IR 05000277/1990015

Insp Repts 50-277/90-15 & 50-278/90-15 on 900723-27. Violations Noted.Major Areas Inspected:Cleaning & Testing of Both Diesel Engine & Generator

ML20059K740
Person / Time
Site:	Peach Bottom
Issue date:	09/06/1990
From:	Anderson C, Julio Lara, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20059K725	List: IR 05000277/1990015 ML20059K721 ML20059K734
References
50-277-90-15, 50-278-90-15, NUDOCS 9009240208
Download: ML20059K740 (11)

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U. S. NUCLEAR REGULATORY COMMISSION-REGION I Report No /90-15-50-278/90-15  ;

Docket No '

License Nos DPR-44 i DPR-56 Licensee: Philadelphia Electric Company Correspondence Control Desk P. O. Box-195 Wayne, Pennsylvania 19087-0195 Facility Name: Peach Bottom Atomit, Dower Station Units 2 and 3 Inspection At: Delta, Pennsylvania

Inspection Conducted: July 23-27, 1990  !

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f Inspectors: 3.f' Lax. /A eM s/3W/9a !

J. F. Lara, Reattor E71gineer, Plant Systems ~ ' d Yt'e ,

Section, EB, DRS  ;

O./ feb C. H..Woodard, Reactor Engineer, Plant Systems e x/so/n

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Section, EB, DRS Other NRC p sonnel: R. Skokowski ( - -

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' Approved by: O 7 JJ fo '

C.J.fAnderson, Chief,PlantSystems date Section, EB, DRS i LInspectiy Summary: Inspection on July 23-27, 1990 Report Nos. 50-277/93_1,5 ;

and 50-278/90-1 i

Areas Inspected: Routin'e announced inspection of the licensee's mairtenance iiEtivities .on the emergency diesel generators (EDG). These activities included

. inspection,. cleaning, and testing of both the diesel engine and the gener. to =Interf aces between the various groups that are involved in the maintenance activities.were also evaluated. Previously identified items were also reviewe )

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'Results: The licensee's EDG maintenance activities were found to be well coordinated among the various groups involved. One violation, pertaining to ma19tenance activities that were not accomplished in accordance with procedures, was identified. In addition, two previously identified NRC items were close PDR ADOCK 05000'~7

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DETAILS 1.0 Personnel Contacted 1.1 Philadelphia Electric Company (PEco)

• Behrend, C., Common Systems Engineer

• Cook, J., Maintenance Dalson, D., I&C Maintenance Donnell, A., NQA Superintendent

• Foparty, G., Project Manager

• Franz, J. Plant Manager

• Fulvio, A. , Regulatory' Manager

• Hart, J., System Engineer

'*Hinnenkamp, P., I&C Maintenance

• Knieriem, R., OD Macentee, l. Training Coordinator

• PcElwain, J. , Senior System Engineer

, *Meyers, D., Superintendent-Technical Polaski, .F., Assistant Operations Superintendent

~ * Smith, R , Regulatory Group - ,

• Wilson, Maintenance Superintendent

' Young, F., NQA 1.2 -U.S. wclear Regulatory Commission (NRC)

Lyash, J. , Senior Resident Inspector Meyer, ' Resident Inspector F Urban,-R., Resident Inspector

• Denotes personnel present at. exit meeting held on July 27, 199 .0 Status of Previously Identified Items (Closed) Unresolved Item 50-278/89-07-01 Voltage Adequacy for DC Equipment During a previous NRC electrical team inspection, it was noted that the licensee had not established the adequacy of the DC voltage at DC equipment such a MOVs, contactors, coils, and relays. Inadequacies in the design ,

of DC MOVs and failure of DC MOVs to develop rated torque because of irr. proper cable sizing were the subject of Information Notices 88-72 and 89-1 '

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As documented in a subsequent NRC inspection (89-13), the licensee identi-fied several MOVs with starting resistors which could not produce sufficient torque for timely valve actuatio To resolve this problem, modification No. 5125 was performed removing the starting resistors from the motor circuits of Unit 2 valves. At the time of the previous inspection,-the licensee stated that similar actions would be performed for affected Unit 3 valves. During this inspection, the inspector reviewed the licensee's computerized database to verify that the modification to remove or bypass starting resistor circuits for the affected MOVs was completed. The affected a Unit 3 MOVs are: MO-3-23-14, MO-3-23-19, M0-3-23-20 and MO-3-10-1 L Following testing, these MOVs were considered operable on October 14, 198 The modification was closed on October 18, 19S ,

