IR 05000353/1988001

Insp Rept 50-353/88-01 on 880111-15.Violation Noted.Major Areas inspected:safety-related Electrical Sys & Components

ML20148G733
Person / Time
Site:	Limerick
Issue date:	03/02/1988
From:	Anderson C, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20148G627	List: IR 05000353/1988001 ML20148G624 ML20148G712
References
50-353-88-01, 50-353-88-1, NUDOCS 8803290213
Download: ML20148G733 (9)

Text

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-353/88-01 Docket N License No. CPPR-107 Category B_

Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Nuclear Generating Station Unit 2 Inspection At: Limerick, Pennsylvania Inspection Conducted: January 11-15, 1988 In speci.or: #> 6W '

C H'. Woodard, Reactor En esr ~D 'date Approved by: 2 &,cag -.

. 'J. AndersonT Chief, Pjfj l SysAms /datfe Section, DRS v U Inspection Summary: Ing ection on January 11-15, 1988 Inspection Report '

50-353/88-01 Areas Inspected: Routine, onsite, unannounced inspection by one region-based inspector of activities pertaining to the safety-related electrical systems and component Results: One violation was identified,10 CFR Appendix B, Criterion II, lack ;

of controls of environmental conditions for activities affecting qualit ;

,

Two previously identified items are closed (50-353/87-06-02 and 50-353/87-06-01). I

!

l I

l

i l3 880321 I O hCK05009353 DCD

.

. .

.

Details 1.0 Persons Contacted 1.1 Philadelphia Electric Company (PECO)

J. Corcoran, Manager QA

• D. DiPaolo, Branch Manager, QA

• G. Hoke, Engineer, QA

• Lauderback, Engineer, QA

• T. Tucker, Engineer, QA

• S. Loofboorow, Engineer, QA

• Teller, Engineer, Construction

• S. Bobyock, Engineer, Test

• E. Gibson, Engineer, QA T. Oey, Engineer, QA 1.2 Bechtel

• Sakers, Engineer Project Construction, QC

• Kelly, Engineer, Site QA

• J. Howell, Engineer, Electrical

• G. Bell, Project QA G. Young, Engineer, QA J. Smith, Engineer, QA 1.3 General Electric A. Lileck, Site Manager 1.4 United States Nuclear Regulatory Commissior) ,

i

• R. Gramm, Senior Resident Inspector l

• Denctes those present at the exit meeting at Limerick on January 15, 193 I 2.0 Licensee's Action on Previous Inspection Findings 2.1 (0 pen) Deviation 50-353/87-06-03, Undervoltage in Class 1E Circuits {

'

The licensee had not satisfied an October 21, 1981 letter commitment to the NRC to correct unacceptable undervoltage :onditions in certain J

Class 1E circuits which had been identified under Significant

,

Deficiency Report No. 52 by June 198 !

By letter dated July 14, 1987, the licensee acknowledged the tardi-ness of their corrective actions. They provided the overall delay in the Unit 2 schedule as the reason for the delay. Based upon the

, current schedule, the licensee stated that the 10 CFR 50.55 (e) work

i

.-

associated with correcting the deficiencies in the adequacy of the electrical system will be completed by March 198 This item remains open pending completion of the work to correct the undervoltage condition .2 .( Closed) Unresolved Item 50-353/87-06-02, Interim Storage of Pre-Cut Electrical Cables Inspection 87-06 revealed that a few coils of Class 1E electrical cable which had been pre-cut to length were being stored temporarily outside prior to taking inside for pullin The coils of cable were laying on the ground and were subject to degradation from contact with groundwate The inspector reviewed licensee procedure CP-E-2 Permanent Plant Cable Installation and Termination which included revisions to the requirements to "Assure that cable in the field interim storage /

receiving areas pending installation is adequately protected, stored on pallets, wood, e+.c.." Inspection of both the interim cable storage areas in and around the plant and the cable yard did not reveal any instances of inadequate cable storag This item is close .3 (Closed) Unresolved Item 50-353/87-06-01, Need for Control to Prevent Damage in the Removal of Electrical Cable from Reels at Low Temperatur Inspection 87-06 revealed that the licensee was removing cable from reels (handling, uncoiling) without regard to the potential degrada-tion that could be caused if the cable temperature was below a value to which the cable had been qualified by the manufacture !

Following NRC Inspection 87-06, the licensee amended procedures CP-F-2, Receipt Inspection Storage and Withdrawal of Materials and Equipment, and CP-E-2, Permanent Plant Cable Installation and Termi-

'

nation, to include requirements to assure that the temperature of the cable is above +10*F prior to uncoiling handling and pullin During this inspection on January 11, 1988, the inspector found cable handlers in the outside cable storage yard pulling (uncoiling)

cable off reels in order to pre-cut pull lengths without regcrd to the cable temperature. .Several members of the cable cut crew were interviewed by the inspector regarding temperature control measures during cable handling operation. The crew members stated they were not aware cf any temperature control i l

l

. .

