(2)* all QC inspections requiring witnessing for splices have been performed and properly documented, and (3) all butt splices are properly identified on the appropriate design drawings and are physically identified within the appropriate panels."

Item (1) regarding installations requiring heat-shrinkable insulation sleeves was addressed by Results Report I.a.1,

" Heat-Shrinkable Cable Insulation Sleeves."

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' Page 2 of 34- '

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% ~RESULTS REPORT

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-ISAP 1.a.2 i /

(Cont'd) i

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3.0 BACKGROUND

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! The following information should be considered in addressing the V issue identified by the NRC:

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From late 1982 through'mid 1983, while incorporati g 'certain j-

" human factors" modifications and while completing vacious

[ other rework on control panels, some conductors were found to be too short to be properly terminated at designated '

i termination points. In lieu of repulling cables or ,

redesigning cabinet internals, either of which wo, uld have ,e involved significant disassembly and rework, the \?SES ProjectJ elected to add extensions to the subject conductor 9 by using

{- butt-splices. The type of butt-splice used by the CPSES 'Q

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Project for splicing in panels was'the AMP Pre-Insulated

j. Environmentally Sealed (PIES). splice.

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IEEE.383-1974, "IEEE Standard for Type Test of Class 1E  !

}- Electric Cables, Field Splices, and Connections for Nucigar ,

I- Power Generating Stations," recognizes that qualified field splicing is acceptable, and provides criteria for the i ./ (

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qualification of such splices. As discussed in ISAP I.a.3,t '

i " Butt Splice. Qualification," the AMP PIES splices have been '

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qualified for use in electrical panels at CPSES.

Section 8.1.5.2.4 of the FSAR originally committed to the

} provisions of Draft Standard IEEE 420-1973, "IEEE Trial-Use 1

I Guide for Class 1E Control Switchboards for Nuclear Powstr, i Generating Stations," which states that splices are not '

allowed within control switchboards (including panels).

Regulatory Guide 1.75, Rev. 1, " Physical Independence of

{ Electric Systems " states that splices in raceways should be ,

j prohibited.

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In July, 1983, TUGC0 contacted the NRC staff to discuss the *

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I potential need to revise the FSAR to cover these splices.

FSAR Amendment 44 was issued in October, 1983, to encompass ' .

l the use of these splices'in control panels. The TRT ' '

investigation occurred in July, 1984 - subsequent to the submittal of this amendment, but prior to the NRC response.

! Upon inspection of documentation associated with twelve of the j control panel splices, the TRT noted the concerns listed in Section 1.0. 1 1

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Ravicion: 1 Pags 3 of 34 O RESULTS REPORT l

U) ISAP I.a.2' (Cont'd)

3.0 BACKGROUND

(Cont'd)

- In September, 1984, the NRC Staff approved the FSAR amendment

,? with the provisions that: (1) the installation procedures provide for verification of the operability of those circuits

' *y for which splices are being used; (2) the wire splices used i

are qualified for anticipated service conditions; and (3) the splices are staggered within the panel so they are not adjacent to each other in the same wire bundle and pressing against one another.*

. 4.0',CPRTACbWNPLAN 4.1 SchpeandMethodology The objectives of the action plan were to assure that known j butt-splices are properly identified on the appropriate design drawing.s. are physically and properly installed where requifed, and that required inspections have been performed and properly documented.

The. scope of this plan included the investigation of all Class 12< essential and associated cables that were known to be spliced with AMP PIES splices. This action plan was divided i . , into three sequential phases.

1 4.1.1 Phase I Phase I consisted of a review of the in-process,

, post-installation and final Inspection Reports (irs)

}iorthetwelvecablesruviewedbytheTRTandtwelve (12) additional cables selected by TUGCO. The purpose jof this review was to determine if required documentation for splice witnessing existed and was 4

acceptable. This review substantiated the NRC concerns, and Phase II was initiated.

4.1.2 Phase II Phase II consisted of the following items:

s 3 Items (1) and (2), and the procedure changes for item (3) are discussed in the Results Report for ISAP I.a.3. The reinspections for item (3) are discussed in this report.

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i Revision: 1

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./ KESULTS REPORT v' ISAP I.a.2 fe (Cont 'dI/

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r p 4.0 CPRT ACTION PLAN (Cont'd) T i

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s Review of all drawings and design change documents for Class.lE essential and '

• associated' cables iri the control room and cable spreading room panels of Unit 1 to e

identify those panels that included cables that had been authorized to be spliced.*

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Inspection of.these panels to determine

' whether the drawings ecd actly reflected the

• e, as-built condition, and Ithether the AMP PIES

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splices met the FSAR and installation g

requirements, and the NRC requirements listed in Section 2.0. If the drawing did not reflect the as-built condition of the cable, the drawing was revised to show the actual a

hardware configuration. A review of the t'

s associated CPSES Project irs for the spliced cables was .61so performed to determine n ' ' 4' whether the splices had been inspected and

' had becu found acceptable per Quality Inspection Procedure QI-QP-11.3-28.

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Removal of any AMP PIES splices that were considered unsatisfactory after1 evaluating i

the above inspection results. .These removed

,, splicts were pullout-tested to' determine the

, ,J> accerrability of the splices for their intended service conditions. The test was

'? conddcted in accordance with C;L. Standard 486C. 'Section' 13. " Pullout Tests ." Prior to

,, this destructive test, the splices were l

radiographed to determine. the actual depth of I conductor insertion into the wire barrel of the splices. (The design of the splices l

normally precludes determining this depth l

l risually,af ter installation.'p.

To be reasonably sure thct no undocueented AMP PIES splices existed in Class IE essential and associated circuits in the control room and cable spreading room paneis l

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• As discussed in Section 5.0, this scope was later expanded to lV I

include! panels outside these two rooms.

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Nl Revision: 1

,, Page 5 of 34 1 '

RESULTS REPORT

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4' ISAP I.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) of Unit 1, the population of Class 1E panels for which drawings and design change documents did not indicate the presence of l any AMP PIES splices was inspected to confirm that no splices were present. These inspections were accomplished without separating all cable bundles or dismantling equipment.

4 Phase 11 also accomplished part of Action Plan I.a.3, i

" Butt-Splice Qualification," by inspecting for known

' splices located adjacent to and pressing against one i another in the same wire bundle -(i.e., inspection for  :

" stagger" of splicas). '

If one or more AMP PIES splices were found not to be l proporly installed (e.g., not fully inserted, crimped with the wrong tool, wires curled back, or incorrect O size splice used), Phase III was to be initiated by TUGCO. (This occurred.)

4.1.3 Phase III 4

Phase III consisted of the identification and inspection of all essential circuits where AMP PIES splices may have been used for terminations of equipment (e.g., pigtails on solenoids or electrical e

devices) or splicing of cables in Units 1, 2 and Common areas that were not inspected during Phase II.