This item is close :

(Closed) Unresolved Item (50-278/89-13-01) Administrative Controls on Electrical Load Growth i

. This item addressed the lack of an up-to-date engineer.ing calculation to 2

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demonstrate acceptability of Emergency Diesel Generator loads-and an on-line program to monitor and evaluate the load changes resulting from plant modification ,

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The licensee performed a Diesel Generator Load Study to verify th '

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adequacy of the standby diesel. generators to supply the required power during design basis events. The study identified each load cont.ected to the 4.16kV power system. The tabulated load totals were compared to the ,

steady state output capacity ratings of the diesel generators. The inspector reviewed selected 480V MCC to verify that connected' loads were included in the EDG load stuoy, The Safety Evaluation fr Modification 2123A,

" Diesel Generator Load Profiles and System Voltage Regulation Study," was also reviewed, during this inspectio No deficiencies were identifie .

The. inspector reviewed Nuclear Engineering Department's Interim Guidance-No'. ~IG 3.'17- This IG orovides procedural guidance to control electrical .

load change It is applicable to all current and future modifications at '

Peach Bottom as well as to other load changes identified as'a result of some other process. Accordingly, lead responsible engineers are responsible for developing Load Change Evaluation Forms which are reviewed by the Load

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Change Coordinator to determine if the load change can be accommodate .

In addition to determining if the power supply has sufficient capacity, the coordinator also determines if the load change affects the system short circuit current, voltage regulation values, motor starting voltage drop or the degraded voltage relay settings and updates the load databas .

This guidance procedure is in the final stage of review, prior to being redesignated as NED Procedure 3.17. No deficiencies were identified during this revie This item.is close ...

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3.0- Technical Specifications Emergency Diesel Generator (EDG) Inspection Peach Bottom Technical Specifications require an annual inspection of the four EDG units. The inspection of the four EDG units is performed on an alternating basis. Once an EDG is placed out of sarvice for.the inspection, Units 2 and 3 are both in an T.S. LCO. Until the inoperable EDG is returned to service, the other units are required to be demonstrated operabl The licensee's EDG inspection' attributes include mechanical and electrical inspections and tests. These activities were reviewed to verify thei conformance to technical specification requirements, vendor recommendations, site procedures, and generally accepted industry practice .

t 3.1 EDG Mechanical Maintenance Procedures l

The inspector determined that the currently scheduled EDG maintenance was i being conducted, for the first time, with licensee's procedures and without the direction of the manufacturer's field service representative A review was made of the EDG manufacturer's 12-18 months interval maintenance'

recommendations, as contained in the licensee's contro,lled copies of the '

Operations and Maintenance Manual These manuals, appeared to be current j and included ' nufacturer's Site Information Letters (SIL) revisions.' The t manufacture- maintenance recommendations were compared in several areas to the mai ,

'ce requirements contained in:the licensee's Procedure

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U-052-00 n appeared that the licensee had addressed each of the manu- '

facturer's maintenance recommendations. However, the procedure appeared ,

to lack detailed step-by-step directions. The licensee indicated tnat '

when they used the procedures for the first time, they did find some  :

procedural problems, which were administratively changed. The licensee's maintenance program-dees include feedback from the performing maintenance q

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personnel which is used to upgrade and correct the maintenance procedure '

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The licensee stated that, at the conclusion of'this maintenance period, a maintenance evaluation meeting between the various maintenance engineering and systems personnel would ba held. At that time, the need 'for revisions

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3.2 Maintenance Inspection a

V The inspector conducted walkdown inspections and observed EDG Unit E2 l maintenance in progress in the following areas: j

Hydrostatic leak testing of the jacket water cooling system and the associated examination of the system to detect leaks. Minor external  ;

leaks were detected in cylinder adapter units (corrected by 0-ring seal replacements). A substantial leak, which developed at the con-necting pipe flange to the auxiliary jacket water circulating pump,

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was corre" ' by a new gasket and flange bolt-up. No internal leaks into the ci inders or other vital engine areas were detecte .j

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Replacement of pre-formed stainless steel tubing between the fuel injector pumps and the fuel injectors to correct fuel leakage problems observed during earlier EDG operatio a

• Measurement of lower crankshaft strain;

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Inspection of vertical drive couplings;

Inspection of cylinder liners;