,

.

The inspector expressed his concern to the Philadelphia Electric Management and Quality Assurance personnel regarding the lack of control in the implementation of Procedure CP-F-2 temperature re-quirements to assure the integrity of the cable This is in viola-tion of 10 CFR 50 Appendix B, Criterion II, which states in part that

"..... Activities affecting quality shall be accomplished under suitably controlled conditions. Controlled conditions include ..... suitable environmental conditions for accomplishing the activities..... The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained....." This item is upgraded to a violation (50-353/88-01-02), and item 50-353/87-06-01 is close Subsequently, the licensee took some immediate corrective actions as follows:

-

Contacted the cable manufacturer and obtained recommendations which included methods for handling cable at temperatures below

+10*F (down to minus 40 F).

-

Re. vised Procedures CP-F-2 with regards to the 10 F temperature limitation to remove a temperature limit on cable handling

'

activitie Conducted a training class on January 14, 1988 for eight electrtcal personnel to emphasize procedural requirement .0 Procedures Review Selected licensee documents associated with the procurement, storage, installation, inspection, surveillance and maintenance of the class 1E electrical systems components and cabling observed during this inspection were reviewed. The procedures reviewed are listed in Appendix This review was to ascertain whether NRC requirements had been adequately 1 translated into applicable documents and to determine if the construction specifications, drawings procedures, and instructions were of sufficient I detail and clarity to perform and control the work. A deficiency was noted l regarding the implementation of the cable temperature control provisions l of licensee procedure CP-F-2, Procedure for Receipt Inspection Storage I and Withdrawal, This problem is discussed in Section 5.4 of this report.

!

No other deficiencies were identifie l l

l

. . - . .- .- - . . . - - -. .- -. . .. -

-

,

,

'

l

-

l

!

'

i i

1 i 4.0 Record Review j

., A sample of licensee records, associated with the Class IE electric i systems was reviewed by.the inspector. Specifically those documents associated with the emergency diesel generators, electrical cables and 1 the Power Generation Control Complex (PGCC) were addressed, These j

'

records are listed in Appendix :

This review was to determine the adequacy of the licensee's activities for .

Class 1E electric systems and components including the cabling to assure  !

that they were procured, stored, installed and maintained as required by the procedures of Section 3 of this report in order to perform their safety-related function No deficiencies were observed.

1 5.0 Electrical Components and Systems - Work Observation  ;

i The inspector observed work in progress and completed work to determine .

whether activities related to safety electrical systems and components are being controlled and accomplished in accordance with NRC requirements, commitments and licensee procedures. Areas inspected included the j

' emergency diesel generators, electrical cables and the PGCC wiring. The -

following observations were made of the installed Class 1E components and l systems: I

-

The components were properly identifie Dust covers were in place over electrical component ;

-

Components were installed at the correct location with the correct orientatio No electrical separation deficiencies were observe .1 Emergency Diesel Generators Oil Leakage problem The emergency diesel generators (EDGs) at Limerick (Units 1 and 2)

-

are powered by Fairbanks Morse Model 3800 TD 8 1/8 engines. This

) model engine has a history of problems at nuclear plants with oil ,

l i

1eakage from the exhaust line flanges. This oil comes from pre- l lubrication and normal lubrication of the upper crankshaft. Excess 1 oil drains down through the cylinders into the exhaust manifolds and j seeps through the gasket Such leakage has caused excessive smoking  !

and fires and there is a possibility of the oil causing a hydraulic l cylinder lock with consequent engine damage. The excessive oil leakage problem for Unit 1 is reported in a Brookhaven National Laboratories Report dated March 27, 1985 and in NRC Inspection Report

50-352/87-31.

i 1 l

ll b

I l l _

. _ . - - _ - _ _ _ . _-

- -

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

. - - . --_

.-

'

.

.

The inspector discussed concerns for the Unit 2 potential leakage problem with the licensee. The licensee stated that they were in-vestigating a solution to this problem on Unit 1. They stated that upon resolution of this issue at Unit 1, they would establish correct-ive measures for Unit 2. Any correctivo measures developed would be applied to Unit 2 prior to plant operatio .2 Emergency Diesel Generators Maintenance Inspection of the four emergency diesel generators indicated a weakness in the licensee's Maintenance Action Plan Inspection which requires inspection of the "in place storage" generators on a quarterly basi This inspection includes the verification that the generators heaters are on (to protect the windings from moisture).