Nonconformance Reports (NCRs) were issued by the CPSES Project to identify and initiate inspections of these cables. Phase III was overviewed by CPRT third-party personnel.

4 4.2 Participants Roles and Responsibilities The organizations and personnel that participated in this effort are described below with their respective work scope.

4.2.1 CPSES Project 4.2.1.1 Reviewed drawings and design change j documents.

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q Revision: 1 Pags 6 of 34 RESULTS REPORT

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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.2 Assisted the Review Team Leader in identifying cables to be inspected for AMP PIES splices.

4.2.1.3 Processed NCRs that were generated due to '

this action plan.

4.2.1.4 Assisted the Review Team Leader in the pullout test program preparation and execution.

4.2.1.5 Prepared pullout test procedure.

4.2.1.6 Performed Phase III activities.

4.2.1.7 Personnel Mr. W. I. Vogelsang TUGC0 Coordinator

() 4.2.2 Electrical Review Team 4.2.2.1 Reviewed and approved the third-party reinspection procedure.

4.2.2.2 Reviewed third-party Inspection Reports and CPSES Project NCRs.

4.2.2.3 Reviewed and approved the pullout test procedure.

4.2.2.4 Reviewed and evaluated the pullout test results. Approved the test report.

Determined any ongoing corrective actions l based on the test report results.

4.2.2.5 overviewed the CPSES Project inspection t

effort described in 4.1.3 (Phase III).

4.2.2.6 Determined root cause and generic implications, and evaluated safety significance.

4.2.2.7 Personnel (prior to October 18, 1985)

Mr. M. B. Jones, Jr. Review Team Leader

Rsvision: 1 Page 7 of 34 RESULTS REPORT O .

ISAP I.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Mr. E. P. Stroupe Issue Coordinator 4.2.2.8 Personnel (starting October 18, 1985)

Mr. J. J. Mallanda Review Team Leader 1

Mr. J. R. Pearson Issue Coordinator Mr. M. B. Jones, Jr. Third-Party Adviser Mr. E. P. Stroupe Third-Party Adviser 4.2.3 CPRT - QA/QC Review Team '

i 4.2.3.1 Prepared the inspection procedure.

4.2.3.2 Inspected the AMP PIES splices for compliance with acceptance criteria.

4.2.3.3 Reviewed CPSES Project inspection documentation to determine whether evidence of splice witnessing existed.*

4.2.3.4 Performed the overview inspection (see Section 4.2.2.5) as determined by the Electrical Review Team Leader.

4.2.3.5 Personnel Mr. J. L. Hansel Review Team Leader -

QA/QC 4.2.4 Third-Party Adviser 4.2.4.1 Reviewed pullout test procedure.

1 4.2.4.2 Supervised pullout test.

4.2.4.3 Personnel Mr. L. D. Bates Electrical Engineering Adviser O-

• In some cases this review was performed by the Electrical Review ,

Team. t 1

Ravision: 1 Pags 8 of 34 RESULTS REPORT f,

• l V ISAP 1.a.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Qualification of Personnel Where inspections required the use of certified inspectors, qualification at the appropriate level was to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Teste g Personnel at Nuclear Power Plants". CPRT third-party inspectors were certified to the requirements of the third-party employer's Quality Assurance Program, and specifically trained in accordance with the CPRT Program Plan.

' Where tests required the use of certified test personnel, qualification at the appropriate level to the requirements of ANSI N45.2.6 and Regulatory Guide 1.58 was not met. These requirements were not part of the CPRT Program Plan at the time of testing. However, the qualifications of the individuals supervising the tests were considered by the Review Team Leader to be more than sufficient to render the tests valid.

' Third-party participants in the implementation of this acticn plan met the personnel qualification and objectivity requirements of the CPRT Program Plan.

Other participants were qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. CPRT activities performed by other than third-party personnel are governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality," of the CPRT Program Plan.

4.4 Procedures 4.4.1 Instruction QI-002, "CPRT Action Item I.a.2, Inspection of Butt-Splices and CPRT Action Item I.a.3, Butt-Splice Qualifications."

4.4.2 Test Procedure I.a.2/I.a.3-001, " Butt-Splice Pullout Test Procedure."

4.4.3 Test Procedure I.a.2-002, " Butt-Splice Special Test."

(See Section 5.2.6.)

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Rsvision: 1 Page 9 of 34

^ RESULTS REPORT ISAP I.a.2 (Cont'd) 4.0 CPRT" ACTION PLAN (Cont'd) 4.5 Acceptance Criteria 4.5.1 The acceptance criteria for the butt-splice reinspection Revision 4. are listed in Instruction No. QI-002 ,

4.5.2 The acceptance criterion for drawings is that ach e

Class IE essential and assoelated cablesrefle n

4.5.3 Test I.a.2-002.Procedure I.a.2/I.a.3-001 and Test P e e in 4.5.4 The acceptance inspection report criterion for the review of an the splice was witnessed.(IR) is that the IR indicates that 4.6 because of other findings, then e.

oved an NCR Decision Criteria, the acceptance criteria ofIn Phase II, failure 4.5.1, 4 5 2 of one or more ces to meet initiate Phase III. . .

, or 4.5.4 will 5.0 (This occurred.)

IMPLEMENTATION OF ACTION PLAN ULTS AND DISCUSS The Phase I review of CPSES Project irs subst afindings result, that splice witnessing had not always bantiated the TRT Staff een documented. As and document review of AMP PIES splices pection in Class IE associated spreading circuits room in1.panels located in the contr of Unit essential and o l criteria of Sections 4.5.1, 4.5.2, and 4.5.4 were disMany deviation result, two further investigations were initiated covered. As a was expanded to include the reinspection and docum First, Phase II known splices in electrical panels in other ar ent review of Second, Phase III was initiated by the CPSES eas ofP Unit 1.

and reinspect any essential cables in areas not covroject to identify for which AMP PIES splices might have been ered usedby Phase II included Units 1, 2 and Common. .

Phase III O

Rovision: 1 Pags 10 of 34

' RESULTS REPORT i

s ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Sections 5.1 through 5.3 provide a discussion of the results from the implementation of Phases I, II and III, respectively. Use of J the results from these activities is discussed in Section 5.4. l Other CPRT activities related to this ISAP are discussed in Section 5.5. Analyses of the findings, including safety significance, adverse trend, root cause and generic implications, as well as recommended corrective actions are presented in subsequent sections.

5.1 Phase I Phase I consisted of a review of the documentation for the twelve cables reviewed by the TRT and for an additional' twelve cables selected by TUGCO. As the TRT had found, the documentation failed to meet the requirements for splice witnessing. As a result, Phase II was implemented. The scope of Phase II included any AMP PIES splices reviewed in Phase I.