Inspection of jacket water check valve;

Inspection of exhaust ports and exhaust system; and

Hi potential testing of generator stator winding No deficiencies were observe .3 Maintenance Personnel Qualification '

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A review was made of the licensee's training and qualification program i6 for the maintenance personnel particularly those involved in the EDG_ i !

maintenance. The licensee's maintenance training coordinator present-d .

the overall program, beginning with the initial apprentice level a~<.

progressing up through the. senior levels. The training involves cl6.sroom training at the licensee's corporate facilities, on the jeb training, and specialized training, both in-house and at' manufacturer's facilitie The training includes EDG training and qualification on specific plant modules and procedure Documentation of personnel training and qualification is maintained by both the corporate training center and by the local training coordinato The training and qualification records for selected personnel who-are currently performing the EDG maintenance were reviewe Based.upon this'

review, it_was concluded that the maintenance group leaders and their group members are qualified to perform EDG maintenance activitie ,~ However, the inspector noted that, although the maintenance personnel-performing the EDG mainten'.nce were qualified, some training / qualification records did not indicate training on the specific procedures. The

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j licensee indicated that additional qualification was gained by on the ' Job i discussions held with the maintenance group leaders and other team worker i

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3.4 Electrical Maintenance [

The licensee's maintenance activities associated with the generator. unit j were reviewed to determine whether they were performed in accordance with l t

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F manufacturer's recommendations, site procedures, and industry practice The generator inspection activities included the following attributes:

• Meter calibrations

• Rotor and stator insulation resistance testing

Testing and calibration of the generator static exciter voltage regulator

• Winding-brush-brush holder-collector ring examination 1'

During review of the procedures associated with the above activities and of .t)mpleted maintenance results, the inspector observed the discrepancies described belo Maintenance Procedure MP-052-001, "Di stor Maintenance,"

Revision 1, requires that the brushes ad and documented as-

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being acceptable, taking note of bru .. 4 i force. Step 5. L t

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requires the measurement and documents: ion of the "as-found" brush force. Step 5.3.19 requires the reinstallation, adjustment, and documentation of the "as-left" brush force. Both of these steps

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l require that the brush force be within 1.75 lbs. (MIN) and 2.25 '1b ,

(MAX) to prevent excess sparking or overhesting of the brushe These steps are designated as " Independent Verification Points" ' '

During the review of completed ma ntenance esults performed on EDG d

E4 (MFR 9061624, 7-17-90), the inspectors nt ted that all four (4)

"as-found" and three of the four (3/4) "as- ef t" brush forces exceeded the maximum limit specifieo in the procedure. The "as-left" brush rces exceeded the limit by as much as 0.25 lb These steps were igned-off.by'the individual performing'che measurements as well as by an independent reviewer as being ace.eptable. The results were also reviewed and approved by maintenance supervision. However, there was no indication that the "as-left" brush-forces were evaluated

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for acceptability in the light of the fact that they exceeded the maximum limi The Post-Maintenance Test Form MG-8.1-1:4 (MRF 9061624 dated 7-19-90) included remarks which stated in part " brushes reinstal-led, seated and spring tension adjusted- properly." Discussions with ;

maintenance personnel indicated that maintenance personnel apparently misunderstood the maximum limi '

Failure to ensure that the "as-left" brush forces were within the

.specified tolerance limits, as required by the procedures,. is considered a violation of 10 CFR.50, Appendix B, Criterion V (50-277/90-15-01)

and 50-278/90-15-01).

The inspectors expressed concern'to the licensee that various pro-cedures contained requirements for " Independent Verification,"

" Double Verification" and " Verification" points. The differences

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, 7 between the various verification points were not clear. These' term, were not defined in any maintenance procedures. The licensee stated that these terms were defined in other nuclear procedures and all'

maintenance personnel would receive additional training as to the requirement *

The inspectors noted that Section 7.0 of the procedure " Acceptance Criteria" of the procedure did not contain quantitative or qualitative criteria to assure that procedural activities were completed satis- ,

factoril This weakness was also noted in the procedures listed belo *

TL-11-02001, " Procedure for Field Testing Alternating Current Generators," Revision * MP-M-052-022, " Diesel Jacket Water and Air Cooler Coolant Check Valve Maintenance", Revision .

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MP-M-052-020, " Diesel Generator Air Start System lh" Grove F'exflo

. Regulators and Solenoid Operator Maintenance," Revision 0,

MP-M-052-001, " Diesel Generator Maintenance," Revision .