Inspection disclosed that the heaters were off on two of the generator There were portable type personnel heaters adjacent to provide for hea However, one of the heaters had been moved and turned away from the generator (to provide heat to construction personnel). The licensee reported problems with the installed generator heaters for the two units whera the portable heaters were use In view of the apparent lack of control of the portable heaters being used, and the infrequent (quarterly) inspections, additional licensee actions appear warranted to ensure that proper heating is maintained en the diesel generators winding This item is unresolved pending appropriate rasolution of the generator problems (50-353/88-01-01).

5.3 Electrical Power Cables Installation Insper. tion was made of the three single conductor 750 KCM and one single conductor 250 KCM electrical power cables pulled from the emergency diesel generator power switchboard in the "D" diesel room to the 4kV emergency switchboard cubicl The inspection consisted of a review of the cable routing and pull 1ng calculations, E-544 dated September 23, 1987, and a review of the QC record card for the cable installation, QCIR No. 20650188-143 dated December 28, 1987. An independant calculation of the expected cable pulling tension was made to confirm the licensee's calculation A walkdown of the cable pull was made to confirm the routing and to inspect the unterminated coiled cable ends in the DG room power switchboard. One of the 750 KCM cables was not pulled all of the

'

.

.

.  !

way into the 4KV switchboard cubicle but was tagged with a Non-Conformance Report (NCR) Tag. This tag was traced back to QC records which were found to be in order. The nature of the NCR was cable jacket damaae and the NCR was awaiting appropriate disposition to either accept the cable as is, repair / rework, or to replace the cabl No unsatisfactory conditions were observe .4 Power Generation Control Complex Wiring A review was made of the licensee's current status in the overall evaluation and correction of wiring problems in ' 4 Power Generation Control Complex (PGCC) as originally reported by n 1C Inspection Report 87-13 and by licensee 10 CFR Part 50 55 (e) Interim Signi- '

ficant Deficiency Report No. 219-2 dated December 31, 1987. Findings are the following: One hundred percent reinspection of all of the wiring and .

terminations in the safety related panels has been complete Deficiencies reported are categorized as follow Missing, illegible and incorrect labels - Approximately 1300 finding Damage, including wire insulation and broken lugs -

Approximately 20 finding Design problems, including wires installed but not on design drawings, wires not installed but on the design ,

drawings, more than two wires on a termination point, and i wires terminated to the wrong side of a terminal board - '

Approximately 150 finding . Rework and correction of these deficiencies is approximately 75 percent ccmplete. Completion is planned by mid 198 ! The licensee and General Electric are evaluating each design !

daficiency for its impact on systems operation. Completion of this evaluation is planned by January 31, 1938. The evaluation I will include verification of whether pre-operational tests l would have detected these deficiencies. A repcrt of the l overall safety implications of the deficiencies is scheduled j for complet on by mid 198 i

One hundred percent re-inspection of the balance of plant non-safety related panels is complete. Evaluations and correc- i tions of deficiencies are scheduled 'or completion by mid 198 l

!

l i

l l

l

'

.

.

. As a consequence of the substantial deficiencies in the PGCC panels at Limerict possibly having generic implications, it was understood from the GE site representative that wiring inspec-tions are being performed on other PGCC panels for other facili- '

ties which were wired at the GE NEB 0 panel facilities at San Jose.

The inspector had no additional comments on this issu .0 U m solved Item UnresolYed item is . matters about which more information is required in order to ascertain whether it is an acceptable item, item of non-compliance or deviations. Unrosolved 'isclosed during this inspection is discus-sed in detail in paragraph this repor .0 Exit Interview The inspector met on site with licensee representative (denoted in Details, Paragraph 1.0) at the conclusion of the inspection on January 15, 198 The inspector summarized the scope and the inspection findings. At no time during this inspection was writ c; *aterial given to the licensee or his representative !

.

{

l

I I

l

l i

l

!

i

__

,

I

. .

,

f

.

,

Appendix A - Documents Reviewed The following documents were reviewed by the inspector:

-

FSAR Section 8 l

-

Bechtel Drawing E-1412 "Wire and cable Notes and Details

-

Bechtel Construction Procedures (CP) E-2 "Permanent Plant Cable Installation and Termination".

-

Bechtel Electrical Computer Program Manual for Cable Tension Calculations - EE-35 Bechtel Drawing E-1406, Conduit & Cable Tray Notes Symbols and Detail Cable Pulling Tension Calculations E-544, E-587, and E-59 Bechtel Construction Procedure (CP) F-2 "Receipt, Inspection, Storage and Withdrawal of Materials and Equipmen NRC Inspection Report 50-353/87-13 (PGCC Wiring Problems).

-

Brookhaven ':ational Laboratory Technical Review Report of AC and DC Electric Power Systems, March 27, 198 PECO Significant Deficiency Evaluation No. 219-2 of Discrepancies in PGCC Wirin l 1