Section 5.2 includes a detailed discussion of the findings from Phase II and the corrective actions taken.

5.2 Phase II 4

1 5.2.1 Design Document Review The CPSES Project reviewed drawings and design change documents for Class 1E essential and associated cables in the control room and cable spreading room panels of Unit 1 and identified those panels where design documentation indicated that AMP PIES splices (1) were and (2) were not installed. These lists were then used for the third-party reinspections described below.

5.2.2 Reinspection of AMP PIES Splices Reinspection Methodology The initial reinspections included, with one exception involving nine splices *, all Class 1E essential and

• The splices in two HVAC panels were inaccessible for this inspection. Later three splices in these panels were judged accessible and were reinspected. One other splice has been replaced subsequently due to inadequate inspection documentation.

O. The CPSES Project has been requested by the Electrical Review Team to reinspect the remaining splices in these panels.

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L Revision: 1 Page 11 of 34 s RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) associated cables that had been identified by the design document review as authorized to be spliced.

Cable bundles were disassembled to the extent necessary to identify and reinspect any splices in these cables.

During this. identification and reinspection activity, the panels were also reinspected for unauthorized splices. This aspect of the reinspection was limited to those conductors that were initially visible or made visible by the cable bundle disassembly described above. However, for those panels that were considered highly likely to contain additional unauthorized splicing, the cable bundles were disassembled to allow any other unauthorized splices to be identified and reinspected. As a result of the above activities, 577 AMP PIES splices were identified and reinspected.

Because of many construction _ deviations identified during these reinspections, the scope of Phase II was O expanded to include the reinspection and document review of other known AMP PIES splices in panels in Unit I and Common. (This scope otherwise would have been included in Phase III.) As a result of this expansion, which included Motor Control Centers (MCCs) and local Heating Ventilating and Air Conditioning (HVAC) panels, 31 more AMP PIES splices were identified and reinspected, thus bringing the total number reinspected to 608.

The reinspections of each AMP PIES splice consisted of a check of each of the following attributes:

that the correct splice for the associated conductor size had been installed; that the splice was properly crimped, including use of the proper tool (evidenced by a " dot code");

that no conductor strands showed outside the wire barrel of the splice; that the conductors at each end of the splice were the same color and size as each other;

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that the splice was identified on the associated CPSES Project drawing; and

R* vision: 1 Paga 12 of 34

(~'s RESULTS REPORT

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ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) that the splice had not been heat-shrunk.*

Following completion of the reinspection of the splices, the conductors were verified to be satisfactorily rebundled. Rebundling was considered satisfactory when the following three criteria were met:

that splices in the same bundle were staggered or spaced so that they were not adjacent to and touching one another**;

that the cables for redundant trains met separation requirements ***; and that the bend radius requirement for the conductors was met ***.

The results of the reinspections were evaluated, and

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\s- those splices judged unacceptable were removed. All but three of the removed splices were pullout-tested **** to determine the actual effect of the noted deviation (s) on splice integrity. The results of these reinspections are discussed below and the findings are summarized in Appendix A. Where the discussion below indicates that certain splices were removed and included in the pullout test, the safety significance of the respective findings was assessed by that test (see Section 5.2.4).

The AMP PIES splice is designed to allow for heat-shrinking of the splice insulation in order to achieve an environmental seal.

However, for mild environments such as these control panels, heat-shrinking is not necessary. CPSES Project design documents usually instructed craft not to heat-shrink the splices.

The verification of this criterion completed the commitment made in the Results Report for ISAP I.a.3.

• • • These attributes are out-of-scope with respect to the AMP PIES splices, but are fundamental to proper rebundling.

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(^ **** The three exceptions are discussed in the appropriate sections below.

Rsvision: 1 Pags 13 of 34 RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Correct Splice Installed Eight splices were found where the wrong size splice had been installed for the conductor size involved.

All eight were splices intended for #12-14 AWG conductors, bat were installed on #16 AWG conductors.

All eight splices had been authorized by CPSES Project engineering on the same Design Change Authorization (DCA 17,762). This DCA actually specified the wrong splice. These are considered to be design deviations.

All eight splices were removed and included in the pullout test.

Proper Crimping Sixteen (16) splices were noted as having improper crimps, including crimps on the wire stop (rather than the wire barrel), twisted crimps, and off-center p crimps. Fourteen (14) of these were removed and

(. included in the pullout test. The remaining two were omitted from this test erroneously due to an ambiguous aspect of the inspection procedure. Both of these splices were noted as having crimps that " appeared twisted." NCRs were written, resulting in both splices being replaced. The Electrical Review Team has evaluated these two splices separately and considers that they were adequate to perform their intended satety function. These 16 cases are considered to be construction deviations.

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Three splices were noted as having insulation damage caused during crimping. For two of these, protection of the underlying wire barrel and conductors was still provided. For the remaining splice, the damage resulted in the wire barrel being exposed. This splice l was noted as being installed within a large wire bundle I such that it was protected by the surrounding conductors. Consequently, the splice could still have performed its intended safety function. As this was the only such deviation, and essentially all of the known splices have been reinspected, there is no adverse trend. All three of the splices with insulation damage were removed and included in the pullout test. These are considered to be construction deviations.

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- RESULTS REPORT O ISAP I.a.2 (Cont'd) 7 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Twenty-four (24) more splices were noted during reinspection as unsatisfactory because the dot code left by the crimping tool was incorrect (thus indicating that the wrong tool had been used). These splices were all removed and included in the pullout test. Two other splices that had been noted by third-party inspectors as improperly crimped due to the crimps being twisted were also noted by the Electrical Review Team as evidencing the wrong dot code. These i

two had been included in the pullout test because of the twisted crimps. These 26 cases are considered to be construction deviations.

Thirty-four (34) splices were noted as indeterminate for this attribute because the dot code could not be discerned due to the splice having been heat-shrunk.

(AMP's literature indicates that the dot code will disappear when the splice is heat-shrunk.) For

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( ,)g 28 of.these, the CPSES Project irs indicated that a QC inspector had witnessed the correct tool being used.

These Vere not considered to be deviations. For five of these, the CPSES Project irs indicated that the wrong tool had been used. These five were removed and i

included in the pullout test. These are considered to be construction deviations. One was indeterminate because witness documantation was not found. Though 4

this one was later removed, it was not included in the pullout test. Based on the results from pullout i

testing of other similar specimens, for which pullout j forces ranged from 50 to 126 pounds, the Electrical Review Team considers that this splice would have been able to perform its intended safety function. This is considered to be a construction deviation.