The licensee stated that the lack of specific criteria in Section 7 of maintenance procedures had been identified previously by their maintenance staff and efforts would be undertaken to include such criteria where appropriate. It was noted that some of the procedures contained criteria within the body of the procedure but not in the c -"Acceptance Criteria" section of the procedure. See Section B below for further discussion on the general lack of acceptance criteri I Procedure TL-11-02001 " Procedure for Field Testing Alternatin !

Current Generators" Revision 1 specifies the following activities to 1 be performed on the Diesel Generators:

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Rotor DC Resistance Test

• Rotor Capacitance Test

Rotor 60 HZ Impedance Test

Rotor Insulation Resistance Test

Stator DC Resistance' Test

• Stator. Capacitance Test

Stator Dissipation Test

Stator Insulation Resistance Test '

Stator fixed time step Voltage Test During review of this procedure the inspectors noteo that there was no k acceptance criteria.or guidelines to allow personnel to determine the adequacy of the measurement In addition to the lack of guidance for measurement acceptance, there were no written instructions given to the

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personnel to review past test results to determine if any insulation l

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degradation'had occurred. However, it was noted that personnel conducting the resistance testing on Diesel Generator E-2 on July 25, 1990, had the last performance test results available at the generator to evaluate the current results. The inspectors expressed concern that since there was no W procedural acceptance criteria, the possibility exists that the evaluation of re ,ults may be evaluated as a specific case and not consistently applied for all cases. This lack of acceptance criteria or guidance was also evident in other procedure as indicated in paragraph ' A' above. This issue of a general lack of acceptance criteria is an unresolved item pending NRC review of the licensee's actions to ensure that appropriate acceptance criteria is incorporated into the maintenance procedures (50-277/90 *,5-02 and 50-278/90-15-02).

. 3.5 Diesel Generator Testing '

Following the Diesel Generator inspection and maintenance, the licensee performs the following. operational tests: i

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• Sensor to Relay Tests  ; }

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• ' Logic Functional Tests

Initial " Slow" Start Test .

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Normal Start, and " Diesel Running" Test j j

• Final Run (As per ST 8.1) Test t l During the " Slow" Start Test, the Diesel Generator is started locally and I operated unloaded for less than thirty (30) minut'es then shutdown. The i normal start and " Diesel Running" Test starts the Diesel from the control room with 3 minute prelube time prior to the actual diesel start. It-includes an'overspeed trip check, a thirty-(30)-minute full. load test with g the generator loaded (2500 - 2700 kW and C00-1100 kVAR), followed by a i load rejection test with the generator loaded at 1300 kW. The final run test is a one (1) hour full- load: test. While any individual Emergency  ;

e Diesel Generator is inoperable, Technical Specification 3.9.B, SevenL(7)-  !

day LCO, requires that the other diesels be demonstrated operabl <l

- Accordingly, the available diesels were tested daily per procedure ST. 8.1-  :

" Diesel Generator Full Load Test," Revision 36. The inspectors witnessed '

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the testing of Diesel Generators E3, and E4 on July 24, 1990, from their j respective diesel room.- For both diesels it was observed that the three-

-l (3) minute prelube time-and ten (10) second time requirements for the '[

diesel generator to reach rated frequency (60 HZ) and voltage (4160V) were satisfied. The inspectors noted the availability _of alarm response

- pre::edures locally to provide guidance to the operators for alarms, t On July 25, 1990, the inspectors observed the diesel generator full load test of Diesel Generator E4 from the control room. The EDG was star.ted, synchronized and paralleled with the offsite power system and loaded to  :

power the required inadt for one hou Prior to closing the diesel )

generator output breaker to parallel the diesel to the offsite system, the i EDG must be at rated speed and frequency and the output voltage must be of the-same magnituce and frequency as the bus voltage. Once these conditions-are meti the contro room operator must synchronize the generator to the