4 No Strands Outside Barrel t

This QI step was apparently intended to check for strands showing outside the insulating barrel of the splice. No such deviations were noted. However, three j cases were noted where the inspector was able to discern that strands had not been inserted into the wire barrel of the splice. These were removed and included in the pullout test. During review of the radiographs of the other pullout specimens, 10 more

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.5 Revision: ~1 Page 15 of 34 RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) cases were noted where strands had not been inserted into the wire barrel of the splices. This condition can not always be detected by visual inspection, either because the opaque quality of the splice insulation prevents the inspector from noting that a strand is curled back or cut off, or because the insulation of the conductor is flush with the end of the splice wire barrel. The implications of this' potential shortcoming in the reinspection process are discussed in Section 5.2.6. These 13 cases are considered to be construction deviations.

Matching Conductor Size and Color-Four cases were found where the inspector could not determine whether the correct size of extending conductor had been spliced onto the field conductor.

' As these four were a subset of the eight splices that (N were the wrong size for the given size of field cable (see first attribute above), they were removed and included in the pullout test. Examination during 4

pullout testing indicated that the correct extending

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conductor size had been used, thus these are not considered to be deviations.

Six cases were found where the color of the extending conductor did not precisely match the color of the field conductor. In each case, it appeared that the extending conductor was from a different cable type, and thus differed in chromatic content. Though this condition had no direct functional impact (all were

terminated correctly), all six splices were removed and included in the pullout test. These are considered to i

be construction deviations.

Splice Shown on Drawing There were 109 cases where the splice was not shown on CPSES Project drawings. Sixteen (16) of these were

! cases where the corresponding conductor had been

spared, and thus these were not considered to be valid O

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I Ravision: 1 Pags 16 of 34 e3 RESULTS REPORT

-\ tj-ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) deviations.* Another 16 of these were found never to have been authorized by engineering and thus constituted construction deviations. (Splicing is prohibited without engineering approval.) The remaining 77 cases involved splicing that had been authorized by DCA, but where CPSES Project drawings had never been revised to reflect the splicing. These were considered to be design deviations. In 70 of these cases, the DCA had actually been revised later to delete the authorization for the splices. These splices were removed and subject to pullout testing only in cases where other findings were noted that

impacted the quality of the splices.

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There were 149 cases where the CPSES Project drawings indicated that conductors were spliced but where third-party reinspections found no splices. NCRs were written to initiate the correction of the drawings.

These are considered to be design deviations.

> Splice Not Heat-Shrunk As discussed above, 34 cases were found where the splice had been heat-shrunk. Design documentation was revi- ad for these cases. For 29 there was no reqr -ment prohibiting heat-shrinking at the time of insta .ation. As there is no technical reason to avoid heat-shrinking, these are not considered to be deviations. For the remaining five, the DCAs in effect instructed that the splices should not be heat shrunk.

Because of this prohibition, these are considered to be construction deviations. All five were removed and included in the pullout test.

Seven of those splices that had been heat-shrunk were noted as having insulation damage. It appears that these splices wers overheated causing a slight split in the sleeve of the splice at a point of crimping-induced stress. In all seven cases the wire barrel and As discussed in the Results Report for ISAP I.a.4, " Agreement Between Drawings and Field Terminations," spare conductors are not

( required to be shown on drawings per CPSES Project procedures.

J i

. _ , , , _ . . . . _ _ . _ - ,s __,-.m.. . _ _ , _ ..____..m.~-_m__, ____.-________,,___,__-.._r._-,.._______~m ...,,,-.,_m. _ _ . . _ ,

I

-Rsvision: 1 Pags 17 of 34 '

RESULTS REPORT

+

ISAP I.a.2 (Cont'd)

+

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i conductors were still protected. The damage would not have affected the intended safety function of the splices. Nevertheless, all seven splices were removed

' and included in the pullout test. These are considered to be construction deviations.

4 Proper Rebundling and Stagger

, In many cases, the reinspections also found that the splices had.not originally been staggered in the wire bundles. These were not considered to be deviations, i

because no such requirement was in place at the time that the splices had been installed. (The requirement was added following the receipt of the NRC comment.to FSAR Amendment 44.) During the rebundling process that followed the reinspections, CPSES Project personnel ensured that the splices were staggered. This activity e

was verified by third-party inspectors. In one case,

f' which involved one cable with six spliced conductors, j ( ,)s there was insufficient slack in the conductors to achieve the required staggering. The CPSES Project e issued an NCR to document this finding, and j

dispositioned the NCR by directing craft to install .

insulating material between the conductors.

, Other Observations Over the course of the reinspections, third-party j

inspectors noted that a significant portion of the splice population had a condition described as

" improper insertion depth and/or overstripped insulation." The indeterminacy of the condition is due to the inability to determine insertion depth of the i conductors into the wire barrel by post-installation visual inspection. Therefore, when there is a gap noted between the conductor insulation and the wire

. barrel, it is not known whether the conductor was i

underinserted, the insulation was overstripped, or

both. None of the conditions involved the conductors i being exposed beyond the insulating barrel of the

splice. The implications of this potential shortcoming

, in the reinspection process are discussed in Section l: 5.2.6. >

O

Revision: 1 Paga 18 of 34 RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

During the reinspection effort, other findings that were unrelated to splicing (e.g., cable separation violations) were identified. These findings were tracked as out-of-scope observations and, as noted in Section 5.4, were forwarded to the appropriate RTLs for consideration.

5.2.3 Documentation Review A review of CPSES Project irs was conducted for the AMP

• PIES splices that had been identified by reinspection.

This review involved.a check of the irs to verify that the PIES splice installations had been witnessed by QC during installation. In addition, a check was performed of irs for cables that had been authorized to be spliced, but where no splice had been found.

This review found that adequate evidence of QC witnessing did not exist-for 101 of the splices discussed above. This review also found several other O unsatisfactory conditions. Appendix B summarizes the documentation review findings and the corrective actions taken.

' Of particular concern was a finding where splice witnessing was indicated on eight irs for certain conductors that had not actually been spliced. As a result of this finding, in addition to all of the construction deviations noted during reinspection, CPSES Project QA initiated Corrective Action Report CAR-050 to explore further the work of four electrical QC inspectors whose work came into question. This investigation found that one of these inspectors had completed inspection documents for items that he had not actually inspected. This inspector was immediately relieved of all inspection duties, and his historical work was thoroughly rechecked by the CPSES Project.

The work of the remaining three inspectors was found to be acceptable.

One other notable finding from the documentation review was that the irs indicated that an incorrect crimp tool O

Revision: 1 Page 19 of 34 RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) had been used for 19 of the splices.* All 19 of these-splices were removed and included in the pullout test.

5.2.4 Pullout Test Program A test program was initiated that provided the basis for an evaluation of the acceptability of AMP PIES splices with construction deviations.

Samples for the test program were obtained by removing 48 AMP PIES splices (and a portion of the attached conductors) with deviations potentially affecting splice integrity and 32 others that either had no identified deviations or had deviations not expected to affect the integrity of the splices.**

Each splice was first radiographed so that the depth of insertion of wire strands into the wire barrel could be determined. Continuity checks were performed prior to O application of pullout forces on the splices. Splices on #12 AWG conductors were exposed to gradually increasing pullout forces up to 35 pounds, and then maintained at that level for 60 seconds. If they survived this stage, they were then destructively tested by increasing the pullout force until the splice failed. Splices on #16 AWG were subjected to the same test except that the stopping point was 15 pounds.

Of the eighty removed splices subjected'to the pullout tests, three (2-#12 AWG, and 1-#16 AWG) failed to meet the U.L. Standard 486C pullout force requirements. The details of these three'is as follows:

One (#12 AWG) had an improper (twisted) crimp and failed at 15 pounds.

• 14 of these also showed physical signs of an incorrect tool and 5 were indeterminate due to the splices having been heat-shrunk.

In addition, 12 prepared test samples were made using the correct wire size / connector / cool combination and varying insertion depths of the conductor into the wire barrel of the splice. These were O used for comparisons with the radiographed samples removed from the field.

Rsvision: 1 Pags 20 of 34 RESULTS REPORT

\-

.)

ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULT 3 (Cont'd)

One (#16 AWG) had the wrong size splice for the conductor size and had been crimped by the wrong tool. This splice reached the required 15 pounds, but did not maintain that force for the full 60 seconds.

~

One (#12 AWG) had two (out of seven) strands not inserted into the wire barrel. These strands were curled back between the wire barrel and the conductor insulation which also prevented adequate insertion of the remaining five strands into the barrel. This splice failed at 25 pounds.

One other splice was improperly tested. It was on a

1. 16 AWG conductor, but was taken past 15 pounds without stopping. It failed at 27 pounds. Those performing the test presumed that it would likely have passed at

(g 15 pounds for 60 seconds if properly tested. This was (j another case of the wrong size splice and the wrong crimping tool having been used.

Each of the 80 tested splices was found to have acceptable electrical continuity prior to the pullout tests. Although the pullout force did not meet the minimum U.L. test requirements -in three cases, it was noted that in all cases cable bundles are securely fastened together with cable burdle ties at regular intervals, and thus the tension exerted on the splices themselves was expected to be minimal. Stone and Webster Engineering Corporation (SWEC) performed an analysis demonstrating that, under assumptions of proper cable bundle support intervals per FSAR commitments, the maximum pullout force that would be exerted on one of these splices under a design basis seismic event would be 5 pounds for 10 seconds. This became the acceptance criterion for further evaluations of AMP PIES splices. The third-party adviser who administered the pullout test considers that the three splices that failed to meet the UL limits would have passed at a 5 pound load for 10 seconds.

O

Revision: 1 Pege 21 of 34 RESULTS REPORT

.h N. / - ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.5 Inspection of Panels Where Splices Were Not Shown on Drawings Fifty-five (55) panels were identified where the design document review did not indicate the presence of splices. These panels were reinspected by third-party inspectors to determine whether it was reasonable to conclude that splices do not exist in these panels. In 10 panels, cable bundles were broken apart entirely for reinspection; in one panel, the cable bundles were partially separated during inspection; one panel contained no cable bundles; and one panel contained no Class 1E cables. For the remaining 42 panels, the reinspections were accomplished without separating all cable bundles or dismantling equipment.

One AMP PIES splice was found during these reinspections. However, further review revealed that this splice had been authorized by the CPSES Project subsequent to the design document review discussed in Section 5.2.1. Based on these results the Electrical Review Team concludes that few, if any, unauthorized splices exist in these panels.

, 5.2.6 Assessment of Findings As noted in Section 5.2.2, there were two conditions that raised concerns about the ability to judge splice quality by post-installation inspection. The first was the inability to detect missing or curled-back strands, as evidenced by 10 such cases noted by radiographic inspection that had not been detected by field inspection. For the 12 tested splices that had one out i

of seven strands missing or curled back, the destructive pullout forces ranged from 50 to 116 pounds. For the one splice that had two out of seven

! strands curled back, the destructive pullout force was 25 pounds. This condition had been detected during reinspection. This splice was also noted as having the remaining five strands underinserted by approximately l 1/8 inch (half of the wire barrel length). Because all cases where one strand was missing had acceptable

!. pullout forces, and the definitive worst case was i

I detected during reinspection, the post-installation inspection process is considered to be an acceptable

('")s

(, screen for splice quality.

l

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I Rsvision: 1 Pags 22 of 34 i

l

's RESULTS REPORT 1

J ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The, second concern was due to the inability to judge insertion depth of conductor strands into the wire barrel of the splice. Eighteen (18) splices that had been noted during reinspection as bcing overstripped and/or underinserted were included in the pullout testing. If the insulation strip length were closely controlled, then adequate insertion depth could be determined by examining the distance from the conductor insulation to the wire barrel. Radiographic examination suggested that this close control did not exist (i.e., strip length varied significantly), and that there were some cases where conductor strands were indeed underinserted. Only two of the 80 splices _

radiographed were underinserted by as much as 1/8 inch.

These were the two #12 AWG splices discussed in Section 5.2.4 that failed to meet the UL Standard requirement of 35 pounds for 60 seconds. However, it is noted that both of these splices had other deviations affecting O the quality of the splices. For the remaining 16 splices included in the pullout test that had been noted during reinspection as overstripped and/or underinserted, the pullout forces ranged from 58 to 125 pounds. For the three of these for which potential underinsertion was the only noted concern that could impact upon pullout force, the tested pullout forces were 114, 115 and 125 pounds. These data suggested that insertion depths of the remaining AMP PIES splice installations were likely to be acceptable.

In addition to the above concerns about the efficacy of the post-construction inspection process, the design j

document review had failed in identifying all splices at CPSES (evidenced by splices found during i

reinspection that had not been authorized on design i documents). Therefore, the Electrical Review Team recommended a reinspection to identify any remaining undetected splices, and the replacement of all splices installed prior to the time that adequate procedures and training were in place.* However, the CPSES 4

Refer to Section 5.7 for a discussion of procedures and training.

i

. - . . . - - . , , - - . - - . . . - - - . ~ . . - - . . . . - . _ _ ,- - - - _ _ - _ - - . _ . ~ , _ . . . - _ . - _ . . , , , , - - - - - _ , , - . - _ _ _ ,

Ravision: 1 Page 23 of 34 RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i

' Project proposed an alternative approach, which consisted of: (1) an analysis of the maximum pullout force that could be expected at CPSES; (2) an analysis 2

of electrical performance characteristics of the splices; (3) parametric testing of a random sample of-those splices remaining in the field that had passed the Phase II reinspections; and (4) an assessment of the need for further reinspections based on the results I

of steps 1-3. The Electrical Review Team accepted this approach and overviewed its implementation. The results of these activities (discussed below) demonstrated that there is reasonable assurance that the AMP PIES splice installations in electrical panels I at CPSES are capable of performing their intended safety function.