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offsite power system. The Peach Bottom control room EDG panel consists =of two redundant sets of synchroscopes and-associated voltmeters (incoming <

and running) to provide indication to operators during synchronizing operations. The Class IE 4.16 KV system voltage is at a nominal 4350 volts. When the' diesel generator starts, its nominal output voltage is 4.16kV. Therefore, in accordance- with procedures, prior to closing the EDG output breaker, the control room operator must raise the EDG voltage to match the running voltage. During the test, the inspectors observed that, once the operator placed the "Bkr Sync" switch in the "On" position, the two (2) redundant synchroscopes and voltmeters were activated. The operator uses either set of voltmeters to adjust the EDG voltage to match- l the offsite voltage. Proc M ure 5052B.1.A, " Synchronization Diesel Generator

and Loading" allows the EDG output voltage to be a maximum of 100 volts higher then the running voltage. Once the associated voltmeters.were ,

activated, it was observed that there was a disagreement between the >

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" Incoming" voltage on EDG synchronizing. panel A and that indicated on panel C. " Incoming" voltmeter A indicated approximately 4160 volts while

" Incoming" voltmeter C indicated approximately 4350 volts. Since the

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. " Incoming" voltage refers to the EDG voltage, the correct indication is j 4160 volts. The control room operator, seemingly aware of this mismatch,-

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adjusted ~the EDG output voltage using the indication p,rovided by the voltmeter on panel A prior to closing the EDG output breaker, ,

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lack of calibration on these instruments since:they are relied upon by the- i cperators to safely synchronize the EDG units. The isspector verified that other instruments on,the EDG panel are calibrated on a periodic interya _

Subsequent discussions with the licenser staff resulted in the licensee initiating work requests _to calibrate the subject instruments and ,

to establish a periodic calibration interva No other deficiencies were identifie .0 Modification Testing Review The inspector reviewed the functional testing of equipment-associated with modifications performed on the Diesel Generators. The modification tests-reviawed are listed belo * Modi fication Acceptance Test 207 This modification installed check and block valves, along with- associated piping, in the EDG Air Start Syste + -Modificttion Acceptance Test 253 This modification installed a ball vaive in the air starting line between the-air start manifold and ,

the regulator for the bearing lube oil booste ,

No deficiencies were identified during the review of the above test document .. .

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5.0- Information Notices (IN) l A review was made of the licensee's internal response to NRC IN 89-50,

" Inadequate Emergency Diesel Generator Fuel Supply." Upon review of IN 89-50, the licensee initiated Reportability Evaluation Form (REF)

RI-90-05 to document that the existing Technical Specification value for onsite fuel (104,000 gallons) would not support 7 days of full load operation of each diesel generator as specified in the FSAR and SER. A total of 32,500 gallens per DG fuel tank was-determined to be necessary  ;

to support 7 day full load operation. Therefore, a total of 130,000 gallons would be required onsite as opposed to the T.S.' value. This item was initially deemed to be reportable as a condition outside the _!

design basis. At the time of the discovery, the licensee took administrative actions to ensure that the onsite fuel storage satisfied  ;

the FSAR commitmen Surveillance test procedures and logs were revised  !

to reflect new fuel oil limits to meet the FSAR commitments. Tank level instrument setpoints (low and high level alarms) were also changed to accommodate the new fuel oil storage requirement l The licensee plans to further evaluate the actual diesel fuel oil consumption to decide on whether to change the T.S. limits, revise the '

FSAR, or maintain the current fuel oil storage requirement ['j No deficiencies were identified during this revie !

6.0 Exit Meeting Tne inspector met with licensee represer'.sives, denoted in Section 1.0, at the conclusion of the inspection on JL 27, 1990. The inspector summarized 4 the scope and findings of the inspect- .

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At no time during the inspection, was written material provided by the inspector to the licensee. The licensee did not indicate that_ proprietary

,information was involved'within the scope of this inspection.'

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i Attachment A

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Documents Reviewed  !

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+- ST Diesel Generator Full Load Test Rev 38

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• ST8.1.14 Capacity Test of the Diesel Generator Starting Air Compressors Rev 0

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M-52.17 . Diesel Lube Oil System Check Valve Maintenance Rev 0 l

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ST8.1.10 Diesel Generator and Bear ng- i

- Insulation Chect Rev 3

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M-052-001 Diesel Generator Maintenance Rev 1 1

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TL-11-02020 . Testing'and_ Calibrating Diesel Generator ,

Voltage Regulators Rev 0 j

+- ST-8. Diesel Generator Annual Inspection Post Maintenance Test Rev 28

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M-052-002 PECo Diesel Engine Maintenance Procedure- Rev.0, 3/15/90

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Fairbanks Morse - Colt Industries Operations and Maintenance Manuals o VolumesE1, 2 and 3 for the Emergency Diesel-Generators PEco, Colt , Revision 2 4/5/89 (Controlled-Library Copies).

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