As discussed in Section 5.2.4, SWEC performed a seismic

' analysis that demonstrated that the maximum pullout force that the splices would encounter under worst-case design basis seismic activity at CPSES is 5 lbs. for 10 seconds.* The minimum failure point encountered during the pullout testing was 15 lbs. for the visually-rejected splices and 84 lbs for the visually-accepted splices. Though the three splices that failed pullout testing per the U.L. Standard were not specifically maintained at 5 lbs. for a full 10 4-seconds, the Electrical Review Team considers that those three splices would have passed such a test.

Analysis and testing of electrical characteristics showed that the splices would be capable of carrying rated current under either of the following conditions:

4 (1) uncrimped and with all strands underinserted by 1/8 inch (significantly worse than any deviation j encountered); (2) crimped but with 2 of 7 strands not i

inserted (1 similar deviation encountered and none

^ worse). Furthermore, the spliced field cables are all for instrumentation and control circuits. The actual j

current levels of these circuits will be significantly lower than the rated current of the cables.

i This assumes maximum spacing between wire bundle supports of 15" horizontally and 24" vertically. The CPSES Project has committed '

to a walkdown of electrical panels to confirm this spacing. Any deviating conditions will be corrected.

e

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Ravision: 1 Page 24 of 34

~'

RESULTS REP' ORT s

l ISAP I.a.2 (Cont'd) 5.0

. IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

To determine the adequacy of the splices that had passed visual reinspection, parametric testing of the pullout force was performed on a random sample of 50 of t these splices. The samples for this testing were obtained by removing 50 of the' splices still installed in the field. This testing revealed an average pullout force of 128 lbs. and a standard deviation of 14 lbs.

(thus, the average was more than 8 standard deviations above the maximum expected force at CPSES). The minimum force at which any of the 50 splices failed was 84 lbs. Prior to being pulled to destruction, each specimen was tested at 5 pounds for 10 seconds, 10

) pounds for 10 seconds, and 35 pounds for 60 seconds.

All 50 splices passed at each of these levels.

i Acceptable electrical continuity was verified before and after each level. This testing was overviewed by third-party personnel. Though the destructive pullout forces of the sample did not conform closely to that of

O a normal distribution, the strengths of all of the tested splices were so many times greater than the

1. maximum

• expected force at CPSES that the probability of a deficient splice existing in the be. lance of the population must be negligibly small.

Phase II reinspections were extensive and detailed.

Essentially all of the AMP PIES splices in Class 1E essential and associated circuits in control panels of Unit I have been identified. Of those reinspected.

approximately 10% were replaced because of visual defects. The seismic analysis and original pull testing demonstrated that even these would have i

performed their intended safety function. Therefore,

' further activities, involving equipment disassembly, for the purpose of identifying some minimal number of

' unknown splices, would be very unlikely to lead to the I

discovery of a construction deficiency and are not recommended.

5.3 Phase III Because of the numerous conditions found during Phase II that did not meet the acceptance criteria, Phase III was initiated.

Phase III consisted of the identification and inspection of i all essential circuita where AMP PIES splices may have been i

used for equipment termination or cable splicing in Units 1, 2 and Common areas that were not reinspected during Phase II.

Revision: 1 Page 25 of 34 RESULTS REPORT

(~x ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Phase III was performed by the CPSES Project. CPRT third-party overviewed any reinspections where AMP PIES splices were actually used.

Two of these cables were found to be terminated to vendor pigtails using AMP PIES splices (two splices per two-conductor

, cable). In both cases the vendor wiring was #18 AWG, and the splice was one designed and specified by CPSES Project design documents for use only on #12 and #14 AWG wire. These splices were cut out and replaced with the proper connector per CPSES Project procedures. Upon examination of one of the removed splices by the Electrical Review Team, the vendor wire was able to be pulled out of the splice with minimal effort.

Based on this observation of the mechanical integrity of these splices, these findings have been classified as safety-significant deviations constituting a construction deficiency.

("N

(,) The CPSES Project activities for Phase III also included the reinspection of several cables that had terminations covered by heat-shrinkable insulation sleeves. One finding from this activity (sleeve overlapping fiberglass braid) was reported in the Results Report for ISAP I.a.l. An additional finding pertaining to these sleeves was noted for Cable EG109955A, where there was lack of proper adhesive flow and one sleeve was overlapping the braided cable insulation. The CPSES Project has issued NCR E-86-100865 to document this finding.

The Electrical Review Team considers that the corrective actions described in the Results Report for ISAP I.a.1 are sufficient to encompass any concerns raised by this finding.

5.4 Use of Results The CPSES Project has generated NCRs (or equivalent) to document all unsatisfactory conditions requiring corrective l

' action. The Electrical Review Team has reviewed these documents and provided comments to the CPSES Project for resolution. In some cases documentation findings did not require NCRs because the corresponding splice was replaced due to hardware findings (thus resulting in the documentation being superseded). Discrepant conditions noted after removal of splices from the field (e.g., from examination of radiographs) were not specifically appended to the NCRs because those splices were no longer installed.

, , _ _ . _ _ _ _ _ . _ . - - _ . _ , _ . _-_ _ . . ~ _. . . . _ , ____-_.m. ._.m. _. -

Ravision: 1 Page 26 of 34 RESULTS REPORT

/\

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ISAP I.a.2 (Cont'd) 5.0 IHPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULIS (Cont'd)

All deviations and out-of-scope findings were forwarded to the appropriate RTLs for consideration in the various ISAPs, DSAPs and collective evaluations as considered appropriate by the Electrical Review Team.

5.5 Related CPRT Activities In addition to the Phase III findings presented above, a related finding was forwarded from ISAP 1.a.1, " Heat Shrinkable Cable Insulation Sleeves." Cable AG130695 was found to be terminated using AMP PIES splices, one of which had split insulation. NCR E-85-100265S was issued to document this finding and was dispositioned by instructing craft to install new AMP PIES splices. However, the field cable was

1. 12 AWG and the vendor cable was #18 AWG. Therefore, this was an incorrect application of the subject splices, and contrary to CPSES Project design documents. The hardware aspects of this finding are essentially identical to those described gs above under Phase III. However, the disposition of the NCR,

() which directed craft to again install AMP PIES splices instead of the proper connector for the application represents a design deviation, which has been forwarded to the Design Adequacy Program for further evaluation.

5.6 Safety Significance Evaluation For the Phase I and II findings, the testing and analysis performed by the CPSES Project and SWEC has demonstrated that the AMP PIES splices would have performed their intended functions. Therefore, the individual findings are not considered to be safety-significant.

However, 10CFR50 Appendix B, Criterion V. " Instructions, Procedures and Drawings," requires activities affecting quality to be prescribed by documented instructions, procedures or drawings, and to be accomplished in accordance with same. This requirement was not met in the following two areas:

Craft and QC procedures contained no detailed instructions on the proper selection, installation, and inspection requirements for AMP PIES splices. This is considered to be a QA/QC Program Deviation.

O I

l l

I Revision: 1 Pags 27 of 34 RESULTS REPORT s_,l' ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Witnessing of all splices was required by CPSES Project procedures. (Witnessing is appropriate because of the noted inability to determine such characteristics as insertion depth by post-installation inspection.)

However, a substantial percentage (15-20%) of the splices identified by this ISAP appear not to have been witnessed. Thus the witness program was not accomplished in accordance with prescribed instructions. This is considered to be a QA/QC Program Deviation.

Because of the type and number of construction deviations encountered, and the extensive tasting and analysis that was required to determine the acceptability of the remaining hardware installations, the Electrical Review Team considers that the above two deviations constitute a QA/QC program deficiency as defined in Appendix E to the CPRT Program Plan.

() As noted in Section 5.3, the Phase III findings have been classified as a construction deficiency.

5.7 Root Cause Analysis The Electrical Review Team has assessed the root cause and/or contributing causes for the QA/QC Program Deficiency and the construction deficiency discussed above.

Prior to the time of the TRT investigation, the craft Construction Procedure EEI-8, " Class 1E and Non-Class 1E Terminations," did not contain specific instructions regarding the selection, installation or inspection of AMP PIES splices.

This procedure did indicate that manufacturers' instructions were to be used for installation of connectors, but no specific instructions with respect to selection of splice type or size, the correct tool to use, or accept / reject criteria for installation were included. It is noted that CPSES Project Drawing 2323-El-1701 contains the typical details for splice installations, including a chart defining the correct choice of a splice for a given set of wire sizes.

However, this drawing was not referenced in the craft procedure. The uncertainty over actual insertion depths required extensive testing and analysis in order to determine the adequacy of existing splice installations. This procedure did not include adequate controls over conductor strip In fact, craft were allowed to strip conductor lengths.

$nsulation with pocket knives.

Rsvision: 1 Page 28 of 34 j- RESULTS REPORT I

ISAP I.a.2 t (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Prior to the time of the TRT investigation, the QC Inspection Procedure QI-QP-11.3-28, " Class 1E Terminations," did not contain specific instructions regarding the selection, installation or inspection of AMP PIES splices. This procedure did contain some general statements about using manufacturers' instructions, but no specific instructions in-the area of splicing. Again, there was no reference to Drawing 2323-El-1701.

Specific trainin6 in the selection, installation, and inspection of these splices was not researched. As there were no specific requirements in the procedures and training was based on the content of the procedures, little insight.could have been gained by such research.

Because the construction deficiency was a result of the wrong size splices being chosen, and because the two procedures

' referenced above did not include proper references to or N

contain the necessary information regarding the selection of s splice size, the Electrical Review Team has concluded the following:

The primary root cause was inadequate craft installation procedures.

A principal contributing cause was inadequate QC '

, inspection procedures.

i The QA/QC program deficiency was a result of the failure to comply with 10CFR50, Appendix B, and the resultant effort required to assess the adequacy of the hardware installations.

The components of this deficiency include: (1) failure to j

maintain a proper witness program for splices as required by CPSES Project procedures; (2) failure to maintain accurate configuration control with respect to identifying splices on l

design documents; and (3) failure to install the splices properly. The causes of each aspect of this deficiency are discussed below.

i QC Inspection Procedure QI-QP-11.3-28 required QC witness of all splices. However, approximately 15-20% of the splices identified by this ISAP appear not to have been witnessed.

Some were documented on post-installation inspection forms without indicating that witnessing had occurred, while for

( others the documentation does not suggest that the QC i

I l

m ._. _ _ _ _ _ . . _ _ , _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _

-- -. ~ - . .

Ravision: 1 Pags 29 of 34 RESULTS REPORT ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) inspector was aware that splices were installed. It was noted

' that craft Construction Procedure EEI-8 contained no hold points for QC witness. . Based on this evidence, the Electrical Review Team concludes the following:

The primary cause of this aspect of the deficiency was inadequate QC supervision, allowing such a widespread breakdown in the witness program.

A contributing cause was inadequate craft procedures due to the lack of hold points for QC witness.

For the failure to maintain proper configuration control, the i

apparent root cause was a breakdown in the interface between

' engineering and construction personnel. The prevalent occurrences of unauthorized splices, splice authorization being deleted from DCAs after splices had been installed, and

{ drawings indicating many splices where no such splices were N installed, indicate that feedback and verification as to the

( specific conductors being spliced were either extremely inaccurate or else nonexistent.

The causes of the repeated failure to install the splices

! correctly were:

The primary cause was inadequate craft procedures as discussed above (and the resultant lack of adequate training).

A contributing cause was inadequate QC procedures as I

discussed above (and the resultant lack of adequate training).

5.8 Generic Implications Evaluation The implication of the Phase III construction deficiency and associated primary and contributing causes is that other cases l may exist in associated Class 1E circuits where AMP PIES splices were used to terminate to vendor wiring that is not the correct size for the splices. Implications beyond the hardware scope of this ISAP will be considered in the coll;ctive evaluation process.

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Rsvision: 1 Page 30 of 34

(~^ RESULTS REPORT V

ISAP I.a.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The primary and contributing causes of the QA/QC program deficiency do not have any generic implications within the population of AMP PIES splices because the ISAP essentially was formulated with built-in corrective actions (i.e., 100%

reinspection of known AMP PIES splices). Specifically:

The craft procedure was inadequate in that it did not include hold points for QC witness of splices, or instructions for the proper selection or installation of the splices. As discussed in the Results Report for ISAP I.a.3, this procedure has been revised and appropriate training has been accomplished. The reinspection, testing and analyses performed for this ISAP have demonstrated that remaining installations are acceptable. No further implications exist for the population of AMP PIES splices.

The QC procedure was inadequate in that it did not include instructions for the proper inspection of the

("')'

( splices. As discussed in the Results Report for ISAP I.a.3, this procedure has been revised and appropriate training has been accomplished. Further, though this procedure had required QC witnessing of all butt splices, a full witness program did not exist. The reinspection, testing and analyses performed for this ISAP have demonstrated that remaining installations are acceptable. No further implications exist for the population of AMP PIES splices.

There was a lack of configuration control due to an apparent breakdown in the interface between engineering and construction. Drawings have been or are being revised as appropriate to reflect the as-built configuration of known AMP PIES splices in the field in Class 1E essential and associated cables. No further implications exist for the population of AMP PIES splices.

The various causes of the deficiencies discussed in Section 5.7 will be assessed in the collective evaluation process for any further implications outside the scope of hardware covered by this ISAP.

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Rsvision: 1 Page 31 of 34-s i

RESULTS REPORT ISAP I.a.2

. (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.9 Corrective Action Recommendation The Phase I and II-findings have been or are being corrected >

as indicated in Appendixes A and B. The concern about splices (both known and unknown) still remaining in the field have been adequately addressed by the program discussed in Section 5.2.6.

As discussed above, safety-significant deficiencies were identified in Phase III. The Electrical Review Team has recommended that all associated Class IE pigtails terminated with AMP PIES splices be reinspected by the CPSES Project for correct application of hardware.

6.0 CONCLUSION

S The following major findings were identified during the course of implementing the Phase I and II activities of this ISAP:

Some splices.were installed without authorization on design documents. Also, some design documents were revised by deleting splices, even though the corresponding conductors had actually been spliced. These findings were the apparent result of a breakdown in the interface between construction and engineering. '

There were eight conductors spliced with the wrong size splice. All eight cases were caused by a single DCA, in which engineering had specified the wrong splice.

There were no specific instructions regarding the installation j

or inspection of AMP PIES splices in the applicable CPSES Project procedures at the time that the splices were installed. Consequently, there were many inadequate splice installations that were not detected by QC inspection.

Documentation of splice witnessing by QC did not exist for 15-20% of the splice population._ This substantiated the TRT finding regarding aplice witness documentation.

Some cable inspections were documented by QC as including splice witnessing when actually no splices existed in those l

' cables. CPSES Project QA took prompt action to correct this situation and investigate the magnitude of the problem. No evidence of a further programmatic breakdown was found.

l l

E s

Revision: -1 Pass 32 of 34 es RESULTS REPORT ISAP'I.a.2 (Cont'd)

6.0 CONCLUSION

S (Cont'd)

Despite the various breakdowns in engineering, craft, and QC that occurred, the testing and analysis discussed in this report demonstrated that the splices reviewed in Phases I and II would have been able to perform their intended function. All known AMP PIES splices have been or will be reinspected. Corrective action has been initiated for each of the findings. Drawings have been updated to show-all known splices. Inspections have been performed to verify that splices are now staggered.

In Phase III, the Electrical Review Team found instances where AMP PIES splices had been used for terminating field cables to vendor pigtails. These splices were not the correct connectors for these terminations due to the size of the vendor wiring. Corrective action has been recommended to and concurred with by the CPSES Project. With the completion of this corrective action, all known AMP PIES splices in Class lE essential and associated circuits in Units 1, 2 and Common that were installed prior to the middle of 1985 will have been reinspected and findings noted and corrected as appropriate.

7.0 ONGOING ACTIVITIES The CPSES Project will implement the recommended corrective actions discussed in Section 5.9. Third-party personnel will overview this process, and will ensure that comments to NCRs are incorporated, and that reinspections of previously-inaccessible splices discussed in Section 5.2 are performed. The results of these activities will be presented in a Supplementary Report.

8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE The corrective actions taken as a result of the findings presented herein together with the completion of ongoing activities will ensure that existing installations are adequate. Current pre:edures provide adequate instructions for the installation and inspection of AMP PIES splices. Training accomplished to date together with ongoing periodic training will ensure that craft and QC personnel are adequately aware of the installation and inspection requirements. No other actions are necessary, b

U

Ravision: 1 Page 33 of 34 RESULTS REPORT

( \

ISAP I.a.2 (Cont'd)

Appendix A Summary of Phase II Reinspection Findings NO OF ITEM DESCRIPTION OF ITEM FINDINGS RESOLUTION

• 1 Splice Not Shown on Drawing 109 Drawing Updated 2 Drawing Shows Splice - No 149 Drawing Updated Splice Found 3 Splice Heat Shrunk - Crimp Tool 34 Reviewed IR for Tool #

Indeterminate by Reinspection 4 Splice Insulation Split from 7 Replaced Defective Splice Heat Shrinking 5 Incorrect Color Extending 6 Replaced Splice Conductor Spliced On 6 Improper Crimp 16 Replaced Defective Splice 7 Crimping Damaged Insulation 3 Replaced Defective Splice 8 Incorrect Tool Used 26 Replaced Defective Splice (Wrong Dot Code) 9 Strand (s) Outside Wire Barrel 13 Replaced Defective Splice 10 Wrong Size Splice 8 Replaced Incorrect Splice

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11 Stagger Unsat After Rebundling 6 Inserted Insulating Mat-erial Between Conductors Total 377 The noted resolution was the usual one. However, in some cases, circumstances dictated a different, but equally adequate, resolution (e.g., conductor is now spared, so the defective splice was removed rather than replaced by a new splice).

Ravision: 1 Paga 34 of 34

m. RESULTS REPORT ISAP I.a.2 (Conc'd)

Appendix B Summary of Phase II Document Review Findings NO. OF ITEM DESCRIPTION OF ITEM FINDINGS RESOLUTION

• 1 Splice Not Documented as 101 Reinspected Splice Witnessed 2 IR Indicates Splices as Witnessed 8 CAR on QC Inspectors But No Splice Exists 3 IR Indicates Splicing of Conductors 1 CAR on QC Inspectors But Conductors Don't Exist '

4 Incorrect Drawing Referenced 1 Reinspected Splice (s) 5 Incorrect Drawing Rev. Ref'd 3 Reinspected Splice (s) 6 No Drawing Referenc'ed 22 Reinspected Splice (s) 7 Incorrect Cable ID Referenced 1 IR Superseded 8 Incorrect Cable End Referenced 1 IR Superseded 9 Incorrect Tool for Splice 19 Removed Splice Referenced 10 IR Altered w/o Initials & Date 4 Corrected per Procedures 11 IR States Conductor Scrapped, 1 IR Corrected Relugged and Retermed. But Conductor Found Spliced -

IR Altered after Level II Review 12 Two Crimp Tools Noted on IR 3 Reinspected Spliceis?

Total 165

• The noted resolution was the usual one. However, in some cases, circumstances dictated a different, but equally adequate, Ox resolution (e.g., the documentation finding was rendered moot due to corrective action taken because of a hardware finding).

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